U.S. DODD-FRANK WALL STREET REFORM ACT (CONFLICT MINERAL REPORTING)
Van Meter Inc. has reviewed the conflict minerals reporting obligations contained in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and fully supports this Congressional effort to combat the role played by the trade of conflict minerals in financing armed groups in the Democratic Republic of the Congo.
Section 1502 calls on certain publicly traded companies to determine whether any tin, tantalum, tungsten or gold, if necessary to the functionality or production of their products, originated from the Democratic Republic of the Congo or its neighboring countries, with the determination accomplished by carrying out supply chain due diligence and then reporting the results of this due diligence to the Securities Exchange Commission.
As a wholesale distributor, Van Meter does not manufacture the products it distributes nor does Van Meter exert influence over the materials, parts, ingredients or components contained in the products that it distributes. Accordingly, Van Meter is not subject to the requirements of Section 1502 and does not have routine access to the information necessary to perform the due diligence called for by Section 1502.
Van Meter understands that some of its customers are involved with the reporting requirements of Section 1502 and/or are a part of the Conflict-Free Sourcing Initiative. While Van Meter fully supports these initiatives and has communicated this support to our suppliers, for the reasons stated above, we are not generally in a position to sign off on customer letters or to complete documentation, such as the Conflict Minerals Reporting Template, pertaining to our suppliers’ national and international supply chains. However, to assist our customers in their efforts to comply with these initiatives, we encourage our customers to contact the relevant suppliers for compliance information and also are willing to assist our customers in reaching the appropriate contact. Please let us know if we can assist you in reaching the appropriate contact.