Tranzact Conflict Minerals Policy

Tranzact, Inc. acknowledges the United Nations’ Security Document (S/2001/357): “Final Report of the Panel of Experts on the illegal Exploitation of Natural Resources and Other Forms of Wealth of the Democratic Republic of the Congo”. This report outlines the enterprises surrounding the illegal exploitation of tantalum and tungsten containing minerals from the DRC and adjoining areas (Sudan, Uganda, Rwanda, Burundi, United Republic of Tanzania, Zambia, Angola, Congo, and the Central African Republic) that finance illegally armed groups and perpetuate human rights violations. In response to this report and pressure from non-profit organizations, the US Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 (July 21, 2010). Specifically, the legislation contains an SEC ruling designed to eradicate Conflict Minerals from the global supply chain.

Pursuant to these events, Tranzact, Inc. does not purchase or supply tantalum and tungsten materials whose origin can be traced back to the DRC or surrounding countries. Tranzact, Inc. requires the necessary documentation from all of our suppliers in accordance with the Conflict-Free Smelter Program (CFSP) to guarantee that only conflict-free materials enter our facility. Specific to tantalum, Tranzact, Inc. only purchases secondary or scrap/recycled materials as defined by the Conflict-Free Sourcing Initiative (CFSI). These materials have been designated as exempt by US legislation and the Electronic Industry Citizenship Coalition (EICC). Our Conflict-Free Minerals policy is elemental to Tranzact’s Standard Operating Procedure for purchasing, processing, and supplying tantalum and tungsten materials.

January 15, 2015