CONFLICT MINERALS COMPLIANCE PROGRAM
Iridium Satellite LLC (“Iridium”) is committed to maintaining the highest standards of business conduct and ethics.
In recognizing that the trade of tin, tantalum, tungsten and gold (“Conflict Minerals” or “3TG”) has been a primary source of funding for the Democratic Republic of Congo (DRC) government’s armed conflict and human rights violations in the region surrounding the DRC, Congress enacted Section 1502 of the Dodd Frank Act to promote peace and security in the region. That Section provides, in part that effective January 1, 2013, companies that are regulated through the U.S. Securities and Exchange Commission (SEC) are required to disclose annually whether the Conflict Minerals (or their derivatives) in their products originated from the DRC region, and to disclose the due diligence conducted on the Conflict Minerals source and chain of custody.
Iridium is committed to complying with the SEC regulations regarding the reporting of the use of 3TG minerals.
Using the guidance provided by the Organization for Economic Cooperation and Development (OECD), Iridium is in the process of implementing a due diligence program to identify the source and chain of custody of 3TG minerals in our supply chain. Our due diligence program will include:
- Establishing a strong supply chain management system to guard against using 3TG mined or processed in the DRC and surrounding countries.
- Identifying and assessing risk in our supply chain.
- Designing and implementing a strategy to respond to identified risks.
- Carrying out an independent third-party audit of the supply chain due diligence.
- Reporting on supply chain due diligence.
At this time, most manufacturers are not yet able to provide detailed information as to the smelters, refiners or ultimate sources of the 3TG minerals used in electronic devices, such as our subscriber equipment, because of the complex and fragmented supply chains involved.
As part of this commitment to comply with the new SEC requirements, , Iridium is surveying all of its suppliers to confirm where 3TG minerals used to manufacture its subscriber equipment are mined, smelted or refined.
Iridium requests that our suppliers cooperate with us in our efforts to comply with SEC regulations by:
- Developing a Conflict Minerals due diligence program consistent with OECD guidelines.
- Adopting a policy of responsible sourcing of 3TG minerals and require that their suppliers to do the same.
- To the extent available, use Electronic Industry Citizenship Coalitions (EICC) – Global e-Sustainability Initiative (GeSl) designated Conflict-Free Smelters Program list of compliant smelters as the source for any 3TG minerals used in the products supplied to Iridium.