Conflict Minerals Responsible Sourcing Policy

ValvTechnologies’ Conflict Minerals Responsible Sourcing Policy

In 2013, the Dodd-Frank Wall Street Reform and Consumer Protection Act identified and addressed the mining and sourcing of tin, tungsten, tantalum, and gold (also known as 3TG or “conflict minerals”) from the Democratic Republic of Congo (DRC) and adjoining countries. These conflict minerals are mined in conditions of armed conflict and their sale contributes to human rights abuses in the region. As a severe service valve manufacturer who uses 3TG minerals, ValvTechnologies commits to ensure that the 3TG minerals in our products do not directly or indirectly benefit or finance any human rights violations in the DRC or adjoining countries. While we do not procure directly from these countries, it is important to have downstream visibility into our supply chain to ensure the responsible sourcing of conflict minerals.

It is for this reason that ValvTechnologies commits to the ethical, sustainable, and responsible sourcing of all our products.

Under Section 1502 of Dodd-Frank, all public companies are required to report 3TG activity to the Security and Exchange Commission (SEC) on an annual basis. While ValvTechnologies is not a publicly traded company, our commitment to responsible sourcing is aimed at serving and providing our customers with full supply chain transparency. ValvTechnologies will work with suppliers and collect downstream supply chain data using the industry standard CMRT form. The following bullet points state the commitments ValvTechnologies has towards our suppliers and customers.

ValvTechnologies’ Suppliers are required to:

  • Comply with all federal and international laws in the sourcing of conflict minerals.
  • Submit a declaration of conflict minerals using the CMRT form.
  • Send the CMRT form downstream to sub-suppliers for supply chain visibility.
  • Maintain the CMRT form with any updates on a yearly basis.

ValvTechnologies is committed to:

  • Exercising due diligence in reporting any 3TG activity within our supply chain.
  • Collaborating with suppliers to provide due diligence information regarding their sourcing of conflict minerals.
  • Providing our customers with full visibility regarding our usage of any 3TG materials.
  • Maintaining a sustainable and ethical sourcing strategy to ensure a conflict-free supply chain.

Due to the nature of our supply chain, we cannot guarantee that 100% of our materials will be free of conflict minerals originating in the DRC and adjoining countries. However, by committing to the requirements above, we will work to increase our downstream visibility and, when practicable, act to adjust our supply base to ensure our commitment to conflict mineral free definition remains focused.