Amphenol Conflict Minerals Corporate Policy
Approved By: President and CEO, R. Adam Norwitt
Effective Date: 10/01/2010
To outline Amphenol Corporation's practices regarding the sourcing of Conflict Minerals as well as the verification of such practices.
This Policy applies to all employees of Amphenol Corporation ("Amphenol" or the "Company") and its subsidiaries and affiliates. Amphenol will, as far as it is reasonably practicable, ensure that the Company's activities, and those of its suppliers and subcontractors, will comply with this Policy.
Amphenol is committed to implementing programs and practices that promote environmental sustainability and social responsibility, while continually improving product quality and reliability. To that end, Amphenol considers it unacceptable that the sourcing of certain "Conflict Metals" eventually incorporated into its products could be contributing to armed conflict. Conflict Metals are defined as: gold (Au), tantalum (Ta), tin (Sn) and tungsten (W) derived from ores which have been mined in the Democratic Republic of the Congo or adjoining countries.
In carrying out this policy, Amphenol will implement programs and practices that, wherever practicable:
- Prevent the introduction of Conflict Metals into its products.
- Verify the sources of gold, tantalum, tin and tungsten used in its products.
- Audit its suppliers for the continued accuracy of those verifications.
- Maintain records of verifications for both internal and/or external audit.
- Assign internal roles and responsibilities and provide appropriate staff training to manage program.
- Communicate the Company's efforts to stakeholders.
All Amphenol managers, employees, partners and suppliers are expected to adhere to the spirit as well as the letter of this Policy.
The senior executive responsible for each local operating unit is ultimately responsible for stewardship of the products made there and shall:
- Provide appropriate staffing and assign internal roles and responsibilities to manage the Product Stewardship - Conflict Metals Program.
- Maintain an awareness of and familiarity with regional, national and multi-national (e.g., European Union) statutes, regulations, directives and criteria applicable to the operation.
- Develop and implement programs and procedures necessary to carry out this Policy, addresssing existing and new product lines.
- Provide training to all affected employees of the requirements of this Policy and the implementation of its programs and procedures. In particular, those personnel who interface with Amphenol's customers (e.g., sales and marketing, product designers, quality assurance staff) should be familiar with all material aspects of this programs.
- Maintain an adequate, verifiable database, consistent with the products being manufactured at a local operating unit, to facilitate transfer of information to customers and other stakeholders.
- Provide current information as input to an Amphenol-wide database of product information, if such is available.
The Company reserves the right to unilaterally terminate, suspend or amend this Policy at any time.