Conflict Minerals Policy Statement
Overview
As a responsible company, THECLIP.COM, Inc. supports the goal of the Dodd-Frank Act of preventing armed groups in the Democratic Republic of the Congo and adjoining countries from benefitting from the sourcing of Conflict Minerals from that region.
As a manufacturer and supply distributor of hundreds of branded and private label products manufactured by us, or our manufacturing partners located around the world, THECLIP.COM, Inc. is committed to avoiding conflict materials at all costs.
This Policy shows THECLIP.COM’s commitment and its expectations for its product suppliers regarding actions to address Conflict Minerals.
OUR COMMITMENT:
- Support the aims and objectives of the Dodd-Frank Act concerning Conflict Minerals sourcing by working to educate the manufacturers of the products we distribute about Conflict Minerals.
- Help our manufacturing partners understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products produced for THECLIP.COM, Inc.
- Not continue to source from a manufacturing partner any product that contains Conflict Minerals if THECLIP.COM, Inc. determines the product is not DRC Conflict Free and the supplier fails to implement reasonable steps to transition to DRC Conflict Free sources.*
Commitment to Responsible Sourcing
THECLIP.COM, Inc. distributes hundreds of products that are manufactured by us, our partner factories, or other companies located around the world.
THECLIP.COM, Inc. supports the humanitarian goals of the Dodd-Frank Act and encourages the manufacturers of the products distributed by THECLIP.COM, Inc. to adopt that same policy for their businesses.
As a distributor of products sometimes manufactured by other companies, THECLIP.COM, Inc. does not directly purchase any raw Conflict Minerals from any source and is levels removed from the mines, smelters, and refiners that produce the metals used in the products manufactured by THECLIP.COM’s suppliers.
The supply chain for Conflict Minerals is sometimes complex and lacks an established structure for product manufacturers to trace the minerals in the finished goods distributed by THECLIP.COM, Inc. back to their source.
THECLIP.COM, Inc. is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they manufacture and sell to THECLIP.COM, Inc.
Supplier Code
THECLIP.COM, Inc. has the following expectations of its manufacturing partners:
Suppliers should not include in any products sold to THECLIP.COM, Inc. any Conflict Minerals that are not DRC Conflict Free;
Suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to THECLIP.COM, Inc.; and
THECLIP.COM’s suppliers are expected to source Conflict Minerals only from sources that are DRC Conflict Free.
In doing so, supplier and manufacturing partners will be expected to:
Implement and communicate to their personnel and suppliers policies that are consistent with this Policy, and require their direct and indirect suppliers to do the same;
Put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable;
Use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require their direct and indirect suppliers to do the same;
Advise THECLIP.COM, Inc. of any determination that the supplier either has concluded or has a reasonable basis to believe that products it currently sells or has sold to THECLIP.COM, Inc. are not DRC Conflict Free;
Maintain reviewable business records supporting the source of Conflict Minerals; and
from time to time, at THECLIP.COM’s request, provide THECLIP.COM, Inc. with information concerning the origin of Conflict Minerals included in products sold to THECLIP.COM, Inc., which THECLIP.COM, Inc. shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of any confidentiality agreements that do not specifically reference this paragraph.
Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.
Consequences of Supplier Non-Compliance
THECLIP.COM, Inc. evaluates its relationships with its suppliers on an ongoing basis.
THECLIP.COM, Inc. reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.
THECLIP.COM, Inc. reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals included in any products sold to THECLIP.COM, Inc.
Suppliers who do not reasonably comply with this Policy shall be reviewed by THECLIP.COM’s supply chain organization for future business.
In the event THECLIP.COM, Inc. determines that a supplier’s efforts to comply with this Policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, THECLIP.COM, Inc. reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.
Nothing in this Policy is intended to in any way grant any additional rights or expectations to a THECLIP.COM, Inc. supplier or in any way modify or otherwise limit in any way any of THECLIP.COM’s contractual or legal rights.
Grievance Mechanism and Reporting
Our employees, suppliers, and other parties can confidentially report concerns and alleged violations of this Policy as follows:
(i) Write us at THECLIP.COM, Inc.: THECLIP.COM, Inc. 2735 HWY 40 W, VERDI, NV 89439
(ii) Email us at: sales@theclip.com; or
(iii) Call us at: 1-775-481-6011.
Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law. We will not take any retaliatory action against our employees, suppliers, or other parties who make a report in good faith. Our suppliers are encouraged to contact sales@theclip.com if they wish to seek guidance on the application of this Policy.
Conclusion
THECLIP.COM, Inc. fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.
