The Conflict Minerals Rule, which was adopted under the Dodd-Frank Wall Street Reform and Consumer Protection Act, requires publicly traded companies that manufacture or contract to manufacture products containing tantalum, tin, tungsten or gold (“3TG”) that is necessary to the functionality or production of such products to take certain steps to determine the origin of such necessary 3TG, and to report findings annually to the U.S. Securities and Exchange Commission (“SEC”). The Conflict Minerals Rule is intended by Congress to address the concern that trade in 3TG from the Democratic Republic of the Congo and surrounding countries is helping to finance the ongoing conflict and humanitarian crisis in that area.
As a company that provide procurement and manufacturing services to clients that are publicly traded, SLWM, LLC dba SupplyLogic (”SupplyLogic”) hereby attest that it does not directly source any 3TG from mines, smelters or refiners, and is in many levels removed from these market participants. To the best of our knowledge, our products do not contain any Conflict Minerals or their derivatives. We therefore require the cooperation of our suppliers with this policy to enable us to assist our clients in meeting their SEC compliance obligations.
SupplyLogic has the following expectations of its suppliers for products that we contract with them to manufacture:
- We expect our suppliers to promptly, completely and accurately respond to our informational requests with respect to any 3TG that is necessary to the functionality or production of such products, including by providing a written attestation that the products provided to SupplyLogic and its clients do not contain any Conflict Minerals that directly or indirectly finance or benefit the Democratic Republic of Congo (DRC) or any adjoining country.
- We expect our suppliers to (1) determine whether there is any 3TG in any such products, (2) survey their upstream suppliers regarding the ultimate source of any such 3TG, and (3) verify and document such information.
- We expect our suppliers to implement policies and management systems to support compliance with these expectations and require their upstream suppliers to adopt similar policies and systems.
- We expect our suppliers to cooperate in the event we determine that any further inquiry or due diligence is required or advisable with respect to the supply of 3TG in any such products.
SupplyLogic believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that a supplier may be violating this policy, we may require them to commit to and implement a corrective action plan within a reasonable timeframe, or we may terminate our business relationship with such supplier. Nothing contained in this policy shall be interpreted to preclude SupplyLogic from terminating any supplier relationship at any time for any reason.
Concerns regarding this policy, or suspected violations of this policy, can be reported to compliance@slwmco.com.
- Revision History
| Version # | Description | Approved Date |
| 1 | New policy created. | 23 May 2023 |
| 2 | Annual review and minor updates | 22 March 2024 |
| 3 | Annual review – no updates | 4 April 2025 |
| 4 | Rebrand | 22 October 2025 |