Conflict Mineral Policy

At Senior Flexonics LPE we are committed to eliminating illegal trade in gold, tin, tantalum and tungsten (Conflict Minerals).


In 2010, Congress enacted the Conflict Minerals provisions of the Dodd‐Frank Street Reform and Consumer Protection Act with the goals of eliminating the illegal trade in gold, tin, tantalum and tungsten (Conflict Minerals) and cutting the funding of armed groups in the Democratic Republic of the Congo (DRC) and its neighbouring countries (Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia) that are engaged in human rights abuses.

Section 1502 of the Dodd‐Frank Act requires publicly traded companies to report to the US Securities and Exchange Commission (SEC) whether any of the Conflict Minerals in the products they manufacture or contract to manufacture originate in the DRC Region and the due diligence conducted to determine if the original sale of the mineral funded armed conflict.


LPE are committed to operating and sourcing in an ethically and socially responsible manner. LPE is committed to ensuring our principles are honoured in all of our business decisions, including those with our customers, manufacturers and suppliers.

We are committed to taking steps to ensure that the products we manufacture, those that we purchase from our manufacturers and suppliers, are responsibly sourced, including sourcing from companies that share our values around human rights, ethics, and social & environmental responsibility.

If LPE identify suppliers whose actions are contributing to the conflict, LPE will suspend or disengage from using those suppliers and will follow all ethical practices in sourcing of these minerals.


To comply with the Securities and Exchange Commission’s reporting regulations related to Conflict Minerals, LPE requires, from relevant suppliers within our Supply Chain, chain of custody declarations to verify the origin of the Conflict Minerals contained in their products.

In addition, LPE require the following from our suppliers:

To source materials from socially responsible sub-tier suppliers and manufacturers.

To assist LPE to comply with the SEC regulations related to Conflict Minerals and to provide all necessary declarations.

To undertake reasonable due diligence within their supply chain to determine the origin of the Conflict Minerals, if applicable, including developing policies and management systems designed to transition suppliers away from the use of Conflict Minerals or derivative minerals sourced from mines that directly or indirectly finance armed groups through mining or mineral trading in the Democratic Republic of Congo (DRC) or any neighbouring country.

To pass the above requirements along to theirs sub-tier suppliers and require them to do the same with lower tiers of suppliers.


Please do not hesitate to contact us regarding any matter relating to our Conflict Minerals Policy using the form on our contact us page.

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