“Conflict minerals”1 originating from the Democratic Republic of the Congo (DRC) are sometimes mined and sold, “under the control of armed groups”2, to “finance conflict characterized by extreme levels of violence”2. Some of these minerals can make their way into the supply chains of the products used around the world, including those in the electronics industry. Eclipse MDI’s suppliers acquire and use conflict minerals from multiple sources worldwide. As part of Eclipse MDI’s commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is Eclipse MDI’s goal to use tantalum, tin, tungsten and gold in our products that do not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries while continuing to support responsible mineral sourcing in the region.

Eclipse MDI expects our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free3. Eclipse MDI expects our suppliers to comply with the Electronic Industry Citizenship Coalition (EICC) Code of Conduct and conduct their business in alignment with Eclipse MDI’s supply chain responsibility expectations.

In support of this policy, Eclipse MDI will:

  •   Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
  •   Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm the tantalum, tin, tungsten, and gold in our supply-chain are “conflict free”2.
  •   Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.
  •   Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.

1. “Conflict minerals” as defined by Securities and Exchange Commission (SEC) rules is a broad term which means columbite- tantalite (coltan), cassiterite, gold, wolframite, or their derivatives which are limited to tantalum, tin or tungsten, regardless of whether these minerals finance conflict in the Democratic Republic of the Congo (DRC) or adjoining countries.
2. Dodd-Frank Act Section 1502.

3. DRC conflict free “means that a product does not contain conflict minerals necessary to the functionality or production of that product that directly or indirectly finance or benefit armed groups” as defined SEC Rule 13p-1 under the Securities Exchange Act of 1934.
4. We use the term “conflict free” in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.

Conflict Materials Frequently Asked Questions

3) Do any of the smelters in your supply chain source the 3TG from the covered countries?

It is unknown at this time. Please check back periodically for more information.

5) What percentage of relevant suppliers have provided a response to your supply chain survey?

100% of relevant suppliers have provided Eclipse MDI with adequate responses.

6) Have you identified all of the smelters supplying the 3TG to your supply chain?

Yes, Eclipse MDI has identified all of the smelters which supply the 3TG for our supply chain.

7) Has all applicable smelter information received by your company been reported in this declaration?

Yes, Eclipse MDI has included all applicable smelter information received by us, has been reported in this declaration.

E. Have you implemented due diligence measures for conflict-free sourcing?

Yes we have established measures for conflict-free sourcing.

F. Does your company conduct Conflict Minerals survey(s) of your relevant supplier(s)?

Yes, in conformance with IPC1755 (e.g., CMRT compliance statement)

G. Do you review due diligence information received from your suppliers against your company’s expectations?

Yes, Eclipse MDI reviews all due diligence information received from our suppliers against our companies expectations.

H. Does your review process include corrective action management?

Yes as per our ISO9001-2015 process flows.

I. Is your company required to file an annual conflict minerals disclosure with the SEC?

No, Eclipse MDI is not required to file an annual conflict minerals disclosure because we are not a public company as per U.S. SEC regulations imposed.