The Dodd-Frank Wall Street Reform and Consumer Protection Act required the U.S. Securities and Exchange Commission (SEC) to adopt rules requiring SEC reporting companies (such as STERIS plc (the "Company")) to file reports with the SEC disclosing their use of tin, tantalum, tungsten, and gold ("conflict minerals" or "3TG") in products sold anywhere in the world. These requirements have been imposed because some of the conflict minerals originating in certain portions of Africa have been mined and sold under the control of armed groups. The SEC rules implementing these disclosure requirements provide that reporting companies that manufacture products (or contract with others to manufacture products) that contain 3TG must review their supply chains and gather and disclose information about the source and chain of custody of the 3TG in their products, with a focus on minerals that originate from the Democratic Republic of Congo ("DRC") and adjoining countries.
In accordance with these legal requirements and as a part of the overall commitment of the Company (collectively with its subsidiaries, "STERIS") to responsible sourcing, STERIS is working with its suppliers to ensure transparency to the smelter/refining source for 3TG materials used in STERIS products. Furthermore, STERIS seeks to identify the countries of origin of the 3TG in our products and the smelter/refiners that process the 3TG in our products. We undertake this effort to promote responsible sourcing. STERIS does not support the direct or indirect funding of armed groups operating in the DRC or adjoining countries, and supports responsible sourcing throughout the region and world.
Because of STERIS's general downstream position in the supply chain, it relies on its suppliers for information. STERIS expects its suppliers to respond to its requests for complete transparency about the sources whose 3TG materials are used in STERIS products and to conduct due diligence measures to ensure the information provided is accurate, up-to-date and complete. This Policy applies to all suppliers of products and materials to the Company and to all STERIS affiliates.
As a result of this policy, STERIS:
STERIS will consider taking various progressive actions with respect to suppliers who do not make reasonable efforts to cooperate with STERIS's requests for information or requests to take corrective actions to enable STERIS to identify smelters and refiners in its supply chains. These measures may include continuing business with the supplier as the supplier undertakes risk mitigation measures or temporarily suspending business with the supplier while the supplier pursues ongoing risk mitigation efforts. Ultimately, with respect to suppliers who have failed or refuse to make requested mitigation efforts or where mitigation appears unfeasible, these measures may include termination of the relationship.
To provide feedback on the content or execution of this Policy, please contact STERIS by emailing ConflictMinerals@steris.com
For more information, please refer to the links below: