UNICOM Engineering supports and respects the protection of human rights, including the fundamental human rights of workers throughout our supply chain. We believe in treating all people with respect and dignity and incorporate these principles into our business processes and relationships. UNICOM Engineering encourages our suppliers to adhere to the same high standards.
As part of our global approach to the protection of human rights, we believe in the ethical sourcing of materials used in our products.
One area of global concern is the Democratic Republic of the Congo (DRC) and its adjoining countries (“Covered Countries”). Some mining operations in the Covered Countries are controlled by warring militias who use profits from the sale and trade of certain rare earth minerals to finance violent ongoing, armed conflict the United Nations has linked to human rights violations, labor abuses, and environmental degradation. Four of these minerals (Tantalum, Tin, Tungsten, and Gold), commonly referred to as 3TG, have been used in electronics.
In August 2012, as required by Section 1502 of the Dodd-Frank Act, the U.S. Securities and Exchange Commission adopted Rule 13(p)(1) under the Securities Exchange Act. This Rule requires all public companies annually to report any 3TG contained in products they manufacture or contract to manufacture to the extent 3TG is necessary for the functionality or production of their products. UNICOM Engineering supports this legislation and is committed to responsible sourcing of 3TG.
As a system integrator, UNICOM Engineering does not directly source 3TG from mines, smelters, or refiners and is several levels removed from manufacture involving 3TG minerals. Instead, we rely on declarations of compliance from the complex global value chain of suppliers and other stakeholders who provide the parts used in the products we build. In addition, UNICOM Engineering expects suppliers to implement controls on their own supply chain, so they are able to provide us this information to demonstrate that any 3TG in the parts we purchase from them are “conflict-free.”
On a scheduled basis, UNICOM Engineering will request Suppliers to provide a Conflict Minerals declaration. The periodicity of the request will be determined by the Compliance Manager at UNICOM Engineering.
Supplier/OEM agrees to respond to update requests from UNICOM Engineering promptly in one of the formats listed below.
1. Conflict Minerals Reporting Template (CMRT)
a) Download and complete the latest Conflict Minerals Reporting Template (CMRT) to declare mineral country of origin, smelters and refiners.
b) Check declared smelters and refiners against our Smelters Issues List. Address documented concerns and take appropriate action.
2. Conflict Minerals Disclosure Statements
Any declaration form or statement other than a CMRT and originating with the Supplier or OEM shall be considered a legally binding document.
Company-wide or SEC Disclosure Statements are acceptable if they are available in the reader’s language and include:
Assertion that the company or product complies with the Directive. Declare:
Return a copy of the completed CMRT or Supplier statement(s) to the Compliance Manager or Compliance Specialist in Regulatory Compliance for our records, or submit a copy to email@example.com.
Download the company-wide UNICOM Engineering Conflict Minerals CMRT. For more information, view our Conflict Minerals Policy Statement.
For additional information about the Responsible Minerals Initiative or guidance completing the Conflict Minerals Reporting Template, visit the Responsible Minerals Initiative (RMI) website at https://www.responsiblemineralsinitiative.org/conflict-minerals-reporting-template/training
Also, see our: Supplier Product On-Boarding Checklist section.
Contact the UNICOM Engineering Environmental Compliance Specialist at 972-673-1373.