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Our REACH and Conflict Mineral Policies

August 16, 2022

Our Policy

Powell Industries is dedicated to supporting both vendor partners and customers in their efforts to comply with section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd- Frank Act) and the latest REACH Regulation. While a number of Powell Industries vendor partners have developed targeted communications regarding their corporate positions in reference to REACH and conflict minerals, customers should refer directly to the manufacturer for any questions regarding this issue. Powell representatives can and will assist you in contacting manufacturers to obtain information but moving forward, in no situation will a Powell Representative make statements or claims on behalf of the manufacturers in reference to their policies and compliance with any REACH requirement and/or on conflict minerals. There are far too many products that Powell provides for us to know every substance. For some of the materials we provide, the suppliers consider them proprietary and will not release all of the content(s) information. Powell simply cannot make claims about so many distributed materials that may not be accurate.

Background

Conflict minerals are minerals mined in areas with armed conflicts and human rights abuses, most notably in the Democratic Republic of Congo by the Congolese National Army and various armed rebel groups. Commonly extracted minerals from the Congo, such as cassiterite, wolframite, coltan, and gold are usually passed through a variety of intermediaries before potentially being purchased by multinational companies. These minerals are essential for manufacturing a variety of devices, especially electronic devices.

U.S Law

Section 1502 of the Dodd-Frank Act requires companies to verify and disclose their sources of cassiterite, wolframite, and tantalum. On July 25, 2011, the US State Department issued a statement: “Section 1502(c) of the Law mandates that the State Department work in conjunction with the SEC on certain elements of conflict minerals policy development and support.”

Auditing and reporting requirements

The US Conflict Minerals Law contains two requirements that are closely connected: independent third party supply chain traceability audits and reporting of audit information to the public and the SEC. Even companies not directly regulated by the SEC will be impacted by the audit requirements because this information will be pushed down through entire supply chains.

Michael A. Powell
General Manager