Gadjets, Inc. ("Gad-jets") is committed to conducting its business in an ethical and socially responsible manner. This policy establishes our commitment to ensuring that the minerals used in our products—including high-performance exclusion seals, rod wipers, and scrapers—are sourced responsibly and do not contribute to human rights abuses or environmental degradation.
This policy applies to all materials purchased by Gad-jets, with a specific focus on "Conflict Minerals" (3TG: Tin, Tantalum, Tungsten, and Gold) and "Minerals of Concern" (such as Cobalt), which are frequently present in the specialized metal alloys, super-alloys, and coatings required for our aerospace and industrial components.
Gad-jets recognizes the risks of significant adverse impacts which may be associated with extracting, trading, handling, and exporting minerals from conflict-affected and high-risk areas (CAHRAs). We commit to:
Human Rights: Supporting the protection of human rights and refusing to tolerate any activities that contribute to the financing of conflict or involve forced labor, child labor, or gross human rights violations.
Ethical Sourcing: Working toward a supply chain that sources minerals only from smelters and refiners that have been successfully audited by the Responsible Minerals Assurance Process (RMAP) or equivalent third-party schemes.
Sustainability: Continuing our practice of utilizing recycled materials (currently near 100% for metal products) to reduce the demand for primary mining and minimize our environmental footprint.
As a component manufacturer, our influence is greatest within our direct supply chain. We require our suppliers to:
Adopt a Policy: Maintain their own policy regarding responsible mineral sourcing that is consistent with the OECD Due Diligence Guidance.
Due Diligence: Conduct reasonable due diligence within their supply chains to determine the origin of the minerals contained in the alloys, coatings, and compounds provided to Gad-jets.
Transparency: Complete and submit the Conflict Minerals Reporting Template (CMRT) and, where applicable, the Extended Minerals Reporting Template (EMRT) annually or upon request.
Smelter Verification: Work toward sourcing exclusively from "Conformant" smelters and refiners as designated by the Responsible Minerals Initiative (RMI).
Data Accuracy: Ensure that all information regarding the chemical composition of metals (e.g., Tungsten in super-alloys or Tin in copper-based alloys) is accurate and verifiable.
Gad-jets follows a risk-based approach to supply chain management:
Identification: We review the Material Test Reports (MTRs) and Safety Data Sheets (SDSs) for all purchased metals to identify the presence of 3TG or Cobalt.
Assessment: If a supplier is found to be sourcing from a "Non-Conformant" or high-risk smelter, Gad-jets will engage with that supplier to encourage a transition to a responsible source.
Discontinuation: If a supplier fails to cooperate or is found to be knowingly sourcing minerals that fund armed conflict or human rights abuses, Gad-jets reserves the right to terminate the business relationship.
A core tenet of Gad-jets’ operations is the use of recycled content. We prioritize suppliers who provide certified recycled alloys. Metals derived from 100% recycled or scrap sources are considered "responsibly sourced" under this policy, provided the supplier can provide adequate documentation of the material's origin.
Gad-jets will communicate this policy to all relevant stakeholders, including employees, suppliers, and customers. We will respond to customer inquiries regarding mineral origin in a timely manner to support their own regulatory compliance (e.g., Section 1502 of the Dodd-Frank Act).
This policy will be reviewed annually and updated as necessary to reflect changes in international standards, regulatory requirements, and the evolving nature of our supply chain.
Approved by:
Management Team, Gadjets, Inc.
Last Updated: January 2025
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