Conflict Minerals Sourcing Policy

Conflict Minerals Sourcing Policy

Trimm Inc is committed to conducting our business activities in accordance with the highest legal and ethical standards. We are committed to comply with all applicable laws and regulations, to support ethical and responsible conduct within our operation and our supply and we expect that our business partners to share in this commitment.

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 requires publicly traded companies to inquire into the origin of 3TG (Tungsten, Tin, Tantalum, Gold ) minerals in their supply chains and to report on their due diligence processes and findings in filings with the Securities and Exchange Commission. Trimm Inc, a private company, fully supports this legislation and is committed to responsible sourcing of 3TG as well as full compliance with the requirements.  Trimm Inc expects our suppliers to implement processes and controls to ensure the components, parts and products that we purchase from them are "conflict free”. 

Trimm Inc has implemented a due diligence program to identify and track any use of 3TG minerals in our supply chain utilizing tools provided by the EICC and the Organization for Economic Co-operation and Development (OECD).

 

Due diligence program 

1.  Monitoring the use of 3TG in our supply Chain: The EICC Mineral Reporting Template was sent to all of our direct suppliers, their responses were filed as supporting evidence and the data was used to update our 3TG database. This database will be maintained to reflect the overall progress of the program and each supplier’s status towards compliance. Updates to the database will occur as new information is received.

2.  On-going communication to suppliers: Our Purchase Order terms and conditions now include a statement expressing expectations that all our suppliers comply with applicable laws and regulations including the Dodd-Frank Act 2010 and the reporting of any origin of 3TG. 

3.  Collection of data: The EICC , GeSI template will continue to be used to collect supplier information and to share all the Conflict Free smelters that have been certified as conflict free.

 

Future Steps

1.  Sustainment Process: Trimm Inc will work with our suppliers to support and meet the intention of the Dodd-Frank Act of 2010, and maintain a supply chain that is both ethical and socially responsible with the ultimate goal of becoming "3TG Conflict Free".

2.  Frequency: On an annual basis, survey all our suppliers to confirm their 3TG status.

3.  Upon request Trimm Inc will update our 3TG status to our customers.