FKA Conflict Mineral Policy
SCOPE: Our structure, business and supply chains
Made on behalf of FKA Brands, this Conflict Mineral Policy encompasses FKA Brands Co. LLC. and its covered subsidiaries to prevent the use of Conflict Minerals Tin, Tungsten, Tantalum and/or Gold (3T&G) in our products.
Objective
FKA Brands manages its business and supply chain and upholds fairness and humane treatment of all individuals involved in the production and distribution of our products – something which is backed by its board of directors. FKA Brands believes that forced labour of any kind is unacceptable, and it remains committed to combatting forced labour in all forms.
We also have contractual obligations to our customers to ensure compliance with a conflict-free supply chain, as many of them are required to abide by US & EU Legislation regarding Conflict Mineral.
Our policies intend to, as far as is reasonably possible, ensure that the Conflict Minerals used in our products come from recycled, scrap or other conflict free sources.
Management System
Risk identification
- As a supplier of a wide range of products many of the products offered under our brands may contain one or more of the targeted 3TG metals (Tin, Tungsten, Tantalum and/or Gold).
- Products are “DRC Conflict Free” if they contain only Conflict Minerals that did not originate in the DRC or an adjoining country, are from recycled or scrap sources, or have not benefitted the armed groups identified as perpetrators of the abuse.
Mitigation
- Suppliers must demonstrate that they understand the Conflict Minerals Laws and be diligent about their component sourcing.
- Each year suppliers will be audited, they will be required to list all the smelters used within their supply chain for components on a list of sample products using the CMRT template. That list is checked against the Responsible Business Alliance 3TG Standard Smelter List for any anomalies.
Supplier engagement
- Each year suppliers receive a reminder to source the components that contain 3T&G from suppliers that diligently check their supply chain for the use of conflict minerals, specifically that such components and manufacturing materials are sourced from compliant smelters.
- Links to further educational materials are provided.
- Results from the surveys are used in face to face and virtual supplier meetings to drive continuous compliance.
- The regional Employee Handbooks detail our whistleblowing policies enabling employees to report any concerns.
Corrective Action
If FKA detected the use of Conflict Minerals in any of its suppliers, FKA would:
- cease all production of any non-compliant products immediately
- work with the factory on a corrective action plan (if a plan could not be agreed upon, FKA would remove the supplier from its Active Supplier List)
- notify its Trade Associations
- notify the local authorities and provide any evidence obtained by FKA
- make a statement on our website
CONCLUSION
Based upon information provided by our suppliers FKA does not knowingly use Conflict Minerals in our products that have not originated from a conflict free source.
