Conflict Minerals

The Dodd-Frank Act requires US-listed companies to submit annual reports on their use of gold, tin, tantalum and tungsten from illegal mines in the Democratic Republic of the Congo and its neighboring countries.

The issue of conflict minerals is well known in the electronics and other industries and is extremely complex. Resolution will require the commitment and cooperation of businesses, governments and non-governmental organizations (NGOs).

Luckylight is not a US-listed company and is not directly regulated by the US Securities and Exchange Commission (SEC). We are, therefore, not in the direct scope of the regulations. However, being a supplier to many large companies who are regulated by the SEC, we recognize that the Dodd-Frank Act will also affect our business, and that our customers will expect us to be able to trace the respective minerals in our products, and by doing so facilitate our customers’ disclosure obligations.

Luckylight commitments and measures

We have established internal processes to determine whether 3TGs in our products are DRC Conflict-Free.

We will continue to:

  • Luckylight does not procure nor support the use of conflict minerals. Luckylight requires all suppliers not to procure conflict minerals. Luckylight also asks suppliers to cascade this requirement to sub-tier suppliers.
  • Identify potential sourcing risks affecting our products in which 3TGs are required and proactively require all minerals in our supply chain to be DRC conflict-free;
  • Exercise due diligence regarding the origin and chain of custody of the 3TGs contained in products in our supply chain that we manufacture or contract to manufacture;
  • Encourage our suppliers to responsibly source 3TGs through smelters and refiners that have been verified as DRC conflict-free through the Conflict Free Smelter Program (CFSP) or a similar framework;
  • Support and adhere to national and international standards and guidelines for responsible supply chains of 3TG minerals like the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals;
  • Collect and report information about the origin of the 3TGs in our supply chain through the use of the EICC/GeSI Conflict Minerals Reporting Template.

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