Conflict Minerals Policy
As Many of our suppliers and customers have acknowledged publicly, the Dodd-Frank Act1(1) created a new expectation for product manufacturers, which may be far removed from the source of the raw minerals in their products.
Ranger Plastic Extrusions Inc. manufactures custom plastic profile extrusions. Ranger Plastic Extrusions Inc. is committed to acting in a socially and environmentally responsible manner, to complying with the law, to meeting it's customer commitments, and to supporting it's customers' businesses. Because of the complexity of many supply chains and the lack of an established system for product manufacturers to track Conflict Minerals back to their source, the joint efforts over an extended period by many governments, industry groups, and companies will be required to make it possible to effectively trace Conflict Minerals back to their source. This document set forth is the policy of Ranger Plastic Extrusions Inc. regarding Conflict Minerals.
1. Support the aims and objectives of the Dodd-Frank Act concerning Conflict Minerals sourcing by working to educate the manufacturers of the products we purchase about Conflict Minerals.
2. Help our suppliers understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products they sell to Ranger Plastic Extrusions Inc.
3. Not continue to source from a supplier and product that contains Conflict Minerals if Ranger Plastic Extrusions Inc. determines the product is not DRC Conflict Free(2) and the supplier fails to implement reasonable steps to transition to DRC Conflict Free sources.
Commitment to Responsible Sourcing
Ranger Plastic Extrusions Inc. manufactures custom plastic profile extrusions utilizing numerous raw materials purchased from various companies. Ranger Plastic Extrusions Inc. supports the humanitarian goals of the Dodd-Frank Act and encourages the manufacturers of the raw material we purchase to adopt that same policy for their businesses. Ranger Plastic Extrusions Inc. converts the raw materials and does not formulate any material. As a convertor of products manufactured by other companies, Ranger Plastic Extrusions Inc. does not directly purchase any raw Conflict Minerals from any source and is many levels removed from the mines, smelters, and refiners that produce the metals used in the products manufactured by Ranger Plastic Extrusions Inc.'s suppliers. Ranger Plastic Extrusions Inc. is committed to working with it's suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they manufacture and sell to Ranger Plastic Extrusions Inc.
Ranger Plastic Extrusions Inc. has the following expectations of it's suppliers:
1. Suppliers should not include in any products sold to Ranger Plastic Extrusions Inc. any Conflict Minerals that are not DRC Conflict Free.
2. Suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to Ranger Plastic Extrusions.
3. Ranger Plastic Extrusions Inc. suppliers are expected to source Conflict Minerals only from sources that are DRC Conflict Free.
In doing so, suppliers will be expected to:
1. Implement and communicate to their personnel and suppliers policies hat are consistent with this Policy;
2. Require their direct and indirect suppliers to do the same;
3. Put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable;
4. Use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require the direct and indirect suppliers to do the same;
5. Advise Ranger Plastic Extrusions Inc. of any determination that the supplier either has concluded or has a reasonable basis to believe that products it currently sells or has sold to Ranger Plastic Extrusions are not DRC Conflict Free;
6. Maintain reviewable business records supporting the source of Conflict Minerals;
7. And from time to time, at Ranger Plastic Extrusions Inc. request, provide Ranger Plastic Extrusions, Inc with information concerning the origin of Conflict Minerals included in products sold to Ranger Plastic Extrusions, which Ranger Plastic Extrusions Inc. shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of any confidentiality agreements that do not specifically reference this paragraph.
Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.
Consequences of Supplier Non-Compliance
Ranger Plastic Extrusions Inc. evaluates its relationships with it's suppliers on an ongoing basis. Ranger Plastic Extrusions Inc. reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy. Ranger Plastic Extrusions Inc. reserves the right to request additional documentation from it's suppliers regarding the origin of any Conflict Minerals included in any products sold to Ranger Plastic Extrusions Inc. Suppliers who do not reasonably comply with this policy shall be reviewed by Ranger Plastic Extrusions Inc.'s supply chain organization for future business. In the event Ranger Plastic Extrusions Inc. determines that a supplier's efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Ranger Plastic Extrusions Inc. reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.
Nothing in this policy is intended to in anyway grant any additional rights or expectations to a Ranger Plastic Extrusions Inc.'s supplier or in anyway modify or otherwise limit in anyway any of Ranger Plastic Extrusion Inc.'s contractual or legal rights.
Grievance Mechanism and Reporting
Our employees, suppliers, and other parties can report concerns and alleged violations of this policy as follows:
(i) Write us at Ranger Plastic Extrusions Inc., Attn. John M. Earnest, PO Box 5443, Arlington, TX 76011
(ii) Email us at: email@example.com; or
(iii) Call us at 1-817-640-6407
Ranger Plastic Extrusions Inc. fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.
(1)On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act, was signed into law. The Dodd-Frank Act and related 2012 U.S. Securities and Exchange Commission rules require certain companies to disclose whether the products they manufacture or contract to manufacture contain Conflict Minerals necessary for the production or the functionality of the products that are sourced from mines in the Democratic Republic of the Congo or adjoining countries. Conflict Minerals are tantalum, tin, tungsten, and gold.
(2)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 abuses that are the subject of the Dodd-Frank Act.