On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted a final rule to implement reporting and disclosure related to "conflict minerals," as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rule requires manufacturers who are SEC filers to disclose whether the products they manufacture or contract to manufacture contain "conflict minerals" that are "necessary to the functionality or production" of those products.
Conflict minerals refer to tin, tantalum, tungsten and gold (commonly referred to as 3T&G), regardless of where they are sourced, processed or sold. The intent of these requirements is to further the goal of ending violent conflict in the Democratic Republic of the Congo (DRC) and in adjoining countries, which has been financed, in part, by the exploitation and trade of conflict minerals. Mallinckrodt has initiated a comprehensive process to comply with the reporting and disclosure related to "conflict minerals," as directed by the Act.
In line with this policy, Mallinckrodt is specifically:
Mallinckrodt must rely on its suppliers' cooperation in the implementation of and adherence to this policy in order to meet its obligations to the SEC. Our specific expectations of suppliers include a timely response to our queries about purchased components, assistance in reaching out to their suppliers in case the source of minerals is not currently known, and regular communications with Mallinckrodt about suppliers' conflict mineral tracking and tracing efforts.
Supplier shall have a policy to reasonably assure that the tin, tantalum, tungsten and gold in the materials they manufacture do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Supplier shall exercise due diligence on the source and chain of custody of these minerals and make its due diligence measures available to Mallinckrodt upon request. Supplier is responsible for putting a process in place to communicate these requirements to its suppliers and to monitor supplier compliance with these requirements.
More details on the complete Mallinckrodt supplier expectations may be found here.
Concerns or reports of possible violations of this policy can be reported confidentially through Mallinckrodt's Integrity Hotline:
Suppliers and other external parties are encouraged to contact us if they wish to seek guidance on the application of this approach, or if they wish to report suspected abuse. They, and other external stakeholders, may also report problems or concerns via the above Mallinckrodt contact methods. Applicable to all employees and suppliers, this policy will be regularly reviewed, updated and communicated.