Conflict Minerals Policy Statement

Dye Sheet Metal Limited Liability Company to be hereafter listed as DSM LLC, is committed to act in a socially and environmentally responsible manner, to comply with the law, to meet its customer requirements, and to support its customers’ businesses.

DSM LLC fully understands the importance of the Conflict Minerals issue to its customers and is committed to supply chain initiatives that reflect DSM LLC’s overall corporate social responsibility and sustainability efforts that work towards a Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.

Because of the complexity of many supply chains and the lack of an established system for manufacturers to track Conflict Minerals back to their source, 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.

As a responsible company, DSM LLC supports the goal of the Dodd-Frank Act of preventing armed groups in the Democratic Republic of Congo and adjoining countries from benefitting from the sourcing of Conflict Minerals from that region.

As a contract precision sheet metal solution provider of customer based metal fabricated products and sub components, DSM LLC is invariably many levels away from the beginning of the supply chain for any Conflict Minerals or derivatives that may be involved within the fabrication process, but DSM LLC will strive to comply with requirements of the Dodd-Frank Act.

This policy demonstrates DSM LLC’s commitment and its expectations for its supply partners regarding actions to address Conflict Minerals.

Our Commitment: 

1.) To support the objective and the purpose of the Dodd-Frank Act concerning Conflict Minerals sourcing.

2.) To work with our suppliers by providing this policy and encouraging the due diligence steps that can be taken to determine the source of any Conflict Minerals that may be part of the products or process that they provide to DSM LLC.

3.) To discontinue sourcing from any supplier on any product or process that contains Conflict Minerals if determined that the product or process is not Conflict Free and the supplier fails to implement reasonable steps to transition to Conflict Free sources.

As a fabricator of products manufactured for other companies, DSM LLC does not knowingly purchase any raw Conflict Minerals from any source and is many levels removed from the mines, smelters, and refineries that produce the materials used in the products manufactured within the DSM LLC fabrication process and DSM LLC will not knowingly purchase said conflict materials from DSM LLC suppliers.

Supplier Code:

DSM LLC has the following expectations of its suppliers:

Suppliers should not include in any products or services sold to DSM LLC any Conflict Minerals that are not Conflict Free.
Suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Materials that are not Conflict Free from being included in the products and services sold to DSM LLC
Suppliers will provide to DSM LLC a copy of their Conflict Minerals policy and upon request provide any of their supply chain Conflict Minerals policies and/or Conflict Minerals statements.
DSM LLC suppliers are expected to source Conflict Minerals only from sources that are Conflict Free.
In doing so, suppliers will be expected to:

Implement and communicate to their organizations and suppliers Conflict Mineral policies that are consistent with the Conflict Free sourcing process.
Put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable.
Use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being Conflict Free, and require their direct and indirect suppliers to do the same.
Advise DSM LLC of any determination that the supplier either has concluded or has a reasonable basis to conclude that products or services that it currently sells or has sold to DSM LLC are not Conflict Free.
Maintain reviewable business records supporting the source of Conflict Minerals.
Suppliers are also encouraged to support industry efforts to enhance traceability and responsibility practices in Conflict Minerals supply chains.

DSM LLC evaluates its supplier relationships on an ongoing basis.

DSM LLC reserves the right to evaluate the extent to which the supplied has failed to reasonably comply with this Policy.

DSM LLC reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals included in any products or services sold to DSM LLC


Consequences of Supplier Non-Compliance

Suppliers who do not reasonably comply with this policy shall be reviewed by DSM LLC for future business.

In the event that DSM LLC determines that a supplier’s effort to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable steps to comply, DSM LLC reserves the right to take appropriate actions up to and including discontinuing the supplier relationship and any purchases of products or services from the supplier.