Conflict Minerals Policy

Arcturus Networks Inc. - Conflict Minerals Policy Statement


Arcturus Networks Inc.

Conflict Minerals Policy Statement

Arcturus Networks Inc. (Arcturus) supports the reduced use of minerals sourced from conflict zones throughout the world. It is our policy to design products that reduce the use of components containing tantalum, tin, gold and tungsten. Where the use of tantalum, tin, gold or tungsten is required, Arcturus takes efforts to source its components from electronic component manufacturues who provide disclosures of mineral sourcing.

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act) enacted in July 2010 imposes new supply chain reporting requirements on publicly traded companies to promote transparency and consumer awareness regarding the use of "conflict minerals" columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives (tantalum, tin,gold and tungsten) that directly or indirectly finance or benefit armed groups in that region. As directed by the Act, the U.S. Securities and Exchange Commission (SEC) has adopted rules requiring publicly traded companies to disclose whether they use tantalum, tin, gold and tungsten that originated in the DRC and if so, to issue a report identifying their products that are not conflict free and their due diligence efforts to determine the source and chain of custody of the metals. Conflict free means the product does not contain tantalum, tin, gold and tungsten that directly or indirectly finances or benefits armed groups in the DRC or an adjoining country. In addition, governments around the world are developing policies related to supply chain due diligence of these metals.

Arcturus supports efforts to eliminate the use of tantalum, tin, gold and tungsten from improper sources that could promote such serious problems in the DRC and adjoining countries. Arcturus, like many companies in the consumer and industrial electronic industries, uses sub-assembles and components that may contain tantalum, tin, gold and tungsten. Each of these metals has specific electrical properties which are necessary for the function of our products.

Arcturus expects our suppliers and contract manufacturures to honour our policy by ensuring disclosures of mineral sourcing and to take measures with their suppliers to eliminate mineral sourcing from conflict zone throughout the world.

16 March 2020