Committed to doing the right thing

At Kautex Textron, we are proud of a long-established history of Compliance, Ethics and Honesty, Respectful Business Conduct and Integrity. Kautex’s strict adherence to Compliance principles and our good business ethics are essential and critical business assets that allow our customers, business partners, shareholders, stakeholders, employees and their families to take pride in their association with Kautex and rewarded for the trust placed in us. We constantly endeavor to earn and keep the trust of our business partners and the communities where we work and live. One way that we meet this commitment is through Kautex’s Ethics and Compliance program. Our program aims to identify risks, develop policies and processes and bring these policies and processes to life in our business.

All of us are needed to do the right thing together!

MATERIAL COMPLIANCE

Material compliance is part of good governance and is important in current global scenario. Kautex Textron is committed to material compliance, which includes a number of policies, including the Environment Policy and Supplier Code of Conduct, and is committed to ensure high social, environmental and human health and human rights standards. We encourage and expect our suppliers and sub-contractors to adopt similar standards and to comply with all the regulatory requirements.

Legal frameworks worldwide have very strictly been put in place. This means Kautex Textron is required to monitor the source of certain minerals more closely, and phase out the use of hazardous substances in its products and processes. Kautex Textron expects suppliers to actively support ongoing efforts to manage and demonstrate product compliance with regulations such as ELV, REACH, RoHS and Conflict Minerals, etc.,

At Kautex Textron, we are determined to comply with regulatory and customer requirements regarding the prohibition and restriction of substances, including hazardous substances and conflict minerals. Therefore, it is the responsibility of the suppliers that they shall ensure  the goods provided to Kautex Textron are in compliance with requirements covered under the scope of all relevant regulations. In particular, you will

− Declare to Kautex Textron through the Supplier Portal, the substances which are listed as Prohibited and Restricted Substance and contained in the goods you supply to Kautex Textron;

− Implement a policy regarding conflict minerals and exercise due diligence to investigate the source of these minerals; and

− Respond in a timely manner to our requests for evidence of your compliance with these requirements:

Committed to ensure high social, environmental and human health and human rights standards

Conflicts Mineral Policy statement

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Kautex Textron Policy on Conflict Minerals

Kautex Textron is aware of and concerned by the conflicts occurring in the Democratic Republic of the Congo and is actively working to identify which products and material from suppliers may contain conflict minerals.

Our organization continues to support responsible minerals sourcing and industry initiatives, while working with our suppliers to facilitate conflict-free sourcing that contributes to economic growth. In addition, Kautex Textron is a member of the the Conflict-Free Sourcing Initiative (CFSI) and adheres to the OECD guidelines to increase the transparency of conflict minerals in our supply chain.

Conflict-Free Sourcing Initiative

Current as of May 12, 2016

Background

In August 2012, the United States Securities and Exchange Commission (“SEC”) issued its final rules regarding “Conflict Minerals” (known as ‘3TG’ – Tantalum, Tin, Tungsten and Gold) as defined in and required by section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). As a result, many companies are now focusing on whether and to what extent their products contain Conflict Minerals and whether such Conflict Minerals come from the Democratic Republic of Congo and the adjoining countries named in the Act.

Kautex Textron is to committed to ensuring the health, safety and protection of people who come into contact with our products and business, and we require high social, environmental and human rights standards among our suppliers. Managing our obligations in relation to Conflict Minerals is a part of this corporate responsibility. 

Kautex Textron’s Commitments

We work to ensure our products do not contain Conflict Minerals that have been sourced from mines that support or fund conflict within the Democratic Republic of Congo or adjoining countries. This involves:

  • Identifying which products are impacted and targeting our efforts accordingly.
  • Not buying products and materials containing Conflict Minerals directly from Conflict Mines.
  • Asking our supply base to work towards ensuring that any Conflict Minerals contained in the products and materials supplied to Kautex Textron are Conflict Free.

We are also committed to engaging with our customers regarding their disclosure obligations.

Measures Taken

In order to fulfill these commitments, we have taken a number of steps that include:

  • Establishing a robust Conflict Minerals Process that has been approved by the Top Management within Kautex Textron and Textron Inc. to review the use of Conflict Minerals in our products and to be in a position to fulfill our reporting obligations to the SEC and respond to customer inquiries. This program was developed based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and other appropriate international standards.
  • Have set  strong obligatory terms in our supplier portal to ensure that our entire supply base implements a policy regarding Conflict Minerals and exercise due diligence to investigate the source of these minerals.
  • Engaging with our suppliers so that they respond in a timely manner to our requests for evidence of compliance.
  • Updating the Global Supplier Manual Code of Conduct and our purchasing terms and conditions to reflect this policy.

Like many other companies tracing Conflict Minerals, it will take time for a company of our size and complexity to collect the information needed for us to fully understand our use of Conflict Minerals and therefore be able to address all related customer concerns