Conflict Minerals Policy
Metal Casting Development LLC (“MCD”) is committed to conducting business in a socially and environmentally responsible manner, respecting human rights, and supporting efforts to end the violence and human rights abuses associated with the mining of certain minerals.
Purpose
This policy outlines MCD’s commitment to responsible sourcing of materials and to compliance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires companies to disclose the use of “conflict minerals” originating from the Democratic Republic of the Congo (DRC) or adjoining countries.
Definition
“Conflict Minerals” refer to tin, tantalum, tungsten, and gold (3TG), regardless of where they are sourced, processed, or sold. These minerals are used in many manufactured components and products.
MCD is committed to:
- Sourcing responsibly and working to ensure that materials used in our products do not directly or indirectly finance armed conflict or contribute to human rights abuses.
- Requiring our suppliers to source 3TG minerals only from smelters and refiners that are certified as conflict-free by recognized third-party audit programs, such as the Responsible Minerals Initiative (RMI).
- Maintaining transparency within our supply chain by requesting suppliers to provide accurate and timely information using the latest RMI Conflict Minerals Reporting Template (CMRT) or equivalent documentation.
- Taking corrective action when suppliers are found to be in violation of this policy, including suspension of business relationships when necessary.
MCD expects its suppliers to:
- Adopt and implement a conflict minerals policy consistent with this one.
- Conduct due diligence on the source and chain of custody of 3TG in their products.
- Provide MCD with completed CMRT declarations upon request.
- Support continuous improvement in supply chain transparency.
Continuous Improvement
Metal Casting Development LLC will periodically review and update this policy to ensure
alignment with evolving regulations, industry standards, and customer expectations.
Modern Slavery and Human Trafficking Policy
Purpose and Commitment
Metal Casting Development LLC (“MCD”) is committed to conducting all business ethically, responsibly, and in full compliance with applicable laws and international standards regarding human rights. We recognize our responsibility to ensure that modern slavery, human trafficking, forced labor, and child labor have no place in our operations or within our supply chains.
Scope
This policy applies to all employees, contractors, consultants, and suppliers working with or on behalf of MCD, in the United States and abroad.
Our Values
MCD operates with integrity and respect for people and communities. We are committed to:
• Treating all individuals with dignity and fairness.
• Supporting freely chosen employment and fair labor practices.
• Ensuring that workers are not subjected to any form of coercion, servitude, or trafficking.
Supply Chain Responsibility
MCD engages suppliers who share our commitment to ethical and responsible sourcing. We expect suppliers to:
• Prohibit the use of forced, bonded, or involuntary labor.
• Ensure that all employment is freely chosen and that workers are free to leave employment with reasonable notice.
• Comply with all applicable labor, wage, and working condition laws.
• Communicate this policy to their own suppliers and subcontractors.
• Allow transparency and cooperation in audits or information requests from MCD.
Due Diligence and Risk Management
To reduce the risk of modern slavery in our business and supply chain, MCD will:
• Conduct due diligence on suppliers as part of our onboarding and review processes.
• Evaluate risk factors such as geographic location, industry sector, and labor practices.
• Require compliance declarations and corrective actions where risks are identified.
• Collaborate with industry partners and organizations that promote responsible and ethical supply chains.
Training and Awareness
MCD provides training and awareness to relevant employees and management teams to ensure understanding of the risks of modern slavery and how to recognize and report potential issues.
Reporting and Whistleblowing
MCD encourages employees and suppliers to report any concerns related to modern slavery or unethical practices. All reports will be handled confidentially and investigated promptly. Retaliation against individuals who raise concerns in good faith is strictly prohibited.
Continuous Improvement
We are committed to reviewing and improving our policies, procedures, and supply chain practices to ensure ongoing compliance and promote human rights across all operations.