Conflict Minerals Policy
Adopted May 29, 2020.
This document contains our policy regarding the use of conflict minerals in our products. As used in this Policy, “IDEXX,” “we,” “its,” “us” and “our” refers to IDEXX Laboratories, Inc. and its consolidated subsidiaries. Conflict minerals are cassiterite, columbite tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten (collectively, “3TG”), irrespective of the location of origin of the minerals.
IDEXX has adopted this Policy in connection with our compliance with the U.S. Conflict Minerals Rule and our efforts to encourage our suppliers to respect human rights and not contribute to conflict. This Policy applies to conflict-affected and high-risk areas worldwide.
IDEXX policy statement
In addition to complying with the Conflict Minerals Rule, IDEXX more generally seeks to ensure that the 3TG in its products are responsibly sourced. To help IDEXX meet this goal, it follows the applicable processes and procedures in the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including its related supplements (the “OECD Guidance”).
IDEXX does not directly source 3TG from mines, smelters or refiners, and is in most cases many levels removed from these market participants. We therefore require the cooperation of our suppliers in the implementation of this Policy.
We do not seek to embargo responsibly sourced 3TG from conflict-affected and high-risk areas. In recognition of the adverse impact that embargoes have on the livelihood and well-being of the most vulnerable workers and their families, IDEXX strongly discourages its suppliers from embargoing responsibly sourced 3TG from conflict-affected and high-risk areas.
Suppliers who supply or manufacture components, parts or products containing 3TG are expected to source those minerals from socially and environmentally responsible sources that do not directly or indirectly contribute to conflict. This Policy applies irrespective of whether the supplier or manufacturer has manufactured or provided the specifications for the particular component, part or product or directly sourced or included the 3TG contained therein.
In furtherance of this Policy, suppliers are expected to:
- implement and communicate to their personnel and suppliers policies that are consistent with this Policy;
- familiarize themselves with the Conflict Minerals Rule and the OECD Guidance;
- put in place procedures for the traceability of 3TG, working with their suppliers as applicable;
- source 3TG from sources that do not support conflict and, where possible, source from smelters and refiners that are conformant with an independent “conflict free” assessment protocol;
- maintain reviewable business records supporting the source of 3TG;
- from time to time, at our request, provide to us written certifications and other information concerning the origin of 3TG included in components, parts and products supplied to IDEXX and the supplier's compliance with this Policy generally;
- adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with this Policy;
- otherwise establish policies, due diligence frameworks and management systems that are consistent with the OECD Guidance; and
- encourage their direct and indirect suppliers to adopt policies and procedures that are consistent with those contained herein.
Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in global minerals supply chains.
IDEXX reserves the right to request from any supplier at any time such information, certifications and documentation as it shall deem necessary to monitor or assess compliance with this Policy.
Assessing and responding to identified risks
IDEXX believes in establishing and maintaining long-term relationships with suppliers whenever possible. If we determine that a supplier may be violating this Policy, we may require them to commit to and implement a corrective action plan within a reasonable timeframe. Continued failure to adhere to IDEXX's policies and refusal to address issues of concern may lead to termination of our business relationship with the supplier. Nothing contained in this Policy shall be interpreted to preclude IDEXX from terminating any supplier relationship at any time for any reason.
Grievance mechanism and reporting
Concerns regarding this policy, or violations, can be reported as follows:
Via email: firstname.lastname@example.org
Suppliers are encouraged to in the first instance contact their regular sourcing channel if they have any questions concerning this policy.