Conflict of Minerals Policy


Dodd-Frank Act

In 2010, Congress enacted the Conflict Minerals provisions of the Dodd‐Frank Street Reform and Consumer Protection Act with the goals of eliminating the illegal trade in gold, tin, tantalum and tungsten (Conflict Minerals) and cutting the funding of armed groups in the Democratic Republic of the Congo (DRC) and its neighboring countries (Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia) that are engaged in human rights abuses.

Dodd‐Frank Act, Section 1502 requires that public traded companies report to the U.S. Securities and Exchange Commission (SEC) and disclose on their website whether any of the Conflict Minerals in the products they manufacture or contract to manufacture originate in the DRC Region and caution need to be conducted to determine if the original sale of the mineral funded armed conflict.  The SEC issued implementing regulations and guidance on August 22, 2012.

Although Beranek, Inc. is not subject to the Dodd-Frank Act, in support of our customers’ due diligence efforts, Beranek, Inc., has adopted a conflict minerals policy and has determined that all products sold by Beranek, Inc., to our customers are “DRC Conflict Free.”

Beranek, Inc.- Commitment to Responsible Sourcing

Beranek, Inc. is strongly committed to conducting its business ethically, including engaging with suppliers committed to the same principles of environmental, ethics, and social responsibility.

Beranek, Inc. fully supports the humanitarian goals of the Dodd-Frank Act – eliminating illegal mineral trading and the funding of armed conflict while supporting legitimate commercial ventures.

Beranek, Inc. purchases raw materials from manufacturers who have certified that their products are “DRC Conflict Free,” We do not directly buy any Conflict Minerals from any source.

Since the supply chain for Conflict Minerals is complex, we are committed to working with our supply chain to increase transparency regarding the origin and traceability of minerals contained in our products to ensure that all products sold by Beranek, Inc., to our customers are “DRC Conflict Free.”

Beranek, Inc. will be carrying out our supply chain due diligence consistent with the Organization for Economic Cooperation and Development (OECD) guidelines.  

Beranek, Inc.,  Suppliers  Requirements Flow down

  • Raw material suppliers may not include any products sold to Beranek, Inc., tin, tantalum, tungsten, or gold mined in the DRC or adjoining countries that fund armed conflict.
  • Raw material suppliers must develop Conflict Mineral policies, management systems consistent with the Organization for Economic Cooperation and Development (OECD) guidelines and drive those efforts throughout their supply chain.

NOTE: Any question(s) in regards to Beranek, Inc. Conflict of Minerals Policy can please get in touch with Beranek, Inc. 310-328-9094


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