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It is the policy of Carpenter Technology Corporation to comply with the rules issued by the U.S. Securities and Exchange Commission (“SEC”) implementing the “conflict minerals” reporting and disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. As a responsible participant in the metals supply chain, we take seriously our corporate responsibility to ensure materials used in our products are sourced in an ethical manner in compliance with applicable laws and regulations, including SEC’s “conflict minerals” rules. These rules establish reporting and disclosure requirements for certain minerals, defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, and tungsten (the “Minerals”), which are sourced from the Democratic Republic of Congo and adjoining countries (“DRC”). Our intention is to comply with these rules which require the Company, as a manufacturer, to file certain reports with the SEC to disclose whether the products we manufacture or contract to manufacture contain the Minerals that are “necessary to the functionality or production” of those products. To ensure we meet these standards, we require our Suppliers to declare the following with regard to products:
The Company evaluates its relationships with its suppliers on an ongoing basis to ensure continued compliance with this policy. The Company reserves the right to request additional documentation from its suppliers regarding the source of any minerals included in its products. In addition, suppliers must maintain and provide to the Company, upon request, traceability data for a minimum of five years. Carpenter Technology does not work with Suppliers who do not comply with these disclosure requirements.
The Company opposes any use of slavery or human trafficking in the manufacture and distribution of our products. The Company will not tolerate or condone any form or practice that constitutes human trafficking or slavery in any part of our global organization.
The Company recognizes that slavery and human trafficking can occur in many forms, such as forced labor, child labor, domestic servitude, sex trafficking and workplace abuse. Therefore, when used in this policy, the terms "slavery and human trafficking" encompass all of these various forms of coerced labor.
The Company does not and will not permit its employees, subcontractors, vendors, suppliers, or other entities that it does business with to engage in any form of slavery and human trafficking.
The Company prohibits retaliation against anyone who files a complaint or reports a suspected violation of this policy. An employee or other party who violates this policy will be subject to appropriate discipline by the Company, including, but not limited to, disclosure of the violation to government officials, when required by law or contract, and termination.