L.B. Foster Company is committed to the highest standards of ethics and business conduct. Accordingly, we fully support the goals and objectives of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act"), which aims to prevent the use of certain "Conflict Minerals" that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) and adjoining countries (as defined in the Act).
"Conflict Minerals" are defined to include columbite-tantalite (coltan), cassiterite, gold, wolframite and three specified derivatives (tin, tantalum and tungsten) and any other mineral or its derivatives (collectively, the "Designated Minerals") determined by the U.S. Secretary of State to be financing conflict in the DRC or an adjoining country.
The Act requires manufacturers, like us, who file certain reports with the Securities and Exchange Commission to disclose whether the products they manufacture or contract to manufacture contain "Conflict Minerals" that are "necessary to the functionality or production" of those products.
L.B. Foster Company supports the humanitarian goal of ending violent conflict in the DRC and surrounding countries and is committed to avoiding the use of "Conflict Minerals" in our products that either directly or indirectly contribute to the ongoing turmoil in the DRC and adjoining countries. L. B. Foster Company does not directly purchase any Conflict Minerals. We recognize that tracing the origin and chain of custody of the Designated Minerals contained in our products will be a complex process, which will require the cooperation and support of our direct and indirect suppliers. To this end, L.B. Foster Company suppliers of products that contain any Designated Mineral will be required to perform due diligence on the source and chain of custody of such Designated Mineral in order to provide L.B. Foster Company with the source country of the Designated Mineral and a conclusion relative to the mineral's conflict status.
We expect our suppliers to (both directly and indirectly) source any Designated Minerals from socially responsible sources and we reserve the right to request from any supplier at any time such information, certifications and documentation as we deem necessary to monitor or assess compliance with this policy.
Any supplier who is found to be in violation of our Conflict Mineral Policy, will be required to promptly implement a remediation plan. L.B. Foster Company reserves the right to conduct audit procedures to assess vendor supply chains and to confirm vendor compliance with our Conflict Mineral Policy. Continued non-compliance or lack of willingness to take steps to address issues of concern may ultimately lead to the termination of the supplier relationship.