CONFLICT MINERALS & REACH

conflict minerals policy

  • The term “conflict mineral” means, as defined in 2010 United States legislation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502(e)(4):
    • Columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives; or
    • Any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
  • Vanguard Electronics recognizes our role as a responsible citizen of the electronic manufacturing community and we are committed to managing our suppliers to assure we are obtaining responsibly sourced materials from those suppliers.
  • Vanguard Electronics will exercise due diligence with relevant suppliers consistent with the applicable guidelines in the Electronic Industry Citizenship Coalition (EICC) Code of Conduct.
  • Vanguard Electronics supports our customers who require documentation demonstrating our compliance with the Dodd Frank rule on Conflict Minerals.
  • Vanguard Electronics accepts our responsibility to provide information requested in the EICC and GeSI template to these customers who require it and to diligently collect accurate and complete sourcing information.

REACH / SVHC declaration

  • Vanguard Electronics is an environmentally responsible company and supports legislation aimed at protecting human health and the environment. Vanguard Electronics manufactures “articles” and as such is subject to the REACH provisions governing articles. All substances required to be registered by our suppliers have been registered or will be registered per the legislation. None of the “articles” or their packaging through normal and foreseeable conditions contain any substance intended to be released.
    • Based on review of information available from our suppliers and estimates of weight content, Vanguard Electronics reports that products manufactured and assembled in our factories do not contain greater than 0.1% weight (w/w) t of any Substance of Very High Concern (SVHC 191) as published on the European Chemicals Agency (ECHA)
  • We collect and review material safety datasheets (MSDS) for all preparations used in our processes and review the List of SVHC substances for new entries and continue to survey our supplier base for statements of compliance to REACH. The information certified here is based on reasonable inquiries made to our suppliers and represents our best knowledge of that content.