Kappa Environmental Management

Goals - RoHS, WEEE and REACH - Conflict Mineral Policy Statement

Kappa optronics GmbH is fully aware of its responsibility towards environmental protection. Our economic acting is committed to a sustainable environmental protection to preserve our natural resources for future generations.

 

One of our main goals is to make the products we develop and manufacture environmentally safe. This starts early in the development process when the environmental compatibility and recyclability of the product is reviewed.  The analysis focuses on hazardous materials and substances with the aim to avoid them wherever possible.

 

Another high priority is the energy efficiency of our products, beginning with our low-energy company buildings and production processes.

 

RoHS, WEEE and REACH

Our commitment to environmental protection includes, of course, the compliance with the respective environmental regulations, e.g., RoHS, WEEE and REACH. Due to continual observation we stay up-to-date with national and international legal and normative regulations. Thus, in the case of amendments or modifications we can assure fast implementation – for the benefit of the environment and our customers.

REACH is the EU regulation for registration, evaluation, authorization and restriction of chemicals in the European Union. This regulation applies to manufacturers of chemicals as well as to importers and downstream users of substances and preparations.

 

Kappa optronics has analyzed the statutory provisions with regard to its activities and come to the following conclusion: Kappa is not a manufacturer of chemicals or preparations and does not market such substances. In fact, we manufacture products which do not release substances at normal use. According to the regulation we can be classified as a downstream user and in particular as industrial user and product manufacturer.

 

Therefore a registration of substances is not required for our products. Nonetheless, we identify our process materials as well as the substances used in our products and analyze the areas of application in order to derive potentially required measures.

 

Kappa Environmental Management – Conflict Mineral Policy Statement

As a result of concerns that profits from the sale of certain minerals from the Democratic Republic of Congo and adjoining countries (the “DRC Region”) may be financing armed groups that are engaged in civil war and are committing human rights violations, the United States Congress included certain disclosure requirements in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act enacted in July 2010. The disclosures are designed to create greater transparency regarding the use of “conflict minerals” columbite tantalite (coltan), cassiterite, gold, wolframite, or their derivatives (tantalum, tin, gold and tungsten).


The U.S. Securities and Exchange Commission (SEC) stated rules under the Dodd-Frank Act that require publicly traded companies to annually disclose whether any Conflict Minerals that are necessary to the functionality or production of a product that is manufactured by such company originated in the DRC Region. If any such Conflict Minerals originated in the DRC Region, the issuer must submit a report to the SEC that includes a description of the measures taken by that issuer to exercise due diligence on the Conflict Minerals’ source and chain of custody of those minerals.

 

The Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) have requested that companies undertake reasonable due diligence with their supply chain to ensure that specified metals are not being sourced from conflict mines in the DRC Region.

Kappa does not directly purchase any Conflict Minerals from any source and does not knowingly procure any product containing Conflict Minerals from the Conflict Region. Kappa, like many of companies in the electronics industries, uses several of these metals in our devices as these minerals have specific electrical properties that are necessary for the functions of our products. Kappa supports efforts to eliminate the use of conflict minerals from improper sources, and we fully support the actions of the EICC and GeSI with respect to Conflict Minerals.

As Kappa does not purchase these metals directly from smelters, we must rely heavily on information that will be provided by our suppliers to determine the source and chain of custody of the metals in our products.

Kappa is committed to working with our suppliers to increase transparency regarding the origin and traceability of minerals contained in products. Kappa’s due diligence is based on those described in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Kappa expects our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
Each supplier must demonstrate that they understand and support EICC-GeSI actions and will not knowingly procure metals that specifically originate from the conflict mines in the DRC Region. We request that our suppliers provide evidence of their due diligence activities, and completion of the EICC-GeSI Conflict Minerals reporting template.
If Kappa becomes aware of a supplier whose supply chain includes metals from a conflict source, we will take the appropriate actions to remedy the situation in a timely manner, including reassessment of supplier relationships.

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