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U.S. law requires Securities and Exchange Commission reporting companies, including Mechanical Technology, Incorporated (MTI) and its subsidiary, that manufacture products containing “Conflict Minerals”1 which are “necessary to the functionality or production”2 of their products to report annually to the Securities and Exchange Commission.
The law was enacted to address concern that Conflict Minerals originating from the Democratic Republic of the Congo, or adjoining countries (collectively, the DRC), are being sold by armed groups to “finance conflict characterized by extreme levels of violence.”3
As a result, MTI is required to conduct Reasonable Country of Origin Inquiries (RCOI), and undertake due diligence as necessary, to determine whether Conflict Minerals in its supply chain may have originated in the DRC, and if so, whether those minerals benefited armed groups in those countries.
MTI expects its suppliers to support its compliance obligations by being aware of relevant Conflict Minerals law, cooperating in the RCOI process, and by making their due diligence measures and results available to MTI upon request.
REPORTS REGARDING CONFLICT MINERALS
1 Conflict Minerals are defined by Dodd-Frank Act section 1502 and SEC Final Rule 13p-1 under the Securities Exchange Act of 1934 as cassiterite, columbite-tantalite (coltan), and wolframite, or their derivatives specifically tin, tantalum, and tungsten, respectively, and gold.