Alpha Technologies Ltd.'s Position on Conflict Minerals Trade Act 1502
Alpha Technologies Ltd. ("Alpha") is fully aware of the Conflict Minerals Trade Act under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("the Dodd-Frank Act"). Although we are not a publicly traded company, as a supplier, Alpha fully supports this industry approach initiative to address an end to human suffering and environmental impact that has been associated with mining in the Democratic Republic of Congo (DRC) and adjoining countries. Alpha is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility.
We recognize that achieving a conflict-free supply chain will take time and effort, and tracing the origin and chain of custody of minerals throughout Alpha's global supply chain is a complex process. Alpha has either obtained, or is in the process of obtaining, information from our current metal suppliers concerning the origin of the metals that are used in the manufacture of Alpha's products. Based upon information provided by our suppliers, Alpha does not knowingly use metals derived from the Conflict Region in our products. In addition, Alpha does not purchase any of the affected minerals directly from smelters or mines; in fact, there are many supply chain layers between Alpha and where these metals are sourced. However, as an organization we believe this is a problem that our entire supply chain must approach together to take the proper steps towards an effective solution that ensures those responsible for human rights violations do not gain from their activities. While getting contract manufacturers and supplier into alignment with these new policies will take some time, we will continue to do everything in our power to work towards final products that are conflict-free.
In support of this legislation, Alpha:
- Will survey suppliers in our supply chain to understand what programs they have in place to track the source of minerals used in the products they manufacture.
- Will use our supply chain due diligence process, driving accountability within the supply chain
- Will be asking all of our suppliers of products containing 3TG (specifically gold, tin, tantalum, and tungsten if any) to take some immediate actions if any of the 3TG is traced to the DRC and its surrounding region.
- Will require that supplier to demonstrate that they understand the conflict minerals laws and will not knowingly procure specified metals that originate from the Conflict Region.
- Will be evaluating our sourcing decisions based on our suppliers' willingness to cooperate in this program.
- Will require suppliers to review and agree in writing to the following conflict minerals contractual language:
- Will require supplier to cooperate with Alpha to make available to Alpha or its agent, full material declarations that identify the sources of and amount of all substances contained in the Products.
Alpha promotes these principles in our business and our sustainability practices.
Statement on the Restriction of Hazardous Substances
Alpha Technologies Ltd. Statement on the Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU
Alpha Technologies Ltd. is committed to meeting RoHS requirements. Our company has launched an extensive RoHS program on substitute materials to restrict potentially harmful materials in its products where technically feasible while ensuring high product quality and reliability.
In support of the RoHS and Directive, Alpha:
- Will produce RoHS Compliant versions of existing products, providing all parts used in existing products are obtainable with reasonable lead times, pricing, packaging, and minimum quantity requirements from component suppliers.
- Will consider redesigning products to adhere to the Directive if an existing product cannot be directly converted to lead-free manufacturing.
- Where possible, new product designs will be manufactured to comply with the RoHS Directive and likely will not be available in versions that contain lead.
- Will implement inspection techniques to verify vendor claims that components supplied to Alpha are RoHS Compliant. These techniques may include: factory audit, chemical analysis, X-ray Fluorescence Spectrometry (XRF), and vendor’s product labeling.
- Will have separate rework stations for lead-containing and lead-free products. Assembly subcontractors have installed equipment to support lead-free manufacturing and exercise a RoHS management program.
Alpha is also committed to meeting all applicable emerging requirements related to restrictions of hazardous substances in products. As the industry as a whole moves toward RoHS compliance, there will be a transition period during which Alpha will have to maintain both traditional leaded and lead-free products to accommodate customers. Alpha will clearly mark RoHS-compliant products with internationally recognized icons or equivalent as practical.
If you have a question or a concern about a certain product please contact our Sales department for status on that product.
Statement Concerning REACH Regulation
Alpha Technologies Ltd’s Statement Concerning REACH Regulation
Alpha is fully aware of the European REACH regulation EC 1907/2006, entered into effect on Jun 1, 2007. Alpha is committed to meet this regulation which is designed to protect humans and the environment by controlling the use of harmful substances within the EU region.
Alpha is a supplier of products which are referred to as “completed articles” and does not import more than 1 ton of the said chemicals per year. As such, Alpha is not required to register although we are continuously working with suppliers of “substances”, “preparations”, and “articles” as defined in REACH to confirm that appropriate and timely actions are being taken to comply with the regulations. At the time of writing and until further notice, Alpha does not ship “articles that contain more than 0.1 % by weight of the defined SVHC list of substances” into EU members countries.
In support of the REACH regulation, Alpha:
- Will notify downstream users to the presence of any SVHCs within a defined time frame of the substance being added to the list, starting from 1 June 2011 which is the effective date for SVHC.
- Will make our best efforts to obtain all information on substances used in order to assess the risks arising from their use, to ensure that the risks which the substances may present are properly managed, and to pass the required information up and down the supply chain.
- Will work with its suppliers to ensure that it receives all necessary information on SVHC in order to fulfill its related obligations and to ensure that the notification requirements are met.
- Has set up internal working groups which are assessing the scope of application of this regulation to our business and products and devising mechanisms to ensure that Alpha and the products which it sells to affected countries will comply with the Regulation's provisions.
- Will monitor periodically ECHA published Candidate List of Substances of Very High Concern (SVHCs).
Should you have any questions regarding the application of this Regulation and how it may affect your transactions with Alpha, please contact us.