Business policies and practices
Last Updated: July 1, 2020
Purpose of This Policy
We also have separate privacy notices that applies to our employees, job applicants and independent contractors.
Personal Information We Collect
We collect personal information about individuals we interact with in our business, such as individuals at our customers, suppliers and service providers, so that we can operate our business and supply our products and services. Categories of personal information we may collect and process include:
- Identifiers, such as name, job title, address, phone number, email and similar contact information;
- demographic information, such as gender, age, education, employment history, and occupation;
- information about interests or affiliations;
- images and voice recordings;
- preferences for marketing communications, products and services, and feedback about our business;
- information for recruiting, hiring and human resources, such as work eligibility status, financial account information, employment history, protected classifications, government identification, health or medical information and similar personal information of employees and job applicants; and
- additional information individuals voluntarily submit to us.
We collect health information about individuals that visit our facilities or attend functions we host as necessary to safely operate those facilities and functions. We may ask visitors to our facilities to supply identification, which may include personal information such as government identification numbers. Visitors may be recorded on our electronic security systems.
Where required by law, we may require persons that transact business with us or that visit our facilities to provide name, address, or other personal information to allow us to perform required screenings.
How Personal Information Is Collected
We receive personal information from the following sources:
- directly from you, such as when you complete forms, contact us or visit our facilities;
- from your devices, such as when you visit our Site;
- affiliates and subsidiaries;
- customers and prime contractors; 巴西电影19禁最新观看 免费在线完整视频 巴西电影19禁最新观看 免费在线完整视频 , 结城美纱美熟女番号 高清完整视频 结城美纱美熟女番号 高清完整视频 , 亚洲自国产拍偷在线视频 高清完整视频 亚洲自国产拍偷在线视频 高清完整视频
- service providers, suppliers, distributors and sales representatives that provide goods and services;
- internet websites, social media and similar digital sources; and
- governmental entities and regulatory authorities.
We may also receive your personal information from third parties in connection with a business transition such as a merger, reorganization, acquisition, or purchase of all or a portion of business assets. In such transactions, personal information is generally one of the transferred business assets and we may receive your personal information as an asset in any such transaction.
Our Site uses information gathering technologies, such as cookies and similar technologies, to collect information as you navigate the Site.
Types of Cookies. Cookies may be session cookies, which are temporary cookies that expire or are erased when you close your browser. Cookies may also be persistent cookies that have an expiration date and therefore stay in your browser until they expire or you delete them.
We may use first party cookies on our Site, which are cookies placed by us to collect information about you or to personalize your experience on the Site.
Cookies Used on this Site. The following describes the cookies we may use on our Site and the purpose for which they are used.
When you first visit the Site, you will be given the choice to accept or not accept the following cookies. If you change your mind, you can update your preferences about these cookies by following the instructions below about how to configure your browser settings to limit or exclude these cookies.
|Cookie||Cookie Expiration||Cookie Description|
Persistent cookie which remains up to 10 years
These cookies are set by Pardot to track visitors and prospect activities on the Site and landing pages. Pardot is a marketing tool from Salesforce.com. These cookies are set to remember visitor preferences when a visitor returns to the Site. These cookies are also used for logged-in visitors to maintain the session and remember table filters. Pardot sets first-party cookies for tracking purposes, and sets third-party cookies for redundancy. Pardot cookies use a unique identifier. For a more detailed description of each listed cookie, please visit /articleView?id=pardot_basics_cookies.htm&type=5.
Our Site also sets the following cookies by default. These cookies do not provide us with personal information about you. You can configure your browser settings to limit or exclude these cookies as described below.
|Cookie||Cookie Expiration||Cookie Description|
Persistent cookie which remains up to 3 years
|These cookies are set by Google Analytics. These cookies are performance cookies that are used to improve how the Site works. They collect information about how visitors use our Site, such as which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that specifically identifies a visitor. All information that these cookies collect is anonymous.|
For more information, please visit www.google.com/policies/privacy/partners.
If you wish to disable Google Analytics on your browser please visit /dlpage/gaoptout.
|Wpfront-notification||Session cookie that expires at the end of the session||This WordPress cookie allows the Site to remember choices you make to notification banners on the Site.|
|Session cookie that expires at the end of the session|
|The PHPSESSID cookie is native to PHP and enables websites to store serialized data about the state of a visitor. It is used to establish a user session and to pass this data via a temporary cookie, which is commonly referred to as a session cookie.|
Cookie Settings. You can configure your browser settings to limit or exclude the use of these and other cookies, or to delete these and other cookies that have already been placed on your computer.
However if you disable or delete certain cookies in your browser settings, you might not be able to access or use important functions or features of this Site. Cookie settings vary from one browser to another, so you may need to consult instructions for the particular third party provider of your browser for instructions. The links below provide you with information on how to manage and disable cookies on popular browsers:
Cookies in Emails. We may place cookies or similar technologies in emails that we send to you to assist us in determining if an email recipient has opened an email or to understand how a recipient has interacted with the email, such as clicking on a link. If you do not want to accept cookies in emails, you can close the email before downloading any images or clicking on any links. You can also set your browser to restrict cookies or to reject them. In some cases, depending on your email or browser cookie settings, cookies in emails may be automatically accepted. Please refer to your browser settings for more information.
Use of Personal Information
We may use personal information we collect for our business or commercial purposes, which include one or more of the following:
- Providing products and services to customers, including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; providing advertising or marketing services; hosting or attending industry events and tradeshows;
- Human resources and recruitment, by managing all aspects of our relationships with job applicants, employees and independent contractors, including paying wages, fees and expenses; performing screenings, checks and verifications; providing access to facilities; and where appropriate for job applicants and employees, for recruiting; evaluating applications; checking references; administering reviews, discipline, and grievance processes; providing benefits and health programs; and conducting opinions and surveys;
- Legal compliance and protection, including investigating and respond to claims against us; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; responding to legal process; protecting against malicious, deceptive, fraudulent, or illegal activity and prosecution of those responsible; complying with internal policies and procedures; complying with applicable laws (g., tax, health and safety);
- Information technology and security, including detecting security incidents; debugging to identify and repair errors that impair existing intended functionality; monitoring the use of IT resources; performing data analytics; securing our facilities;
- Auditing a current interaction or transaction, including but not limited to auditing compliance;
- Business administration, including engaging in strategic planning and project management; maintaining records related to business activities, budgeting and financial management; undertaking internal research for technology development and demonstration, including without limitation to developing and improving our products, services and our websites; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade or enhance the service or device;
- Acquisition and business transactions including evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and
- Other purposes as described to you when collecting your personal information.
Sharing Personal Information
We may share or disclose your personal information with the following third parties:
- affiliates and subsidiaries;
- service providers and suppliers (for example IT companies and others who we engage to provide us services or to whom we outsource work to);
- distributors and sales representatives;
- professional advisors (such as our accountants or legal counsel); and
- government entities and regulatory authorities.
We have centralized certain aspects of our data processing and administration in accordance with applicable laws in order to allow us to better manage our business. That centralization may result in our sharing your personal information with our affiliates. For example, your personal information may be provided to managers or staff of our affiliates in other locations to enable those affiliates to provide us with support services.
As we continue to develop our business, we may buy or sell businesses in transactions such as mergers, reorganizations, acquisitions, or the purchase of all or a portion of business assets. We or our assets may also be purchased in these types of transactions. Personal information is often transferred as part of these transactions.
We may be required to disclose personal information if we are compelled to do so by a court of law or requested to do so by a governmental entity, regulatory authority or stock exchange, or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws.
Please note that the types of third parties we share your personal information with set out above is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate this Site and our business. Where required by applicable law, we will notify you of any other circumstances where we would share your information on a case-by-case basis.
Sale of Personal Information
We do not sell personal information.
Personal Information of Children
This Site is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16.
Third Party Websites
We maintain appropriate technical and organizational measures to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, we have implemented data protections policies, information about you is stored on secured information systems, and physical access to our information systems is limited to authorized individuals.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guaranty the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
Access and Choice
Where required by law, we provide you with access to the personal information maintained about you and a reasonable opportunity to correct, amend or delete the information where it is inaccurate or has been processed erroneously, as appropriate. We may limit or deny access to personal information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of third parties would be violated.
Last Updated: July 1, 2020
This Privacy Notice for California Consumers
- applies solely to those individuals who reside in the State of California and whose personal information (as defined below) is collected by us, who are referred to in this Notice as “consumers” or “you“.
This Privacy Notice for California Consumers applies to Doble Engineering and those subsidiaries that use the Doble name or that are listed on this Site, including Morgan Schaffer Ltd., Manta Test Systems Ltd. and Xtensible Solutions, LLC, to the extent they are subject to the CCPA. These entities are referred to in this Privacy Notice for California Consumers as the “Company”, “we”, “us”.
This Privacy Notice for California Consumers does not apply to employment-related personal information collected from California-based employees, job applicants or independent contractors. The CCPA also temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements and accordingly this Notice does not apply to B2B personal information in those circumstances.
Personal Information We Collect About California Consumers
When we talk about personal information in this Privacy Notice for California Consumers, we mean information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.
Personal information does not include information that has been excluded from the scope of the CCPA, such as publicly available information from government records; de-identified or aggregated information; and certain categories of information governed by other sector-specific privacy laws.
Our Privacy Notice above describes the personal information we collect on or through this Site and in other situations and interactions with you. The personal information we collect, and have collected within the 12-month period preceding the date of this Privacy Notice for California Consumers, depending on the particular business situation or transaction, includes the following categories of personal information (as such are defined under the CCPA):
|Category||Examples and Explanation|
|Identifiers||We collect identifiers, such as a name, alias, address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.|
|Personal information subject to the California Customer Records statute (Cal. Civ. Code § 1798.80(e))|
|We collect additional information, such as signature, physical characteristics or description, education, employment information, employment history, bank account number, credit card number, or any other financial information, and medical information. Some personal information included in this category may overlap with other categories.|
|Protected classifications under California or federal law|
|We collect information in protected classifications, such as age, race, sex, national origin and citizenship.|
|Commercial information||We collect records of products or services purchased, obtained, or considered.|
|Online or other similar network activity|
|We collect information about physical location.|
|We collect audio, electronic, visual, or similar information, such as voice messages and video surveillance for security purposes at our facilities.|
|Professional or employment-related information|
|We collect professional or employment-related information.|
Use, Sources and Sharing of Personal Information of California Consumers
California Consumer Privacy Rights
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we provide certain information about our collection, use and disclosure of your personal information over the past 12 months. You can request that we disclose to you:
- the categories of personal information we collected about you;
- the categories of sources for the personal information we collected about you;
- our business or commercial purpose for collecting that personal information;
- the categories of third parties with whom we shared that personal information;
- the specific pieces of personal information we collected about you (also called a data portability request);
- the categories of information we disclosed for a business purpose and the categories of third parties to whom we disclosed each category of personal information.
Although we do not sell personal information, you can request that we tell you the categories of information we sold and the categories of third parties to whom we sold each category of personal information.
Your request is subject to our verifying your identity and authority as described in the section called Verifying Requests. We may deny your request to the extent permitted by the CCPA. We do not currently provide these access and data portability rights for B2B personal information.
You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Verifying Requests below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request as permitted by the CCPA. We do not currently provide these deletion rights for B2B personal information.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell personal information of consumers, including those known to be less than 16 years old. However, the CCPA provides that if you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”).
How to Submit a Request
To exercise the rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (866) 895-2290
- Emailing us at email@example.com.
In submitting an email request to exercise your rights, please provide us in the email with the State in which you reside, your name, a return email or phone number where we can contact you, or indicate we can reply to the email you send to us. Please also identify which privacy rights you would like to exercise. In responding to you, we will take steps to verify your identity before granting you access to your personal information or comply with your request as described in Verifying Requests below.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity.
The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request to know or delete. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf, that authorized agent must provide us with a copy of the signed written permission from you. We can deny a request from an agent that does not submit proof that the agent is authorized by you to act on your behalf. We may also require you to verify your own identity directly with us (as described above) and confirm with us that you provided that permission.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights provided by the CCPA.
To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Privacy Notice for California Consumers is available in alternative formats upon request. Please contact us as described in the section called CCPA Notice Contact Information to request this privacy notice in an alternative format.
Other California Privacy Rights
While we do not disclose personal information of consumers to third parties for their direct marketing purposes, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us or write to us as described in the section called CCPA Notice Contact Information.
CCPA Notice Contact Information
EU & UK Privacy Notice
Last Updated: July 1, 2020
This EU & UK Privacy Notice
- is intended to meet the requirements of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal information and on the free movement of such data (known as “GDPR”); and
This EU & UK Privacy Notice applies to the processing of personal information by Doble Lemke GmbH and Doble PowerTest Ltd. and to any non-European Doble entities to the extent they are subject to GDPR. These entities are referred to in this EU & UK Privacy Notice as “we” or “us”.
To the extent that any of these entities process your personal information as described in this EU & UK Privacy Notice, each will be considered a “data controller” of your personal information.
This EU & UK Privacy Notice describes our online and offline privacy practices with respect to personal information that we collect about residents of the EU and the United Kingdom through this Site (referred to in this EU & UK Privacy Notice as “you” or “your”), as well as personal information that we might collect or process in other situations or interactions with you.
This EU & UK Privacy Notice does not apply to employment-related personal information collected from employees, job applicants and independent contractors.
Personal Information We Collect About EU Residents
Purpose of Processing and Legal Basis
We rely on the following legal basis for processing the personal information:
- the processing is necessary to provide services you request;
- your consent;
- the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
- the processing is necessary for compliance with a legal obligation to which we are subject;
- the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Where we process personal information to provide products and services, our legal basis for processing is that it is our legitimate interests (and those of our customers) to process personal information in this way to ensure we provide the products and services requested by our customers in an effective and efficient way.
Where we process personal information for marketing purposes, it is in our legitimate interest to process personal information in this way (except where consent is required by local law in which case we will obtain consent).
Where we process personal information for legal compliance and protection, information technology and security, auditing, business administration, or acquisition and business transactions, our legal basis for processing personal information is that it is in our legitimate interests (and those of our customers) to process personal information in the ways described to ensure that our business is secure and operates in an effective and efficient way.
Sources and Sharing of Personal Information About EU Residents
Where our use or processing of personal information requires your consent, you can provide that consent at the time that we collect your personal information following the instructions provided, or by informing us by email, mail or phone using the contract details set out in this EU & UK Privacy Notice. Note that if you consent to additional uses of your personal information, we may use your personal information in the manner consistent with that consent.
Data Transfers Outside the EU
In particular, when transferring your personal information outside the EU and the UK, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented: (1) we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; (2) where we use certain service providers, we may use specific contracts approved by the European Commission referred to as the “model clauses” which give personal information the same protection it has in the EU; or (3) where we have partners or suppliers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the EU and the US.
How Long We Keep Personal Information
We keep your personal information only for as long as is necessary for the purposes described in this EU & UK Privacy Notice, after which it is deleted from our systems. We may retain your personal information for a period of time consistent with the original purpose of collection. For instance, we may retain your data during the time in which you engage in a transaction with us and for a reasonable period of time afterward. We also may retain your information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
Opt Out of Unwanted Communications
To opt out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section of this Notice called EU & UK Notice Contact Information.
Rights of EU Residents
This EU & UK Privacy Notice gives you transparency on how we process and handle your personal information. You may exercise the following rights in relation to your personal information:
- The right of access. You are entitled at any time to obtain confirmation that we process personal information about you, to access and obtain copies of the personal information, and to receive information about our processing of personal information. Information will be provided within the time periods required by applicable law.
- The right to rectification. You are entitled to have personal information corrected or rectified if it is inaccurate or incomplete.
- The right to erasure or to be forgotten. You can request the deletion or removal of your personal information where appropriate. This includes, for example, where your personal information is no longer necessary in relation to the purposes for which it was processed, or where you have withdrawn your consent. Your rights are subject to certain exceptions, such as where we are required to retain personal information by applicable law. If we have shared your personal information with others, we will let them know about the deletion where possible. If you ask us, we will also tell you who we have shared your personal information with so that you can contact them directly, but only where that is possible and lawful.
- The right to restrict processing. You have the right to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of the personal information while we investigate your concern. We can, however, continue to store your personal information. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, we will also tell you who we have shared your personal information with so that you can contact them directly, but only where that is possible and lawful.
- The right to data portability. You have the right, where our processing is based on your consent, to receive your personal information from us in a commonly used electronic format to allow you to transfer your data to a third party. If you ask, we will transfer the personal information to another third party where it is technically feasible and lawful.
- The right to object. You have the right to object to processing where we are relying on ours or a third party’s legitimate interest to do so or for the purpose of direct marketing.
- The right to withdraw consent. You have the right to withdraw your consent at any time when processing relies upon consent.
- The right not to be subject to automated decision making. You have rights in relation to automated decision making and profiling.
You can access these rights verbally or in writing using our contact information provided in the section below entitled EU & UK Notice Contact Information. We will make efforts to promptly respond to your requests. Where you ask us to provide a copy of your personal information we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal information from you than we currently have.
We are responsible for implementing this EU & UK Privacy Notice. Violations of the applicable data protection legislation in the EU and UK may lead to penalties and/or claims for damages.
If at any time you believe that your personal information has been processed in violation of this EU & UK Privacy Notice, or if you have any inquiries or complaints about the use or limitation of use of your personal information, you may contact us as described in the section called EU & UK Notice Contact Information.
If you have a complaint about our privacy practices, you may contact your local Data Protection Authority. We are committed to cooperating with Data Protection Authorities and to comply with dispute resolution procedures in cases of complaints. We are also committed to complying with any regulations or guidelines that Data Protection Authorities may issue from time to time in accordance with applicable data protection legislation. Where required by law, we will register and/or keep our registration updated as a data controller and/or processor in required jurisdictions.
EU and UK Notice Contact Information
If you have any questions or comments about this EU & UK Privacy Notice, or questions or concerns about our privacy policies and practices, please contact us at:
5 Weyvern Park
Surrey GU3 1NA
tel +44 1483 514120
fax +44 1483 514149
Doble Software Information and Resources
Some Doble proprietary programs, software, and related offerings may contain certain third party code, commonly referred to as “Open Source Software” (OSS). In the event that any OSS is present in Doble offerings, please reference the items on the Doble Software Information and Resources page for more information.
Transparency in Supply Chain Disclosures
As an original equipment manufacturer, Doble Engineering Company (Doble) is sensitive to the human injustices suffered by laborers in the world and, as such, will not do business with any vendor or other business partner that it knows to be involved in human trafficking or slavery. However, as Doble does not believe such practices to be in use in its industries, Doble does not, at this time, engage in any third party or internal verification of product supply chains to evaluate and address risks of human trafficking and slavery, conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, or require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Further, while Doble does not tolerate retaining or continuing any sort of business or employee relationship with any entity that it knows to be involved in such slavery or trafficking, it does not, at this time, actively maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking or provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Should slavery and trafficking become a legitimate concern in its industries, Doble reserves the right to revisit and change this policy to better address the need, should it emerge.
Conflict Minerals Policy
The mining and trading of “conflict minerals” and their derivatives – cassiterite (tin), wolframite (tungsten), coltan (tantalum) and gold – in the Democratic Republic of the Congo is helping to finance armed groups which promote widespread violence, human rights violations and environmental degradation in the DRC and adjacent countries (the DRC Region).
Section 1502 of the Dodd-Frank Act and related SEC regulations endeavor to reduce these actions by motivating businesses to obtain their conflict minerals from sources which do not support armed groups in the DRC Region. The Act and regulations require SEC reporting companies to make certain inquiries and conduct due diligence on their entire supply chain regarding the sources of any conflict minerals used in their products, and to report annually as to whether or not they have found these conflict minerals to have originated in the DRC Region and to be “conflict free.”
As an SEC reporting company, ESCO is subject to the conflict minerals provisions of the Act and SEC regulations, and we fully support their objectives. However, because we do not smelt or refine conflict minerals ourselves, we must rely on assistance from our many suppliers – and their own suppliers in turn – in gathering the information necessary for our due diligence and reports, and in attempting to trace the conflict minerals used in our products all the way back to their ultimate sources. We realize this places a burden on our suppliers, many of whom are private or foreign companies which are not themselves subject to the conflict minerals provisions. In addition, many of the procedures for determining whether sources are “conflict free” have not yet been fully developed, and we expect that the refinement and implementation of these due diligence procedures will be an ongoing process requiring cooperation among entities throughout our entire supply chain.
Accordingly, it is ESCO’s policy that:
- We expect our suppliers to cooperate with us in the conflict minerals compliance process, to assist us in identifying the sources of the conflict minerals in the products and components they supply to us, and to endeavor to become “conflict free” themselves;
- Our eventual goal is to procure products and components containing conflict minerals exclusively from sources which are “conflict free”; and
- In making procurement decisions we will evaluate our suppliers on the extent to which they meet these expectations and share this goal.