41
PLENCO CSR Initiative
Plenco Sustainability Policies at Work
The following policy statements are in line with Plenco’s commitment to a sustainable enterprise:
Plenco understands that our products are part of a wider supply chain. In that sense, our customers’
products are only as good as our own. Thus, our customers’ reputations depend on the timely delivery
of our quality products and the knowledge that they are receiving a responsibly produced and sourced
product. Below are several commitments regarding the sustainable sourcing of Plenco products:
Conflict Minerals Act
In 2010, Congress passed provisions known as the Conflict Minerals Act, which requires certain companies
to disclose their use of conflict minerals if those minerals are “necessary to the functionality or production
of a product” manufactured by those companies. Under the Act, those minerals include tantalum, tin, gold
and tungsten (often referred to as 3TG).
Congress passed the legislation because of concerns that the exploitation and trade of conflict minerals
by armed groups was helping to finance conflict in the Democratic Republic of Congo region and was
contributing to an emergency humanitarian crisis.
In accordance with the law, Plenco policy forbids use of the listed conflict minerals. None of the following
is intentionally part of the formulation or intentionally added during the manufacture of Plenco thermoset
molding compounds: tin, tantalum, tungsten, or gold or any other derivatives of columbite-tantalite (coltan),
cassiterite, or wolframite.
REACH (Registration, Evaluation, Authorization and Restriction of Chemicals)
REACH is a regulation of the European Union that entered into force in 2007, adopted to improve the
protection of human health and the environment from the risks that can be posed by chemicals. It seeks to
regulate the use of chemicals in production processes taking place within the European Union.
With respect to REACH, Plenco believes that in virtually all cases, neither we nor our North American
molding material customers will have any obligation to take any action. In drawing that conclusion, we have
made the following assumptions:
• We assume that our North American customers for Plenco molding materials are using our molding
materials as sold to them and are not adding any additional substances to them.
• We assume that our North American customers for Plenco molding materials actually are molding our
materials in North America, not shipping them unmolded to Europe.
• We assume that our North American customers for Plenco molding materials are using our materials to
produce a molded part in a conventional manner, as opposed to using it in some other way.
Given the above assumptions, we believe we do not have any obligations under REACH if the molded parts
are shipped to Europe. The obligations under REACH apply to manufacturers or importers in Europe of
chemical substances or mixtures (called “preparations”) and in limited circumstances to manufacturers or
importers in Europe of “articles.”