Harvard Apparatus Conflict
Minerals Policy Statement

Harvard Apparatus is deeply concerned that the profits from the sale of certain metals mined in the Democratic Republic of the Congo (DRC) and surrounding regions have helped fuel armed conflict resulting in human rights violations in the eastern Congo.

The U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act seeks to eliminate sourcing tin (Sn), tantalum(Ta), tungsten (W) and gold (Au) from mines in the Democratic Republic of Congo or adjoining countries due to the region's human-rights abuses. The law requires publicly traded U.S. companies to disclose the extent to which their products contain conflict minerals sourced from Congo-area mines and to eliminate these sources.

The U.S. Securities and Exchange Commission (SEC) has adopted rules requiring publicly traded companies to disclose whether they use tantalum, tin, gold or tungsten that originated in the DRC or an adjoining country and if so, to issue a report identifying their products that are not conflict free and their due diligence efforts to determine the source and chain of custody of the metals. Conflict free means the product does not contain any of these metals that directly or indirectly finances or benefits armed groups in the DRC or an adjoining country.

Harvard Apparatus supports efforts to eliminate the use of tantalum, tin, gold and tungsten from improper sources that could promote such serious problems in the DRC and adjoining countries.

These metals are not sourced directly by Harvard Apparatus, but are included in other materials that we purchase such as electronic components that we use in many of our products. These metals are required for the proper functioning of many electronic components because of their specific electrical properties.

Because Harvard Apparatus does not purchase these metals directly from any smelter or mine, we must rely on source information that our suppliers provide. We are collecting this information from our suppliers. We recommend using the Electronic Industry's Citizenship Coalition/Global E-Sustainability Initiative's Conflict Minerals Reporting Template http://www.eicc.info/tools_and_resources05.shtml , which helps companies trace metals back through their supply chain when appropriate.

We also support industry initiatives, such as the Conflict-Free Smelter Program, http://www.conflictfreesmelter.org to validate responsible and sustainable sources of these minerals. This list of validated conflict-free smelters is available. Harvard Apparatus requires suppliers whose products contain tantalum, tin, gold and tungsten to implement their Conflict-Free policies and source from approved smelters.

If Harvard Apparatus becomes aware of a supplier whose supply chain includes metals from a conflict source, Harvard Apparatus will take the appropriate actions to remedy the situation in a timely manner, including reassessment of supplier relationships. Harvard Apparatus expects our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.