Conflict Minerals POLICY MANUAL

Transcription

1 Conflict Minerals POLICY MANUAL

2 Published by: Air Methods Corporation 7301 South Peoria Street Englewood, CO Copyright 2014 Air Methods Corporation All Rights Reserved. No part of the contents of this document may be reproduced or transmitted in any form by any means without the written permission of Air Methods Corporation. Air Methods, the Air Methods Logo and AirCom are registered trademarks of Air Methods Corporation.

3 Record of Revisions Rev Date Summary of Changes Received Via IR 04/18/14 N/A Initial Revision Rev IR Pg. I

4 Table of Contents RECORD OF REVISIONS... I TABLE OF CONTENTS... II 1. INTRODUCTION TERMS/DEFINITIONS POLICY AIR METHODS CORPORATION SUPPLIER REQUIREMENTS ASSESSING AND RESPONDING TO IDENTIFIED RISKS... 2 Rev IR Pg. II

5 1. Introduction This document contains Air Methods Corporation s (AMC) policy regarding the use of conflict minerals in its products. In July 2010, the President signed into law the Wall Street Reform and Consumer Protection Act, also known as the Dodd-Frank Act. On August 22, 2012, the Securities and Exchange Commission (the "SEC") adopted a conflict minerals rule (the "Conflict Minerals Rule") as mandated by Section 1502 of the Dodd-Frank Act. The Act, as implemented through the SEC Conflict Minerals Rule, imposes certain reporting requirements on manufacturers if their products contain metals derived from minerals defined as "conflict minerals." This reporting requirement is intended to eliminate funding for armed conflict in the Democratic Republic of Congo (DRC) and surrounding countries ( covered countries are the Democratic Republic of Congo, Burundi, Central African Republic, Tanzania, Zambia, Angola, Rwanda, South Sudan, and Uganda). As a publically traded company, Air Methods is required to ensure that our supply chain complies with these requirements. 2. Terms/Definitions Terms Conflict Minerals Covered Countries Definitions Columbite-tantalite (or coltan, the colloquial African term) is the metal ore from which the element tantalum is extracted. Cassiterite is the chief ore needed to produce tin. Wolframite is a source of the element tungsten. Gold. Democratic Republic of Congo, Burundi, Central African Republic, Tanzania, Zambia, Angola, Rwanda, South Sudan, and Uganda 3. Policy 3.1 Air Methods Corporation AMC takes its obligations under SEC and other regulations seriously. As such, AMC has adopted this policy as part of our efforts to encourage our suppliers to respect human rights and not contribute to conflict. Therefore, it is AMC s policy to: 1. Refrain, to the extent possible, to do business with DRC Conflict Minerals suppliers. In the event sole or single-source suppliers are identified as DRC Conflict Minerals suppliers, AMC shall take immediate action to qualify alternate suppliers. Rev IR Pg 1

6 2. Give preference to non-drc Conflict Minerals suppliers during the bid process. 3. Require every supplier to provide a certification regarding their DRC Conflict Minerals status to include details regarding their due diligence process. 3.2 Supplier Requirements AMC will not directly source conflict minerals from mines, smelters or refiners, and is in most cases several or more levels removed from these market participants. AMC therefore requires the cooperation of its suppliers in the implementation of this policy and in enabling AMC to meet its SEC compliance obligations on a timely basis. Suppliers who supply or manufacture components, parts or products containing conflict minerals are expected to source those minerals from socially and environmentally responsible sources that do not directly or indirectly contribute to conflict. Without limiting the foregoing, suppliers are expected to directly and indirectly source conflict minerals only from sources that do not directly or indirectly benefit or finance "armed groups" (as that term is defined in the Conflict Minerals Rule) in the DRC or another covered country. AMC shall require Suppliers to: 1. implement and communicate to their personnel and suppliers policies that are consistent with this policy, and require their direct and indirect suppliers to do the same; 2. familiarize themselves with the Conflict Minerals Rule and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High- Risk Areas (the "Guidance"); 3. put in place procedures for the traceability of conflict minerals at least to the smelter or refiner level, working with their direct and indirect suppliers as applicable; 4. where possible, source conflict minerals from smelters and refiners validated as being conflict free, and require their direct and indirect suppliers to do the same; 5. maintain reviewable business records supporting the source of conflict minerals; 6. provide to AMC written certifications and other information concerning the origin of conflict minerals included in products and components supplied to AMC and the supplier's compliance with this policy generally, and require their direct and indirect suppliers to do the same; and 7. otherwise establish, and require their direct and indirect suppliers to establish, policies, due diligence frameworks and management systems that are consistent with the Guidance. 3.3 Assessing and Responding to Identified Risks AMC believes in establishing and maintaining long-term relationships with suppliers whenever possible. If we determine that a supplier may be violating this policy, we may require them to commit to and implement a corrective action plan within a reasonable timeframe. Continued failure to adhere to AMC s policies and refusal to address issues of concern may lead to termination of our business relationship with the supplier. Nothing contained in this policy shall be interpreted to preclude AMC from terminating any supplier relationship at any time for any reason. Rev IR Pg 2