VCA Inc., and its subsidiaries (collectively, the “Company”) support the initiatives embodied in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) and its implementing regulations. The Act is intended to reduce human rights abuses in the Democratic Republic of the Congo (“DRC”) and adjoining countries by limiting the flow of funds from conflict minerals mined in that region to armed groups responsible for the abuses. Under the Act, publicly traded companies like the Company must annually report to the Securities and Exchange Commission (the “SEC”), the presence of conflict minerals originating in the DRC or adjoining countries in the products they manufacture or contract to manufacture if the conflict minerals are necessary for the functionality or production of their products.
The Company is committed to providing ethically produced products for its clients. Consistent with this commitment and its obligations under the Act, the Company has adopted due diligence methods to assess whether the materials and products it includes in products that it manufactures or contracts to manufacture contain conflict minerals, and where appropriate, is collecting sourcing information through supplier inquiries.
Expectations for Suppliers
The Company’s suppliers are expected to make the following representation:
“Any conflict minerals contained in products supplied to VCA Inc. do not originate in the Democratic Republic of the Congo or its adjoining countries or, in the alternative, that based upon supplier’s due diligence conducted in accordance with a nationally or internationally recognized framework, the proceeds from those conflict minerals did not directly or indirectly finance or benefit armed groups operating in the Democratic Republic of the Congo or its adjoining countries.”
- The Company expects its suppliers to adopt a commitment to source conflict minerals responsibly and to implement policies to support that commitment, in a manner consistent with the Conflict Minerals Policy of the Company.
- The Company will require its suppliers to respond to its due diligence requests and to provide the Company with reasonable assurance of the accuracy and reliability of their representations regarding the origin, source, and chain of custody of the conflict minerals included in the products they supply to the Company.
In the event that a supplier cannot or will not make these representations, or provide reasonable assurances about the source of any Conflict Minerals contained in goods or materials purchased from them, it is the Company’s intent to limit purchases from that supplier to the extent reasonably practicable and to seek alternative suppliers where commercially feasible.