Conflict Minerals Policy

Introduction

Acklands-Grainger (AGI) distributes hundreds of thousands of branded and private label products that are manufactured by hundreds of other companies located around the world.

AGI is committed to acting in a socially and environmentally responsible manner, to complying with the law, to meeting its customer commitments, and to supporting its customers’ businesses.

Because of the complexity of many supply chains, especially those of broad-line industrial distributors like AGI, and the lack of an established system for product manufacturers to track conflict minerals back to their source, the joint efforts over an extended period by many governments, industry groups, and companies will be required to make it possible to effectively trace conflict minerals back to their source.

This document sets forth the policy of AGI regarding conflict minerals.

Overview

As a responsible company, AGI supports the goal of preventing armed groups in the Democratic Republic of the Congo (DRC) and adjoining countries from benefitting from the sourcing of conflict minerals from that region.

As an industrial supply distributor of hundreds of thousands of branded and private label products manufactured by hundreds of other companies located around the world, AGI is invariably many levels away from the beginning of the supply chain for the products it distributes.

This policy shows AGI’s commitment and its expectations for its product suppliers regarding actions to address conflict minerals.

Our Commitment

  • Working to educate the manufacturers of the products we distribute about conflict minerals.
  • Help our suppliers understand the due diligence steps they can take to investigate the source of any conflict minerals in the products they sell to AGI.
  • Not continue to source from a supplier any product that contains conflict minerals if AGI determines the product is not DRC Conflict Free and the supplier fails to implement reasonable steps to transition to DRC Conflict Free sources*.

*Products are “DRC Conflict Free” if they contain only conflict minerals that did not originate in the DRC or an adjoining country, are from recycled or scrap sources, or have not benefitted the armed groups identified as perpetrators of the abuses that are the subject of the Dodd-Frank Act.

Commitment to Responsible Sourcing

AGI distributes hundreds of thousands of branded and private label products that are manufactured by thousands of other companies located around the world.

AGI supports the goal of procuring product that is DRC Conflict Free and encourages the manufacturers of the products distributed by AGI to adopt that same policy for their businesses.

As a distributor of products manufactured by other companies, AGI does not directly purchase any raw conflict minerals from any source and is many levels removed from the mines, smelters, and refiners that produce the metals used in the products manufactured by AGI’s suppliers.

The supply chain for conflict minerals is complex and lacks an established structure for product manufacturers to trace the minerals in the finished goods distributed by AGI back to their source.

AGI is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they manufacture and sell to AGI.

Supplier Code

AGI has the following expectations of its suppliers:

  • Suppliers should not include in any products sold to AGI any conflict minerals that are not DRC Conflict Free;
  • Suppliers should develop conflict minerals policies, due diligence frameworks, and management systems that are designed to prevent conflict minerals that are not DRC Conflict Free from being included in the products sold to AGI; and
  • AGI’s suppliers are expected to source conflict minerals only from sources that are DRC Conflict Free.

In doing so, suppliers will be expected to:

  • 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;
  • Put in place procedures for the traceability of conflict minerals, working with their direct and indirect suppliers as applicable;
  • Use reasonable efforts to source conflict minerals from smelters and refiners validated as being DRC Conflict Free, and require their direct and indirect suppliers to do the same;
  • Advise AGI of any determination that the supplier either has concluded or has a reasonable basis to believe that products it currently sells or has sold to AGI are not DRC Conflict Free;
  • Maintain reviewable business records supporting the source of conflict minerals; and
  • From time to time, at AGI’s request, provide AGI with information concerning the origin of conflict minerals included in products sold to AGI, which AGI shall be entitled to use or disclose in satisfying any legal or regulatory requirements (including those of its affiliates) or in any customer or marketing communications, notwithstanding the terms of any confidentiality agreements that do not specifically reference this paragraph.

Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in conflict minerals supply chains.

Consequences of Supplier Non-Compliance

  • AGI evaluates its relationships with its suppliers on an ongoing basis.
  • AGI reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this policy.
  • AGI reserves the right to request additional documentation from its suppliers regarding the origin of any conflict minerals included in any products sold to AGI.
  • Suppliers who do not reasonably comply with this policy shall be reviewed by AGI’s product management and supply chain organization for future business.

In the event AGI determines that a supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, AGI reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.

Nothing in this policy is intended to in any way grant any additional rights or expectations to an AGI supplier or in any way modify or otherwise limit in any way any of AGI’s contractual or legal rights.

Grievance Mechanism and Reporting

Our employees, suppliers and other parties can report concerns and alleged violations of this policy as follows:

i. Write us: W.W. Grainger Inc., Attn: Conflict Minerals Team, 100 Grainger Parkway, Lake Forest, IL 60045


ii. Email us at: conflictminerals@grainger.com  indicating “AGI Supplier” in the subject heading; or


iii. Call us at: 1-888-873-3731.

Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law.

Our suppliers are encouraged to contact conflictminerals@grainger.com (indicating “AGI Supplier” in the subject heading) if they wish to seek guidance on the application of this policy.

Conclusion

AGI fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.