Corporate Responsibilities

UEI Conflict Minerals Policy

Universal Electronics supports ending the violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region”, which is situated in the Democratic Republic of the Congo (DRC) and surrounding countries. 

In August 2012, the U.S. Securities and Exchange Commission (SEC) adopted section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Conflict Minerals Regulations). This mandate requires that all publicly traded companies subject to SEC rules report annually on their use of tin, tantalum, tungsten and gold (3TG minerals) that originate from conflict mines in the Conflict Region. Additionally, the proper level of due diligence must be demonstrated in determining whether 3TG minerals originated from the Conflict Region and whether such minerals were obtained from sources that directly or indirectly finance or benefit armed groups in this region (Conflict Minerals).

3TG minerals are widely used in the electronics industries, of which Universal Electronics is a part of, and many of our products use these minerals.  Universal Electronics does not procure 3TG minerals directly from mines or smelters. 

Universal Electronics will comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as well as Section 1502 of the Dodd-Frank Act and is committed to the following:

• Supporting the objectives of the Conflict Minerals Regulations. 
• Not knowingly procuring materials or manufacturing products that contain Conflict Minerals. 
• Asking all suppliers within scope to undertake reasonable due diligence efforts within their supply chains to ensure that any 3TG minerals are being sourced either from mines outside of the Conflict Region or from mines and smelters which have been certified as “conflict free” if sourced from within the Conflict Region.
• As part of our continuous improvement to evolve and include other minerals that the Responsible Minerals Initiative (RMI) and the OECD Due Diligence Guidance publishes, we have expanded to include both cobalt and mica in our annual Conflict Minerals campaign.  We utilize the standardized Extended Minerals Reporting Template (EMRT) developed by the Responsible Minerals Initiative to identify and collect due diligence information in the cobalt and mica supply chains.

UEI’s aim is to ensure that only “conflict free” materials and components are used in the products that we manufacture or contract to manufacture. If we discover that any 3TG, cobalt or mica minerals used in our products are considered to be “non-conflict free”, we will take appropriate actions to transition such minerals and associated products to be “conflict free”.

A copy of our most recent Form SD and Conflict Minerals Report may be obtained on this site at http://www.uei.com/FormSD  under “SEC Filings”.   

 Please direct any comments or questions regarding our compliance efforts to UEIConflictMinerals@uei.com.