Conflict Minerals

Introduction

Sepura Limited (“Sepura” or “the Company”) aims to ensure that its business operates in an open and transparent way. This statement sets out the Company’s approach to tackling the risk of the use of Conflict Minerals¹ in its supply chain.

Supply chain

Sepura’s principal activities comprise the design, development, manufacture, supply and support of digital radio products and solutions. Sepura does not directly source or process any minerals. However minerals including tantalum, tin, tungsten and gold may be included in the components or products sourced from sub-contract manufacturers and suppliers in its supply chain.

Commitment and actions

Sepura expects that its business around the world is always conducted to high ethical standards and legal principles. To that end, all employees and business partners are expected to demonstrate high standards of professionalism and integrity at all times when conducting business on the Company’s behalf.

Sepura is therefore committed to sourcing components and materials from companies that share its values for human rights, ethics and environmental responsibility. Accordingly, Sepura requires its suppliers to source minerals only from socially and environmentally responsible sources that do not directly or indirectly contribute to conflict and that do not benefit or finance armed groups.

Sepura’s suppliers are therefore required to:

• comply with UK Government and local guidance and legislation (such as the United States’ Dodd-Frank Act and the EU’s Regulation 2017/821 “Conflict Minerals”) to ensure conflict-free supply chains;
• adopt policies and management systems to demonstrate a responsible approach to sourcing minerals;
• establish a due diligence programme to ensure conflict-free supply chains; and
• demonstrate compliance with the above during Sepura’s periodic supplier assessments and audits.

Only those organisations operating in accordance with this policy are approved suppliers to Sepura.

¹ “Conflict Minerals” are generally defined as Tantalum, Tin, Tungsten and Gold (also referred to collectively as “3TG”), together with their ores and concentrates and certain alloys, which are mined or sourced from Conflict-Affected and High Risk Areas ("CAHRAs"). CAHRAs are territories in a state of armed conflict or fragile post-conflict conditions, witnessing weak or non-existent governance and security, or widespread violations of international law including human rights abuses.