Quality Excellence
We commit to excellence in standards, performance and responsiveness to our customers. We strive for precision in our products, innovation and integrity in our methods, timeliness in our delivery and value in our pricing. Our goal is to do the right thing, the right way, the first time.
In providing industry-leading products and excellence in customer service, we aim to provide the value that enables our customers to meet their quality objectives. By focusing on both the human and technical aspects of our internal facility operations, we prevent, and promptly and efficiently identify and solve quality problems. Our employees are personally committed to continually improve our products and market position. Our commitment to quality will ensure the continued success of our Company and the satisfaction of customers and employees.
The successful operation of the system relies upon the cooperation and involvement of personnel at all levels. We are committed to improving our performance in every aspect of our business.
Environmental Health and Safety (EHS) Excellence
We commit to the protection of the environment through integrating sound environmental practices into all aspects of our operations and by preventing pollution. We will meet or exceed compliance with the letter and intent of all applicable EHS regulations, industry consensus and voluntary requirements to which our company is subject to or subscribes;
• International: (e.g. European Union REACH & ROHS)
• National: (e.g. United states Environmental Protection Agency [EPA], Occupational Safety and Health Administration [OSHA] & Department ofTransportation [DOT])
• State of Maine: (e.g. Maine Department of Environmental Protection [DEP])
• City of Biddeford
We will continually improve our performance through environmentally and socially responsible and technologically practicable processes that produce meaningful environmental improvements through such practices as pollution prevention, efficient use of resources and waste reduction, and substitution of hazardous chemicals.
We are committed to providing a safe and healthy work environment for all personnel who work for us or on our behalf and all visitors to our facilities. We will continually improve working conditions by involving employees at all levels of the organization in proactively assessing EHS risks and taking steps to prevent injury and to eliminate health hazards. Employees are involved through measures such as interactive training, consultation, reporting and investigation of incidents, and participation in safety committee meetings.
We strive to attain a reduction in OH&S incidents and to become a zero-injury organization. Our training is aimed at promoting employee safety both on and off the job, stressing personal responsibility and encouraging reporting of near misses.
Conflict Materials Policy Statement
Regulatory Background
On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) approved the final rule regarding the sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under this rule, publicly traded companies must report to the SEC the presence of tantalum, tin, tungsten or gold (3TG minerals) originating in the Democratic Republic of Congo (DRC) or adjoining countries in the products they manufacture or contract to manufacture, if those minerals are necessary to the functionality or production of the product. Reports must be filed initially by May 31, 2014 and annually thereafter.
Our Policy
At Soleras Advanced Coatings, our goal is to use tantalum, tin, tungsten, and gold that are verified as “DRC conflict-free” minerals as defined under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, while continuing to support responsible mineral sourcing both inside and outside this region.
Our Due Diligence Procedures
Although Soleras Advanced Coatings is not required to report to the SEC the use of conflict minerals as defined in Section 1502, we are committed to having a socially responsible supply chain and to providing our customers with accurate information about our mineral sourcing. As part of our regular business practices, we have initiated a process to determine which of our products contain 3TG minerals and are working with our suppliers to ensure the sources can be traced to DRC conflict-free mines. This process involves the establishment of compliance requirements for our direct suppliers, implementing purchasing controls and internal reporting procedures, and providing our customers with the data necessary for completion of their SEC reporting documents.
Soleras Advanced Coatings is working to implement the framework described in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-affected and High-risk Areas. We are currently completing reasonable country-of-origin inquiries (RCOIs) on vendors throughout our supply chain to understand what programs they have in place to track the source of minerals used in the products they provide to us and what these sources are. Soleras Advanced Coatings has opted to use the supply chain due diligence format made available by the Electronic Industry Citizenship Coalition/Global e-Sustainability Initiative (EICC/GeSI) and commonly used throughout the industry for conflict minerals due diligence efforts.
Soleras Advanced Coatings does not directly source minerals from mines or smelters; these companies are typically several tiers removed from our direct suppliers. Implementing a process for obtaining verifiable information and tracing materials back to their mine of origin can therefore become a complex and time-consuming aspect of responsible sourcing. We will disclose our ongoing progress in implementing this conflict minerals policy publicly through our Web site and privately via direct contact with our customers. Soleras Advanced Coatings will continue to evaluate our supply chains in keeping with this legislation for the duration of its implementation.
We encourage individuals or suppliers who wish to report possible violations of our conflict minerals policy or to alert us to risks in our supply chain to contact us immediately. We intend to investigate allegations of misconduct and take corrective actions when claims are substantiated. Submissions will be kept strictly confidential.
Our Expectations for Suppliers
Soleras Advanced Coatings expects our suppliers to commit to the EICC Code of Conduct related to the responsible sourcing of minerals. We expect suppliers to have in place their own policy and due diligence program to reasonably determine whether the tantalum, tin, tungsten and gold in the products they supply to us are DRC conflict free, and if not, to make deliberate progress toward becoming so.
Soleras Advanced Coatings expects our suppliers to respond to these survey requests in a timely manner and with full disclosure. In the event that Soleras Advanced Coatings determines that a supplier’s efforts to comply with our policy have been deficient, a supplier has failed to cooperate with our due diligence efforts, or that a supplier has refused to adhere to our requests for remediation, we reserve the right to take appropriate actions up to and including discontinuing purchases from that supplier.
Further Guidance
- Customers may request a copy of Soleras’ Conflict Minerals Report. Link below.
- The list of compliant smelters and refiners is posted at www.conflictfreesourcing.org
- The EICC-GeSI conflict minerals reporting template can be found at http://www.conflictfreesourcing.org/conflict-minerals-reporting-template/
- Additional information about the OECD due diligence guidelines can be found at http://www.oecd.org/investment/mne/mining.htm