NORDAM supports the SEC’s final rule concerning Conflict Minerals, which was promulgated pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Rule”). In order to support the rule, NORDAM requires our Suppliers to provide the necessary effort in obtaining the information required to support our Customer’s SEC filing requirements. Supplier will support NORDAM by participating in the Conflict Minerals “Reasonable Country of Origin” inquiry for all products supplied to NORDAM. Support means responding in a timely manner to all inquiries NORDAM requests for products supplied by Supplier. (NORDAM currently utilizes the CFSI EICC GeSI Survey Template to gather information.)
Supplier will comply and support regulatory compliance requirements as identified by Federal, State, Local and international laws and regulations to ensure that products provided to NORDAM do not violate basic working conditions, human rights and safety as identified in the Trafficking Victims Protection Reauthorization Act (TVPRA) and other such laws and regulations protecting individuals in the workplace. It is NORDAM’s expectation that Suppliers flow down this requirement to their suppliers. If Supplier suspects a potential violation, Supplier must immediately contact NORDAM to discuss remedy solutions. For guidelines on how to accomplish this in your supply chain, please review the information provided by the US Department of Labor and US Department of State.
Supplier will comply and support NORDAM in regulatory compliance requirements as identified by federal, state, local and international laws and regulations [e.g., Clean Air Act (CAA), Clean Water Act (CWA), TSCA, DOT, OSHA and REACH]. As required, Supplier will identify and provide NORDAM with the chemicals (by CAS #) contained within their products and/or articles in order to comply with domestic and international reporting requirements.
“Applicable Law” means any applicable statute, treaty, code, regulation, ordinance, order, procurement policy, rule, license or certificate of a government, and includes but is not limited to (i) the regulations of EASA and the FAA, including without limitation, Federal Aviation Regulations Part 121 Appendix I & J – Anti drug and Alcohol Misuse Prevention Program; (ii) the Export Administration Regulations (EAR) of the U.S. Commerce Department’s Bureau of Industry and Security (BIS); (iii) the International Traffic in Arms Regulations (ITAR) of the U.S. State Department’s Directorate of Defense Trade Control (DDTC); (iv) the rules and regulations of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC); (v) all applicable environmental and export and import laws; and (vi) the Federal Acquisition Regulations (FAR) and supplements thereto.
Supplier voluntarily participates in supply chain security programs as follows: