Statement of Policy
Dynamic Controls is fully committed to the Dynamic range of controllers complying with all applicable EU Directives in advance of regulatory enforcement deadlines. Medical devices currently covered under Category 8 of the WEEE2 Directive 2012/19/EUare required to meet minimum recovery/ recycling targets as stipulated under Annex V. Effective 22 July 2014 all medical devices placed on the EU market will not contain the specified Hazardous Substances of RoHS2 Directive 2011/65/EU in excess of restriction limits stipulated, as well as any additional Hazardous Substances periodically included under Annex II.
The WEEE2 Directive requires finished device manufacturers to provide reuse and treatment information to recycling centres, with instructions for the dismantling of products at end-of-life. As component manufacturers, Dynamic Controls will make relevant information available to OEMs, as necessary, to assist in processing Dynamic products at the time of disposal.
Since 13 August 2005 all Dynamic controllers (excludes items like cables or loose PCBs) are labelled, as appropriate, with the crossed-out wheelie bin symbol of EN 50419 - indicating the product contains substances requiring separate waste collection and recycling.
Dynamic Controls is committed to the design and production of products that comply with the revised requirements from the implementation due dates, or enable a finished product into which they may be incorporated to meet applicable requirements of WEEE2 Directive 2012/19/EU and RoHS2 Directive 2011/65/EU.
Policy on REACH Compliance
Dynamic Controls manufactures electronic products considered 'Articles' as defined in the European REACH Regulation 1907/2006.
As a supplier of Articles placed on the EU market, Dynamic Controls has a duty to communicate information on any Hazardous Substances contained in Dynamic Controls' products, in accordance with REACH Article (Section) 33.
No Dynamic Controls product is intended to release any Hazardous Substance under normal and reasonably foreseeable conditions of use, as stipulated under REACH Article (Section) 7. Following periodic additional Substances of Very High Concern (SVHC) inclusions on the Candidate List published by ECHA, Dynamic Controls shall review the product Bill of Materials (BoM) to identify the presence of any item containing the identified SVHCs. All Articles with SVHC content at component level above 0.1% by weight in total part weight will be documented, and communicated to customers to meet Dynamic Controls' legal obligations.
REACH compliance information will be made available on the Dynamic Controls website and updated periodically.
Dynamic Controls Policy Statement on Conflict Minerals
In 2010, The United States Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") requiring the Securities and Exchange Commission ("SEC") to issue rules specifically relating to the use of "Conflict Minerals" within manufactured products. Conflict Minerals are defined by the US State Department as tin, tantalum, tungsten and gold (also known as the "3TG") originating from the Democratic Republic of the Congo ("DRC") and adjoining countries (collectively, "DRC Region"). The SEC rules require all SEC registrants whose commercial products contain any 3TGs
necessary to the functionality or production of those products to determine whether the minerals originated from the DRC Region, and, if so, whether they are conflict free. By enacting this provision, Congress intends to further the humanitarian goal of ending the extremely violent conflict in the DRC Region, which has been partially financed by the exploitation and trade of Conflict Minerals originating in the DRC Region.
Dynamic Controls' Commitment
Dynamic Controls is guided by its core values and believes that its commitment to respect, honesty and integrity extends to its worldwide supply base. Dynamic Controls is committed to sourcing its products responsibly, and it expects its suppliers to source materials from responsible suppliers. To aid our customers in complying with the SEC disclosure requirements, Dynamic Controls is working with its suppliers to perform appropriate due diligence in determining the potential for Conflict Minerals in our supply chain and products. We are designing our due diligence in accordance with the Organization for Economic Cooperation and Development Due Diligence Framework.
Expectations of Suppliers
Dynamic Controls expects its suppliers to partner with it to comply with Dodd-Frank's Conflict Minerals reporting rules. Dynamic Controls expects its suppliers to:
(i) Complete Dynamic Controls' Conflict Minerals survey, identifying 3TG containing products they sell to Dynamic Controls and the smelter that provided the original 3TG material (Dynamic Controls' direct
suppliers may have to require successive upstream suppliers to complete Dynamic Controls' Conflict Minerals survey until the smelter is identified);
(ii) Agree to cooperate with Dynamic Controls in connection with any due diligence that Dynamic Controls determines necessary to perform with respect to its country of origin inquiries; and
(iii) Provide reasonable proof of the due diligence performed by the supplier, when Dynamic Controls deems it necessary, to support the country of origin certification provided by the supplier to Dynamic Controls.