Conflict Minerals Policy
John Bean Technologies Corporation (“JBT”) is committed to safeguarding human rights and promoting good business ethics, including a desire to abide by the word and spirit of laws meant to uphold such values around the world. To these ends, JBT is committed to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), regarding the sourcing of gold, columbite-tantalum (coltan), cassiterite and wolframite, including their derivatives, tantalum, tin and tungsten, and the U.S. Secretary of State may designate other minerals in the future (together, the “Conflict Minerals”) from certain mines within the Democratic Republic of Congo and its adjoining countries (together, the “DRC”) as defined in the Act. The Act is intended to reduce a significant source of funding for armed groups that are committing human rights abuses in the DRC and is focused on specific minerals sourced from the DRC. As a publicly-traded company, we are required to make certain disclosures annually to the U.S. Securities and Exchange Commission (the “SEC”) concerning the Conflict Minerals that are necessary to the functionality or production of products that we manufacture or contract to manufacture and whether those conflict minerals support armed groups in the DRC.
JBT takes its obligations under SEC regulations and the laws in countries in which we operate seriously. We are committed to principles of ethical business practice and recognition of the dignity of others, including the responsible sourcing of Conflict Minerals, and we expect that our suppliers share this commitment. We have adopted this policy as part of our efforts to encourage our suppliers to respect human rights and source product in a socially and environmentally responsible manner in compliance with all applicable laws.
In furtherance of our commitment, we instituted an assessment of our supply chain to identify areas where there may be Conflict Minerals use and we work closely with our suppliers to determine the use and origin of such minerals in our supply chain. Furthermore, we follow the processes and procedures set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) and have hired outside advisors to advise us in our compliance efforts.
Like many companies, JBT does not directly source conflict minerals from mines, smelters or refiners, and is many levels removed from these market participants. We therefore require the cooperation of our suppliers in the implementation of this policy and in enabling JBT to meet its compliance obligations. In furtherance of this policy, we expect our suppliers to:
- Put in place procedures for the traceability of Conflict Minerals in their supply chain;
- Cooperate with our Conflict Minerals due diligence process, which includes providing us, from time to time, with written certifications and other information concerning the origin of Conflict Minerals included in products and/or components supplied to JBT;
- Maintain reviewable business records supporting the source of Conflict Minerals and supply such records upon request;
- Adopt policies and procedures with respect to Conflict Minerals consistent with the policy and practices set forth herein and the OECD Guidance, including the adoption of a risk mitigation strategy to respond to identified risks in the supply chain, and communicate such policies and procedures to their personnel, direct suppliers and indirect suppliers; and
- Require their direct and indirect suppliers to adopt policies and procedures that are consistent with our Conflict Minerals Policy.
Suppliers are encouraged to contact the production teams with whom they regularly conduct business if they have questions concerning this policy. In addition, concerns regarding this policy, or violations, can be reported as follows:
Attention: Supply Chain
70 West Madison Steet, Suite 4400
Chicago, IL 60602 USA
VP, Supply Chain