As defined by US legislation, “conflict minerals” include tantalum, tin, tungsten and gold, which are the derivatives of the minerals cassiterite, columbite-tantalite and wolframite, respectively. The derivatives of these minerals are referred to as 3TG. These minerals are commonly used in electronics products. Some of the mining operations for these minerals in the Democratic Republic of the Congo and adjoining countries are controlled by warring militias who may be financing armed conflict with profits from the sale of these minerals. This ongoing conflict has been linked to human rights violations, labor abuses, and environmental degradation.
It is Netscout’s goal to use 3TG in our products that do not directly or indirectly finance or benefit armed groups in the region and to ensure the responsible supply chain management of 3TG from conflict-affected and high-risk areas.
In support of this policy, Netscout will:
- Establish processes to identify and assess 3TG risk in the supply chain and respond to risks, consistent with applicable industry guidance including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
- Expect our suppliers to commit to the responsible sourcing of minerals, including establishing a policy to reasonably assure that any 3TG in the products they manufacture does not directly or indirectly finance or benefit armed groups in the region.
- Report the results of our risk assessment and due diligence activities as appropriate.
You may view NETSCOUT’s SEC Form SD (Specialized Disclosure) and Conflict Minerals Report for Calendar Year 2018 (PDF) here.
Conflict Minerals Questions or Concerns?
Netscout has established a mechanism by which customers, employees, and other interested parties may provide or request information relevant to the Company’s Conflict Minerals Management Program (CMMP) and report any grievances with respect to Conflict Minerals issues in general.
Slavery and Human Trafficking
In accordance with applicable legal requirements including the California Transparency in Supply Chains Act of 2010 and the UK Modern Slavery Act, Netscout has taken steps to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its own business.
Netscout’s Group Structure, Business, and Supply Chains
The Company designs, develops, manufactures (or contracts to manufacture), markets, licenses, sells, and supports application and network performance management and service assurance solutions focused on assuring service delivery quality, performance, and availability for large, demanding, and complex internet protocol (IP) based service delivery environments. The Company manufactures, or contracts to manufacture, and markets these products in integrated hardware and software solutions that are used by commercial enterprises, large governmental agencies, and telecommunication service providers worldwide.
The Company’s Due Diligence Processes in Relation to Slavery and Human Trafficking
Netscout conducts its own business in compliance with applicable laws regarding slavery and human trafficking in the countries in which we conduct our business. Netscout has implemented the policy and process described below to ensure that slavery and human trafficking is not taking place in any part of our own business or in any of our supply chains.
Netscout Labor Practices
Netscout acknowledges the unfortunate fact that in many countries, child and forced labor practices continue to be a pervasive problem. While Netscout appreciates cultural differences, the company does not, in any circumstance, condone the exploitation of any child, child labor or forced labor in any of its global operations. More detail can be found in our Statement on Child and Forced Labor.
Netscout has implemented the policy and process described below to ensure that slavery and human trafficking is not taking place in any of our supply chains.
- Netscout has established a Vendor Code of Conduct that requires all direct suppliers to certify that they comply with all laws regarding slavery and human trafficking in the countries in which they do business. Netscout does not employ a third party for verification.
- Netscout does not perform, or use third parties to perform, audits of our suppliers to evaluate supplier compliance with laws and standards regarding slavery and human trafficking. We will, however, consider audits or third party verifications for direct suppliers if we determine they are of high risk.
- Netscout requires that its direct suppliers certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking in the countries in which they are doing business.
- Netscout supply chain personnel are responsible for obtaining the above certifications from our direct suppliers. Netscout may terminate suppliers for failure to comply with laws and standards regarding slavery and human trafficking. Netscout personnel who fail to obtain the above certifications from Netscout’s direct suppliers may face internal disciplinary measures.
- Netscout provides training regarding the eradication of slavery and human trafficking to Netscout employees and management who have direct responsibility for supply chain management.