Business policies and practices
This policy applies to the Doble Engineering Company website, as well as the websites of our Doble affiliates, subsidiaries, and business units.
For more information about Doble.com’s information practices, please view the Company’s full Privacy Statement.
We are responsible for monitoring compliance with relevant legislation in relation to the protection of personal data.
Some Doble proprietary programs, software, and related offerings may contain certain third party code, commonly referred to as “Open Source Software” (OSS). In the event that any OSS is present in Doble offerings, please reference the items on the Doble Software Information and Resources page for more information.
As an original equipment manufacturer, Doble Engineering Company (Doble) is sensitive to the human injustices suffered by laborers in the world and, as such, will not do business with any vendor or other business partner that it knows to be involved in human trafficking or slavery. However, as Doble does not believe such practices to be in use in its industries, Doble does not, at this time, engage in any third party or internal verification of product supply chains to evaluate and address risks of human trafficking and slavery, conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, or require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Further, while Doble does not tolerate retaining or continuing any sort of business or employee relationship with any entity that it knows to be involved in such slavery or trafficking, it does not, at this time, actively maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking or provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Should slavery and trafficking become a legitimate concern in its industries, Doble reserves the right to revisit and change this policy to better address the need, should it emerge.
The mining and trading of “conflict minerals” and their derivatives – cassiterite (tin), wolframite (tungsten), coltan (tantalum) and gold – in the Democratic Republic of the Congo is helping to finance armed groups which promote widespread violence, human rights violations and environmental degradation in the DRC and adjacent countries (the DRC Region).
Section 1502 of the Dodd-Frank Act and related SEC regulations endeavor to reduce these actions by motivating businesses to obtain their conflict minerals from sources which do not support armed groups in the DRC Region. The Act and regulations require SEC reporting companies to make certain inquiries and conduct due diligence on their entire supply chain regarding the sources of any conflict minerals used in their products, and to report annually as to whether or not they have found these conflict minerals to have originated in the DRC Region and to be “conflict free.”
As an SEC reporting company, ESCO is subject to the conflict minerals provisions of the Act and SEC regulations, and we fully support their objectives. However, because we do not smelt or refine conflict minerals ourselves, we must rely on assistance from our many suppliers – and their own suppliers in turn – in gathering the information necessary for our due diligence and reports, and in attempting to trace the conflict minerals used in our products all the way back to their ultimate sources. We realize this places a burden on our suppliers, many of whom are private or foreign companies which are not themselves subject to the conflict minerals provisions. In addition, many of the procedures for determining whether sources are “conflict free” have not yet been fully developed, and we expect that the refinement and implementation of these due diligence procedures will be an ongoing process requiring cooperation among entities throughout our entire supply chain.
Accordingly, it is ESCO’s policy that: