Supply Chain Management
POLICY REGARDING CONFLICT-FREE MINERALS
CalAmp strongly disapproves of the violence in the Democratic Republic of Congo (“DRC”) and adjoining countries (collectively and with DRC, the “Covered Countries”), and is committed to supporting responsible sourcing of the subject minerals (cassiterite, columbite-tantalite, wolframite, their derivatives tin, tantalum and tungsten, and gold (collectively “3TG”) to help ensure that they do not fund armed conflict in the Covered Countries.
In furtherance of the goal of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, CalAmp expects its suppliers to supply us with components and materials that are “DRC conflict-free.” This means: (1) any 3TG materials necessary to the functionality and production of supplied components and materials do not directly or indirectly finance armed groups through mining or mineral trading in the Covered Countries, or (2) any 3TG materials in supplied components and materials are from recycled or scrap sources.
CalAmp uses the Conflict Minerals Reporting Template (the “Template”), maintained by the Conflict-Free Sourcing Initiative (“CFSI”), to solicit information on 3TG materials from its suppliers. CalAmp also expects its suppliers to adopt policies with respect to conflict minerals in support of this Policy and to require their upstream suppliers to adopt similar policies.
Here is a link to CalAmp’s 2019 Conflict Minerals Report filed with the U.S. Securities and Exchange Commission.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB657)
SUPPLY CHAIN VERIFICATION
CalAmp has a verification process in place to evaluate and address the risks of human trafficking and slavery in its direct supply chain. At the present time we accomplish this verification using internal resources.
CalAmp has implemented a supplier audit program to evaluate the risk of human trafficking and slavery in the company’s direct supply chain. At the present time the audits are performed using internal resources. These audits may be announced or unannounced depending on the circumstances.
DIRECT SUPPLIERS’ CERTIFICATION OF MATERIALS
We require our direct suppliers to certify that materials incorporated into the products they sell to us comply with laws regarding slavery and human trafficking of the countries in which they are conducting business.
INTERNAL ACCOUNTABILITY STANDARDS
If a supplier or one of our employees is found to violate laws or our company standards, they will be held responsible for improving performance in compliance with a remediation plan. If the supplier or employee fails to make progress against that plan, they will be subject to review and sanctions, including potential termination.
CalAmp provides training on identifying and mitigating supply chain risks, including human trafficking and forced labor, to its managers and employees with direct responsibility for supply chain management.
CALIFORNIA ELECTRONIC WASTE RECYCLING ACT OF 2003 (SB20)
Under the California Electronic Waste Recycling Act of 2003 (known as SB20), retailers, resellers and CalAmp partners that ship to, sell or lease certain electronic products in California must collect a fee from the consumer at the time of purchase. The fees are collected by the State, and are used to reimburse registered collectors and recyclers for the electronic devices that they collect and recycle in California. Click here for a list of registered recyclers.
Resellers and Partners may be required to charge this fee to customers on Covered Electronic Devices purchased from CalAmp and remit the fee to the California Board of Equalization. Resellers & Partners are allowed to keep 3% of that fee amount to cover administrative costs. The remainder of the fee must be remitted to the California Board of Equalization. Click here for details on fee remittance.
Resellers are responsible for understanding and complying with the Electronic Waste Recycling Act of 2003, and all other laws and regulations. CalAmp will not collect and remit this fee on your behalf. Resellers and Partners should monitor the CalRecycle website for updates and guidance.
Fee amounts are based on screen size. CalAmp screens are less than 15 inches and the fee amount is three dollars ($3).
California Proposition 65
Proposition 65, officially the Safe Drinking Water and Toxic Enforcement Act of 1986, is a law that requires warnings be provided to California consumers when they might be exposed to chemicals identified by the State of California as causing cancer or reproductive toxicity. The warnings are intended to help California consumers make informed decisions about their exposures to these chemicals from the products they use. The California Office of Environmental Health Hazard Assessment (OEHHA) administers the Proposition 65 program and publishes the listed chemicals, which includes more that 850 chemicals. In August 2016, OEHHA adopted new regulations, effective on August 30, 2018, which changes the information required in Proposition 65 warnings.
CalAmp is providing the following warning label for products affected by Proposition 65 identified chemicals:
Read more about Proposition 65 at https://www.p65warnings.ca.gov
UK MODERN SLAVERY ACT STATEMENT
CalAmp and its subsidiaries are dedicated to complying with the UK Modern Slavery Act of 2015. This statement summarizes CalAmp’sinitiatives to eliminate the risk of slavery and human trafficking in ourglobal supply chain. This statement serves as the disclosure for CalAmp and its subsidiaries for the fiscal year ended February 28, 2018,and has been approved by our Board of Directors.
CalAmp is a telematics pioneer leading transformation in a global connected economy. Our operations in the UK are carried out through our wholly-owned subsidiary, CalAmp UK Limited.
CalAmp maintains internal policies for managing its supply chain business partners and adheres to the Code of Business Conduct and Ethics (“Code”), available at this link on our website: CalAmp Code of Business Conduct and Ethics
DUE DILIGENCE AND VERIFICATION
CalAmp prohibits any form of forced labor, including slavery and human trafficking in its supply chain. We evaluate suppliers through questionnaires, supplier audits, and risk-based assessments. Verification is not conducted by a third party.
CalAmp’s supplier agreements and purchase order terms and conditions require suppliers to comply with all applicable laws and regulations.
CalAmp requires all employees, directors, officers, and consultants to comply with our Code which prohibits any form of forced labor, including slavery and human trafficking in the supply chain. CalAmp maintains a compliance program and periodically requires employees to certify compliance with the Code, investigates potential violations of the Code and other company policies, and takes disciplinary action when necessary.
CalAmp’s supply chain management and staff receive training on applicable company procedures designed to eliminate the risk of human trafficking and slavery in the supply chain.