Responsible Labor & Human Rights Statement

DCL Technologies, Inc. is committed to conducting business ethically and in compliance with all applicable laws prohibiting forced labor, human trafficking, modern slavery, and child labor.

DCL aligns its practices with the Responsible Business Alliance (RBA) Code of Conduct and applicable U.S. regulations, including the Uyghur Forced Labor Prevention Act (UFLPA).

DCL:

  • Prohibits forced labor, bonded labor, prison labor, and human trafficking
  • Prohibits child labor
  • Prohibits recruitment fees and retention of identity documents
  • Requires suppliers to implement equivalent standards
  • Applies a risk-based due diligence process to its supply chain
  • Maintains a grievance mechanism without retaliation

DCL reviews its policies annually and updates them as necessary.

Responsible Sourcing & Conflict Minerals

DCL Technologies is committed to responsible sourcing of tin, tantalum, tungsten, gold (3TG), cobalt, and other high-risk minerals.

DCL’s responsible sourcing program aligns with:

  • OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
  • Responsible Business Alliance (RBA) Code of Conduct
  • SEC Rule 13p-1 under the Securities Exchange Act of 1934

DCL requires suppliers to:

  • Provide Conflict Minerals Reporting Templates (CMRT) or equivalent disclosures
  • Conduct due diligence within their supply chains
  • Source from validated conformant smelters where feasible
  • Comply with U.S. forced labor laws, including UFLPA

DCL reserves the right to request documentation supporting mineral origin and supply chain traceability.

Governance & Oversight

Oversight of responsible sourcing and labor standards is assigned to DCL’s General Manager and reviewed annually by executive leadership.

DCL does not operate manufacturing facilities and employs professional staff which reduces direct operational labor risk exposure. The Company’s primary labor and sourcing risk exposure exists within its supply chain.

Contact Information

For questions regarding DCL’s responsible sourcing or labor standards policies, please contact:

Michael Steward
General Manager
Compliance@dcltek.com