This Report relates to our Covered Products under our Hughes business segment for the entire reporting period, which consisted of the following:
Broadband and Satellite Services — The Company’s broadband and satellite products included broadband systems and terminals, mobile satellite systems, handheld devices and IP data terminals for mobile satellite operators, all of which support the delivery of a wide range of bandwidth-intensive services as well as privately-branded service offerings, including high-speed internet/intranet access, video conferencing, distance learning, telemedicine, newsgathering, fleet operations and broadband on planes, trains and maritime.
Certain of our Covered Products were designed, developed, engineered, manufactured, assembled and/or distributed by us; however, we also outsourced a significant portion of these functions to third parties. We worked with third-party vendors for the development and manufacture of components that are integrated into our Covered Products. We developed dual sourcing capabilities for critical parts when practical and we evaluated outsourced subcontract vendors on a periodic basis.
PART II. DESIGN OF OUR DUE DILIGENCE MEASURES
We designed our due diligence measures based on the five-step framework laid out by the Organization for Economic Co-operation and Development in its OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”). Summarized below are the components of our due diligence measures as they relate to the five-step framework from the OECD Guidance.
1.Establish Strong Company Management Systems for Conflict Minerals Supply Chain Due Diligence
Designate Internal Corporate Team
The Company has designated an internal team, composed of senior members of the Company’s supply chain and procurement operations and the legal department, which evaluates the Company’s applicable supply chain processes and sourcing procedures and designs and supports the Company’s due diligence efforts. The team meets periodically to develop and refine a due diligence process that:
•is consistent with the OECD Guidance,
•conforms to the requirements of the Rule, and
•is appropriate given the structure and operations of the Company’s supply chain departments.
The Company’s internal audit department monitors the diligence process, provides feedback and reviews the due diligence results. Senior supply chain managers disseminate necessary information and documentation to relevant employees responsible for interfacing directly with suppliers and manufacturers (collectively referred to as “suppliers”).
Commit to a Supply Chain Policy for Minerals from Conflict-Affected and High-Risk Areas
The Company maintains a policy relating to Conflict Minerals (the “Policy”), which generally requires suppliers to:
•have a policy to reasonably assure that the Conflict Minerals in the products they manufacture for or supply to the Company do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Covered Countries;
•exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to the Company upon the Company’s request; and
•be prepared to assist the Company in meeting the Conflict Minerals reporting requirements under the Rule, as well as other national or international mineral reporting regimes that may arise in the future.