Conflict Minerals Policy

Mallinckrodt Pharmaceuticals Conflict Minerals Policy

On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted a final rule to implement reporting and disclosure related to "conflict minerals," as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rule requires manufacturers who are SEC filers to disclose whether the products they manufacture or contract to manufacture contain "conflict minerals" that are "necessary to the functionality or production" of those products.

Conflict minerals refer to tin, tantalum, tungsten and gold (commonly referred to as 3T&G), regardless of where they are sourced, processed or sold. The intent of these requirements is to further the goal of ending violent conflict in the Democratic Republic of the Congo (DRC) and in adjoining countries, which has been financed, in part, by the exploitation and trade of conflict minerals. Mallinckrodt has initiated a comprehensive process to comply with the reporting and disclosure related to "conflict minerals," as directed by the Act.

In line with this policy, Mallinckrodt is specifically:

  1. Using the Organization for Economic Co-operation and Development’s (OECD) Due Diligence Guidance as the international framework for meeting the sourcing expectations of our customers, regulators and stakeholders
  2. Strengthening its due diligence capabilities and processes to identify the source of minerals used in Mallinckrodt's products — we further expect the support of our suppliers in determining the country of origin of the minerals used in our products
  3. Committed to improving, over time, our ability to track and trace conflict minerals in our supply chain — Mallinckrodt is in the process of contacting its tier 1 suppliers to determine the country of origin of the conflict minerals used in their supply chains

Mallinckrodt must rely on its suppliers' cooperation in the implementation of and adherence to this policy in order to meet its obligations to the SEC. Our specific expectations of suppliers include a timely response to our queries about purchased components, assistance in reaching out to their suppliers in case the source of minerals is not currently known, and regular communications with Mallinckrodt about suppliers' conflict mineral tracking and tracing efforts.

Mallinckrodt Supplier Code of Conduct

Supplier shall have a policy to reasonably assure that the tin, tantalum, tungsten and gold in the materials they manufacture do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Supplier shall exercise due diligence on the source and chain of custody of these minerals and make its due diligence measures available to Mallinckrodt upon request. Supplier is responsible for putting a process in place to communicate these requirements to its suppliers and to monitor supplier compliance with these requirements.

More details on the complete Mallinckrodt supplier expectations may be found here.

Grievance Mechanism and Reporting

Concerns or reports of possible violations of this policy can be reported confidentially through Mallinckrodt's Integrity Hotline:

  • Send us an email
  • Visit the contact page and choose "Compliance & Business Integrity"
  • Call 888.696.9864 in the U.S. and Canada

Suppliers and other external parties are encouraged to contact us if they wish to seek guidance on the application of this approach, or if they wish to report suspected abuse. They, and other external stakeholders, may also report problems or concerns via the above Mallinckrodt contact methods. Applicable to all employees and suppliers, this policy will be regularly reviewed, updated and communicated.