Reporting Template, where they report on their usage and sourcing of materials containing the subject Minerals. The RMI Conflict Minerals Reporting Template was developed by several of the
worlds leading consumer electronics companies and is generally regarded as the most common reporting tool for conflict minerals content and sourcing information.
Based on the RCOI, we believe that the sources of the Minerals necessary to the functionality of the hGH Device are from:
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(i) smelters or refiners not sourcing Minerals from the DRC or the other
covered countries, |
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(ii) smelters or refiners sourcing Minerals from the DRC or the other
covered countries but are designated as conflict free by the RMI; |
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(iii) smelters or refiners that have not been designated as conflict free
by the RMI, but that we believe are from areas other than the DRC and the other covered countries; and/or |
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(iv) scrap or recycled sources. |
Design of Due Diligence Measures
Ascendis Pharmas due diligence measures are inspired by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas. The following are the due diligence measures we performed on the source and chain of custody of the Minerals used in the hGH Device, and as a result of our RCOI:
1. Survey. Our supplier of the hGH Device conducted supply-chain surveys with its direct suppliers (our
sub-suppliers). All sub-suppliers of the hGH Device who indicated that there are Minerals present in a component which they supply supplemented their response with a
Conflict Minerals Reporting Template to identify the smelters and refiners and to determine the risks of any sources from the DRC-conflict areas within their supply chain.
Sub-supplier responses were evaluated for plausibility, consistency and gaps, both in terms of which products were stated to contain or not contain the Minerals, and the origin of the Minerals. In addition, we
validated the information received from our sub-suppliers to the extent possible.
2. Follow-up on Survey Responses. We followed-up with our supplier for the hGH Device on its suppliers surveyed, to the extent possible, on missing and inconsistent
information.
3. Continual Investigation. We continually strive to identify risks within our supply chain. If any source is found to benefit
armed groups in the DRC or other covered countries, we plan to work together with our primary supplier to remove such suppliers from our supply chain.
Location of Smelters and Refiners
As part of the due
diligence process, we reviewed surveys from the sub-suppliers of the parts making up the hGH Device from our sub-suppliers of the hGH Device. Out of the responses
received, certain sub-suppliers were deemed in scope of supplying components containing the subject Minerals. These sub-suppliers declared their smelter or refiner list,
which listed several hundred possible smelters and refiners.
In each instance we were unable to identify the specific smelters which the Minerals used in
the hGH Device were sourced from since the responses were company based and not product specific. We are unable to determine with certainty at this time a complete list of smelters and refiners listed in the surveys that actually provide the
Minerals used in the hGH Device.
Country of Origin
Due to the use of company-wide surveys by some sub-suppliers and the multiple levels of suppliers in our supply chain
we are unable to determine with certainty at this time a complete list of countries of origin listed in the surveys that provide the specific Minerals used in the hGH Device. Based on the responses provided, we believe the smelters and refiners
supplying Minerals used in the hGH Device supply such Minerals that could originate from over 50 countries, including but not limited to, Angola, Belgium, Bolivia, Burundi, Brazil, Central African Republic, China, the DRC, Germany, India, Indonesia,
Italy, Japan, Malaysia, Myanmar, Peru, Philippines, Poland, Rwanda, Singapore, South Africa, South Sudan, Spain, Switzerland, Taiwan, Tanzania, Thailand, Uganda United States of America, Vietnam and Zambia. Based on the responses provided, we cannot
exclude the possibility that certain of these smelters may be sourcing Minerals used in the hGH Device from the DRC or other covered countries.