Clearfield, Inc.

Climate Impact & Sustainability Data (2015, 2024)

Adopted a company policy regarding conflict minerals in its supply chain and communicated this policy to all suppliers.
Strengthened its competence in supply chain management to support conflict mineral due diligence through additional training, additional control processes designed to provide transparency to conflict minerals in the Company’s supply chain, and establishment of a management system for review of conflict minerals in the Company’s supply chain.

Incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.
Difficulty in obtaining complete and properly filled Conflict Minerals Reporting Templates from suppliers (11.6% of dollar volume of purchases).

Reviewed additional available information, both publicly available and generated in the course of the supply relationship, to determine if there exist warning signs or other circumstances indicating that conflict minerals originated or may have originated in the Covered Countries.
Independently compared the list of smelters/processors collected from suppliers and to the conflict-free smelter lists published by the Conflict-Free Sourcing Initiative.
Developing a risk management plan consistent with its policy if any conflict minerals from the Covered Countries are included in any products supplied to the Company.
Intends to strengthen its conflict minerals supply chain management as necessary to respond to newly identified or changed risks, to develop further assurances relating to the accuracy of conflict minerals country of origin information, and to improve engagement with suppliers in the Company’s compliance efforts.

Frameworks Used: OECD Due Diligence Guidance

Climate-related risks (potential impact on supply chain, manufacturing, and demand due to extreme weather events and increased regulation), supply chain disruptions due to material shortages and long lead times, customer inventory levels impacting demand.

Supply chain improvements to enhance resiliency and mitigate risk of disruption, inventory management strategies to address excess inventory, assessment of climate-related risks and potential for increased regulation.

Climate Change Data