Responsible Materials Sourcing Policy
Beverly MFG. CO., INC.
Policy date: · Version 1.0
Purpose and Scope
Beverly MFG. CO., INC. is committed to responsible purchasing that respects human rights, protects the environment, and supports ethical business practices. This policy covers all materials and components we purchase from suppliers, distributors, and original equipment manufacturers. We give particular attention to higher-risk minerals, including tin, tantalum, tungsten, and gold, and other minerals where sourcing concerns arise, especially in conflict-affected or high-risk areas.
Supplier Expectations
We expect suppliers to comply with applicable laws and communicate these expectations to their own suppliers:
- Respect human rights and prohibit forced, bonded, trafficked, and child labor.
- Provide safe and healthy working conditions and comply with applicable wage and working-hour requirements.
- Manage environmental impacts responsibly, including hazardous substances, waste, and emissions, and meet applicable material restrictions.
- Conduct business honestly, avoid bribery and corruption, and avoid sourcing that finances armed groups or contributes to serious human rights abuses.
- Provide accurate compliance and sourcing information and cooperate in addressing identified concerns.
Supplier Verification
Beverly collects material certifications and requests supplier compliance information as described in our existing materials policies. Under this policy, staff responsible for purchasing and quality will obtain and review supplier declarations, material certifications, and applicable compliance information in proportion to the material, sourcing risk, and customer requirements.
Where appropriate, we will request additional origin, mineral, smelter, or refiner information, including available industry reporting templates. We will check whether information covers the materials supplied, follow up on missing, outdated, or inconsistent responses, and retain relevant records. Reviews will be revisited when materials, suppliers, requirements, or identified risks change.
Our assessments rely on information supplied by suppliers and manufacturers. We do not independently verify every upstream source or guarantee the origin of every material. Gaps or uncertainty will be considered in purchasing decisions and communicated when responding to relevant customer requests.
Handling Concerns and Corrective Action
Management will review reported concerns, seek supporting information, and investigate with the relevant supplier. Where corrective action is appropriate, we will request a plan with a reasonable timeframe and review progress. Serious concerns, unreliable information, failure to cooperate, or unresolved issues may lead to suspended purchases or termination of the supplier relationship. The immediate-disengagement commitment in our Conflict Minerals Policy continues to apply where a supplier poses a reasonable risk of supporting conflict.
Responsibility and Review
Beverly management oversees this policy, supported by staff responsible for purchasing and quality. Management will review the policy and its implementation at least annually, and sooner when significant sourcing risks or applicable requirements change. The review will consider supplier responses, concerns raised, and corrective-action progress.
Reporting Concerns
Employees, suppliers, and customers may report sourcing concerns to Beverly management at info@beverlymfginc.com, by telephone at (856) 764-7898, or by mail to 63 Webster Street, Riverside, NJ 08075. Please identify the supplier or material involved and provide available details. Beverly will handle reports with discretion, share information as needed to investigate, and will not tolerate retaliation for concerns raised in good faith.
Related Policies and Guidance
This policy complements our Conflict Minerals Policy, Conflict Minerals Statement, and Modern Slavery Statement, together with applicable materials compliance policies, including RoHS3, REACH, Proposition 65, TSCA, and PFAS.
The OECD guidance on responsible mineral supply chains informs our approach to identifying and addressing sourcing risks.