Conflict Minerals Policy

Green bar under Header


Wesco International, Inc., its subsidiaries, and other businesses that it controls ("Wesco" or the "Company") purchases materials and manufactured products following the highest legal and ethical standards. Wesco expects its suppliers and vendors to cooperate in ensuring that metals and other minerals contained in the products we sell are obtained and produced in an environmentally and socially responsible manner and are not sourced in ways that contribute to human rights abuses.

Wesco is committed to complying with Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act and the EU Conflict Minerals Regulation (the “Conflict Mineral Regulations”) on the mining and smelting of gold, columbite-tantalite (tantalum), cassiterite (tin) and wolframite (tungsten) (collectively, the “Conflict Minerals”). The Conflict Minerals Regulations are intended to ensure that trade in Conflict Minerals does not finance armed groups, support corruption, and encourage forced labor or other human rights abuses. These regulations require companies to monitor their sourcing activities to understand how Conflict Minerals are used in their products and whether those minerals originate in countries or regions characterized by armed conflict (e.g., Angola, Burundi, Central African Republic, the Democratic Republic of the Congo, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia).

The Conflict Mineral Regulations set out different rules regarding monitoring and reporting on the presence of Conflict Minerals in a company’s supply chain depending on whether the company is a mining company, raw material trader, importer of processed metals, manufacturer of goods utilizing processed metals, or a distributor of such goods. As such, the Conflict Mineral Regulations affect Wesco differently in its role as a distributor of products than in its limited role as a manufacturer. Compliance with the Conflict Minerals Regulations is important to Wesco, and Wesco has developed and implemented due diligence policies and processes appropriate to each of those roles.

The U.S. Securities and Exchange Commission (“SEC”) requires publicly traded companies like Wesco to file annual reports with the SEC that describe measures taken to exercise due diligence on the source and chain of custody of Conflict Minerals in products they “manufacture” or “contract to manufacture.” Only a small portion of Wesco’s business involves those functions. To meet SEC reporting requirements for the limited number of products we manufacture or contract with others to manufacture, Wesco periodically surveys suppliers that provide parts, or components for those products, to determine if they are using Conflict Minerals, the origin of any such Conflict Minerals, and the products in which they are found. Where feasible, Wesco also takes steps to ensure that Conflict Minerals are removed from its supply chain.

As a distributor of products others manufacture, Wesco supports its suppliers’ efforts to track Conflict Minerals in their supply chains. Wesco also responds to its customers’ inquiries about potential

Conflict Minerals in the products they purchase from Wesco by conducting annual Conflict Minerals surveys of Wesco’s larger, strategic suppliers and by making the results of those surveys available to customers upon request.

Wesco supports industry-wide efforts to identify and reduce the purchase and use of Conflict Minerals. We also expect our suppliers and vendors to adopt procedures to meet this standard by establishing their own Conflict Minerals policies and cooperating with Wesco to identify Conflict Minerals in their supply chains. Suppliers and vendors must also respond to Wesco’s due diligence inquiries by providing complete and timely responses to our periodic surveys.

Wesco works closely with a third-party compliance consulting company to conduct the SEC and customer-facing campaigns and keep abreast of developments regarding conflict minerals regulation. Questions regarding Wesco’s Conflict Minerals compliance activities can be sent directly to the Wesco ethics and compliance office at ethics@wesco.com, or through the Wesco Business Integrity Line.

 

Revised as of 1 January, 2023.