Conflict Minerals Policy

INTEGRA LIFESCIENCES HOLDINGS CORPORATION (AND ITS SUBSIDIARIES) CONFLICT MINERALS POLICY

INTEGRA LIFESCIENCES HOLDINGS CORPORATION AND ITS SUBSIDIARIES (collectively, the “Company,” “we,” “our,” or “Integra”) are committed to ensuring that we conduct our business with respect for human rights and in full compliance with all applicable laws, governmental regulations, rules, requirements, ordinances, and other requirements of local, state, federal and foreign authorities. Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Act”) aims to identify whether products companies manufacture or contract to manufacture (“Products”) contain conflict minerals (as described below) that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining countries including Angola, Burundi, Central African Republic, Rwanda, South Sudan, Tanzania, the Republic of the Congo, Uganda and Zambia (collectively, the “Covered Countries”). In August 2012, the United States Securities and Exchange Commission (the “SEC”) adopted a final rule under the Securities Exchange Act of 1934, Rule 13(p)-1, requiring SEC-reporting companies that manufacture or contract to manufacture products that contain “Conflict Minerals” to conduct due diligence on the origin, source and chain of custody of such minerals and provide specialized disclosure regarding the findings of such diligence.

The SEC defines “Conflict Minerals” as columbite-tantalite (coltan), cassiterite, gold, wolframite and three specified derivatives: tin, tantalum and tungsten, regardless of where they are sourced, processed or sold. The U.S. Secretary of State may designate other minerals in the future.

Integra supports responsible sourcing from the Covered Countries and expects its suppliers to procure material containing Conflict Minerals from socially responsible sources. The goal is to eliminate funding to human rights abusers while continuing to support socially responsible commerce in the Covered Countries.

Integra is committed to conducting its business worldwide with respect for human rights and support government and industry efforts to prevent human rights abuses in Conflict Minerals sourcing. Integra is committed to instituting and maintaining procedures and reporting systems, and to conducting the necessary diligence to comply with the Act and Rule 13(p)-1.

Accordingly, Integra will conduct due diligence regarding the origin, source, and chain of custody of any Conflict Minerals utilized in its products and will report on such due diligence activities in conformance with The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas. The Company also relies on information the Responsible Minerals Initiative (“RMI”) in which an independent third party audits the procurement activities of a smelter or refiner to determine, with reasonable confidence, that the minerals it processes originated from conformant sources.

IN SUPPORT OF THE POLICY, INTEGRA WILL AMONG OTHER THINGS:

  • Instruct all of our suppliers to take reasonable steps to source conflict minerals responsibility from conformant sources;
  • Require all suppliers to provide verification using a standardized format regarding the sourcing of Conflict Minerals from conformant sources used in the Products supplied to Integra; and
  • Require all suppliers to conduct the necessary due diligence and provide proper verification of the country of origin and source of the materials used in the Products they supply to Integra . In selecting and retaining suppliers, we take into consideration whether a supplier can, in an open and objective manner, demonstrate its cooperation and assistance with such efforts and this Policy. 

We reserve the right to verify any information received from our suppliers. If a supplier is not adhering to the requirements of this Policy, Integra reserves the right to undertake remedial action with respect to that supplier, up to and including terminating the business relationship with the supplier.

We disclose information relating to conflict minerals annually. Please see the SEC Filings, including our Form SD, on our Investor webpage for our latest annual Conflict Minerals Report.

Integra engages with suppliers and others in our industry to promote conformant sourcing and pledges to act with the highest level of integrity as we take steps to fully comply with all applicable laws, governmental regulations, rules, requirements, ordinances, and other requirements of local, state, federal and foreign authorities.