New-Tech Europe | Sep 2017 | Digital Edition

Mini-Circuits’ Ongoing Commitment to Customers and Compliance The purpose of this article is not to dispute the value and importance of ethical business conduct where it pertains to Conflict Minerals, environmental responsibility, and other social issues. At Mini-Circuits, and at most reputable suppliers in the RF/microwave industry, continuous improvement is a central principal of our business, and this applies to our products as much as it does to the benefits our business brings to our employees and our community. But it warrants asking how campaigns like Conflict Minerals and CSR are performing relative to their stated goals. Mini-Circuits recognizes our responsibility to our customers, our employees and to our community. Just we were a leader at the forefront of conversion to the RoHS standard in the RF/microwave industry, we will continue to honor requirements for documentation for Conflict Minerals and CSR as we receive them. We see it as part of our commitment to customer service and support, just as we provide proper export documentation for international shipments. In every area of our business, we measure our performance relative to a stated goal. This applies to everything from the electrical performance of our components to the promptness of our shipments to customers and more. The goals of the latest compliance campaigns in the RF/microwave space are clear, but the evidence of performance toward those goals under the reporting standards are less so. As an industry, we should be asking together if the effort is producing the desired result, and if not, we should be thinking about what a better way might look like.

Committee passed the Financial Choice Act to repeal and replace Dodd-Frank, which includes a provision to repeal Section 1502 from the legislation. When these changes will have a palpable effect on the administration of compliance processes among electronics suppliers remains to be seen. Corporate Social Responsibility: Not a One- Size-Fits-All Proposition The recent industry trend toward Corporate Social Responsibility requirements spans a broad variety of issues ranging from environment, safety, labor, and ethics, among others. Most companies have policies and processes in place to reflect their organization’s values and to ensure their business is contributing to the common good of society. At Mini-Circuits, for example, our company is deeply committed to supporting the education of the next generation of engineering talent and we’ve nurtured a successful program of donations to RF/microwave design labs at academic institutions around the world. As an ISO14001 certified company, we uphold an environmental management system that commits to regulatory compliance, pollution prevention, and continuous improvement. Community involvement is a cornerstone of our company values, and we believe in having a positive impact on the lives of our neighbors in the areas where we do business, so we sponsor our local baseball team, the Brooklyn Cyclones. These are a few examples of internal policies and management principles that comprise our social responsibility as an organization. Due in part to the EU rules on non-financial reporting, customer

requirements for expansive CSR disclosures, including surveys like ECOVADIS and CDP have recently grown in number. Again, while the underlying goal of this campaign is well-intentioned, the new disclosure requirements carry significant cost and administrative burden for suppliers while evidence of their benefit as a universal standard is questionable. Socially responsible behavior has been shown to benefit company shareholder value, but this benefit doesn’t apply to private companies, and we’ve seen no evidence correlating the adoption of the new reporting requirements with a lower risk of socially or environmentally harmful events. The goal of more socially responsible behavior and reduced reputational risk is desirable, but the standardized survey approach to enforcement results in inappropriate fit between some of the reporting requirements and many of the responding suppliers. For example, the CDP survey asks for documentation of the impact of a facility’s water usage on the local reservoir. For a facility of over a thousand employees or a production process that uses large volumes of water, this may be significant, but for a small company of under a hundred employees with only incidental water consumption, it’s irrelevant. As an upstream supplier to many OEMs, at Mini-Circuits, what we’ve seen is a diverse array of reporting requirements on CSR from many different customers, each with different areas of focus. The consequence is a need for ever expanding systems for gathering the different kinds of data requested by different customers, and again, a shift away from the quality, performance and value of our products and toward non-value- added documentation.

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