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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.
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.
30 l New-Tech Magazine Europe