Conflict Materials Position Statement

Since the intent of the Dodd-Frank Act is to reduce the use of “Conflict Materials” mined in the Democratic Republic of the Congo (DRC), the outcome of the Dodd-Frank Act needs to be an increased knowledge of the origination of the raw materials by the supply chain.

To demonstrate Trek's commitment to comply with the Dodd-Frank Act, we have listed those processes that we currently deploy that are capable of monitoring and managing our compliance. These processes are;

  • Quote Development Process - This process recognizes if/when the Dodd-Frank Act is a requirement and ensures our supply chain understands the importance of the contractual obligation prior to quoting.
  • Contract Review Process - This process acknowledges if/when the Dodd-Frank Act is a contractual requirement and ensures we (including our Supply Chain) are capable of complying with the obligation prior to accepting the Contract.
  • Purchasing Process - This process flows down the Contractual requirement onto Purchase Order to our Supply Chain through “Special Requirements, known as Quality Clauses”.
  • Supplier Selection & Evaluation Process - This process ensures the Suppliers who are selected and placed onto our Approved Supplier List are capable of deploying a system to acknowledge where raw materials originate from when/if the Dodd-Frank Act is a contractual requirement.
  • Control of Non-Conforming (NCR) Product Process - This process documents when/if raw material origination can’t be determined through a nonconformance being created at our point of receipt. This occurs when/if this is a contractual requirement. This process also requires notification to the Customer if the disposition of the non-conformance can’t be resolved without deviating from the contract.
  • Corrective / Preventive Action (CPAR) Process - This process identifies chronic areas needing improvement, using Non-Conformances, customer complaints and Internal Audits as data points. As an example, if there was a trend in non-conformances against Dodd-Frank Act requirements, either by NCR, Customer complaints and/or Internal Audits, a Team would be formed to Correct and Prevent this issue from re-occurring. Records of the analysis and the Actions are retained as evidence of Continual Improvement.
  • Internal Audit Process - This process ensures compliance to the aforementioned processes through planned random assessments performed on a regular basis. The results of these audits are recorded, followed up on and used to continually improve Trek's system geared toward Customer Satisfaction.
  • Training Process – This process ensures personnel who are accountable for those processes directly related to the Dodd-Frank Act are trained and they acknowledge their understanding of its importance to Trek and our Customers.

Trek is committed to implementing programs and practices that promote environmental sustainability, cost reduction and social responsibility, while continually improving product quality and reliability. We consider it unacceptable that the source of conflict minerals incorporated into our products could be contributing to armed conflict in the DRC and its adjoining countries.

If you have any questions about the compliance status of our processes, please contact our Customer Service Group at 1-800-For-Trek (1-800-367-8735) or by e-mail at custserv@trekinc.com.


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