Conflict Minerals

Arrow supports responsible mineral sourcing and supply‑chain transparency. The sourcing of certain minerals—tin, tantalum, tungsten, and gold (collectively, “Conflict Minerals”)—from conflict‑affected and high‑risk regions may, in some circumstances, contribute to forced labor, violence, and other human rights abuses.

Scope

Arrow does not directly purchase raw or unrefined minerals. Our due diligence and disclosures relate to products we assemble, integrate, or otherwise modify.

Conflict Minerals at a Glance

Responsible Sourcing and Transparency

At a glance, our approach includes:

• Alignment with internationally recognized standards, including the OECD Due Diligence Guidance for Responsible Supply Chains
• A risk‑based due diligence program focused on conflict‑affected and high‑risk regions
• Supplier engagement and information collection through the Conflict Minerals Reporting Template (CMRT)
• Clear expectations for suppliers, consistent with our Business Partner Code of Conduct and human rights commitments
• Public disclosure through our annual Conflict Minerals Report and Form SD filings

Our Approach

Arrow takes seriously its responsibility to ensure our operations do not support or contribute to human rights violations associated with Conflict Minerals.  While we do not  directly purchase raw or unrefined minerals, we maintain a due diligence program to identify and manage Conflict Minerals risks in the products that we assemble, integrate, or otherwise modify.

Our Conflict Minerals due diligence  program is designed in alignment with  OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‑Affected and High‑Risk Areas and incorporates   strong governance systems, risk assessments, and responsive actions where appropriate.

As part of this process,  Arrow annually collects CMRTs from relevant suppliers, completes and publishes our own CMRT, and publicly files a  Conflict Minerals Report and Form SD pursuant to the Securities Exchange Act of 1934. 

Through these efforts, we seek to promote transparency, support responsible sourcing practices, and align our operations with applicable legal requirements and internationally recognized standards.

Questions: compliance@arrow.com