Conflict Minerals Position Statement

Conflict Minerals Position Statement

In 2012, the U.S. Securities and Exchange Commission (“SEC”) issued rules implementing the “conflict minerals” disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rules”). These Rules require Gogo Inc. (“Gogo”) to undertake reasonable due diligence steps to determine if any of its products contain tantalum, tin, tungsten and gold (“3TG”) originating in the Democratic Republic of Congo (“DRC”) and bordering countries and to report to the SEC on its 3TG inquiries and the potential use of 3TG in its products.

It was determined that Gogo Business Aviation LLC (“Gogo BA”), a wholly-owned subsidiary of Gogo, sells products that contain 3TG. As part of Gogo’s commitment to corporate responsibility and to promote the advancement of fundamental human rights it is our goal to use 3TG minerals in our products that do not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries while continuing to support responsible mineral sourcing in the region. Since the 3TG minerals in Gogo BA’s products enter the supply chain through several sources of supply, and since Gogo BA does not procure these metals from the mines or smelters, we must rely heavily on information from our suppliers to determine the origin of the minerals. Nonetheless, Gogo BA is committed to identifying the 3TG minerals in our products and to compliance with the Conflict Minerals Rules.

Gogo BA’s 3TG compliance program includes the following:

  1. Analysis to identify categories of parts and products that do not contain 3TG or are otherwise not covered by the Conflict Minerals Rules.
  2. Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
  3. Collection of information on 3TG in the supply chain using an online questionnaire based on the Electronic Industry Citizenship Coalition’s Global e-Sustainability Initiative (“GeSI”) template.
  4. Review of supplier responses against criteria developed to determine which responses require further engagement with suppliers.