APEC Kolath 

Plot No. 38 Kunnapattu Road 

Kunnapattu 

Tamil Nadu 6023105 

India 

4th January 2023 

Miss Lee, Environment and Sustainability Manager, Lucky MedTel 

Dear Miss Lee, 

I refer to your recent letter, in which you ask for information to assist with the environmental and social reporting LMT is endeavouring to undertake in all locations worldwide. 

The rebuilding of the warehouse is nearing completion, and as you are, no doubt aware, the 3 employees found guilty of arson are imprisoned, awaiting the death penalty.  APEC Kolath has been cleared of any responsibility in this matter.  The allegations in the newspaper article you included are unfounded, and therefore, no charges have been brought against us. 

I look forward to the visit of the Consultant Auditor.  In the meantime, please find enclosed the information you requested. 

Yours sincerely 

Lalit Choudray 

Lalith Choudray 

General Manager 

Enc   Information Requested 

 I N F O R M A T I O N   R E Q U E S T E D 

1. The top 6 raw materials (in terms of yearly costs) used in APEC Kolath  

The manufacturing of plastic moulding and forming relies on good quality raw materials. These are now imported from China as we had a series of problems with Erfde over components supplied with non-colourfast plastics purchased locally. How our suppliers run their business (e.g. where they make their significant investments or workers’ rights) is not something we concern ourselves with and anyway we do not need to visit any of these Chinese suppliers as we purchase via an importer in Chennai. There was a rumour that the manufacturing companies in China were in trouble for employing child labour but as our contract is with the importer, we are not going to worry about this. 

The manufacturing of our electronic products relies on quality minerals, usually from Africa and Asia. I am not aware of whether these are conflict minerals, but we use large and small suppliers; from foreign companies operating in developing countries (copper-gold from Indonesia) to small-scale family run concerns (minerals from Africa).  Only Tantulum appears on the list of the top 6 raw materials: 

1. Polyvinyl chloride (PVC) is our biggest yearly cost. It is relatively cheap, but we use it in large quantities for the moulding we make for our automotive customers. We are aware of some environmental and health concerns with this material. I have attached some health and safety information for PVC. 

2. Polybutylene terephthalate – 30% glass fibre is the second highest yearly cost. It is purchased as resin powder and melted in the moulding process to form the casing of under bonnet electrical components. 

3. Toluene, a solvent used for cleaning/degreasing metal inserts for our plastic mouldings and as paint thinner, is our third largest spend. We have a contract with A B Chemicals (India) Pvt Ltd. in Mumbai to deliver solvent in batch quantities every 3 months. 

4. Paint is our fourth biggest yearly cost. Despite the high levels of volatile organic compounds in the paint we buy from A B Chemicals it is better value for money than the alternative available locally from Chennai Paints Pvt Ltd. which contains less hazardous materials. 

5. Tantalum is our fifth biggest yearly cost. It is an expensive raw material and is extracted from Coltan (columbite and tantalite). The refined Coltan is used as a heat-conducting mineral in capacitors and is a key component in many products we manufacture for mobile phone technology for cars, Tantalum’s unique ability to withstand extremely high temperatures makes it an ideal material for capacitors, (used to store energy in the electric field between conductors in an electronic device). Our Purchasing Manager has indicated that the supplier is based in Thailand; he believes they source Tantalum from Africa. 

6. Oil is our sixth largest yearly cost. The oil is used to lubricate the moulding and forming machines. Again, we receive the cheapest costs when we buy in large batches every 3 months from A B Chemicals. 

We have not had the opportunity to visit any of these operations, or carry out any supplier audits, as they are far from Kunnapattu. We have a long-standing relationship with our top suppliers and are satisfied that their operations would be to our standard. 

2. Contact details for the supplier of highest yearly spend.  

Our highest yearly spend is with (A.B. Chemicals India) Pvt Ltd, who supply us with the solvents, paint and oil. 

Our supplier is based in Mumbai, there address is: 

A.B. Chemicals (India) pvt. 

I-3A Ganesh Mandir Marg 

Juinagar 

Mumbai 

400706 

India 

3. Recycled raw materials  

2 years ago, our Purchasing Manager investigated the opportunity to use recycled Polybutylene Terephthalate. It proved to be more a little expensive than virgin resin and he believed that supplies of an appropriate quality to move to completely recycled materials could not be guaranteed. We therefore have not pursued this as an option for either full or mixed virgin/recycled raw materials for any of the plastic resins we purchase. In addition, our supervisors feel that recycled resins could not be substituted for virgin resins without modifications to our machinery and processes which will slow production rates and incur additional set up costs. 

3. The photographs you requested: 

• Photos of some employees as they go about their various activities at work. 

Photo 1 : Directors of Erfde Auto pictured with Rinehold Gerter’s corporate helicopter outside the APEC Kolath Factory in Kunnapattu.  

Photo 2. A group of migrant workers, taking packaging waste to be recycled .  At APEC Kolath we recycle 10% of all packaging. 

Photo 3:  This is a photo taken 18 months ago of the 3 migrant workers found guilty of arson. 

Photo 4:  Workers waiting to leave the factory at end of shift 

Photo 5:  Workers moving solvents for use in production 

Photo 6: Workers moving raw materials for use in plastic production 

Photo 7: Rebuilding of Warehouse 

Photo 8:  A Worker carrying out some repair work, after the recent fire.   

Photo 9: Factory after the fire 

 Photo 10: Spraying paint on plastic mouldings 

Photo 11:  APEC Kolath factory 

Photo 12:  Workers Living accommodation (Female) 

Photo 13:  Workers Living accommodation (male) 

Photo 14:  Inside the female dormitory 

Photo 15:  Inside the female dormitory 

 Photo 16:  Inside the female dormitory 

 Photo 17:  Recently refurbished male dormitory 

Photo 18: Workers relaxing in their dormitory. 

Photo 19: Workers relaxing in their dormitory. 

Photo 20: Workers queuing to receive their wages  

4. Health & Safety Committee  

Our Health & Safety Committee meet once a year.  Minutes of these meetings will be available for you to see on your visit.  The members are: 

Name	Position	Nationality
Hans Gustafson*	Operations Director	German
Ron Goldstein*	Human Resources Director	American
Lalit Choudhary	General Manager	Indian
Paul Collingwood	Factory Manager	British
Nigel Simmons	Purchasing Manager	British
Charles Bradley	Sales Manager	American
Helmut Schmidt	Supervisor Shift 1	German
VJ Singh	Supervisor Shift 2	Indian
Ritter Stein	Factory Supervisor	German
Asraf Nural	Factory Supervisor	Indian
Jan Schnuurbart Mitesh Lakhani	Stock Control Supervisor Stock Control Supervisor	German Indian
Klaus Bonn*	Company Accountant	German

5. Details of Accidents 

The HR department keep injury records. Perhaps it is better if you do not report on this indicator, as the explosion claimed the lives of 4 workers, and injured 13 others. 

6. Details of employment opportunity at APEC Electronics. 

We have no written employment procedure. However, our Factory Supervisor is a good judge of character when it comes to recruiting factory staff.  We currently have a vacancy for a factory worker; this is the advert we have placed on the notice board. Please note that we pay approximately the Tamil Nadu minimum wage rates for all our factory workers. 

Figure 1: Job advert 

7. Incidents of Discrimination  

Fortunately, we have not had any incidents of discrimination reported at APEC Kolath.