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Background

In 2010, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) requiring the Securities and Exchange Commission (SEC) to issue rules specifically relating to the use of “Conflict Minerals” within manufactured products. Conflict Minerals are defined by the US State Department as tin, tantalum, tungsten and gold (also known as the 3TGs) and related derivatives originating from the Democratic Republic of the Congo (DRC) and adjoining countries (collectively, DRC Region). The SEC rules require all SEC registrant whose commercial products contain any 3TGs to determine whether the minerals originated from the DRC Region, and, if so, are they conflict free. By enacting this provision, Congress intends to further the humanitarian goal of ending the extremely violent conflict in the DRC Region, which has been partially financed by the exploitation and trade of Conflict Minerals originating in the DRC Region.

Commitment

������� is committed to ethical practices and compliance with applicable laws and regulations wherever it does business. ������� is guided by its core beliefs and values as stated in �������’s Code of Ethics and Conduct. ������� believes that its commitment to integrity and citizenship extends to its worldwide supply base. As a result, ������� has designed its conflict minerals reporting efforts to align and comply with Dodd-Frank’s conflict minerals reporting rules.

Expectations of Suppliers

������� expects its suppliers to partner with it to comply with Dodd-Frank’s conflict minerals reporting rules. ������� expects its suppliers to:


(i) Complete the annual ������� Conflict Minerals Reporting Assessment, identifying 3TG products they sell to ������� and the smelter that provided the original 3TG material (direct suppliers of ������� may have to require successive upstream suppliers to complete �������’s Conflict Minerals Reporting Assessment until the smelter is identified);


(ii) Cooperate with ������� in connection with any due diligence that ������� chooses to perform with respect to its country-of-origin inquiries; and


(iii) When deemed necessary by �������, provide reasonable proof of the due diligence performed to support the country-of-origin certification that is provided.