Conflict Minerals Disclosure Policy

In response to violence and human rights violations in the mining of certain minerals from the "Conflict Region", which is situated in the eastern portion of the Democratic Republic of Congo (DRC) and surrounding countries, the U.S. Securities and Exchange Commission (SEC) has adopted rules to implement reporting and disclosure requirements related to "conflict minerals," as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rules require manufactures who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain "conflict minerals" that are "necessary to the functionality or production" of those products.

The definition of "conflict minerals" refers to gold as well as tin, tantalum, and tungsten, the derivatives of cassiterite, Columbine-tantalite, and wolframite, regardless of where they are sourced, processed or sold. The U.S. Secretary of State may designate other minerals in the future. We support the humanitarian goal of ending violent conflict in the DRC and surrounding countries.

We are committed to the responsible sourcing of "conflict minerals" throughout our supply chain and to continuing to comply with the underlying SEC rules and regulations surrounding "conflict minerals".
Moving forward, it is our policy that we will not accept any materials containing Conflict Minerals unless the vendor can certify to us that the Conflict Minerals in question did not originate in the DRC or adjoining countries. Further, we will not accept shipments from vendors that fail to deliver completed Vendor Questionnaires.