CONFLICT MINERALS POLICY – SR Technologies

OVERVIEW

We at SR Technologies are committed to responsible manufacturing regarding the sourcing of raw materials we will use on our products. In 2010, the U.S. Securities and Exchange Commission (SEC) issued rules implementing the conflict minerals disclosure provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under these rules, U.S. publicly traded companies must report annually on their use of conflict minerals (tantalum, tin, tungsten and gold) from the Democratic Republic of Congo (DRC) or certain adjoining countries. Conflict minerals from the DRC or certain adjoining countries may be used by armed groups to finance conflicts. SR Technologies is not a publicly traded company but sells to publicly traded companies. These rules were necessary because of the complexity of supply chains and the difficulty for product manufacturers to track the origin of conflict minerals. SR Technologies does not directly purchase any raw conflict minerals since we don’t utilize such minerals in their raw form.

SR Technologies shares the concerns regarding the use of conflict minerals that finance armed groups in the DRC or adjoining countries. We are committed to sourcing products from companies that share the same values and that comply with the SEC’s conflict minerals legislation.

MANAGEMENT

SR Technologies will expect that our suppliers and distributors meet the following requirements:

Suppliers or distributors should not include in any parts or products sold to SR Technologies any conflict minerals that are from the DRC or adjoining countries.
A Certificate of Conformance confirming that the conflict minerals used in the parts or products shipped to SR Technologies were not sourced from the DRC or adjoining countries.
We require that details from the smelter source working with tantalum, tin, tungsten and gold, be declared with at least the following information: the type of mineral, the name of the smelter company, smelter ID number, country of origin, state/province and the city.
We encourage our suppliers to develop a conflict minerals policy and associated procedures to also comply with the prevention of use of conflict minerals from their sources.

VERIFICATION

SR Technologies will evaluate supplier’s compliance with this policy during scheduled external audits. If non-compliances are identified, the supplier would need to take corrective actions to remedy the finding(s). In the event we determine that the supplier’s efforts to comply with this policy have been lacking and if there has been a lack of response from our findings, SR Technologies reserves the right to take appropriate actions up to and including suspension.