Policy on Preventing the Use of Conflict Minerals

This web page sets forth the policy of Mosaic Industries, Inc. regarding preventing the use of Conflict Minerals.

In recent years, armed factions in the Democratic Republic of the Congo (DRC) and nearby countries have been illegally mining and smuggling minerals to fund themselves and their wars. These groups further armed conflict and violate human rights through slavery, forced labor and abusive treatment of local people. The conflict minerals they mine are smelted into metals that find their way into many industrial and consumer electronic products.

These conflict minerals include:

At Mosaic Industries, Inc. we do not directly purchase these minerals or the metals smelted from them. Even so, every component on our computer boards, every connector, the boards themselves, and the solder used in their assembly are all likely to include one or more metals refined from minerals that could potentially have been mined in a conflict zone.

Just like consumers buying electronic products, as a downstream user of electronic components we are not positioned to be able to ascertain for ourselves the ultimate source of metals used in the products we purchase. But we are disturbed by the atrocities being committed in the Democratic Republic of the Congo (DRC) and other conflict zones, and we want to do everything we can to assure that these horrible acts are not ultimately financed by our purchases through the electronics supply chain. We will never knowingly use metals or products containing metals sourced from conflict regions.

Consequently, we are using our reasonable best efforts to ensure that we do not use components that may contain metals refined from conflict minerals. To help address this problem, Section 1502 of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act incorporates a provision that requires that publicly-traded US manufacturers annually report their use of conflict minerals. The provision seeks to deter – through increased transparency of companies’ sourcing practices – the extreme violence and human rights violations in conflict regions. Although Mosaic Industries is not subject to the conflict metals reporting requirements of the Dodd-Frank Act, we understand that many of our customers are. We therefore intend to work with our suppliers and customers to assure that conflict minerals are not used in our supply chain.

To this end, we are following the best guidance available for assuring that we do not use components that may contain conflict minerals, including:

• the Electronic Components Industry Association's Conflict Minerals Guidelines;
• the Conflict-Free Sourcing Initiative's Practical Guidance; and,
• the IPC's Conflict Minerals Due Diligence Guidelines.

Because we don't purchase these metals directly, either from smelters or mines, we must rely on the source information provided by our suppliers and their reports on their use of the metals.

If Mosaic Industries becomes aware of a vendor whose products include metals from a conflict region, we will take appropriate actions, including reassessment of our supplier relationships. We expect our suppliers to pass up similar requirements to their suppliers to ensure compliance through the entire supply chain.

At Mosaic Industries we believe we have an imperative to be a socially responsible company in our global community. We are committed to continually evaluating our business practices in view of the moral principles important to us, while considering the interests not only of our customers and suppliers but also of our employees and the communities where we live and work. In this matter like all others, we are committed to sound ethical practices and compliance with all applicable regulations and laws, as they continue to evolve.

For more information on conflict minerals, efforts being made to assure they are removed from the electronics supply chain, and guidelines on implementing Dodd-Frank, please consult these useful resources: