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Conflict Minerals Policy

Accrofab's Policy on Conflict Minerals

'Conflict minerals' originating from the Democratic Republic of the Congo (DRC) are sometimes mined and sold under the control of armed groups, to finance conflict characterised by extreme levels of violence. Some of these minerals can make their way into the supply chains of products used around the world, including those in the aerospace industry.
As part of Accrofab's commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, we expect our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC-conflict free. Accrofab expects its suppliers to comply with the Electronic Industry Citizenship Coalition (EICC) Code of Conduct and conduct their business in alignment with our supply chain responsibility expectations.
In support of this policy, Accrofab will:
Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm the tantalum, tin, tungsten, and gold in our supply-chain are 'conflict free'.
Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.
To provide feedback on the content or execution of this policy, please contact Accrofab through the
'Contact Us' option.
Adopted: May 2015
Notes to policy:
1. 'Conflict minerals' as defined by the U.S. Securities and Exchange Commission (SEC) rules is a broad term which means columbite tantalite (coltan), cassiterite, gold, wolframite, or their derivatives which are limited to tantalum, tin or tungsten, regardless of whether these minerals finance conflict in the Democratic Republic of the Congo (DRC) or adjoining countries.
2. DRC-conflict free "means that a product does not contain conflict minerals necessary to the functionality or production of that product that directly or indirectly finance or benefit armed groups" as defined SEC Rule 13p-1 under the Securities Exchange Act of 1934.
3. We use the term 'conflict free' in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.

Published on 19/05/2015

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