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Conflict Minerals Policy

RESOURCEFUL SUPPLY COMPANY AND AFFILIATES

Gold, columbite-tantalite, cassiterite, wolframite and their "3T" derivatives, which are tantalum, tin and tungsten (collectively referred to herein as the "Designated Minerals") are sometimes used in consumer products. The Democratic Republic of Congo ("DRC") and its surrounding areas 1 have vast reserves of these Designated Minerals. Unfortunately, many of the Designated Minerals from this region of the world are illegally sourced and traded by armed groups who are responsible for various human rights violations throughout that region. Accordingly, these Designated Minerals, when sourced from the DRC and surrounding areas (referred to herein as the "Conflict Region"), have become commonly known as "Conflict Minerals," as the sale of these minerals is believed to be financing conflict in the region.

Resourceful Supply does not condone the use of the Conflict Minerals that fuel human rights violations and is committed to avoiding the inclusion of conflict minerals in the products that we sell. To that end, effective January 1, 2013, we require that each of our suppliers providing us with products that include, or may include, any Designated Minerals certify that such Designated Minerals:

  • (i) were sourced from mines and smelters outside the Conflict Region;
  • (ii) were sourced from mines and smelters that have been certified by an independent third party as "conflict free," if sourced from within the Conflict Region;
  • (iii) were outside the supply chain prior to January 31, 2013; or
  • (iv) come from recycled or scrap sources.
At Resourceful Supply's request, suppliers must be prepared to provide us with any requested relevant documentation demonstrating the origin of such Designated Minerals. We may also require that our suppliers implement other reasonable actions as may be appropriate to ensure that the Designated Minerals that may be used in products supplied to us are "conflict free."

GRIEVANCE MECHANISM AND REPORTING

This policy shall be reviewed on a regular basis and revised as needed. Our employees, suppliers and other parties can report concerns and alleged violations of this policy by contacting us in any of the following ways:

Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law. Resourceful Supply will not take any retaliatory action against our employees or other parties who report in good faith. Our suppliers are encouraged to contact their normal company sources to seek guidance on the application of this policy.