Form SD Exhibit 1.01

EX-1.02 2 formsdexhibit101.htm EXHIBIT Form SD Exhibit 1.01

Exhibit 1.01

CSP, Inc.

Conflict Minerals Report

For the reporting period January 1, 2013 to December 31, 2013

This Conflict Minerals Report (the “Report”) of CSP, Inc. (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2013 to December 31, 2013.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products, and the Conflict Minerals are necessary to the functionality or production of those products.

Section 1 - Description of the Company’s Products Covered by this Report

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2013.

These products, which are referred to in this Report collectively as the “Covered Products,” consist of substantially all of the products that are manufactured or contracted to be manufactured by the Company within the High Performance Products and Solutions segment.

Section 2 - Reasonable Country of Origin Inquiry

The Company has conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals came from recycled or scrap sources.

In conducting the reasonable country of origin inquiry, the Company utilized the conflict minerals reporting template developed by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) Extractives Working Group (the “EICC/GeSI Reporting Template”).

The Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Conflict Minerals that are included in the Covered Products. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are

best situated to identify the sources of Conflict Minerals, and therefore has taken steps to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain.

The Company has concluded that the responses obtained in its reasonable country of origin inquiry are insufficient to form the basis for a reasonable belief that none of the Conflict Minerals necessary to the functionality or production of the Company’s products originated in a Covered Country.

Section 3 - Due Diligence Measures Performed by the Company

1.Design of Our Due Diligence and Description of the Due Diligence Process

Our due diligence processes and efforts have been designed to conform with the framework set forth in the 2nd edition of the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related supplements for gold, tin, tantalum and tungsten.

2.Management Systems

Our conflict minerals due diligence process included: the development of a Conflict Minerals Policy; the establishment of governance structures with cross-functional team members and senior executives; communication to, and engagement of, suppliers; recordkeeping; and the development of escalation procedures.

These efforts included the development of a Conflict Minerals Task Force led by our Vice President and Chief Accounting Officer and Chief Financial Officer and a team of subject matter experts from relevant functions such as, purchasing, quality assurance and manufacturing. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy.

We periodically report to the Audit Committee of the Board of Directors with respect to our due diligence process and compliance obligations.

As stated above, the Company has adopted a company policy which is posted on our website at: http://www.cspi.com/compliance/. The policy states:

CSPI Conflict Minerals Policy

Conflict Mineral Disclosure Rules

On August 22, 2012, the United States Securities and Exchange Commission (“SEC”) adopted final rules pursuant to Section 1502 of the Dodd-Frank Act of 2010 regarding conflict minerals disclosure. These rules require public companies to report to the SEC whether tantalum, tin, tungsten or gold (“conflict minerals”) mined in the Democratic Republic of Congo or adjoining countries are used in the products they manufacture. If conflict minerals originate in these countries, publicly traded companies are required to use due diligence to trace the source and chain of custody of these minerals leading up to their receipt by the reporting company and to describe this due diligence effort and its results in reports filed annually. The first report must be filed with the SEC on June 2, 2014 for the 2013 calendar year.

CSP, Inc. (CSPI) Conflict Minerals Policy Statement

CSPI is committed to complying fully with the SEC’s new conflict minerals disclosure rules. It is our policy to work with our supply chain partners to take reasonable steps aimed at assuring that the identified “conflict minerals” are not sourced by CSPI or any of its supply chain partners.

In supporting the principles and objective of this legislation CSPI requests our suppliers, in the chain of custody, exercise reasonable due diligence to determine the country of origin of these minerals and act in accordance with the “Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”.

3.Report on Supply Chain Due Diligence and Results

a.We conducted a survey of the Company's active suppliers using the EICC/GeSI Reporting Template. The EICC/GeSI Reporting Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters that the company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on the website of the Conflict-Free Sourcing Initiative (“CFSI”). The EICC/GeSI Reporting Template has been widely adopted by many companies in their due diligence processes related to conflict minerals.

b.Survey Responses - The Company surveyed our entire known component and outsourced manufacturing supply chain, which consisted of 19 suppliers. The Company created and maintains a database of the survey responses. A copy of the declared sources of material has been included as part of this filing. The declared sources represent a summary of all available information.

4.Escalation Procedure

We have created follow-up processes to identify and escalate any identified issues associated with non-responsive or problematic responses provided by suppliers in connection with our due diligence efforts.

5.Maintenance of Records

The Company has established our due diligence compliance process and set forth documentation and record maintenance mechanisms to ensure that relevant documentation is retained in a structured electronic database.

6.Supply Chain Risk Identification and Assessment

Because of our size, the breath and complexity of our products, and the constant evolution of our supply chain, it is difficult to identify actors downstream from our direct suppliers. We have identified 19 direct suppliers for our products that are within the scope of our due diligence process. Of these 19 suppliers, we received 16 responses to our request for information. We have relied on these supplier’s responses to provide us with information about the source of conflict minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.

7.Designing and Implementing a Strategy To Identify and Respond to Supply Chain Risk

The Company has followed up with its suppliers in order to secure complete responses regarding both the use, and the supply and chain of custody, of any Conflict Minerals contained in the Covered Products. The Company has also initiated a process sought to review the reasonableness and reliability of its suppliers’ responses.

8. Third Party Audits of Supply Chain

The Company does not have direct relationships with smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain with these Conflict Minerals. We do rely upon industry efforts to influence smelters and refineries to get audited and certified through CFSI’s Conflict Free Smelter Program.

9. Reporting

With the preparation and submission of this Conflict Minerals Report, the Company has provided a public report of its due diligence measures with regard to the sourcing of Conflict Minerals.

Section 4 - Product Categorization and Results of Due Diligence

After exercising the due diligence described above, the Company was unable to determine whether or not each of the Covered Products qualifies as “DRC conflict free,” as defined under the Rule. Accordingly, the Company determined that each of the Covered Products is “DRC conflict undeterminable,” as defined in the Rule.

Based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed below:



Metal		Smelter or Refiner
TIN		CHINA MINMENTALS
TIN		MINMENTALS GANZHOU TIN CO. LTD.
TIN		THAILAND SMELTING AND REFINING CO. LTD.
TIN		PT TIMAH
TIN		YUNNAN CHENGfENG NON-FERROUS METALS CO LTD
TIN		FUNSUR
TIN		MINERACAO TABOCA S.A.
TIN		COOKSON
TIN		MINSUR
TIN		ThAISARCO
GOLD		JX NIPPON MINING & METALS CO., LTD
GOLD		SUMITOMO METAL MINING CO. LTD.
GOLD		SHANDONG ZHAOJIN GOLD & SILVER REFINERY CO. LTD
GOLD		AGR MATTHEY
GOLD		AIDA CHEMICAL INDUSTRIES CO. LTD.
GOLD		ALLGEMEINE GOLD- & SILBERSCHEIDEANSTALT



Metal		Smelter or Refiner
GOLD		ALMALYK MINING AND METALLURGICAL COMPLEX (AMMC)
GOLD		ANGLOGOLD ASHANTI
GOLD		ARGOR HERAEUS
GOLD		ASAHI PRETEC CORP KOUBE KOUJYO
GOLD		ASAKA RIKEN CO LTD
GOLD		ATASAY KUYUMCULUK SANAYI VE TICARET A.S.
GOLD		AURUBIS AG
GOLD		BOLIDEN MINERAL AB
GOLD		CENDRES & METAUX SA
GOLD		CENTRAL BANK OF THE DPR OF KOREA
GOLD		CENTRAL BANK OF THE PHILIPPINES GOLD REFINERY & MINT
GOLD		CHIMET SPA
GOLD		CHINA
GOLD		CHUGAI MINING CO., LTD.
GOLD		COOKSON SEMPSA
GOLD		DAEJIN INDUS CO. LTD
GOLD		DAERYONGENC
GOLD		DO SUNG CORPORATION
GOLD		DONGGUAN CAMEROONCHEMICAL MATERIALS CO., LTD
GOLD		DOWA METALMINE CO.LTD
GOLD		FSE NOVOSIBIRSK REFINERY
GOLD		GUANGDONG HUA JIAN TRADE DO.,LTD
GOLD		HARMONY GOLD REFINERY
GOLD		HEIMERLE + MEULE GMBH
GOLD		HERAEUS LIMITED
GOLD		HERAEUS MATERIALS TECHNOLOGY GMBH&CO.KG
GOLD		HERAEUS PRECIOUS METALS GMBH & CO. KG
GOLD		HERAEUS TECHNOLOGY CENTER
GOLD		HISIKARI MINE
GOLD		HON-HAI
GOLD		HWASUNG CJ CO. LTD
GOLD		ISHIFUKU TOKYO MELTERS
GOLD		ISTANBUL GOLD REFINERY
GOLD		JAPANESE MINT OSAKA
GOLD		JCC
GOLD		JOHNSON MATTHEY LIMITED
GOLD		JOHNSON MATTHEY(SALT LAKE CITY)
GOLD		JSC EKATERINBURG NON-FERROUS METAL PROCESSING PLANT
GOLD		JSC URALECTROMED
GOLD		KAZZINC LTD
GOLD		KOJIMA CHEMICALS CO.,LTD
GOLD		KOREA METAL
GOLD		KYRGYZALTYN JSC
GOLD		L' AZURDE COMPANY FOR JEWELRY
GOLD		LA CARIDAD



Metal		Smelter or Refiner
GOLD		LINGBAO JINYUAN TONGHU
GOLD		LS-NIKKO COPPER INC
GOLD		MATERION ADVANCED METALS
GOLD		MATSUDA SANGYO CO. LTD
GOLD		METALOR
GOLD		METALOR COATINGS (TAIWAN) CORPORATION
GOLD		METALOR HK
GOLD		METALOR SWITZERLAND
GOLD		METALOR TECHNOLOGIES (SUZHOU) LTD.
GOLD		METALOR USA REFINING CORPORATION
GOLD		MET-MEX PEÑOLES, S.A.
GOLD		MITSUBISHI MATERIALS CORPORATION
GOLD		MITSUI
GOLD		MITSUI & CO PRECIOUS METALS INC
GOLD		MITSUI & CO. PRECIOUS METALS INC. HONG KONG BRANCH
GOLD		MITSUI GLOBAL PRECIOUS METALS .INC
GOLD		MOSCOW SPECIAL ALLOYS PROCESSING PLANT
GOLD		NIHON MATERIAL CO.,LTD
GOLD		NIPPON MINING
GOLD		NMMC
GOLD		OHIO PRECIOUS METALS LLC.
GOLD		OJSC “THE GULIDOV KRASNOYARSK NON-FERROUS METALS PLANT” (OJSC KRASTVETMET)
GOLD		OJSC KOLYMA REFINERY
GOLD		PAMP SA SWITZERLAND
GOLD		PAN PACIFIC COPPER CO., LTD.
GOLD		PRIOKSKY PLANT OF NON-FERROUS METALS
GOLD		PT ANEKA TAMBANG (PERSERO) TBK
GOLD		PX PRÉCINOX SA
GOLD		QIANKUN GOLD AND SILVER
GOLD		RAND REFINERY (PTY) LTD
GOLD		ROYAL CANADIAN MINT
GOLD		SABIN METAL CORP.
GOLD		SAMWON METALS CORP.
GOLD		SCHONE EDELMETAAL
GOLD		SEMPSA JOYERIA PLATERIA SA
GOLD		SENJU METAL INDUSTRY CO LTD
GOLD		SHANDONG ZHAOYUAN GOLD ARGENTINE REFINING COMPANY
GOLD		SHENZHEN FUJUN MATERIAL TECHNOLOGY CO,LTD
GOLD		SHENZHEN TIANCHENG CHEMICAL CO LTD
GOLD		SOE SHYOLKOVSKY FACTORY OF SECONDARY PRECIOUS METALS
GOLD		SOLAR
GOLD		SOLAR APPLIED MATERIALS TAIWAN
GOLD		SUPER DRAGON TECHNOLOGY CO., LTD.
GOLD		SUZHOU XINGRUI NOBLE
GOLD		TANAKA TOKYO MELTERS



Metal		Smelter or Refiner
GOLD		THE GREAT WALL GOLD AND SILVER REFINERY OF CHINA
GOLD		THE HUTTI GOLD COMPANY
GOLD		THE PERTH MINT
GOLD		THE REFINERY OF SHANDONG GOLD MINING CO. LTD
GOLD		TIMAH COMPANY
GOLD		TOKURIKI HONTEN CO., LTD
GOLD		TONGLING NONFERROUS METALS GROUP HOLDING CO., LTD
GOLD		TORECOM
GOLD		TOYO SMELTER & REFINERY (EHIME)
GOLD		UMICORE BRAZIL LTD
GOLD		UMICORE SA
GOLD		UMICORE SA BUSINESS UNIT PRECIOUS METALS REFINING
GOLD		UNITED PRECIOUS METAL REFINING INC.
GOLD		VALCAMBI SUISSE
GOLD		WANG TING
GOLD		WESTERN AUSTRALIAN MINT
GOLD		WESTERN AUSTRALIAN MINT TRADING
GOLD		WUXI MIDDLE TREASURE MATERIALS
GOLD		XIAMEN TUNGSTEN CO LTD
GOLD		XINYE CO. LTD
GOLD		XSTRATA
GOLD		YOKOHAMA METAL CO.,LTD.
GOLD		YUNNAN TIN GROUP
GOLD		ZHAOJIN LAI FUK
GOLD		ZHONGSHAN HYPER-TOXIC SUBSTANCE.MORWPOLICED.CO.LTD
GOLD		ZIJIN MINING GROUP CO. LTD
TANTALUM		CONGHUA TANTALUM AND NIOBIUM SMELTRY
TANTALUM		DUOLUOSHAN SAPPHIRE RARE METAL CO. LTD
TANTALUM		EXOTECH INC.
TANTALUM		F&X ELECTRO-MATERIALS LIMITED
TANTALUM		GANNON & SCOTT
TANTALUM		GLOBAL ADVANCED METALS
TANTALUM		H.C. STARCK GMBH
TANTALUM		HI-TEMP
TANTALUM		JIUJIANG JINXIN NONFERROUS METALS CO. LTD.
TANTALUM		JIUJIANG TANBRE
TANTALUM		MITSUI MINING AND SMELTING
TANTALUM		NEWTON, MA
TANTALUM		NINGHUA XINGLUOKENG TUNGSTEN MINING CO.,LTD
TANTALUM		NINGXIA ORIENT TANTALUM INDUSTRY CO., LTD.
TANTALUM		NIOTAN
TANTALUM		PLANSEE GROUP
TANTALUM		RFH
TANTALUM		SOLIKAMSK METAL WORKS
TANTALUM		TAKEI CHEMICALS



Metal		Smelter or Refiner
TANTALUM		TANTALITE RESOURCES
TANTALUM		TELEX
TANTALUM		ULBA METALLURGICAL PLANT JSC
TANTALUM		UNION TOOL CO.LTD
TANTALUM		ZHUZHOU CEMENTED CARBIDE WORKS IMPORT AND EXPORT CO.
TIN		AIM
TIN		CHINA GUANGXI LIUZHOU CITY, TIN METAL MATERIALS BRANCH
TIN		COOPER SANTA
TIN		CV DS JAYA ABADI
TIN		CV DUTA PUTRA BANGKA
TIN		CV JUSTINDO
TIN		CV MAKMUR JAYA
TIN		CV NURJANAH
TIN		CV PRIMA TIMAH UTAMA
TIN		CV SERUMPUN SEBALAI
TIN		CV UNITED SMELTING
TIN		DAEWOO INTERNATIONAL
TIN		EMPRESSA NACIONAL DE FUNDICIONES (ENAF)
TIN		FEINHÜTTE HALSBRÜCKE GMBH
TIN		GEJIU NON-FERROUSMETAL PROCESSING CO.LTD.
TIN		GEJIU ZILI MINING&SMELTING CO. LTD.
TIN		GUANGXI PINGGUI PGMA CO., LTD.
TIN		GUANGXI ZHONGSHAN GOLD BELL SMELTING CORP.LTD
TIN		HERAEUS PRECIOUS METALS GMBH & CO. KG
TIN		HONGQIAO METAL
TIN		HUAXI TIN (LIUZHOU) CO. LTD
TIN		HUICHANG JINSHUNDA TIN CO. LTD.
TIN		JIANGXI NANSHAN
TIN		KAI UNITA TRADE LIMITED LIABILITY COMPANY
TIN		LINGBAO JINYUAN TONGHU
TIN		LINWU XIANGGUI SMELTER CO
TIN		LIQIAO PLATING
TIN		LIUZHOU CHINA TIN GROUP CO. LTD.
TIN		MENTOK
TIN		MENTOK SMELTER
TIN		MENTOK SMELTER (PT TIMAH)
TIN		METALLO CHIMIQUE
TIN		MINMETALS GANZHOU TIN CO. LTD.
TIN		MITSUBISHI ELECTRIC METECS CO LTD
TIN		MITSUBISHI MATERIAL
TIN		MSC
TIN		NOVOSIBIRSK INTEGRATED TIN WORKS
TIN		OMSA
TIN		PT ALAM LESTARI KENCANA
TIN		PT ARTHA CIPTA LANGGENG



Metal		Smelter or Refiner
TIN		PT BABEL INTI PERKASA
TIN		PT BABEL SURYA ALAM LESTARI
TIN		PT BANGKA KUDAI TIN
TIN		PT BANGKA PUTRA KARYA
TIN		PT BANGKA TIMAH UTAMA SEJAHTERA
TIN		PT BELITUNG INDUSTRI SEJAHTERA
TIN		PT BILLITIN MAKMUR LESTARI
TIN		PT BUKIT TIMAH
TIN		PT EUNINDO USAHA MANDIRI
TIN		PT FANG DI MULTINDO
TIN		PT HP METALS INDONESIA
TIN		PT INDRA ERAMULTI LOGAM INDUSTRI
TIN		PT MITRA STANIA PRIMA
TIN		PT REFINED BANKA TIN
TIN		PT SARIWIGUNA BINASENTOSA
TIN		PT STANINDO INTI PERKASA
TIN		PT SUMBER JAYA INDAH
TIN		PT TAMBANG TIMAH
TIN		PT TIMAH (PERSERO) TBK
TIN		PT TININDO INTERNUSA
TIN		PT YINCHENDO MINING INDUSTRY
TIN		PURE TECHNOLOGY
TIN		RBT
TIN		SAMHWA NON-FERRORUS METAL IND. CO. LTD
TIN		SENJU METAL INDUSTRY CO.,LTD.
TIN		SHANDONG ZHAOJIN GOLD&SILVER REFINERY CO.,LTD
TIN		SHEN MAO SOLDER(M)SDN BHD
TIN		SHENZHEN BOSHIDA SODERING TININDUUSTRIAL CO,LTD
TIN		SMELTING BRANCH OF YUNNAN TIN COMPANY LTD
TIN		TABOCA
TIN		TABOCA/PARANAPANEMA
TIN		TAICANG CITY NANCANG METAL METERIAL CO.,LTD
TIN		TAMURA
TIN		TECHNIC INC.
TIN		TENNANT METALS PTY LTD
TIN		TIN PRODUCTS CO. LTD.
TIN		TIN SHARES
TIN		UNIFORCE METAL INDUSTRIAL CORP.
TIN		UNIT METALURGI PT TIMAH (PERSERO) TBK
TIN		UNIT TIMAH KUNDUR PT TAMBANK
TIN		WHITE SOLDER METALURGIA
TIN		XIHAI
TIN		YUN NAN TIN CO. LTD
TIN		YUNNAN TIN COMPANY LTD
TIN		YUNTINIC RESOURCES INC.



Metal		Smelter or Refiner
TUNGSTEN		ALLIED MATERIAL (A.L.M.T) CORP
TUNGSTEN		ALMT
TUNGSTEN		ATI FIRTH STERLING
TUNGSTEN		ATI TUNGSTEN MATERIALS
TUNGSTEN		CHAOZHOU XIANGLU TUNGSTEN INDUSTRY CO LTD
TUNGSTEN		CHINA MINMETALS CORP
TUNGSTEN		GANZHOU NONFERROUS METALS SMELTING CO LTD.
TUNGSTEN		GANZHOU SINDA W&MO CO. LTD.
TUNGSTEN		GTP
TUNGSTEN		HITACHI
TUNGSTEN		HITACHI METALS, LTD.,
TUNGSTEN		HUNAN CHENZHOU MINING GROUP CO
TUNGSTEN		JIANGXI RARE EARTH & RARE METALS TUNGSTEN GROUP IMP.& EXP. CO. LTD.
TUNGSTEN		JIANGXI RARE EARTH METALS TUNGSTEN GROUP CORP
TUNGSTEN		JIANGXI TUNGSTEN INDUSTRY CO LTD
TUNGSTEN		JIANGXI TUNGSTEN INDUSTRY GROUP CO., LTD
TUNGSTEN		MITSUBISHI MATERIALS CORPORATION
TUNGSTEN		MITSUI MINING & SMELTING CO., LTD
TUNGSTEN		PLANSEE
TUNGSTEN		SANDVIK MATERIAL TECHNOLOGY
TUNGSTEN		SICHUAN METALS & MATERIALS IMP & EXP CO
TUNGSTEN		STARK
TUNGSTEN		TAEGUTEC
TUNGSTEN		TEJING (VIETNAM) TUNGSTEN CO LTD
TUNGSTEN		WOLFRAM BERGBAU UND HÜTTEN AG
TUNGSTEN		WOLFRAM JSC
TUNGSTEN		WOLFRAM JSC
TUNGSTEN		XIAMEN GOLDEN EGRET SPEICAL ALLOY CO., LTD
TUNGSTEN		XTC HAICANG
TUNGSTEN		ZHANGYUAN TUNGSTEN CO LTD
TUNGSTEN		ZHUZHOU CEMENTED CARBIDE WORKS IMP.&EXP.CO

The Company does not have sufficient information to determine the country of origin of the Conflict Minerals in the Covered Products.

Section 5 - Future Risk Mitigation and Efforts to Enhance Due Diligence

As we move toward enhancing our due diligence program, we intend to take the following steps to continue to mitigate any possible risk that the necessary Conflict Minerals in the Covered Products could benefit armed groups in the Covered Countries:

i.Enhance supplier communication, training and escalation process to improve due diligence data accuracy and completion.

ii.Continue to influence additional smelters to obtain Conflict Free status throughout our supply chain, where possible.

Where practicable, the Company will work with suppliers who are sourcing from non-Conflict Free smelters to move towards using Conflict Free smelters, within a reasonable time frame. The time frame will be dependent on the criticality of the specific part and the availability of alternative suppliers.