Conflict Minerals Policy

On August 22, 2012, the U.S. Securities and Exchange Commission issued the
final conflict minerals rule under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule”). This rule requires that publicly traded companies must report the presence of conflict minerals (tin, tungsten, tantalum and gold) originating from the Democratic Republic of Congo or adjoining countries (“Covered Countries”).

While Electrotek is not publicly traded company and not subject to these
requirements, Electrotek is committed to assisting our customers in implementing their conflict minerals programs. To that end, Electrotek has formalized a program of due diligence requiring all of our suppliers providing materials that may contain materials falling under the Conflict Minerals Rule to provide declarations using the EICC/GeSI Conflict Minerals Reporting Template.

As our customers require that products do not contain Conflict Minerals, so also do we pass on that requirement to our suppliers and ask that they only provide to Electrotek products that have minerals originating from smelters audited and designated Conflict-Free by the Conflict Free Smelter Program.