> FLABEG Conflict Minerals, Cobalt or Mica Policy

On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted a final rule to implement reporting and disclosure requirements related to Conflict Minerals as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The rule requires manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain Conflict mineral of these products that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or specified adjoining countries. The rule aims to further the humanitarian goal of ending violent conflict in the covered countries, which has been partially financed by the exploitation and trade of Conflict Minerals. The Conflict Minerals currently covered by the rule are: Columbite-Tantalite (Coltan) and its derivative metal Tantalum, Cassiterite and its derivative metal Tin, Wolframite and its derivative metal Tungsten, and Gold. The U.S. Secretary of State may designate additional minerals in the future. On October 20, 2021 the Responsible Minerals Initiative (RMI) supporting Conflict Minerals supply chains surveys has started to identify pinch points and collect due diligence information in the Cobalt and Mica supply chain. A specific Extended Minerals Reporting Template has been released on purpose and can be provided by FLABEG on demand.

> FLABEG and its Legal Entities make reasonable efforts

to know, and to require each FLABEG supplier to disclose to FLABEG the sources of Conflict Minerals used in their products and to eliminate procurement, as soon as commercially practicable, of products containing Conflict Minerals, Cobalt or Mica obtained from sources that fund or support inhumane treatment in the Covered Countries. 

To ensure compliance with the rule, FLABEG request information regarding the use of conflict minerals from its suppliers, who in turn, must solicit that information from the next tier of suppliers, continuing down the supply chain. 

Accordingly, we have introduced to our global supply chain, a requirement that suppliers assist the FLABEG in complying with the disclosure requirements mandated by the Dodd-Frank Act, as well as any related laws and rules.