Modern Industries’ Responsible Minerals Policy

Modern Industries deplores the violence in the DRC and adjoining countries and is committed to conducting due diligence on supply chains in accordance with the internationally recognized frameworks of the OECD Due Diligence Guidance and the UN Guiding Principles for Business and Human Rights. Accordingly, Modern Industries has adopted a responsible minerals policy. Modern Industries encourages its suppliers to adopt a similar policy and to meet the expectations set out below.

Materials Supplied to Modern Industries

Suppliers are required to comply with all applicable local, country[1], and international laws regarding material content for the materials supplied to Modern Industries. At Modern Industries’ request, Suppliers are required to provide to Modern Industries reports on the occurrence of substances in any materials supplied to Modern Industries that may be restricted by, or require disclosure to, governmental bodies, customers and/or recyclers.

Minerals of Concern

Suppliers are encouraged to supply materials to Modern Industries that are “DRC conflict- free.” “DRC conflict-free” means (1) any “conflict minerals” (gold, columbite-tantalite, also known as coltan, cassiterite, wolframite, or their derivatives tin, tantalum or tungsten (collectively the "3TGs")) necessary to the functionality or production of supplied materials do not directly or indirectly finance armed groups through mining or mineral trading in the Democratic Republic of Congo or an adjoining country, or (2) any 3TGs in supplied materials are from recycled or scrap sources [2]. Suppliers are required to adopt policies and management systems with respect to conflict minerals and to encourage their suppliers to adopt similar policies and systems.

In alignment with the Responsible Minerals Initiative and the growing concern within our industry regarding human rights violations beyond the scope of 3TG and the Dodd Frank Act, the minerals of concern also include cobalt.

[1] Updated Conflict Minerals section following publication of final U.S. Securities and Exchange Commission Conflict Minerals Rule, 77 Fed. Reg. 56274 (Sept. 12, 2012).

[2] Conflict minerals are from "recycled or scrap sources" if they are from recycled metals, which are reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing. Recycled metal includes excess, obsolete, defective and scrap metal materials that contain refined or processed metals that are appropriate to recycle in the production of tin, tantalum, tungsten, and/or gold. Minerals partially processed, unprocessed, or a "bi-product" from another ore are not included in the definition of recycled metal. Item 1.01(d)(6) for Form SD, 77 Fed. Reg. 56274, 56364 (Sept. 12, 2012).

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