Conflict Minerals

"Conflict Free" Minerals Declaration

It is the policy of Tosoh SMD, Inc. (TSMD) to procure minerals from sources that share our vision of adhering to the requirements established by the Responsible Business Alliance (RBA). We direct our suppliers to undertake reasonable due diligence with their supply chains to determine the location from which tantalum, tin, tungsten, gold or cobalt are being sourced and whether the smelter or refiner has been verified by an independent third party as conflict free. Conflict-free refers to products, suppliers, smelters and refiners that do not contain or source tantalum, tin, tungsten, gold or cobalt that directly or indirectly finance or benefit armed groups in regions of conflict, such as the Democratic Republic of the Congo and its adjoining countries.

TSMD relies on the auditing process established by RMI to verify the sources of conflict minerals are compliant with conflict mineral guidelines established under the Dodd-Frank Wall Street Reform and Consumer Protection Act.

TSMD has completed a Reasonable Country of Origin Inquiry (RCOI) using the Conflict Free Minerals Reporting Template (CMRT) created by the Responsible Minerals Initiative (RMI). Our products may contain tantalum, tin, tungsten, gold or cobalt because these minerals are necessary to the functionality of the products manufactured. TSMD has taken reasonable steps to ensure the minerals are sourced conflict free. The CMRT template provides a common means for the collection of sourcing information on minerals that could potentially originate from these conflict regions.

This document declares Tosoh SMD, Inc. and its suppliers’ products to be deemed Conflict Free to the best of our knowledge.