Conflict Minerals

"Conflict Free" Minerals Declaration

It is the policy of Tosoh SMD, Inc. (TSMD) to procure materials from sources that share our vision of adhering to the requirements established by the Organization for Economic Co-operation and Development (OECD). We direct our suppliers to undertake reasonable due diligence with their supply chains to determine the location from which materials 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 materials that directly or indirectly finance or benefit armed groups in regions of conflict, identified as Conflict-Affected, High Risk Areas (CAHRA), such as Democratic Republic of the Congo and its adjoining countries.

TSMD relies on the auditing process established by the Responsible Minerals Initiative (RMI) to verify the sources of conflict materials are compliant with conflict materials guidelines established under the Dodd-Frank Wall Street Reform and Customer Protection Act and EU Conflict Minerals Regulation.

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

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