Modern Industries’ Conflict Minerals Policy

Modern Industries deplores the violence in the DRC and adjoining countries and is committed to responsible sourcing of conflict minerals associated with the region. Accordingly, Modern Industries has adopted a conflict 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 encouraged 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 encouraged 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.


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 encouraged to adopt policies and management systems with respect to conflict minerals and to encourage their suppliers to adopt similar policies and systems.

[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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