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Conflict Minerals Policy Statement

Conflict Minerals Policy Statement

In August 2012, the U.S. Securities and Exchange Commission (“SEC”) adopted final rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule”).

Conflict Minerals Rule

Under these rules, publicly traded companies must annually report to the SEC whether the products they manufacture or contract to manufacture contain “conflict minerals” originating from the Democratic Republic of the Congo (the “DRC”) or adjoining countries. Revenue from the mining and transport of these conflict minerals is believed to be financing or benefiting groups that are responsible for human rights violations. “Conflict minerals” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location or origin of the minerals or derivative metals.

Our Role

Transmission Developments supports industry-wide efforts to identify, reduce and hopefully eliminate the use of conflict minerals originating from the DRC and adjoining countries to the extent believed to be financing or benefiting groups committing human rights violations. As a non-publicly traded company Transmission Developments falls outside of the direct scope of the Act, however we are still committed to assisting our customers with any applicable requirements under the Conflict Minerals Rule.

Supply Chain

Suppliers to Transmission Developments are also expected to establish their own conflict minerals policies, due diligence frameworks and management systems that are designed to prevent conflict minerals originating from the DRC or an adjoining country, to the extent that they benefit groups committing human rights violations, from being included in the products sold to Transmission Developments.

What Next?

Like many other companies tracing Conflict Minerals, it can take time to collect the information needed for us to fully understand our entire use of Conflict Minerals. Transmission Developments will continue to monitor and assess this situation, in order to be able to address all related customer concerns.

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