CONFLICT MINERALS SOURCING POLICY

 

It is the policy of QFC Industries, Inc. and its operating companies (“QFC”) to comply with applicable laws and regulations.  The Security and Exchange Commission, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, issued regulations requiring public companies to disclose whether gold, columbite-tantalite (tantalum), wolframite (tungsten) and cassiterite (tin) (referred to as the “3TG minerals”) contained in their products originated from mines in the Democratic Republic of Congo or adjoining countries financing conflict in the region.

 

QFC uses only conflict-free 3TG minerals in products we sell.

 

Our suppliers must be prepared to assure the 3TG minerals are conflict free.  Suppliers can comply with this policy by sourcing 3TG minerals from outside the covered region or within the covered region from a smelter or mine determined to be conflict free.

 

In each case, the supplier must demonstrate compliance with this policy by exercising reasonable due diligence within its supply chain and flowing these requirements down to suppliers, and be prepared to provide evidence of the original source or smelter location of 3TG minerals. We expect suppliers to develop conflict minerals policies, due diligence frameworks and management systems consistent with the Organization for Economic Cooperation and Development (OECD) guidelines.

 

If a supplier does not comply with this policy, or if QFC determines a supplier is in violation of this policy or QFC’s Supplier Code of Conduct, QFC will work with the supplier toward compliance. If QFC determines compliance is unlikely within a specified time frame, QFC may transition to another supplier.

 

For more information on the Conflict-Free Sourcing Initiative, see www.conflictfreesmelter.org.