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D+M Group Conflict Minerals Policy Statement

We support the ending of the violence and human rights violations that are partially funded by the mining and trading of gold and raw materials used in the production of tin, tantalum and tungsten—collectively known as 3TG—from the eastern portion of the Democratic Republic of the Congo (DRC) and adjacent areas. This location has become known as the “Conflict Region” and such 3TG minerals associated with the funding of violence and human rights violations in the Conflict Region have become known as “Conflict Minerals”.

The US Securities and Exchange Commission (SEC) has adopted rules to implement reporting and disclosure requirements related to the procurement of Conflict Minerals, with the aim to end such violence and human rights violations in the Conflict Region. The governing rules are stated in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

D+M Group’s products, like virtually all electronics products, contain certain levels of 3TG minerals. Even though we, as a private company, are not directly subject to the requirements of the SEC rules regarding Conflict Minerals, we are committed to support the objectives of these rules.

D+M Group Commitment:
1. We do not knowingly use Conflict Minerals in our products.
2. We monitor our supply base to ensure our suppliers do not knowingly use Conflict Minerals in the products supplied to D+M Group.
As such, we expect our suppliers to:
(i) develop Conflict Mineral policies and due diligence frameworks that are designed to prevent the procurement or use of Conflict Minerals; and
(ii) procure 3TG minerals from outside the Conflict Region or procure only those 3TG minerals that have been certified as “Conflict Free”—i.e., not associated with the funding of violence and human rights violations in the Conflict Region.

D+M Group’s commitment includes educating our suppliers regarding the aim of our Conflict Mineral Policy and our expectations associated with it. Our due diligence includes gathering written evidence of our suppliers’ due diligence conducted to ensure that they are not knowingly using Conflict Minerals in products supplied to D+M Group.

If we discover the use of Conflict Minerals in our products, we will take appropriate actions to transition these minerals out of our products.