Conflict Minerals

Conflict Minerals

On August 22, 2012, the Securities and Exchange Commission (“SEC”) issued a final rule on conflict minerals pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”). The rule describes the assessment and reporting requirements for public companies whose products contain conflict minerals, defined as columbite-tantalite (tantalum), cassiterite (tin), wolframite (tungsten) and gold. These minerals, commonly referred to collectively as “3TG”, are used in a wide range of products across numerous industries.

We evaluated our current product lines and determined that certain products that we manufacture contain 3TG minerals. Certain of the minerals are contained in some of the wire and metal components we use in the connector manufacturing process. On a more limited basis, we use certain 3TG minerals in the production of products in our fiber optic cable product lines.

We do not make direct purchases of raw ore or unrefined minerals or any direct purchases from recycled or scrap sources, and we make no direct purchases in the Democratic Republic of the Congo (“DRC”) or its adjoining countries. We have conducted a country of origin inquiry in good faith by identifying suppliers of the parts used in our products that are likely to contain 3TG and conducting a supply chain survey with those suppliers. Some of the suppliers that responded to our survey reported that the minerals contained in their products may have originated in the DRC or adjoining countries, or that they were unable to specify the origin of the minerals. Based on the information received, we do not have sufficient information to determine whether the minerals directly or indirectly financed or benefitted armed groups in that region.

See attached Form SD filed with the SEC for the most recent calendar year.

 

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