Conflict Minerals Policy

There has been increased awareness regarding the human rights violations in the mining of certain minerals from an area known as the “Covered Countries”; the Democratic Republic of the Congo (DRC) and surrounding countries. Through the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, publically traded companies have been chartered to practice reasonable due diligence with their supply chain to determine if “conflict minerals” used in their products are being sourced from mines controlled by non-government or unlawful military groups within the Covered Countries. The definition of “Conflict Minerals” refers to tin, tantalum, tungsten and gold (3TG).

TAT’s Code of Conduct defines the company‘s overall principles and commitment towards legal compliance and ethical conduct. As part of it, TAT is concerned about the link between the illegal extraction and trade of natural resources, and associated human rights violations, conflict and environmental degradation. Currently these issues are acute in the Eastern provinces of DRC in the extraction and trade of ores of tantalum, tin, tungsten and gold, which flow to world markets through the DRC and adjoining countries. Once refined, these metals are commonly used within electronic products and by many other industries. TAT does not procure metals directly and only a fraction of the world‘s minerals produce originates from the DRC, but we are taking action to increase transparency, ensure responsible procurement by our suppliers and sub-suppliers, and drive positive change.

Tracing materials back to their mine of origin is a complex endeavor but an important aspect of responsible sourcing.

TAT is committed to respect human rights and the environment in accordance with accepted international conventions and practices, such as OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and working according to the Conflict Free Sourcing Initiative (CFSI) extractives work group to improve traceability of minerals and ensure responsible sourcing for Multinational Enterprises. We strive that all materials used in our products come from socially and environmentally responsible sources. We do not profit from, contribute to, assist with or facilitate any activity that fuels conflict, leads to serious environmental degradation or violates human rights.

TAT's commitment includes:

• Developing policy and procedures toward preventing the use of conflict minerals or derivative metals necessary to the functionality or production of our product(s) that finance or benefit armed groups in the Covered Countries.
• Prohibiting direct or indirect support to non-state armed groups and not purchasing or sourcing from companies that support or do business with these groups.
• Expecting suppliers whose products contain conflict minerals to establish policies, due diligence frameworks, and management systems consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High Risk-Areas that are designed to accomplish this goal, and requiring their suppliers to do the same.

TAT believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this policy, then we will require the supplier to commit to devise and undertake suitable corrective action to move to a conflict free source. If suitable action is not taken, we will look to alternative sources for the product. TAT’s efforts are not to ban procurement of minerals from the DRC and adjoining countries, but to assure procurement from responsible sources in the region. If we determine that any of the components of our products contain minerals from a mine or facility that is “non-conflict free”, we will work towards transitioning to products that are “conflict free”.

This Policy will be reviewed periodically and updated as needed.

Concerns and violations of this policy can be reported to its non-executive members, or its subcommittees through our official grievance channels:

By mail to the following – Rona@tat-technologies.com