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In July 2010, the Wall Street Reform and Consumer Protection Act, also known as the Dodd-Frank Act was adopted. This law directed the U.S. Securities and Exchange Commission (“SEC”) to enforce rules obligating certain publically traded manufacturing companies to annually report whether the products they manufacture or contract to manufacture contain “Conflict Minerals”. The SEC published its Conflict Minerals rule in August 2012. Under this rule, Conflict Minerals are essentially tin, tungsten, tantalum and gold that are mined either in the Democratic Republic of Congo (“DRC”) or one of nine African nations that share a border with the DRC (the “DRC Region”). The overall purpose and goal of the SEC rule is to help end civil conflict and human rights abuses in the DRC Region committed by armed militant groups. STI intends to comply with the requirements of the SEC’s Conflict Minerals rule and expects our suppliers to do the same. However, STI does not directly purchase raw metal ores that may be used in our contract manufacturing process from smelters or mines. As a matter of fact, we are several supply chain layers removed from the mining and processing of these metals, and as a result, do not have first-hand knowledge of their source.
STI does however, understand the importance and intent of the Dodd-Frank Wall Street Reform and Consumer Protection Act and where applicable and possible, conduct due diligence and expect that its suppliers will, in turn and as necessary, perform the same due diligence in avoiding the sourcing and purchasing of products and/or supplies containing any Conflict Minerals. The process of tracing Conflict Minerals through a global supply chain is complicated and time-consuming, and some component suppliers or sub-suppliers may lack the resources to trace minerals all the way back to their source. STI will endeavor in good faith to have its suppliers exercise reasonable due diligence to evaluate their respective supply chains for the information called for by the Conflict Minerals rule. STI will continue to evaluate our policies to ensure compliance with the SEC’s Conflict Minerals Rule and make adjustments when necessary.