Environmental Policies: Conflict Materials

Recognizing that risks of significant adverse impacts may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, we have the responsibility to respect human rights and not contribute to conflict,

HM Product Solutions, Ltd. commits to adopt and incorporate in purchase contracts and/or agreements with suppliers the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas:

We commit to refraining from any known action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions, resolutions, or where applicable, domestic laws implementing such resolutions.

Suppliers to HM Product Solutions, Ltd. are expected to supply 3TG materials that are “DRC Conflict-Free.”

DRC Conflict-Free means (1) any “conflict minerals” [gold, columbite-tantalite, also known as coltan, cassiterite, wolframite, or their derivatives tin, tantalum or tungsten, collectively the “3TGs”] necessary to the functionality or direct or indirect financing of armed groups through mining or mineral trading in the Democratic Republic of Congo or an adjoining country, or (2) derived from recycled or scrap sources.