Conflict Minerals Policy

Conflict Minerals Policy Statement

Zefon International is committed to our social responsibility to respect human rights, ethical behavior, environmental responsibility and not contribute to conflict.

In July 2010, Congress enacted the Conflict Mineral provision of the Dodd-Frank HR4174 Financial Reform Bill section 1502. The goal of this act is to eliminate the illegal trade in gold, tin, tantalum and tungsten (3TG) being sourced from mines in the conflict region – Democratic Republic of the Congo (DRC) – and in adjoining countries (Angola, Burundi, African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia). The Dodd-Frank requires public traded companies to report to the U.S. Securities and Exchange Commission (SEC) and disclose whether any of the Conflict Minerals in the products they manufacture or contract to manufacture originate in the DRC region. It also requires that due diligence be conducted to determine if the original sale of the mineral funded armed conflict. The SEC issued implementing regulations and guidance on August 22, 2012.

Zefon International does not directly source any of the 3TG minerals, but we expect our suppliers to perform reasonable due diligence with their respective supply chain to assure that the 3TG minerals are not being sourced from DRC region including smelters.

We will continue to evaluate our company policies to ensure compliance to the Dodd-Frank Act of 2010 is maintained and will make adjustments where applicable. Suppliers that will not adhere to the conflict mineral regulations nor demonstrate efforts to become conflict free will be considered for removal from our supply chain.