POLICY: Conflict-Free Minerals Sourcing

Effective Date: September 11, 2014

1. Summary—Statement of Purpose
The purpose of this sourcing policy is to ensure that MLD is in compliance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Therefore, the following policy guidelines will apply to the procurement of “conflict minerals” as defined by the Act.

2. Legal Requirement
17 CFR Parts 240 and 249b – Securities and Exchange Commission (SEC); Final rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act; Effective Date: November 13, 2012; Compliance Date: January 1, 2013; First Reporting Date: May 31, 2014

NOTE: Technically, MLD would not be required by the SEC to file reports on conflict minerals; however, some of our customers are required to report, and expect MLD to provide supporting documentation.

3. Conflict Minerals Definition
This Policy applied to sourcing of the following metallic elements, because of the minerals from which they are extracted:

  • Tin—extracted from the mineral cassiterite
  • Tantalum—extracted from the mineral columbite-tantalite
  • Tungsten—extracted from the mineral wolframite
  • Gold—occurs naturally in metallic form

4. MLD Sourcing Policy
The materials listed above as Conflict Minerals will be purchased only from suppliers that are committed to conflict-free sourcing.

Purchase orders must state that conflict-free sourcing of the material is a requirement of the order.

The supplier must provide information on the approved smelters from which they source these materials, using a standard EICC/GeSI/CFSI Conflict Minerals Reporting Template (CMRT).

The reported information must be updated on a yearly basis, using the latest revision of the CMRT.