Conflict Minerals Policy
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Q-E Manufacturing Co., Inc. is committed to insuring that "Conflict Minerals" which may be contained in our products are sourced with due respect for human rights, and that our supply chain purchases do not contribute to armed conflicts. It is our policy to source products from suppliers that share our values with respect to human rights, ethics, and social and environmental responsibility.

"Conflict Minerals" refers to certain minerals or other derivatives mined in the eastern provinces of the Democratic Republic of the Congo (DRC) or in countries adjoining the DRC (the "Conflict Region"), where revenues may be directly or indirectly used to finance armed groups engaged in civil war or other armed conflicts. These conflicts are resulting in serious social, human rights and environmental abuses. In an effort to stem those abuses, the United States passed the Dodd-Frank Financial Reform Bill in July of 2010. Section 1502(b) of the Act requires all U.S. publicly-traded companies to disclose the use of any Conflict Minerals in products they manufacture or contract to manufacture. The minerals specifically identified are tin, tungsten, tantalum and gold (called the "3TG's"). While the burden of compliance is on public companies, privately-held suppliers within their supply chains are also impacted.

While Q-E Manufacturing is not required by law to report its use or sources of Conflict Minerals, we are committed not to knowingly procure products that contain Conflict Minerals if we determine that the products are not "DRC Conflict Free". Products are "DRC Conflict Free" if they contain only Conflict Minerals that did not originate in the Conflict Region, are from recycled or scrap sources, or have not benefited the armed groups identified as perpetrators of the abuses that are the subject of the Dodd-Frank Bill.

We require and depend on the cooperation of our suppliers in the implementation of this Policy, and we may require suppliers to certify that products sold to us are DRC Conflict Free. In addition, we ask all of our suppliers to undertake steps to ensure the same compliance within their supply chains. We have the following expectations of our suppliers:

  1. Our suppliers should not include in any product sold to us any Conflict Minerals that are not DRC Conflict Free; and
  2. Our suppliers should develop their own Conflict Minerals policies and undertake appropriate due diligence in an effort to prevent Conflict Minerals that are not DRC Conflict Free from being included in products they manufacture or sell to us.

We evaluate our relationships with suppliers on an ongoing basis. Where we determine that a supplier has failed to reasonably comply with this Policy, we reserve the right to take appropriate actions, up to and including discontinuing purchases from that supplier. The relationship for future business may also be impacted.

Nothing in this Policy is intended in any way to grant any additional rights or expectations to our suppliers or in any way modify or limit any of our contractual legal rights or remedies.