Conflict Minerals Policy

Last modified: 1/19/2023

The U.S. Securities and Exchange Commission (“SEC”) has adopted rules regarding disclosure and reporting requirements with respect to “conflict minerals” as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rules require public companies to disclose whether the products they manufacture or contract to manufacture contain conflict minerals (tin, tungsten, tantalum and gold [3TG]) that are necessary to the functionality or production of these products.

UFS Corporation supports the goal of rules to end violence and human rights abuses in the Democratic Republic of the Congo and surrounding countries that may be financed by proceeds from trade in these minerals. We are committed to complying with all requirements applicable to UFS Corporation under the rules.

UFS Corporation will work with our customers cooperatively in connection with their conflict minerals programs. We rely upon our suppliers to support us by conducting their own due diligence and provide written documentation as to whether products containing 3TG are used in the manufacture of materials we purchase from them, upon request. If affirmative, the written documentation is to show that the 3TG products originate from outside the Covered Countries, or, if they originate from within the Covered Countries, that the mines or smelters be verified as “conflict free” by an independent third party.

Any supplier’s continuing failure to comply with this policy or refusal to support UFS Corporation’s conflict minerals compliance program may likely lead to termination of our business relationship with that supplier.