Background:

Mining is an intensive process involving potential social and environmental risks that may cause lasting negative impacts if not properly managed. Certain high-risk minerals (notably tin, tantalum, tungsten, gold and cobalt) sourced from regions of the world with ongoing conflict carries a risk of funding organizations that are involved in illegal or unethical activities including human rights abuses such as child labor, harsh working conditions, environmental destruction and corruption. A growing awareness of the abuses committed in these areas of conflict has prompted an industry wide investigation into any supply chain tainted by these atrocities. In the U.S., the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires publicly traded companies to report annually on the presence of conflict minerals originating in the DRC or adjoining countries in the products they manufacture or contract to manufacture. The purpose is to report any abuses, and through disclosure, halt the sourcing of designated minerals via supply chains implicated in conflict zones.

Consons’s Commitment

Consons’s Responsible Mineral Policy aligns with our commitment to uphold and respect fundamental human rights for all people, including those who work in our supply chain. Consons complies with applicable legislation and strongly supports industry-wide efforts to promote responsible sourcing, protect human rights, and combat child labor throughout supply chain. Consons does not directly procure minerals from mines, or the smelters or refiners that process them, but believe we can influence upstream supply chain actors through our policies and practices. Recognizing the complexity of this issue, we are actively engaged with industry peers, suppliers, and other stakeholders to promote the responsible sourcing of minerals through the Responsible Minerals Initiative (RMI). Our goal is to work collaboratively through the supply chain to source minerals consistent with our values around human rights, business ethics, labor, health and safety practices, and environmental responsibility. We believe this can be done while continuing to source responsibly from the DRC and other high-risk regions.

Consons’s internal due diligence framework is designed to conform, in all material respects, to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) to determine the country of origin and chain of custody for high-risk minerals in our supply chain. To promote responsible investigations of high-risk minerals, Consons uses the Conflict Minerals Reporting Template (CMRT) and the Cobalt Reporting Template (CRT) issued by the Responsible Minerals Initiative (RMI).

Supplier Expectations

To support ethical procurement practices and responsible mineral sourcing, Consons expects suppliers that provide components and/or materials containing “relevant minerals” to adhere to the same high standards to which we hold ourselves. For the purposes of Consons’s Responsible Minerals Sourcing program, relevant minerals currently include:

Columbite-tantalite (tantalum), Cassiterite (tin), gold and wolframite (tungsten) – also known as “conflict minerals” or “3TG”;Cobalt; andAny other mineral identified by Consons as contributing possible risk to the supply chain.

We require suppliers to:

Adhere to Consons’s Supplier Code of Conduct and all applicable laws and regulations related to mineral sourcing; Source only from smelters and refiners validated by a third-party audit program. Accepted programs include: the RMI’s Responsible Minerals Assurance Process, the LBMA’s Responsible Gold Certification; or the RJC’s Chain-of-Custody Program;

Make reasonable efforts to remove all non-participating and non-validated smelters or refiners from Consons’s supply chain;Establish and maintain a publicly available policy on responsible minerals sourcing that aligns with the OECD Guidance to assure that the high-risk minerals in the products they manufacture do not contribute to ongoing conflicts or human rights abuses in conflict-affected areas;

Design and implement due diligence frameworks and management systems consistent with OECD Guidance to achieve responsible mineral supply chains;

Verify and inform Consons whether the minerals included in materials or component parts are conflict-affected or high-risk minerals;Respond to Consons inquiries for reporting templates and due diligence information, and promptly implement corrective actions identified and requested by Consons; andExtend these expectations to their own suppliers.If these requirements are not met, Consons will proactively work with the supplier to further develop their capabilities in responsible mineral due diligence to ensure alignment to Consons’s supplier requirements. Consons will terminate relationships with suppliers that do not make substantive and prompt efforts to comply with our policy.