PM Holdings Minerals Sourcing Policy

PM Holdings Takes A Strong Stance Against Conflict Minerals!

The Conflict Minerals Rules require that all public companies annually disclose and report to the SEC whether any of its products contain Tin, Tantalum, Tungsten or Gold (“3TG”) that may have originated from mines in the Democratic Republic of Congo (DRC) or one of its nine bordering nations (covered countries) that may directly or indirectly support or finance armed militias or rebels in the region (so called “conflict minerals”).

On August 22, 2012, the US Securities and Exchange Commission (the “SEC”) released final rules relating to Section 1502(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) that require all public companies to annually disclose and report to the SEC whether any of their products contain minerals (Tin, Tantalum, Tungsten and Gold, so called 3TG or “conflict minerals”) that may have originated from mines in the Democratic Republic of Congo or any adjoining country that support armed militias or rebels in the region.

Even though PM Holdings is not a public traded company, we are still committed to sourcing our products in accordance with the law and in compliance of the Dodd-Frank rule. We expect our suppliers to do the same. PM Holdings has designed its Minerals Sourcing Policy and reporting efforts to align and comply with the requirements of the Conflict Minerals Rules. This policy applies to all products manufactured by, or on behalf of, PM Holdings, Tech-Life, and GTE Tools, anywhere in the world, including all products or components purchased by PM Holdings and included in the products PM Holdings manufactures or sells.

In addition to committing to sourcing our products in accordance with the law, we also take the additional steps to ensure our company’s products do not contain conflict minerals (3TG). PM Holdings refuses to work with suppliers which deliver components related to the products referenced above that contain conflict minerals. On an annual basis, PM Holdings reviews our upstream supply chain to ensure the conflict minerals are not contained in our products.

FAQs

What are conflict minerals and why are they a concern?
Products containing the minerals Tin, Tantalum, Tungsten or Gold (“3TG”) that may have originated from mines in the Democratic Republic of Congo (DRC) or one of its nine bordering nations (covered countries) that may directly or indirectly support/finance armed militias or rebels in the region (so called “conflict minerals”).

The covered countries in the region include: Democratic Republic of Congo, the Republic of Congo, Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

The belief is that the funds from mining these minerals in the region could be funding armed groups and thus fueling violence in Africa. The U.S. Conflict Minerals Rules are intended to reduce the possible funding of armed groups engaged in regional conflict and human rights abuses in the DRC region by mandating disclosure requirements on the use and source of the specified 3TG minerals.

What does “DRC Conflict Free” mean?
“DRC Conflict Free” means that the 3TG minerals contained in a product did not directly or indirectly finance or benefit armed groups in the DRC, Angola, Burundi, Central African Republic, Congo Republic, Rwanda, Sudan, Tanzania, Uganda and Zambia. “DRC Conflict Free” may also be used to describe products containing 3TG minerals from recycled or scrap sources.

What does “Not Conflict Free” mean?
“Not Conflict Free” means that the 3TG minerals contained in a product originated in the DRC or adjoining country, AND financed or benefited armed groups.

How does PM Holdings stay DRC Conflict Free?
PM Holdings, on an annual basis, conducts a country of origin inquiry to determine the source of any conflict minerals contained in any products. We determine if any conflict minerals are used in the making of products and/or raw materials supplied to PM Holdings.
We are to identify, for the entire calendar year: (i) the supplier products that are free of any conflict minerals content; (ii) the supplier products using conflict minerals that are 100% from recycled or scrap material sources; and (iii) the supplier products using conflict minerals from covered countries (if any).

Is there a minimum quantity of 3TG minerals that must remain in the product to qualify for Dodd-Frank evaluation?
There is no minimum quantity threshold in the Dodd-Frank rules. Even a slight trace of the conflict mineral(s) has to be evaluated and potentially reported.

What is the requirement for recycled and scrap materials?
Recycled and scrap materials are exempt from the Dodd-Frank rule.