Sustainably Powering Our Future

Conflict Mineral Policy

We at SRI Energy recognize the risks of significant adverse impacts, which may be associated with extracting, trading, handling, and exporting minerals from conflict-affected and high-risk areas. SRI Energy recognizes that as part of the supply chain, we have the responsibility to respect human rights and not knowingly contribute to conflict. As such, SRI Energy commits to adopt and to incorporate with suppliers a policy for the responsible sourcing of minerals from conflict-affected and high-risk areas.

SRI Energy commits to refraining, within the best of our abilities and knowledge, from any action which contributes to the financing of conflict and to comply, within the best of our abilities and knowledge, with relevant United Nations sanctions, resolutions or, where applicable, domestic laws implementing such resolutions such as the Dodd-Frank Wall Street Reform and Consumer Protection Act.

In support of this policy, SRI Energy has created a strategy for identifying and reporting on products that contain minerals identified as conflict-affected and high-risk. SRI Energy will work with the supply chain to identify the risks inherent in the sourcing of these minerals and will take corrective action as needed.

SRI Energy uses the following terms as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1502 (e).

a) “Conflict mineral” — columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives.

b) “High-risk areas” — the Democratic Republic of the Congo and the “adjoining countries” including Angola, Burundi, Central African Republic, the Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

 

Procedure

a) SRI Energy has established that products made from the following common materials should be reviewed under this procedure.

Bronze and Brass: cassiterite

b) Prior to 2014, Inconel: columbite-tantalite was also included. However, columbite-tantalite is not a requirement called out in the UNS code for this material. It is sometimes called out in customer specifications in combination with other minerals because of past measurement practices. It is not necessary to the function of Inconel.

The supply chain for products made from these materials are reviewed as requested by the customer to determine the potential percentage of material that could be considered from “conflict” areas and to reduce supply from those sources as they are found. If the source cannot be determined, SRI Energy will so report to its relevant external parties. SRI Energy’ s strategy is to continually improve this process.