The 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) that are necessary to the functionality or production of those products.

Gardan supports the goal of the 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 Gardan under the rules.

Gardan will work with our customers cooperatively, in connection with their conflict minerals programs, and we expect our suppliers to support us in implementing the necessary conflict minerals compliance programs. Gardan requires that suppliers provide us with conflict minerals declarations using the EICC/GeSI Conflict Minerals Reporting Template and/or such other documentation as Gardan may require. Any supplier’s continuing failure to comply with this policy or refusal to support Gardan’s conflict minerals compliance program will likely lead to the termination of our business relationship with that supplier.