CONFLICT MINERALS

The term "Conflict Minerals" refers to certain minerals mined in the eastern provinces of the Democratic Republic of Congo and adjacent countries. The revenues from these minerals may be used, directly or indirectly, to finance armed groups involved in civil wars, leading to serious social problems and environmental misuse.

In July 2010, the so-called "Dodd-Frank Law" on reform and consumer protection on Wall Street in the US was made legally binding. In its adopted form, the "Dodd-Frank Law" required the US Securities and Exchange Commission to adopt regulations obliging listed companies to disclose their use of Conflict Minerals and their provenance and to indicate it in covered regions whether the minerals are "conflict free" or not. The specific minerals to which the "Dodd-Frank Law" refers are cassiterite, columbite-tantalite, wolframite, gold and derivatives of these minerals. In August 2012, the SEC adopted the necessary rules requiring listed companies to conduct a due diligence review of their supply chain and, where appropriate, to disclose information on dealing with conflict minerals.

ACTIA supports the intention of this legislation to eliminate the social and environmental damage caused by the use of Conflict Minerals and any funding of armed groups in the Democratic Republic of Congo.

The supply chain associated with Conflict Minerals is complex and we work with our suppliers to determine the sources of Conflict Minerals in the raw materials we supply. For this reason we have the following expectations for our material suppliers:

• Procurement of minerals from non-conflict regions, or if they originate from conflict regions, must be proven by procurement without conflict. This means that the commodities are not used to fund conflicts in covered countries. This must be documented by an appropriate due diligence program.

• Provide the required information to ACTIA through the report collection template (Conflict Minerals Reporting Template) from the Responsible Minerals Initiative.

• Passing these requirements on to subsequent levels in their supply chain, using reasonable efforts to identify the source, minerals, if not directly from smelters.

ACTIA collects Conflict Minerals due diligence information from its suppliers and requires suppliers to provide melt name, country of origin, contact information, etc. We review the due diligence information received from suppliers. Corrective actions and follow-up are carried out at suppliers who provide inadequate or incomplete answers.

The ACTIA Conflict Minerals policy and subsequent updates are communicated to our supply chain partners and stakeholders through our website. Compliance with this guideline is a prerequisite for all contracts with direct material suppliers.