Conflict Minerals Policy

What is Conflict Minerals Reporting Template (CMRT)? Conflict minerals refer to tantalum, tungsten, tin, and gold originated in the Democratic Republic of the Congo and its adjoining countries (“Covered Countries”). There are concerns that the conflict minerals fund armed forces of the Covered Countries causing many deaths of their own people and infringement of human rights in the course of mineral excavation such as forced labor and abuse of women and children. In response to these concerns, the United States Congress enacted the Dodd–Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Section 1502 of the Dodd-Frank Act (“Conflict Minerals Rule”) requires manufacturing companies listed in U.S. stock exchange to disclose whether the products they manufacture or contract to manufacture contain conflict minerals. LeoLSI’s policy is to eliminate the use of conflict minerals contained in our products that directly or indirectly finance or benefit armed groups in the Covered Countries.

Implement procedures compliant with and in support of the activities of the EICC-GeSI Conflict Free Sourcing Initiative and the OECD Due Diligence Guidance.

To do so, require our suppliers to submit the Form or otherwise verify in written documents that all products supplied to LeoLSI do not contain conflict minerals from the Covered Countries that directly or indirectly finance or benefit armed groups in those Covered Countries.

Therefore, identify through reasonable efforts all smelters that supply conflict minerals in their supply chain.