On August 22, 2012, the Securities and Exchange Commission (SEC) issued the final rules to implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). The rules require each public company, like Hamsar, for which conflict minerals are necessary to the functionality or production of one or more products that it manufactures or contracts to manufacture, to perform due diligence on its supply chain in an effort to determine how those minerals are sourced. Further, such companies must annually report and make public whether any conflict minerals originate from the Democratic Republic of Congo or adjoining countries (together, the “Covered Countries”). These “conflict minerals” are commonly known as tin, tantalum, tungsten  and gold. For additional details, please review the conflict minerals final rule, available at: http://www.sec.gov/rules/final/2012/34-67716.pdf.

Hamsar supports the objective of the Act regarding the use of conflict minerals. We are committed to increasing supply chain transparency in order to identify the sources of conflict minerals as accurately as possible and working toward avoiding the use of conflict minerals that directly or indirectly finance conflict in the Covered Countries. It is Hamsar’s expectation that its suppliers will adopt policies and procedures with respect to conflict minerals that will enable us to reasonably assure products supplied to Hamsar are conflict-free. We are actively working with the Automotive Industry Action Group (AIAG), customers and suppliers to further the awareness of conflict in the Covered Countries. We participate in cross-industry initiatives to develop common tools and practices that support the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High- Risk Areas published by the Organization for Economic Co-Operation & Development (OECD)  (see http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf). Hamsar will continue to evaluate its policies and collaborate with industry groups while applying the OECD due diligence process as part of our compliance effort.

In addition to the above policy,  Hamsar requires suppliers to confirm if any of the products they supply to Hamsar contain the following conflict minerals/elements: Tin, Tantalum, Gold, Tungsten.

If some or all of your products do contain Tin, Tantalum, Gold or Tungsten, please complete this form: EICC- Conflict Minerals Reporting Template. Complete and email forms to hamsar.sales@grakon.com or fax form to Purchasing at 905-332-9020.