Solus Advanced Materials

Introduction

1. The term 'conflict minerals’ refers to minerals such as tin, tantalum, tungsten, and gold that are produced/mined in the Democratic Republic of the Congo (DRC) and neighboring countries, which are in a state of civil unrest.
   Funds generated from conflict minerals flow into armed forces in the region, and support human rights violations such as child labor, forced labor, and abuse of women in the mining process, as well as massacres of civilians.
   
   As international concerns over conflict minerals increased, the US Congress enacted a law (Dodd-Frank Financial Regulatory Reform Act) in 2010 that required reporting on the use of conflict minerals. In accordance with Section 1502 of this Act, companies listed on the US stock market are required to investigate their use of conflict minerals and their origin, conduct due diligence on their supply chain, and report the results to the U.S. Securities and Exchange Commission (SEC).
   

Conflict Minerals Management Policy

1. •  As a responsible company, Solus Advanced Materials Co., Ltd. will ensure that conflict minerals associated with armed forces in conflict areas are not included in the supply chain for the production of its products.
   
   •  Conflict Minerals Management Plan of Solus Advanced Materials Co., Ltd.

   • (1) We will establish a conflict minerals business process to ensure our compliance with the law in accordance with international standards governing conflict minerals, and actively support activities led by the Responsible Minerals Initiative (RMI) to ban the use of conflict minerals.
   • (2) Using the Conflict Minerals Reporting Template and questionnaire provided by RMI, we will identify all smelter names and locations for the minerals used in our products, including tin, tantalum, tungsten and gold.
   • (3) We will request our suppliers to fill out and submit the Conflict Minerals Reporting Template and questionnaire, and to confirm in writing that they are not using conflict minerals (3TG: tin, tantalum, tungsten and gold).
   • (4) We will encourage our suppliers to purchase conflict minerals from smelters certified by RMAP (Responsible Minerals Assurance Process).
   • (5) When we use conflict minerals, we will establish due diligence procedures in accordance with the OECD Due Diligence Guidance. If necessary, we will also conduct due diligence on our suppliers to check their procedures and data for reporting on their use of conflict minerals.

Supplier Requirements

1. •  Solus Advanced Materials Co., Ltd. requires all suppliers to fully understand the laws related to conflict minerals in the United States, and to strictly comply with the company’s conflict minerals management policy so that it can be consistently applied to the lower levels of the supply chain.
   
   •  To this end, partners of Solus Advanced Materials Co., Ltd. must do the following.

   • Suppliers shall establish written conflict minerals management policies and procedures, and ensure that products supplied to Solus Advanced Materials do not contain conflict minerals that contribute to the interests of armed forces in the Democratic Republic of the Congo and neighboring countries.
   • (2) Suppliers should make good faith efforts to find out the names and locations of all smelters that supplied conflict minerals to their supply chain.
   • (3) When requested by Solus Advanced Materials Co., Ltd., suppliers must fill out the Conflict Minerals Reporting Template and questionnaire, and submit it in a timely manner.
   • (4) When risks are discovered in their supply chain, suppliers should take corrective actions in a timely manner.
   • ※ Solus Advanced Materials Co., Ltd. may suspend transactions with a supplier if it fails to provide sufficient information to confirm the use of conflict minerals, provides false information, or finds a risk in its supply chain but does not take appropriate action.

Together with its suppliers and customers, Solus Advanced Materials Co., Ltd. actively supports international efforts to ban the use of conflict minerals.