Conflict Minerals Policy

BittWare is taking several actions to reduce and potentially eliminate the usage of conflict minerals in our products and to facilitate the reporting requirements which will be executed by our valued customers.

With the adoption of a new rule pursuant to section 1502e(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (17 CFR Parts 240 and 249), relating to conflict minerals, BittWare recognizes that many BittWare customers have a legal requirement to disclose annually when conflict minerals necessary to the functionality or production of a product manufactured, originated in the Democratic Republic of the Congo (DRC) or an adjoining country (See Appendix 1). If the conflict minerals originated in the DRC or the adjoining countries, a report must be submitted to the commission describing measures taken to exercise due diligence on the conflict minerals’ source and chain of custody. The report must include a description of the products manufactured that are not “DRC Conflict Free”, the facilities used to process the conflict minerals, the country of origin of the conflict minerals, and the efforts to determine the mine or location of origin.

Although BittWare is a private company not listed on a U.S. Stock Exchange and therefore not subject to U.S. Securities and Exchange Commission (SEC) regulations, the company is taking the following actions:

  • BittWare will make efforts to replace components containing DRC conflict minerals with DRC conflict-free components, and to avoid use of DRC conflict minerals whenever possible.
  • BittWare has subscribed to, and partnered with, SiliconExpert to continuously monitor many of the components in our Approved Supplier List (ASL) to determine DRC conflict-free status of our products and to facilitate reporting compliance, now and in the future.
  • BittWare is currently monitoring and categorizing our components as described below. Data can be provided upon customer request for all matching components. Information can be broken out by specific BittWare products as well.
    • Percentage of BittWare components with matches in Silicon Expert
    • Percentage of components that are “DRC Conflict Free”
    • Percentage “DRC Conflict Undeterminable”
    • Percentage “Not Affected”
    • Percentage “Unknown”
    • Percentage with “No Conflict Materials Information”
  • BittWare has updated our Procurement Quality Codes Quality Management System (QMS) document to include five Quality Codes (Q-Codes) specific to conflict minerals. These Q-Codes will be added to all applicable purchase orders and will be rolled out to all applicable BittWare suppliers.
  • BittWare will be developing an automated search capability within our component database to query existing component parameter fields and determine which specific BittWare components contain Tin (Sn), Gold (Au), Tantalum (Ta), or Tungsten (W).
  • BittWare will require our suppliers to flow down our Q-Codes and our Conflict Minerals Policy through their extended supply chains.
  • BittWare will request our supply base to eliminate the use of conflict minerals wherever possible.
  • BittWare will request suppliers to report conflict minerals through the EICC/GeSI Template. This standard reporting mechanism will facilitate data roll-up and consolidation by BittWare’s customers.
  • BittWare will request our suppliers to only use certified smelters.
  • BittWare has updated our BittWare Supplier Survey Report 7410-04 to include important questions for potential suppliers regarding conflict minerals. How potential suppliers answer these questions will help to determine new supplier status.

For a full and complete BittWare position and commitment statement regarding conflict minerals, please contact BittWare sales.

Appendix 1

The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. – SECURITIES AND EXCHANGE COMMISSION 17 CFR PARTS 240 and 249b [Release No. 34-67716; File No. S7-40-10] RIN 3235-AK84 CONFLICT MINERALS

The term “adjoining country” is defined in Section 1502(e)(1) of the Act as a country that shares an internationally recognized border with the DRC, which presently includes Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. – SECURITIES AND EXCHANGE COMMISSION 17 CFR PARTS 240 and 249b [Release No. 34-67716; File No. S7-40-10] RIN 3235-AK84 CONFLICT MINERALS

Appendix 2

Quality Code Quality Code Description
Q-G10 Regardless of whether or not your company is listed on a U.S. Stock Exchange and subject to U.S. Securities and Exchange Commission (SEC) regulations, all components and/or materials supplied to BittWare containing “conflict minerals” as defined in section 1502e(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act within 17 CFR Parts 240 and 249b must meet all reporting requirements and be disclosed annually on or before established dates in accordance with this U.S. law.  These requirements flow down from BittWare customers who are subject to SEC regulations.
Q-G11 It is preferred that all materials and components supplied to BittWare be “DRC conflict free” in that they do not contain minerals that directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.
Q-G12 It is strongly preferred for BittWare suppliers to report conflict minerals through the EICC/GeSI Template. This standard reporting mechanism will facilitate data roll-up and consolidation by BittWare’s customers.
Q-G13 BittWare prefers all applicable BittWare suppliers to only use certified smelters such as Conflict Free Smelter Program (CFSI), London Bullion Market (LBMA), Tin Industry – Conflict Minerals Council (TI-CMC)
Q-G14 BittWare requires suppliers to flow down our conflict minerals requirements as stated in quality Codes Q-G10, Q-G11, and Q-G12 through their applicable supply chains, and strongly suggests their suppliers use certified smelters such as Conflict Free Smelter Program (CFSI), London Bullion Market (LBMA), Responsible Jewelry Council (RJC), Tin Industry – Conflict Minerals Council (TI-CMC) or equivalents, or the Responsible Jewelry Council (RJC)

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