Conflict Minerals - Statement

The NSG Group has issued the following statement on Conflict Minerals
‘The NSG Group and its subsidiaries support the aims and objectives of the recent US legislation on the supply of Conflict Minerals.

The NSG Group will not, for humanitarian reasons, use raw materials such as tin, tungsten, gold or tantalum mined in the Democratic Republic of Congo or neighboring countries experiencing armed conflict.

If we discover the use of such conflict minerals in any material, parts or components we procure, we will forthwith cease such procurement.’

Detail

We are however aware that the implementing regulations to be issued by the U.S. Securities and Exchange Commission, have not yet been finalized, and many questions remain of what requirements will ultimately be adopted. http://www.sec.gov/index.htm.

In particular there needs to be clarity over the definition of the term ‘derivatives’ in the proposed legislation since this could cover a huge range of materials so far down the supply chain as to make the monitoring and tracing of these materials impossible. We are aware that the OECD Guidelines recognize this issue and do attempt to clarify this position; however the U.S. regulation does not seem to have clarified this point.

Within the scope of our approach we have included conflict minerals and the refined metals extracted from those minerals. Chemical compounds, or formulated products which may include compounds of those metals are assumed excluded from scope with the exception of solder. On this basis we are attempting to identify smelters and refiners within our supply chain and to focus our controls on those parties.

We are working with our suppliers to determine which of our purchased parts/assemblies incorporate metals which derive from the relevant minerals.

Within the scope outlined, the NSG Group and subsidiaries do not purchase or use the Conflict Minerals columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); or wolframite (the metal ore from which tungsten is extracted).

NSG does purchase refined tin, gold, tungsten wire, tungsten metal components and tungsten frit. These purchases are made from the wholesale market and historically there has been no record to confirm the smelter source of such wholesale products. Systems are in place within NSG Procurement to document, assess and review suppliers under our Sustainability Program and this system is being revised to incorporate the additional requirements of this new regulation. Existing suppliers have been notified of our position and of our requirement to comply with this regulation once it is finally in place.

In addition future contracts for the purchase of these materials will stipulate compliance with this regulation.

Our existing procurement procedures are being revised to ensure traceability of these materials goes back down the supply chain to the smelter. The aim is to ensure that only compliant smelters or recycled material ‘DRC conflict free’ are used in products that we procure.

In addition we are aware that solder alloys contain tin and these are being included in our program. Where we purchase assemblies or other components that already contain solder or tin wire we are attempting to identify these but such identification along the supply chain is not yet complete.