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Conflict Minerals - Statement

The NSG Group has issued the following statement on Conflict Minerals

‘NSG Group and its subsidiaries support the aims and objectives of the US legislation on the supply of Conflict Minerals.

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

If we discover the use of such conflict minerals in any material, parts or components we procure, we will implement an urgent action plan to eliminate the use of such materials.’

Detail

Within the scope of our approach we have included conflict minerals and the refined metals extracted from those minerals that are necessary for the functionality of products we produced or are necessary to the production of our products and result in trace amounts remaining in the product. 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 that derive from the relevant minerals.

NSG Group 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. Under our Sustainability Program, processes are already in place within our Procurement function to document, assess and review suppliers, and these are 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 processes are being revised to enhance the traceability of these materials as far down the supply chain as practicable. 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.