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CMR

Background

In 2010, the United States (U.S.) enacted legislation (Dodd-Frank Act) requiring the Securities and Exchange Commission (SEC) listed companies to report on their use of conflict minerals sourced from the Democratic Republic of the Congo (DRC) and adjoining countries.

HLDS Policy for Conflict Minerals

It is HLDS’s policy to take due-diligence measures in procurement activities to avoid sourcing conflict minerals (tin, tantalum, tungsten and gold) which finance or benefit armed groups abusing human rights in the DRC or adjoining countries. The HLDS procurement division is committed to building a sustainable supply chain while avoiding procurement of conflict minerals. This does not mean that HLDS will not procure any materials or parts from DRC or adjoining countries at all, but, rather HLDS will continue to procure minerals that are lawfully permitted.

Support from Suppliers

HLDS is committed to enhance the transparency of supply chains and to implement responsible procurement activities of materials and parts. HLDS encourages our suppliers to conduct due diligence with their suppliers and expect to support HLDS’ policy on CMR.

HLDS will use EICC-GeSI developed tool to carry out due diligence with relevant suppliers consistent with the Dodd-Frank Act and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Currently HLDS is implementing an improved process for excluding conflict minerals from supply chain and if related program is developed and established (eg, expanding the list of CFS currently under way by EICC-GeSI), HLDS expects suppliers to implement such program. HLDS will strive and continue to work together to build a stable and conflict-free supply chain.

Thank you.