Max Levy Autograph

Conflict Minerals Policy

In August 2012, the U.S. Securities and Exchange Commission (“SEC”) issued final rules to implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The new rules require manufacturers that are subject to SEC reporting requirements to provide disclosures regarding their use of “conflict minerals.” Conflict minerals are defined as tantalum (derived from columbite-tantalite), tin (derived from cassiterite), tungsten (derived from wolframite) and gold, regardless of where the minerals are sourced, processed or sold. The intent of these requirements is to further the humanitarian goal of ending violent conflict in the Democratic Republic of the Congo (“DRC”) and the adjoining countries.

Max Levy Autograph (MLA) supports this goal and is committed to sourcing materials from companies that share our values regarding respect for human rights, integrity, and environmental responsibility. MLA is committed to complying with requirements of Section 1502 of the Dodd-Frank Act. To this end, affected suppliers to MLA are required to provide materials that are “DRC conflict-free” and must comply with the above regulations, regardless of whether they are directly subject to SEC disclosure requirements. Each affected supplier is required to complete the EICC-GeSI public Conflict Minerals Reporting Template evidencing such supplier’s commitment to providing conflict-free minerals and sourcing only from conflict-free smelters.

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