Conflict Minerals Policy

Conflict Minerals Policy

Updated February 2019

Crystal Group, Inc. (“Crystal Group”) has adopted the following Conflict Minerals Policy Statement.

In 2012, the Securities and Exchange Commission (“SEC”) adopted final rules under Section 1502 of Dodd-Frank Wall Street Reform and Consumer Protection Act relating to “Conflict Minerals.” Section 1502 of the Dodd-Frank Act was adopted because Conflict Minerals originating from the Democratic Republic of Congo (the “DRC”) and adjoining countries (the “Covered Countries”) may directly or indirectly be funding or benefitting illegal armed groups committing human rights atrocities in that region. These Conflict Minerals from the DRC and the Covered Countries – tantalum, tin, tungsten and gold – are making their way into the supply chain of companies in the United States of America.

Under these Conflict Minerals rules and regulations, publicly-traded companies must report annually to the SEC if they use any Conflict Minerals from the DRC and the Covered Countries in the products they manufacture or contract to manufacture if the Conflict Minerals are necessary to the functionality or production of a product.

While Crystal Group does not source any Conflict Minerals from the DRC and the Covered Countries directly, such Conflict Materials may exist in the products, materials and components that Crystal Group sources from its suppliers. Crystal Group is committed to working with its suppliers to responsibly source the materials and components Crystal Group uses in its products.

To facilitate compliance with these Conflict Minerals rules, Crystal Group conducts inquiries of its supply chain in an effort to determine the source of any Conflict Minerals from the DRC and the Covered Countries and to assist in the reporting of the results of its inquiries. In order for Crystal Group to accomplish this, Crystal Group requires its relevant suppliers to respond to information requests regarding the uses and sources of Conflict Minerals from the DRC and the Covered Countries in their products, including information about minerals that are recycled or scrapped.

In addition, Crystal Group expects the following of its suppliers:

To assist in compliance with the SEC rules and regulations relating to Conflict Minerals and to provide all necessary representations, declarations or certifications;

To undertake reasonable due diligence within their supply chain to determine the source and chain of custody of their Conflict Minerals, including developing policies and systems to avoid the use of Conflict Minerals from the DRC and the Covered Countries; and

To pass these requirements along to their suppliers through the supply chain and require them to do the same.

Crystal Group’s relationships with its suppliers are evaluated on an ongoing basis to ensure continued compliance with this Policy Statement. Crystal Group reserves the right to request additional documentation from its suppliers regarding the source of any Conflict Minerals included in its products, materials and components. Suppliers that do not comply with these requirements will be reviewed by Crystal Group’s buyers for future business.