Conflict Mineral Responsible Sourcing Statement

January 2021

Conflict Mineral and Cobalt Sourcing Statement

Castlebar Corporation is a responsible participant in the tungsten carbide industry that strives to use industry standards and best practices to support our customers and the communities where we operate. We are committed to the responsible sourcing of Conflict Minerals and cobalt.

Federal law defines “Conflict Minerals” as (i) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively known as the “Covered Countries”). Cobalt is another element that is mined and processed in Conflict Affected and High-Risk Areas (CAHRA). Of these minerals, only tungsten and cobalt are present in the materials used to manufacture our products.

We will avoid knowingly using Conflict Minerals and cobalt from sources that support or fund conflict, inhumane treatment, including human trafficking, slavery, forced labor, child labor, torture, and war crimes in the Covered Countries and known Conflict Affected and High-Risk Areas (CAHRA). This policy is not intended to completely ban procurement of Conflict Minerals, cobalt, or other products from CAHRA’s or the Covered Countries, but to promote sourcing from responsible sources in the regions.

Castlebar supports and expects its suppliers to comply with the Responsible Business Alliance (RBA) Code of Conduct, the Responsible Minerals Initiative (RMI), the OECD Due Diligence Guidance Annex II Model Policy, and to work closely with ITIA to purchase raw materials from compliant miners and smelters. Although Castlebar does not directly source Conflict Minerals or cobalt, we request each of our suppliers to, at a minimum, conduct annual due diligence on their own supply chain so they can source responsibly and not knowingly provide Castlebar with materials that contain Conflict Minerals or cobalt from irresponsible sources.

Castlebar has conducted a survey of our key suppliers to determine the use of any Conflict Minerals in the materials they supply to us. The results of that survey demonstrates that our key suppliers do not use Conflict Minerals in the materials they supply us. Consequently, we certify to the best of our knowledge that our products do not contain, nor have been produced, using Conflict Minerals.

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and the Securities and Exchange Commission Rules adopted in connection therewith, require certain corporations to report the use of Conflict Minerals. As a privately held corporation, Castlebar is not subject to the SEC disclosure requirements of the Dodd-Frank Act, however, to support our customers worldwide and our commitment to environmental compliance, we are committed to ensuring our suppliers are conflict free.