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Conflict Mineral Policy

Acumen Components Group is working toward the elimination of conflict minerals (Tantalum, Tin, Tungsten and gold) that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo (“DRC”) or adjoining countries from its supply chain. Acumen’s ultimate goal is to have a supply chain that consists of material that is DRC Conflict Free.

As part of this policy, Acumen will:

  1. Exercise due diligence as specified in the Organisation for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (“OECD Framework”) and related 3T and gold supplements.
  2. Source only from independently validated smelters.
  3. Support and participate in industry groups such as the Responsible Minerals Initiative (RMI) in order to promote industry-wide solutions.
  4. Commit to transparency by providing necessary reports and information to the SEC and customers.

Acumen expects its first tier suppliers of 3TG (“In-scope Suppliers”) to:

  1. Have conflict mineral policy in place, exercise due diligence, and obtain CMRTs (IPC-1755) from their suppliers.
  2. Have a supply chain of only independently validated smelters that are certified as Conflict Free.
  3. Provide the necessary and most up to date industry standard declarations upon request.

In-scope Suppliers who are not in compliance with these requirements will be reviewed in order for us to determine the extent to which Acumen will continue to do business with those Suppliers. Acumen Components Group will terminate business with any In-scope Supplier if we determine that the Supplier’s sourcing of 3TG are directly or indirectly financing armed groups that are perpetrators of serious human right abuses.