Quality, Safety and Environment Statement

Conflict Minerals Policy


Conflict Minerals Policy

Netcomm fully supports the goals and objectives of Section 1502 (“Section 1502”) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), which aims to prevent the use of certain “Conflict Minerals” that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or adjoining countries (as defined in the Act). “Conflict Minerals” include columbite-tantalite (coltan) (i.e. tantalum), cassiterite (i.e. tin), gold, wolframite (i.e. tungsten) or their derivatives and could expand to include other minerals or their derivatives, as determined by the U.S. Secretary of State.

NetComm is committed to complying with the reporting obligations required under Section 1502 of the Act, as well as the related rules and regulations issued by the U.S. Securities and Exchange Commission, including the requirement that NetComm conduct inquiries into the source of any Conflict Minerals included in its products. NetComm also intends to adopt the Electronic Industry Citizenship Coalition Due Diligence reporting process and obtain chain of custody declarations from suppliers to ensure transparency and corporate social responsibility throughout the supply chain.

NetComm suppliers are required to acknowledge NetComm's requirements regarding Conflict Minerals and responsible sourcing and are also responsible for ensuring these same conditions are met by their suppliers.

Suppliers will be required to declare that all products supplied either do not contain tantalum, tin, tungsten or gold that are necessary to their production or functionality or, if they do contain these minerals, that they originate from non-conflict areas or from smelters that have been validated by an independent private sector party to be conflict free.

NetComm will evaluate its relationships with its suppliers on an ongoing basis to ensure continued compliance with this policy. NetComm reserves the right to request additional documentation from its suppliers regarding the source of any Conflict Minerals included in its products. In addition, suppliers must maintain and provide to NetComm upon request traceability data for a minimum of five years. Wherever possible, NetComm will seek alternative sources if any supplier fails to comply with these requirements.