Thermoelectric Cooling Solutions

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Conflict Minerals Policy (the “Policy”)

RMT Limited and each of its subsidiaries (hereinafter the “Company”) is committed to corporate social responsibility and sourcing materials for its products in a socially and environmentally responsible way.

Policy

As part of the Company’s commitment to corporate social responsibility, the Company’s goal is to use Conflict Minerals (as mentioned below) that do not directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or adjoining countries (hereinafter the “DRC”). The Company intends to work with suppliers who comply with the Electronic Industry Citizenship Coalition (“EICC”) Code of Conduct and conduct their business in alignment with the Company’s supply chain responsibility expectations. Conflict Minerals are defined as gold and tin are used in manufacturing thermoelectric coolers as the Company’s products. The Company is intended to make all efforts to determine the source and chain of custody of Conflict Minerals that are necessary to the functionality or production of its products and to report publicly on an annual basis regarding its use of Conflict Minerals from the DRC in the Company’s products. The Company has initiated and is in the process of refining its due diligence program for Conflict Minerals consistent with the framework promulgated by the Organization for Economic Cooperation and Development (“OECD”) and its “Due diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and evaluating its internal controls for Control Minerals, and encourages its suppliers to do the same with their respective suppliers.

The Company intends:     

·         In cooperation with its suppliers provide due diligence information confirming that any Conflict Minerals in its supply chain are “conflict free”;

·         cooperate with its suppliers to enable products that are DRC conflict free;

·         encourage its suppliers to purchase materials from smelters who are listed on the Conflict-Free Smelter Program Compliant Smelter List and have been certified as conflict-free by an independent auditor through the Conflict-Free Smelter Program administered by Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”);

·         Make available reports on its progress to concerned parties and the public.

 

Questions and information exchange:  

Concerns about, and violations of this Policy should be reported to the Company’s management:

Mikhail Volkov  

E-mail: mikhail.volkov@rmtltd.ru

Phone: +7-499-678-208

November 2016.