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Position on conflict minerals

In the United States, the Dodd-Frank Wall Street Reform and Consumer Protection Act, HR 4173, Section 1502 (“Act”) includes provisions directing the Securities and Exchange Commission to promulgate new rules for SEC-reporting companies (both domestic and foreign) that use “conflict minerals” originating in the Democratic Republic of Congo (“DRC”) or adjoining countries, in an attempt to address the violent conflict in the DRC.

The Organization for Economic Cooperation and Development (OECD) has formulated due diligence guidance for responsible mineral supply chain activities related to conflict-affected and high-risk areas (“OECD guidance”).

While no member of the Traxys Group is an SEC-reporting company, we are nevertheless, as a worldwide leader in marketing and sourcing metals, minerals, ores and concentrates, committed to cooperating with our customers and business partners in their compliance with the Act and in furthering the objectives of the OECD guidance.

The Traxys Group will not knowingly purchase material that contains conflict minerals that directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. The Group will take steps to identify and assess risk in the supply chain and will make continued efforts to verify that minerals from the conflict region do not enter our supply chain.

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