Statement on Conflict Minerals

Oliphant Tool Company

Statement on Conflict Minerals

The years of war and human rights violations in the eastern Congo and surrounding areas is of deep concern to peace loving peoples around the world. Of critical concern to us is that profits from the sale of certain metals mined in these areas are fueling this strife and conflict. Oliphant Tool Company is dedicated to supporting human rights and this is reflected in our supply chain guidance policy which ensures that our dollars spent on these minerals do not contribute to this grave problem.

We are committed to ensuring that the tantalum, tungsten and titanium used in our products are sourced with due respect for human rights, the need to avoid contributing to strife and conflict, and the desire to support development through our supply chain practices. But, to ensure that local populations in these combat zones are not subject to a de facto embargo that would impose a serious adverse impact on their living condition, we may source minerals from conflict areas if we are assured that they are sourced in accordance with existing international standards.

We are using the OECD Due Diligence Guidance for meeting the sourcing expectations of those customers along with regulators and other stakeholders. The SEC has also stated that OECD Guidance may be used as a framework for purposes of satisfying the reporting requirements under U.S. law, including the steps to be taken to determine the source and chain of custody of the conflict minerals.

Thus, our task is to identify smelters in our supply chain, a fundamental step in determining the source and chain of custody of the tungsten, tantalum and titanium used in the manufacture of our products.

To this end, we monitor our suppliers to ensure they only use smelters identified as compliant via the Conflict Free Smelter Program. The CFSP is the most reliable source of information regarding responsible sourcing of conflict minerals. We then pass on that information through EICC and GeSI reporting templates up the supply chain to our own valued customers.

Moreover, we require, as part of our purchase order agreements, that our suppliers adopt a broader policy on the responsible sourcing of 3TG minerals, so that even if at risk minerals are not used in the products we purchase, there is less of a chance they may be in products others purchase.

If you are a customer working on your 1502 SEC compliance, feel free to contact us and we will promptly complete your reporting templates with complete and accurate information about our supply chain.

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