Conflict Minerals Policy

1. Purpose & Scope

This Policy defines how Benegon Enterprises LLC identifies, assesses, and manages risks associated with “Conflict Minerals” in our supply chain. It applies to all hardware, components, sub-assemblies, and materials supplied to or on behalf of the Company, whether for production, service, or resale.

2. Standards & Definitions

• UN Guiding Principles on Business and Human Rights (UNGPs)
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (including supplements)
• U.S. Dodd–Frank Act §1502 and SEC Rule (Form SD / Conflict Minerals Report, as applicable)
• EU Conflict Minerals Regulation (Reg. (EU) 2017/821), as applicable to upstream importers

Definitions. “Conflict Minerals” or “3TG” refers to tin, tantalum, tungsten, and gold. “CAHRAs” are conflict-affected and high-risk areas as defined by the OECD Guidance.

3. Covered Minerals & Geographic Focus

This Policy covers 3TG regardless of origin. Where legally required (e.g., U.S. SEC), special attention is given to minerals originating from the Democratic Republic of the Congo (DRC) and adjoining countries. We also evaluate other CAHRAs globally consistent with the OECD Guidance.

4. Policy Statement

• We do not knowingly procure 3TG that finance or benefit armed groups or contribute to serious human rights abuses.
• We expect suppliers to source 3TG from smelters and refiners that are conformant with recognized audit programs (e.g., RMI’s Responsible Minerals Assurance Process, “RMAP”), or otherwise demonstrably responsible.
• We will conduct and continuously improve due diligence consistent with the OECD Guidance and applicable laws.

5. Supplier Requirements

• Maintain a documented 3TG due diligence program aligned with the OECD Guidance.
• Provide an up-to-date Conflict Minerals Reporting Template (CMRT) upon request and at least annually; extend surveys to sub-suppliers.
• Disclose complete smelter/refiner (SOR) lists with RMAP status and country-of-origin information when available.
• Implement policies prohibiting serious human rights abuses, bribery, and money laundering related to mineral sourcing.
• Notify Benegon Enterprises LLC within 10 business days of identifying a 3TG risk in their supply chain and cooperate on remediation.
• Permit reasonable audits or provide independent third-party audit reports on request.
• Flow down equivalent requirements to their suppliers.

6. Due Diligence Framework (OECD)

1. Establish Strong Company Management Systems
   • Adopt this Policy; integrate into contracts, supplier codes, and purchasing terms.
   • Designate a Conflict Minerals Program Lead and cross-functional team (procurement, compliance, engineering).
   • Maintain grievance channels (see Section 13).
2. Identify and Assess Risk in the Supply Chain
   • Use CMRTs and other data to map SORs and countries of origin.
   • Screen against RMAP conformance and CAHRA indicators.
3. Design and Implement a Risk Response Strategy
   • Engage suppliers with corrective action plans, milestones, and deadlines.
   • Prioritize risk mitigation over disengagement where effective and appropriate.
4. Carry Out Independent Third-Party Audits of SORs
   • Leverage industry initiatives (e.g., RMI) and require suppliers to favor conformant SORs.
5. Report Annually on Supply Chain Due Diligence
   • Publish a summary statement and, where applicable, file SEC Form SD and a Conflict Minerals Report.

7. Risk Assessment, Mitigation & Disengagement

Where a supplier is linked to non-conformant SORs, insufficient transparency, or other CAHRA risks, we may:

• Request enhanced disclosures and data validation.
• Require migration to conformant or actively participating SORs within defined timelines.
• Implement corrective action plans; suspend new business if milestones are missed.
• Disengage if risks cannot be mitigated in a reasonable timeframe.

8. Smelters/Refiners (RMAP & Verification)

• We encourage sourcing through RMAP-conformant or actively audited SORs.
• Suppliers must maintain traceability to identified SORs and provide updated lists upon material changes.
• Engineering and procurement teams will consider SOR status in sourcing decisions.

9. Reporting, Declarations & Transparency

• Provide customers with CMRTs, SOR lists, and policy attestations upon request.
• If legally required, Benegon Enterprises LLC will file SEC Form SD and a Conflict Minerals Report, and/or publish annual summaries consistent with the OECD Guidance and applicable regulations (e.g., EU 2017/821).
• We will publish this Policy and a yearly due diligence statement on our website.

10. Record Retention

We retain CMRTs, SOR lists, supplier correspondence, assessments, and related due diligence records for at least 5 years or longer where required by law or contract.

11. Governance & Accountability

• Board/Oversight: Reviews program objectives and risk posture periodically.
• Executives: Ensure adequate resources and integration into sourcing strategy.
• Conflict Minerals Program Lead: Owns due diligence, supplier engagement, and reporting.
• Procurement: Embeds requirements in contracts and monitors supplier performance.
• Engineering/Quality: Supports part/SOR mapping and alternates planning.

12. Implementation Timeline

• Q1 (initial) Publish policy; designate program lead; update contracts and PO Ts&Cs.
• Q2 CMRT outreach to suppliers; initial SOR mapping; risk screening.
• Q3 Corrective actions; supplier training; align to conformant SORs where feasible.
• Annual Refresh CMRTs; update public statement; file regulatory reports as required.