Synaccess Conflict Minerals/Materials Policy

1. Compliance with Regulations: We are dedicated to complying with all applicable laws, regulations, and international standards related to responsible mineral and material sourcing. This includes regulations such as the Dodd-Frank Act Section 1502 in the United States and the EU Conflict Minerals Regulation.
2. Responsible Supply Chain Due Diligence: We will implement and maintain a robust due diligence process to identify and assess the presence and origin of conflict minerals and other potentially high-risk materials in our supply chain. This includes engaging with our suppliers to obtain necessary information and promoting transparency and traceability.
3. Supplier Engagement: We will actively engage with our suppliers to promote responsible sourcing practices. We expect our suppliers to adhere to our Ethical Guidelines, which prohibit the sourcing of materials from conflict areas. We will communicate our expectations and requirements to our suppliers and require them to trace the complex supply chain of metals used in our products to their source.
4. Risk Mitigation: We will assess and mitigate the risks associated with conflict minerals and other potentially high-risk materials in our supply chain. This includes working closely with our suppliers to identify and address any potential risks, supporting responsible sourcing initiatives, and promoting the use of conflict-free and responsibly sourced materials.
5. Continuous Improvement: We are committed to continuously improving our responsible sourcing practices. We will regularly review and update our policies, procedures, and supplier requirements to align with evolving industry standards and best practices.
6. Stakeholder Engagement: We will engage with relevant stakeholders, including customers, industry associations, and civil society organizations, to promote responsible sourcing, share best practices, and contribute to industry-wide initiatives.
7. Transparency and Communication: We are committed to transparency in our responsible sourcing efforts. We will communicate our commitment to responsible sourcing and provide relevant information to stakeholders, including customers, employees, and the general public. We will respond to inquiries related to our conflict minerals/materials practices and share our progress in achieving responsible sourcing goals.
8. Employee Awareness and Training: We will provide our employees with the necessary awareness and training to understand and uphold our Conflict Minerals/Materials Policy. We will foster a culture of responsible sourcing throughout our organization.
9. Collaboration and Industry Leadership: As Synaccess, we will actively collaborate with industry peers, industry associations, and other stakeholders to collectively address responsible sourcing challenges. We strive to be a leader in responsible sourcing within our sector and actively support industry-wide initiatives. We will contribute our expertise, knowledge, and resources to promote responsible mineral sourcing practices and drive positive change in the industry.
10. Audit and Verification: We will conduct periodic audits or engage independent third-party auditors to verify the compliance of our supply chain with responsible sourcing requirements. We will take appropriate actions to address any identified non-compliance.

Synaccess and its suppliers do not knowingly use any virgin gold or tin obtained from conflict mines. We are regularly monitoring our suppliers to ensure that no material obtained under conditions of armed conflict and human rights abuses is used in the production of our products. The only metals we use in large quantities are tin and gold, primarily for the plating of terminals. We do not directly purchase any of the materials listed above. Thus, we have taken steps to ensure our suppliers of finished surfaces also do not purchase conflict materials. We are in constant contact with these suppliers and require them to trace the complex supply chain of these metals to their source. They have to confirm that metals are only sourced from internationally known producers, traders, refiners, and bullion banks with a proven track record in the metals market. If any evidence is found that metals could originate from conflict areas, they will immediately have to undertake corrective actions.

This Conflict Minerals/Materials Policy will guide our decisions and actions as Synaccess works towards ensuring responsible sourcing practices, mitigating risks, and promoting a responsible and sustainable supply chain.