Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly-traded companies subject to SEC regulation to report the presence of certain “conflict materials” in their products that originate from the Democratic Republic of the Congo (DRC) or adjoining countries. The term “conflict minerals” refer to columbite-tantalite, cassiterite, wolframite, and gold, or derivatives which are limited to tantalum, tin, tungsten, and gold (3TGs). This legislation was based on concerns that proceeds from some mining operations in this area have been used to fund human rights abuses including child labor, violence and terror. BGM Fastener Co., Inc. (Hereafter "BGM") supports the humanitarian goals of conflict minerals legislation. However, BGM is not a publicly-traded company, and not subject to SEC regulation, and is therefore not subject to conflict minerals reporting requirements.

Even though BGM is not subject to this legislation, many of our customers are. BGM is committed to maintining our ethical business culture & working with our customers to help them comply with their conflict minerals reporting requirements. BGM has exercised due diligence to ensure all supplied material is free from conflict minerals:

• We have added a Democratic Republic of the Congo Conflict Minerals Purchasing Policy (REF internal procedure DI006).
• We then sampled our AVL of all Non-MRO suppliers and found all manufactures and suppliers are either:
  1. In compliance with Conflict Free Mineral requirements -or-
  2. Do not supply BGM with products that contain these minerals.
• No Cobalt, or 3TGS are intentionally added as part of any production process.

BGM will continue to exercise due diligence to ensure all supplied material is free from conflict mineral and in compliance with section 1502. A PO clause was added to all Non-MRO pruchase orders requiring material(s) that contain tantalum, tin, tungsten, and gold (3TGs) to be conflict free per § 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Any new product line or item(s) will be checked for conflict minerals compliance to this policy & § 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. If we discover that products procured contain conflict materials we will take steps in conjunction with the supplier to ensure the material is properly sourced from conflict free smelter/sources. If the supplier refuses to provide BGM with the necessary information, or refuses to work towards remediation, BGM may issue a corrective action &/or suspend or remove the business from our AVL and we will take appropriate actions to transition toward a conflict free status.

For any questions about this policy or to provide feedback, please contact BGM by using the “Contact Us” form on the website: www.bgmfastener.com