Conflict Minerals Policy

Gadjets Conflict Minerals Policy

Gadjets is committed to ethical business practices and protecting human rights. This includes supporting the goal of ending armed conflicts in the Democratic Republic of the Congo and its adjoining countries (DRC Countries). These conflicts are partially funded by the exploitation of “conflict minerals” sourced from these regions.

Verification Approach

To comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act's Section 1502, Gadjets created a team to develop due diligence measures. These measures aim to determine the source of conflict minerals used in products that Gadjets manufactures or contracts to manufacture (Affected Products).

Gadjets’ verification process includes:

• Requiring direct suppliers to certify that Affected Products sold to Gadjets only contain conflict minerals that do not originate from the DRC Countries and are sourced from smelters or refiners validated as compliant with Conflict-Free Sourcing (CFS) protocol.

• Requiring direct suppliers of Affected Products to verify the accuracy of a completed standard conflict minerals certification, based on the industry-accepted Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template.

• Establishing and implementing a company policy to downgrade the internal supplier rating of any direct supplier of Affected Products that fail to comply with Gadjets’ purchase order terms regarding conflict minerals or that are uncooperative in Gadjets’ due diligence efforts.

Templates

Upon request, Gadjets will provide customers with copies of its standard conflict minerals reporting template, based on the industry-accepted template. Any conflict minerals declarations made by Gadjets apply only to products sold to that customer in the six months prior to the declaration date, or during another specified time period.

Determinations and Assumptions

Based on SEC guidance, Gadjets determined that the Conflict Minerals Regulations do not apply to commercial-off-the-shelf (COTS) products, reconfigurations of COTS products, or Gadjets Assemblies containing only COTS components. This is because Gadjets does not have significant control over the materials in these products. For the same reason, the regulations also don't apply to plating, fasteners, screws or other supporting hardware in Gadjets Assemblies (Gadjets Hardware). Therefore, conflict minerals in these products are excluded from Gadjets' conflict minerals declarations and the definition of “Affected Products”.

These declarations are based on:

• Gadjets’ purchase order terms with its direct suppliers, which require that conflict minerals in affected products do not originate from the DRC Countries and are sourced from CFS-compliant smelters or refiners.

• The responsiveness of Gadjets’ suppliers to Gadjets’ standard conflict minerals supplier certification.

• The information provided by Gadjets’ suppliers, without independent investigation by Gadjets, for any smelter list completed by Gadjets.