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  Conflict Minerals Policy
 

POLICY

Mini-Circuits is committed to the protection of human rights and the promotion of high ethical business standards. Accordingly, Mini-Circuits supports the humanitarian goal of ending the armed conflicts in the Democratic Republic of the Congo and its adjoining countries (collectively, the “DRC Countries”), which are partially financed by the exploitation of “conflict minerals” (as defined in 17 C.F.R. §240.13p-1(d)(3)) sourced from DRC Countries.   

VERIFICATION APPROACH

Towards that end, and in consideration of the disclosure requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (P.L. 111-203, §1502), Mini-Circuits set up a multi-functional team in early 2013 in order to develop an approach to implementation of due diligence measures designed to determine the source of conflict minerals necessary to the production or functionality of products manufactured by Mini-Circuits or which Mini-Circuits contracts to manufacture (collectively, “Affected Products”).

Mini-Circuits verification process consists of:

a) requiring Mini-Circuits’ direct suppliers to certify that components of Affected Products sold to Mini-Circuits either (i) are “DRC conflict-free” (as defined in 17 C.F.R. §240.13p-1(d)(4)), or (ii) contain only conflict minerals sourced from smelters validated as compliant to CFS protocol using the CFS Compliant Smelter List;

 

b) requesting Mini-Circuits’ direct suppliers of components of Affected Products verify the accuracy of a completed standard conflict minerals reporting template, which is based on the industry-accepted Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template, and the responsiveness or non-responsiveness of the direct suppliers in accordance with such requests; and

c) the establishment and implementation of a company policy dictating that Mini-Circuits downgrade the internal supplier rating of any of its direct suppliers of components of Affected Parts that fail to comply with Mini-Circuits’ purchase order terms regarding conflict minerals or that otherwise prove uncooperative in Mini-Circuits’ efforts to engage in due diligence of its conflict mineral supply chains.

REPORTS

Mini-Circuits is pleased to provide our customers with a completed Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template. To access click: EICC_CFSI_CMRT4.20.

DECLARATIONS AND DETERMINATIONS

Based on Securities and Exchange Commission Official Release No. 34-67716, Mini-Circuits has determined and assumes that it does not contract to manufacture the commercial-off-the-shelf (“COTS”) components of its parts because Mini-Circuits does not exert sufficient influence over the materials, ingredients or sub-components contained therein.   Accordingly, conflict minerals contained in COTS components of Mini-Circuits parts are excluded from conflict mineral declarations made by Mini-Circuits.

In addition, these declarations are based on and made subject to: (a) Mini-Circuits’ purchase order term with its direct suppliers, which requires that all products sold to Mini-Circuits are either (i) ‘DRC conflict-free’ (as defined in 17 C.F.R.§ 240.13p-1(d)(4)), or (ii) contain only conflict minerals sourced from smelters validated as compliant to CFS protocol using the CFS Compliant Smelter List, and the responsiveness or non-responsiveness of the direct suppliers in accordance with such purchase order term; and (b) the responsiveness or non-responsiveness of Mini-Circuits’ suppliers to Mini-Circuits’ standard conflict minerals supplier certification in accordance with such certification, which is based on the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Reporting Template. 

INQUIRIES:

Inquiries concerning conflict minerals should be addressed to:conflictminerals@minicircuits.com