In 2012, the Securities and Exchange Commission adopted rules implementing the conflict minerals provisions of the Dodd-Frank Act (the “Conflict Minerals Rules”). This requires public companies to annually disclose information about whether the products they manufacture or contract to manufacture, for which 3TG Minerals are necessary to the functionality or production of those products, contain 3TG Minerals that originated in any of the Covered Countries. If so, information about the source and chain of custody of those 3TG Minerals must also be disclosed.

This Policy applies to Surrette Battery Company Ltd.’s employees who manage relationships with suppliers of products to Surrette Battery Company Ltd.