Conflict Minerals Policy Statement

MCAP is committed to sourcing components and materials from companies that share its values regarding human rights, ethics and environmental responsibility. We expect all of our suppliers to abide by the requirements of our Supplier Code of Conduct, which prohibits human rights abuses and unethical practices. We also require all suppliers to comply with applicable legal standards and requirements.

Background

The United States Securities and Exchange Commission (SEC) issued in August 2012, its final rules regarding the ‘Conflict Minerals’ Tantalum, Tin, Tungsten and Gold (3TG) as defined in and required by section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act). As a result, we are now focusing on whether and to what extent the products we use contain Conflict Minerals and whether such Conflict Minerals come from the Democratic Republic of Congo and the adjoining countries named in the Act.

What we do

MCAP supports the goal of ending violence, human rights violations and environmental devastation in the Covered Countries. We are committed to complying with any requirements applicable to our company under the Conflict Minerals Rule.

MCAP will assist its customers in implementing their Conflict Minerals programs. We strive to work cooperatively with our customers and supply chain partners in implementing Conflict Minerals compliance programs.

MCAP requires all of its suppliers to provide us with completed Conflict Minerals declarations using the EICC/GeSI Conflict Minerals Reporting Template. We may reconsider our willingness to partner with suppliers that fail to comply with this Policy.