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Dodd Frank Conflict Mineral Policy

ECD's conflict mineral policy and statement of conformance

Electronic Controls Design, Inc. (ECD) does conform to the Dodd-Frank conflict minerals act section 1502. ECD is exempt from the recording requirements as we are not a publicly traded company and have less than 50 employees. As a service to our customers and our commitment to humanitarian rights, we do require that all of the materials/products that are supplied to or come from ECD conform to the provisions of this act. As such; we have our suppliers sign an affirmation to the compliance with the Conflict Mineral, Dodd-Frank Wall Street Reform Act section 1502, and state that all materials are conflict free.

Our suppliers must state that a reasonable investigation was performed to determine that the materials/products supplied to ECD do not contain conflict minerals from the DRC or are “conflict free” (that is, they do not directly or indirectly finance armed groups through mining or mineral trading in the DRC region). If a supplier to ECD cannot determine the origin or source of materials defined as conflict minerals, which include tantalum, tin, tungsten, and gold used in our product, they are considered to be from an unknown origin. A list of the materials with unknown origin will be supplied to ECD in order for follow up research as outlined by the Organization for Economic Co-operation and Development’s (OECD) due diligence guideline to determine the origin, or to change suppliers.

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