CONFLICT MINERALS POLICY, OCTOBER 2013

This document contains Elcon Precision LLC’s statement regarding the content of Conflict Minerals in our products.
There has been increased awareness of violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region”, which is situated in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries. In August of 2012 The SEC adopted a new rule to require companies to publically disclose their use of conflict minerals.

The new reporting requirements reflect Congressional concern that revenues obtained from mining and transport of “Conflict Minerals” finance the ongoing conflict in the Democratic Republic of Congo (DRC) and surrounding countries and the resulting humanitarian crisis. The legislation requires SEC-registered companies to report annually to the SEC on (a) their worldwide use of “Conflict Minerals” in products they manufacture or contract to manufacture, and (b) the cooperation of their supply chains in identifying the use of “Conflict Minerals”; identifying the country of origin for any tantalum, tin, tungsten, and gold; and determining whether “Conflict Minerals” from the DRC region are “conflict free”.

The Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) have requested that companies undertake reasonable due diligence with their supply chain to assure that specified metals are not being sourced from mines in the Conflict Region, which is controlled by non-government military groups, or unlawful military factions.

Elcon Precision LLC is not a publically traded company and doesn’t need to file reports with the SEC pursuant to Exchange Action Sections 13(a) or 15(d), we support these actions and have obtained, or are in the process of obtaining, information from our current metal suppliers concerning the origin of the metals that are used in the manufacture of our products. Based upon information provided by our suppliers, we do not knowingly use metals derived from the
Conflict Region.

Suppliers are providing written evidence of due diligence documenting that raw materials used to produce gold and tungsten, supplied to or used in the manufacture of our products, do not originate from mining or smelting operations in the Conflict Region. To learn more about the U.S. Legislation and “Conflict Minerals”,” please consult the SEC website: http://www.sec.gov/news/press/2010/2010-245.htm.

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