Conflict Minerals Overview

The mining of certain minerals in the Democratic Republic of Congo (DRC) and the adjoining countries partially contributes to significant human rights abuses and to the financing of violent conflicts in this region. In 2010, U.S. Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Section 1502 of the Dodd-Frank Act and the final rules adopted by the U.S. Securities and Exchange Commission (SEC) require companies who file reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain "conflict minerals" that are "necessary to the functionality or production" of those products. The Dodd-Frank Act and the SEC define "conflict minerals" as tantalum, tin, tungsten (and the ores from which they originate) and gold, regardless of where they are sourced, processed or sold.

Nichol McKay would fall within the guidance of a “Small Company” for reporting purposes and additionally does not file reports with the SEC and therefore has no legislative obligations to comply with the conflict minerals requirements covered in Section 1502 of the Dodd-Frank Act. At the same time we recognise the SEC final rule for Section 1502 mandates our direct and indirect customers to undertake due diligence across their global supply chains and we will provide an appropriate level of support to help them in their reporting obligations.

Conflict Minerals Statement

Nichol McKay endeavours to not purchase any material that contains "conflict minerals" which directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. We apply reasonable due diligence appropriate to our “Small Company” status to understand if "conflict minerals" are being used in the products supplied to us and to ask our supply chain to confirm this. Due to the range of products we provide to our customers and the relative complexity of the corresponding supply chains this will be a challenging and ongoing process.

It is the objective of Nichol McKay to source its materials from globally known producers who can assure Conflict Minerals compliance. We endeavour to contact our direct suppliers of “at risk” commodities to increase the transparency of the materials they provide to Nichol McKay. We will continue to work closely with customers, suppliers and other stakeholders regarding good practices and feasible solutions.