Conflict Minerals Policy

On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) adopted regulations under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act to enforce disclosure and reporting obligations on covered issuers regarding the use of conflict minerals which are necessary to the functionality or production of a product they manufacture or contract to manufacture.

The regulations enforce reporting and disclosure obligations on all publicly traded companies which file reports with the SEC under Section 13(a) or Section 15(d) of the Exchange Act. This includes domestic companies, foreign private issuers and smaller reporting companies to the extent that conflict minerals are necessary to the functionality or production of a product, or components thereof, that they manufacture or contract to manufacture. It covers issuers, such as automobile manufacturers that manufacture a product by assembling it out of materials, substances or components that are not in raw material form. Regardless of their place of extraction, are deemed conflict minerals gold, columbite-tantalite, cassiterite and wolframite, including their derivatives, respectively tantalum, tin and tungsten.

We are currently requesting our suppliers to submit:

• A completed EICC-GeSI Conflict Mineral Reporting Template
• Official recognition that the product they supply to Captive Fastener Corp does not contain any Conflict Minerals from the Democratic Republic of the Congo and adjoining countries. If products supplied to Captive Fastener do contain these minerals, the minerals must originate outside the DRC, come from scrap or recycled sources, or be supplied from smelters that have been validated by an independent private sector party to be conflict-free. Certified conflict-free smelters are validated as compliant to the EICC (Electronic Industry Citizenship Coalition) conflict free smelter (CFS) protocol using the CFS Compliant Smelter List

In the event Captive Fastener determines that a supplier’s efforts to comply with this Policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Captive Fastener reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.

Although Captive Fastener Corporation is not a publicly traded company, we intend to comply with the rules as part of our commitment to our customer and our community. Captive Fastener is committed to taking all steps to comply with the legislation and in 2011 initiated an ongoing due diligence effort to gather from its supply chain information concerning the country of origin of potential conflict minerals in the supply chain.

Captive Fastener Corp expects its suppliers to commit to the EICC Code of Conduct which includes a provision related to the responsible sourcing of minerals. Pursuant to that Code of Conduct, suppliers must have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture are conflict free. Captive Fastener expects suppliers to establish their own due diligence program to ensure conflict-free supply chains.