Conflict Mineral Policy

 

There is an awareness of violence and human rights violations in the mining of certain minerals from an area described as the “Conflict Region”, located in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 directed the U.S. Securities and Exchange Commission (“SEC”) to adopt rules to implement disclosure requirements related to these “conflict minerals.” These rules apply to manufacturers who file periodic reports with the SEC and who manufacture or contract to manufacture products containing “conflict minerals” that are “necessary to the functionality or production” of those products. These manufacturers are required to make inquiries as to the origin of these “conflict minerals” and file a report with the SEC to describe and disclose the results of their inquiries.

Dataram supports the aims and objectives of the US legislation on the supply of Conflict Minerals, and actively monitors its supply chain to assure that conflict minerals* directly or indirectly supporting civil violence or human rights abuses in the Democratic Republic of the Congo or adjoining countries are not used in the manufacture of Dataram products. Dataram does not directly procure “conflict minerals”, nor does it knowingly procure any material from its suppliers necessary for the manufacturing of our product line containing those “conflict minerals” that originates from the Conflict Region unless they originate from mines or smelters that are certified as “conflict free”.

Dataram’s conflict mineral supply chain monitoring program is consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and integrates tools developed by the Electronics Industry Citizenship Coalition (EICC) - Global e-Sustainability Initiative (GeSI) Conflict-Free Sourcing Initiative.

To learn more about the EICC- GeSI Conflict-Free Sourcing Initiative visit http://www.conflictfreesmelter.org/cfshome.htm/

*Conflict minerals are those minerals regulated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Conflict minerals include columbite-tantalite, also known as coltan (and its derivative tantalum); cassiterite (and its derivative tin); wolframite (and its derivative tungsten); and gold; and defined as such regardless of where they are sourced, processed or sold. The intent of these requirements in the Dodd-Frank Act is to further the humanitarian goal of ending violent conflict in the Democratic Republic of the Congo (DRC) and in surrounding countries, which has been partially financed by the exploitation and trade of conflict minerals.

Approved by:

/s/ David A. Moylan
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David A. Moylan
Chairman and CEO

 

Dataram's Conflict Minerals Policy