💎Conflict Minerals Policy

BACKGROUND

In 2010, the United States passed provisions regarding 'Conflict Minerals' in conflict-affected areas under the Dodd-Frank Wall Street Consumer Reform and Protection Act (Dodd-Frank Act). The law was enacted due to concerns over the exploitation and illegal trade of minerals known as 3TG, or their derivatives, extracted from the Democratic Republic of Congo (DRC) and neighboring countries in conflict zones. Armed groups engaged in the region's civil war financially benefit from the mining, production, and supply of these minerals, raising serious human rights concerns.

STATEMENT

Conflict or high-risk areas, especially those rich in resources, are prone to human rights violations. This can manifest in various forms, such as child labor, sexual violence, disappearances, and forced displacements. At SW®, our aim is to halt violence and human rights abuses associated with the exploitation of certain minerals. To achieve this, we focus on reducing the funding of armed groups in the Democratic Republic of Congo (DRC) and neighboring countries, which have directly or indirectly contributed to these violations. It is crucial to advocate for the protection of human rights globally and take measures to prevent their violation, especially in conflict zones.

While SW® is not a publicly traded company, our commitment is to completely eliminate conflict minerals and metals from our supply chain. We hope that our suppliers, partners, and associates join our commitment and conduct due diligence in their supply chains to ensure that the minerals used are sourced from conflict-free origins.

We work with our partners to create an ethical and sustainable supply chain that promotes respect for human rights and environmental protection. The elimination of conflict minerals is fundamental to promoting a more just and peaceful world.

BUSINESS COMMITMENT

SW® is committed to conducting all its business operations in compliance with applicable laws, regulations, and international initiatives. We respect human rights and ensure that we do not contribute in any way to conflicts, torture, inhumane treatment, forced labor, child exploitation, or other violations of international human rights, crimes against humanity, or genocides.

Furthermore, we encourage our suppliers, partners, and associates to adopt socially responsible policies that ensure the minerals used in our operations are sourced from conflict-free origins. As part of our commitment, we support the goals of the Dodd-Frank Act regarding the sourcing of 'Conflict Minerals'.

We are dedicated to working with our partners to create an ethical and sustainable supply chain that promotes respect for human rights and environmental protection. Our aim is to build a fairer and more peaceful world through our business operations.

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