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                                  SEC LogoConflict Minerals

                                   

                                  What are conflict minerals?

                                  “Conflict minerals,” as defined by the US legislation, include tantalum, tin, tungsten, and gold, which are the derivatives of the minerals cassiterite, columbite-tantalite, and wolframite, respectively. Many companies often refer to the derivatives of these minerals as 3TG. In the U.S. Securities and Exchange Commission (SEC) rule, “DRC conflict-free” is defined as minerals that were extracted and did not directly or indirectly benefit armed groups in the covered countries. The “covered countries” include the DRC, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.

                                  Is Ellsworth Adhesives required to report on conflict minerals?

                                  No. Ellsworth Adhesives is not subject to reporting to the SEC. Ellsworth Adhesives is a private company with less than 500 common shareholders.

                                  Do you fill out an Ellsworth Adhesives Conflict Minerals Reporting Template (CMRT)?

                                  No. Ellsworth Adhesives is not required to report on conflict minerals to the SEC, and our policy is not to complete CMRTs. Ellsworth Adhesives is a distributor, and does not have the authority to fill out documentation on behalf of original manufacturers. For the products that are potentially subject to conflict minerals reporting, we provide the manufacturer’s declaration.

                                  Does Ellsworth Adhesives provide conflict minerals documentation?

                                  Yes. We provide the manufacturer’s conflict minerals documentation. Because many of our customers require CMRT documentation for the items purchased from Ellsworth Adhesives, we provide this documentation upon request. As we are not the manufacturer, our policy is to provide our supplier’s CMRT. Ellsworth Adhesives will provide the most current CMRT form as made available by our suppliers. We will provide a revision 5.01 or higher upon request.

                                  Does Ellsworth Adhesives flow down conflict minerals requirements to our suppliers?

                                  Yes. With respect to any and all products (if any) delivered under the purchase order, seller warrants that such products will at no time contain “conflict minerals,” as such term is defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including, without limitation, columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, or any other mineral or its derivatives (collectively known as “3TG”), determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) sourced from the DRC or adjoining countries. Any “3TG” will be sourced from validated smelters. Seller shall, no later than forty-five (45) days following each calendar year in which seller has delivered any products to buyer, under this agreement or otherwise, complete the Conflict Minerals Reporting Template that will be sent by or on behalf of buyer.

                                  Can you complete CMRT requests in a customer portal (i.e. iPoint, Assent, Source Intelligence)?

                                  Currently, Ellsworth Adhesives does not participate in any third-party portals. Our policy is to provide our customers with the CMRTs available for the applicable items from our suppliers.

                                  Do Ellsworth Adhesive’s products contain any conflict minerals?

                                  It varies based on the type of product. Ellsworth Adhesives does not intentionally add any of the four minerals to the product when carrying out our distribution activities. Contact your inside sales representative to obtain conflict minerals documentation for the items purchased from Ellsworth Adhesives.

                                   

                                  For more information, please refer to our Vendor Terms and Conditions of Purchase or email [email protected].

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