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Conflict Minerals Policy

Protherm Industries, Inc. will not knowingly procure material supplies and components
that contain minerals that directly or indirectly finance or benefit armed groups in the
Democratic Republic of Congo (DRC) or an adjoining country.
We urge our suppliers to support this policy in their own procurement guidelines and
provide us with accurate country of origin information.
Protherm shall:

  • Comply fully with SEC rules.
  • Conduct a reasonable country of origin inquiry to document the origins of the
    Gold, Tantalum, Tungsten and Tin used in our products.
  • Establish reasonable objectives and targets with a goal of ascertaining and
    minimizing Protherm’s risk. With a goal of continuous improvement for our
    Conflict Free Minerals Program, develop a means to measure objectives and
    targets. Protherm will also review, revise and report these measures, and
    overall program updates, on an annual basis.
  • Empower all employees, suppliers, vendors and contractors to take ownership in
    complying with the Conflict Free Minerals Policy and to escalate risks in the
    supply chain to management’s attention.
  • Effectively communicate to all employees this Conflict Free Minerals Policy
    and our Conflict Free Minerals Program.

Our Policy | 17 CFR PARTS 240 and 249b | H.R. 4173

Conflict-Free Smelters & Refiners

Conflict Minerals Reporting Template

ProTherm is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility. We expect all of our suppliers to abide by the requirements of our Supplier Code of Conduct, which prohibits human rights abuses and unethical practices. We also require all suppliers to comply with applicable legal standards and requirements.

On August 22, 2012, the U.S. Securities and Exchange Commission (“SEC”) issued the final conflict minerals rule under Section 1502 the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule”). The Conflict Minerals Rule requires publicly traded companies to report annually the presence of conflict minerals (tin, tungsten, tantalum and gold, or “3TG”) originating in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”).

ProTherm supports the goal of ending violence, human rights violations and environmental devastation in the Covered Countries. We are committed to complying with any requirements applicable to our Company under the Conflict Minerals Rule.

ProTherm will assist our customers in implementing their conflict minerals programs. We strive to work cooperatively with our customers and supply chain partners in implementing conflict minerals compliance programs.

ProTherm requires all of our suppliers to provide us with completed conflict minerals declarations using the EICC/GeSI Conflict Minerals Reporting Template. We may reconsider our willingness to partner with suppliers that fail to comply with this Policy.