Conflict Minerals Policy

Vibco Inc policy on Conflict Minerals:

In August 2012, the United States Securities and Exchange Commission (“SEC”) issued its final rules regarding “Conflict Minerals” (known as ‘3TG’ – Tantalum, Tin, Tungsten and Gold) as defined in and required by section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). As a result, many companies are now focusing on whether and to what extent their products contain Conflict Minerals and whether such Conflict Minerals come from the Democratic Republic of Congo and the adjoining countries named in the Act as all public companies are being required to report their compliance.

VIBCO is committed to the health, safety and protection of people who come into contact with our products and business. We manufacture our product 100% in the United States and we make our best effort to also source component materials originating from the United States when possible. Our supply chain reaches several layers beyond our direct vendors and we are reliant upon the responses of our vendors in order to source information regarding conflict minerals. Most of our vendors that may source 3TG items are public companies and have published their policies and findings as part of their required SEC filings.

Those vendors have all committed to tracking their raw materials and have done extensive due diligence to determine whether or not their 3TG raw materials are sourced from the specified conflicted regions. Smelters that may have sourced materials from areas of conflict are encouraged by their suppliers to source responsibly, meet the requirements of the Conflict Free Smelter Program (“CFSP”) and to obtain a “conflict-free” designation from an independent third party auditor.

Vibco will provide a completed Conflict Minerals Reporting Template (“CMRT”) upon customer request.