Conflict Minerals

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Conflict Minerals Program

As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act which passed in July 2010, the United States Securities and Exchange Commission passed legislation which requires U.S. companies to report on the origin of the conflict minerals of tin, tantalum, tungsten, and gold.

Vanguard EMS supports the legislation and its position to avoid the use of conflict minerals from the Democratic Republic of Congo and adjoining countries. Vanguard EMS requires chain of custody declarations from our suppliers to verify the origin of the conflict minerals contained in their products.

Vanguard EMS expects the following from our suppliers:

•  To source materials from socially responsible sub-tier suppliers and manufacturers

•  To comply with Securities and Exchange Commission regulations and provide all necessary declarations

•  To undertake reasonable due diligence through the supply chain to determine the origin of conflict minerals

•  Suppliers who are non-compliant with our policy will be reviewed to determine supplier status for our organization


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