Exxact Corporation Responsible Minerals Policy

1. Purpose

Exxact Corporation is committed to the responsible sourcing of materials used in our products. This policy addresses the use of tin, tantalum, tungsten, and gold (collectively "3TG," also known as "conflict minerals") that may originate from the Democratic Republic of Congo (DRC) or adjoining countries, and which may contribute to human rights abuses or armed conflict when sourced irresponsibly.

2. Scope

This policy applies to all Exxact Corporation products, operations, and direct suppliers of goods and services that may contain 3TG minerals.

3. Policy Statement

Exxact Corporation does not knowingly source or support the use of conflict minerals that directly or indirectly finance or benefit armed groups in conflict-affected and high-risk areas. We are committed to conducting our business in a manner that respects human rights and promotes responsible mineral sourcing throughout our supply chain.

4. Our Commitments

Exxact Corporation is working toward the following:

• Supply Chain Due Diligence: Developing a conflict minerals due diligence program aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
• Supplier Engagement: Establishing a process to request and collect Conflict Minerals Reporting Templates (CMRTs) from direct suppliers in accordance with the Responsible Minerals Initiative (RMI) framework.
• Smelter Validation: Encouraging our supply chain to source 3TG from smelters and refiners validated through the Responsible Minerals Assurance Process (RMAP) or an equivalent third-party audit program recognized by the RMI.
• Transparency: Responding honestly and accurately to customer conflict minerals inquiries and improving our reporting capabilities over time.
• Continuous Improvement: Maturing our responsible minerals program on an ongoing basis as our supply chain visibility and internal resources allow.

5. Supplier Expectations

As Exxact Corporation develops its conflict minerals program, we are working toward communicating responsible sourcing expectations to our direct suppliers. We expect our suppliers to support our due diligence efforts by providing accurate conflict minerals information upon request and by working toward sourcing 3TG from responsibly validated sources.

6. Governance and Review

This policy is owned by the Vice President and supported by the Quality Engineering function. It will be reviewed annually and updated as regulatory requirements, customer expectations, or business conditions change.

7. Regulatory Alignment

This policy is informed by the following frameworks:

• Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
• Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT)
• IPC-1755 Conflict Minerals Data Standard