Conflict Mineral Policy

Background

Circuit Assembly Corp (“CA”) shares industry concerns that tungsten, tin, tantalum and gold (“Conflict Minerals”) are being illegally sourced from the Democratic Republic of Congo (DRC) and adjoining countries as designated by the U.S. Secretary of State (“Covered Countries”) to fund armed groups who are responsible for committing human rights abuses across the region.

CA stands behind the industry’s objective of excluding the usage of products in its supply chain that contain Conflict Minerals originating from Covered Countries. To further this goal, we are working with our supply base to ensure responsible sourcing practices.

Responsibilities

CA expects suppliers of production materials, components, and manufacturing services (“Production Suppliers”) throughout our supply chain:

• To support this Policy.
• To comply with obligations set forth by the Securities and Exchange Commission’s implementation of the Dodd-Frank ConsumerProtection and Wall Street Reform Act (2010) relating to the sourcing of Conflict Minerals; and
• To adhere to the Electronic Industry Citizenship Coalition (EICC) Code of Conduct. CA engages with its Production Suppliers (if tungsten, tin, tantalum and gold are used in products) to meet disclosure obligations required by these rules.

Supplier responsibilities include:

• Performing a Reasonable Country of Origin Inquiry (“RCOI”) to ensure metals derived from Conflict Minerals originating from Covered Countries are not used in CA products.
• Responding to CA on the EICC-GeSI Common Reporting Template. Responses shall include material disclosure, country analysis, supply chain audits, supply mapping back to the point at which the metal was refined from concentrate by the mineral processor, metal smelter audits, and other documentation reviews.
• Sourcing tungsten, tin, tantalum and goldfrom smelters certified by the EICC-GeSI Conflict Free Smelter (CFS) Program, when feasible.
• Complying with CA inquiries, as needed, to respond to customer requests.

Conflict Mineral Policy DO # 7240
FORM NO.:340151 Rev.A