Conflict Minerals Policy



Sustainability in its three dimensions (environmental, social, and economic) is of the
highest importance for Fides Electrónica. Sustainable conduct forms the basis of our business
decisions and dealings with our stakeholders.

Along with governments, NGOs, the investment community, and many other companies
worldwide, we are concerned about human rights violations including forced labor,
human trafficking and child labor occurring anywhere in the world, as well as the
role that armed conflicts play in causing extreme violence across the Democratic Republic
of the Congo and its adjoining countries (“the DRC region”).

In 2010, the U.S. Congress passed the Dodd-Frank Wall Street Reform and Consumer
Protection Act (the “Act”), pursuant to which the U.S. Securities and Exchange Commission
(the “SEC”) issued rules requiring certain reporting companies to make disclosures
under specific circumstances concerning the use of “Conflict Minerals” – defined in the
Act as tantalum, tin, tungsten (and the ores from which they originate) and gold. Conflict
Minerals are used in the manufacture of a variety of commercial products.


We have rolled out a uniform and enterprise-wide process to determine the use, source

and origin of Conflict Minerals in our supply chain. We work closely with our direct
suppliers to support us in carrying out these steps. Where necessary, we work with
suppliers in order to remediate risks and perform additional due diligence so that we
can continue to source responsibly, building on established management processes.


Because of our support for human rights and our concern that funds from purchases of
materials used in our supply chain may be exploited for illegal purposes, we are taking
systematic steps to understand whether any Conflict Minerals in our products are financing
the conflict and violence in the DRC region.