Conflict Materials Policy

CONFLICT MINERALS POLICY

12 August 2013

“Conflict Minerals” refers to minerals or other derivatives mined in the eastern provinces of the Democratic Republic of the Congo (DRC) and in the adjoining countries (“Conflict Region”) where revenues may be directly or indirectly financing armed groups engaged in civil war resulting in serious social and environmental abuses. In July 2010, the United States passes HR4173, the Dodd-Frank Financial Reform Bill section 1502(b) requiring all US stock listed companies and their suppliers to disclose the chain of custody usage of conflict minerals (Tin, Tantalum, Tungsten, and Gold also called in short as 3TG).

While The Bright Group (TBG) is not required by law to report conflict mineral sources, TBG is committed to implement a socially responsible sourcing policy respecting human rights and avoiding contributions to conflicts through mineral purchasing decisions and practises within its supply chain.

TBG does not purchase or source any of these conflict minerals as raw material directly however being a contract manufacturer, products manufactured by TBG may contain these conflict minerals in the components of assemblies.

TBG is committed not to procure knowingly any parts that contain any of the conflict minerals that originate from facilities in the “Conflict Region” that are not certified as “conflict free”.

TBG will ask all its suppliers to undertake reasonable due diligence to ensure the same compliance within the complete supply chain. We acknowledge the visibility to reach at smelters level is complicated and where a supplier procures these minerals at that level then this information must be declared.

TBG expects all its suppliers will put reasonable effort to report the conflict minerals status and their policy. In support of this, TBG will obtain chain of custody declarations from all TBG sourced and managed suppliers ensuring transparency in its supply chain. All suppliers must pass this requirement up the supply chain and determine the source of specified minerals. Where a source is declared from the “Conflict Region” TBG will request those relevant suppliers to change their source otherwise will stop immediately procuring from these suppliers and they will be reviewed for future business. In case there is no immediate alternative source found for various reasons, as part of our contract manufacturing responsibility, TBG will work with relevant customers in collaboration to identify, qualify and source for alternative part or solutions.

TBG is aware of annual reporting requirements of our customers bound by the above mentioned Bill by 31st May each year and is committed to provide a report to our customers by end of February each year.



Yildiz Taylor

Director of Supply Chain