D Block Metals RMI/RMAP Public Due Diligence Report (2024)

1. COMPANY INFORMATION

D Block Metals, LLC. was established in January of 2012 . Our facility is located at 1808 Indian Creek Road, Lincolnton, North Carolina 28092.  D Block Metals, LLC. (CID0002504) has fully supported the position of the Electronic Industry Citizenship Coalition (EICC), the Global e-Sustainability Initiative (GeSI), and the Tantalum-Niobium International Study Center (TIC) in avoiding the use of minerals which may directly, or indirectly, finance or benefit illegal armed groups from Conflict Affected or High-Risk Areas (CAHRAs) such as the Democratic Republic of Congo and adjoining areas (Sudan, Uganda, Rwanda, Burundi, United Republic of Tanzania, Zambia, and Angola as established by the Dodd-Frank Act and strengthened by the Regulation (EU) 2017/821).

D Block Metals is committed to compliance to the guidelines set forth in the Responsible Minerals Assurance Process (RMAP) and has been within compliance, since 2014.

We adhere to international transportation regulations regarding Class-7 materials and only purchase tantalum materials from companies who objectively demonstrate compliance with the aforementioned guidelines.

2. RMAP ASSESMENT SUMMARY

D Block Metals most recent assessment was conducted by Arche Advisors on 21 April, 2023 and is currently available on www.responsiblemineralsinitiative.org/tantalum-conformant-smelters/.  The current assessment covers the time period from 21 December 2021 to 28 February 2023.  The audit for calendar year 2023 is in-process .  A Responsible Sourcing Audit Firm representative will be conducting this assessment, in accordance with RMI/RMAP protocol, and a copy will be made public to the aforementioned website, as well as the company website, upon its completion.

3. COMPANY SUPPLY CHAIN POLICY

D Block Metals takes seriously our responsibility to the environment, our employees, our local community, and the global community.  Since we began operation in January 2012, we have fully supported the position of the Responsible Business Alliance (RBA); formerly EICC, the Global e-Sustainability Initiative (GeSI), and the Tantalum-Niobium International Study Center (TIC)

To promote and ensure the exclusive use of conflict-free tantalum, D Block Metals commits to:

• OECD Due Diligence Guidance for Responsible supply Chains of Minerals from Conflict-Affected and High-Risk Areas to establish processes avoiding the use of minerals sourced from conflict regions that may facilitate serious human rights abuses (any forms of torture, cruel, inhuman, and degrading treatment) to mine conflict minerals to fuel armed conflict and regional instability.
• Strictly adhering to the guidelines set forth in the Dodd-Frank Act as well as Regulation (EU) 2017/821 as they directly influence our policies concerning conflict minerals and their sources.
• Establishing policies to ensure we adhere to international transportation regulations for class-7 materials and only purchase materials from companies who objectively demonstrate compliance with the aforementioned guidelines.
• Continued cooperation with the RBA’s Responsible Mineral Initiative (RMI) through Responsible Minerals Assessment Process (RMAP).
• Communicating our sourcing policies to all suppliers regarding our requirements pertaining, but not limited to; serious human rights abuses associated with the extraction, transport, or trade of minerals; zero-tolerance of support to non-state armed groups (including public or private security forces); zero-tolerance of bribery or fraudulent misrepresentation of the origins of minerals; and zero-tolerance of money laundering and payments of taxes, fees, or royalties to any party other than the host government.

D Block Metals, LLC. has submitted a copy of this supply chain policy to the following locations for public view, www.responsiblemineralsinitiative.org/tantalum-conformant-smelters/ and the company website at www.dblockmetals.com/company-policies/.

4. COMPANY MANAGEMENT SYSTEM

D Block Metals, LLC. takes product identification and traceability very seriously and disseminates information through several departments and overlaps responsibilities throughout departments to ensure 100% compliance with company policies, as well as federal and global initiatives and programs.  The following internal entities of D Block Metals, LLC. have, at minimum, the following responsibilities within this system:

Sales Department – Responsible for identifying new customers, providing relevant information from new customers to company president for RMI/RMAP compliance, generating quotes for customers, issuing purchase orders (PO’s) or contracts, verifying incoming shipments of material.

Company President – Responsible for verifying new customers are in compliance with RMI/RMAP, verifying existing customers maintain a current status of compliance with RMI/RMAP, generating quotes for customers, issuing PO’s or contracts, verifying incoming shipments of material, matching PO or contract number on incoming shipments accompanying paper work to PO or contract number on company paperwork, reviewing company work orders (WO), verifying assay results, confirms appropriate work processes with Plant Manager.

Shipping and Receiving Department – Responsible for verifying PO or contract number on incoming shipments accompanying paperwork matches PO or contract number on company paperwork, verify the weight of incoming shipments (within 10%) on corresponding paperwork, placing incoming shipments into the Receiving Hold Area until material verification is complete,

collecting and sending samples of incoming materials appropriate assay, generating company work orders, placing material into appropriate inventory location(s), relocates inventoried material to relevant workstations for processing, relocates processed material to processed material holding lanes, verifies assay results, verifies packing and label requirements, generates packing lists.

Plant Manager – Responsible for determining the appropriate work process for incoming material, verifies incoming shipments of material, reviews company work orders to corresponding material, annotates the beginning and end dates of processing materials on WO’s, oversees all production processes, oversees Work-In-Process (WIP) rates and stages.

5. RISK IDENTIFICATION

In the event of material being identified as a risk of RMI/RMAP violation, the entire order will be placed in a quarantined area until the discrepancy is resolved.  Prior to accepting an incoming shipment, the shipping and receiving manager will verify all relevant information, in accordance with company policy.  Prior to generating a WO and corresponding number, the shipping and receiving manager will follow the Purchased Product Verification Procedure for Tantalum (Document PUR7), which includes collecting and submitting samples of material for assay.

If material is confirmed to be a RMI/RMAP violation, the entire shipment will be rejected and OECD guidance will be followed.

RISK MITIGATION

D Block Metals, LLC. does not currently purchase or process tantalum ores or any radioactive materials identified as Class VII materials, nor do we directly source any material directly from any Conflict

Affected / High Risk Areas (CAHRA’s) identified through OECD guidance, the Dodd-Frank Act, or Regulation (EU) 2017/821. D Block Metals, LLC. is registered with www.conflictfreesourcing.org to receive automatic updates on changes or updates to current policies regarding due diligence requirements to avoid the use of conflict minerals.

D Block Metals, LLC. only approves suppliers of secondary tantalum materials based on their approval as a Conflict Free Smelter and approves all suppliers of exempt scrap based on their ability to demonstrate that they meet the requirements of the company policy regarding conflict free minerals purchasing (Document PUR5).  An updated list of Conflict Free Minerals suppliers will always be consulted at www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists to assist in verification.  To be an approved supplier, a supplier must either be listed on the list, or as defined by CFR 17 in section 240-249b.

New suppliers must submit descriptions, or assays, and representative samples to be reviewed and approved by the company president prior to executing any PO or contract.  The approval status of the new supplier will be listed as pending until the requirements are met.

D Block Metals has also implemented a training program to reinforce the intent of our policy on conflict minerals to all of our employees, as well as maintain a good understanding of our due diligence processes to the appropriate personnel.

The company President is responsible for understanding the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 and staying current with policy requirements of the OECD guidance documents for due diligence requirements to avoid the use of CFM’s and develop the Company Policy accordingly. To remain current, D Block is registered with www.conflictfreesourcing.org to receive automatic updates.