TPM Statement on Conflict Minerals.

Overview of the Conflict Minerals Issue

The Democratic Republic of the Congo (“DRC”) is a Central African country with vast mineral wealth, including reserves of cassiterite (tin), columbite-tantalite (aka coltan — source of tantalum), wolframite (tungsten), and gold. For many years, armed groups have fought to control mines within the DRC; those armed groups have been cited for committing violent crimes against locals, including murder, rape, and forced labor. Armed groups controlling mines smuggle minerals out of the DRC and the proceeds are used to further finance conflict and perpetuate criminal behavior — hence cassiterite, coltan, wolframite, and gold are considered conflict minerals.

The elements tantalum, tin, tungsten, and gold are metals used in many manufactured goods across many industries — including aerospace, appliances, automotive, electronics, jewelry, medical, and tool & die.

The Dodd-Frank Wall Street Reform and Consumer Protection Act, passed into law in July 2010, contains requirements that U.S. companies report to the Securities and Exchange Commission (“SEC”) on the origin of conflict minerals or their derivatives, and show due diligence if conflict minerals are sourced from the DRC or an adjoining country. The goal of the Act is to cut direct and indirect funding of armed groups engaged in conflict and human rights abuses.

Definitions Adopted by TPM

Conflict Mineral

(A) columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. Per the SEC 1502 regulations, conflict minerals are necessary to the functionality or production of a product, but must be contained in the end product in order to be considered a conflict mineral under the rules (so tools used to manufacture parts are not included in the scope of products covered by the SEC regulations).

DRC Conflict Mineral Free

DRC Conflict Mineral Free materials do not contain conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country. This term also applies to materials determined to be processed from scrap and/or recycled material. Materials that were already incorporated into products or were already within the supply chain as of December 31, 2012 will not be subject to inquiry or reporting rules.

Armed Group

Armed Group means an armed group that is identified as perpetrators of serious human rights abuses in the annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 (22 U.S.C. 2151n(d) and 2304(b)) relating to the Democratic Republic of the Congo or an adjoining country.

True Precision Machining’s Approach

Suppliers to True Precision Machining (TPM) must develop policies toward preventing the use of conflict minerals or derivative metals sourced from mines controlled by armed groups in all items to be supplied to TPM. In addition, all suppliers to TPM must document their efforts to determine the source of any conflict minerals or derivatives and provide TPM with evidence of the origin of the metals tantalum, tin, tungsten, and gold in products to be supplied to TPM.

Any smelters producing tantalum, tin, tungsten, or gold metals subsequently used in TPM products are requested to seek and obtain certification through the EICC/GeSI Conflict Free Smelter (CFS) program. When there are an adequate number of CFS smelters/refiners available for sourcing, TPM will require sourcing from CFS-certified smelters.

Status of TPM’s Due Diligence

True Precision Machining has taken the following steps toward determining the sources of 3TG within the supply chains of all its products:

Enter into simple contracts

TPM enters into simple contracts with major contractors not to supply illegally mined materials to True Precision Machining. This policy contains provision of verifying the origin/source information of materials to confirm that they are not obtained through illegal mining.

Declare Supplier Code of Conduct

Based on the EICC Code, TPM establishes and declares its Supplier Code of Conduct in this matter through this document. This Code contains the provision that “Suppliers shall evaluate the origin or source of their materials throughout their supply chains to verify that they have not been obtained through any illegal form of mining (e.g., materials obtained from the Democratic Republic of Congo),” contractually binding suppliers to not use conflict minerals.

Identify materials in supply chain

TPM conducts an analysis of all manufacturing parts and materials using our internal materials management system. Results are collated and due-diligence investigation is conducted to assure our suppliers are using DRC-Free materials, and that our suppliers certify as such.

Conduct due diligence survey for identified suppliers

TPM has contacted suppliers of conflict materials and requires a statement of due-diligence policies that address conflict-material assessments, as well as statements or certifications that material received are DRC Conflict Mineral Free.