Conflict Free Minerals Policy

In July of 2010, Congress passed the Dodd-Frank Act, which directed the SEC to issue rules requiring certain publicly traded companies to disclose their use of conflict materials if those minerals are “necessary to the functionality or production of a product” manufactured by those companies. These minerals include tantalum, tin, gold, tungsten, or their derivatives mined in the Democratic Republic of the Congo or an adjoining country.

As a privately held company, L&R Precision Tooling Inc. doing business as L&R Precision Machining and Manufacturing is not required to file reports with the SEC, but we support the Dodd-Frank Act and require our supply chain to make every effort to demonstrate due diligence in ensuring that all materials provided to L&R are smelted with materials from “Conflict Free Regions” to the best of their knowledge. L&R has addressed this issue with our suppliers by adding requirements to our “Supplier Terms and Conditions” that stresses that L&R will not willingly purchase any materials that violate the Dodd-Frank Act as related to Conflict minerals. It must be noted that with the current global recycling efforts, raw materials are being processed with a higher percentage of scrap or recycled materials which are untraceable as to the country of origin.

L&R Precision Machining and Manufacturing encourages its suppliers to implement similar business practices to ensure that their supply chain is free of “Conflict Region minerals” and to utilize responsible sourcing of raw materials, up to and including certification by an independent third party as “Conflict Free”, if there is any question about the country of origin.

Brian C. Leath

President of L&R Precision Tooling Inc.
7/20/2015