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Dodd-Frank Act

Statement of BRAND GMBH + CO KG concerning the use of "conflict minerals"

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On August 22, 2012, the U.S. Securities and Exchange Commission adopted final rules to implement
reporting and disclosure requirements related to "conflict minerals", as directed by the Dodd-Frank
WallStreet Reform and Consumer Protection Act (Dodd-Frank Act) of 2010.

Companies registered on the U.S. stock exchange are required to report annually whether the
products they manufacture or contract to manufacture contain conflict minerals that are necessary
to the functionality or production of those products. The intent of these regulations is to curtail the
trade with conflict minerals, which originate from the Democratic Republic of the Congo (DRC) or
surrounding countries and finance or benefit the ongoing violent conflict in the DRC or an adjoining

Conflict minerals within the meaning of the Dodd-Frank Act (status as of 01.01.2013) are:

  • columbite-tantalite (coltan)
  • cassiterite (tin)
  • wolframite (tungsten)
  • gold
  • and their derivatives

BRAND as a company is not subject to the mentioned reporting and disclosure requirements.

In light of the requirements of the Dodd-Frank Act we are working with our suppliers to trace materia
components in our products in order to determine whether minerals originating from mining or
noncertified smelting operations in the conflict region are used in our products. We will not
knowingly use conflict minerals from noncertified smelters of the conflict region in our products. As a
result, we are requiring our suppliers to trace material components in the products they supply to us
down to a conflict free certified smelter and to provide us with documentation regarding their due
diligence efforts. We are requiring our suppliers to proeure components, parts, or products
containing conflict minerals that have been identified tobe conflict-free.
Supply chains and the routes by which these conflict minerals are traded and sold are very complex.
All potentially affected suppliers responded to our request concerning conflict minerals. Currently
there is no information that conflict minerals originating from the countries concerned might be used
in our products.

Please feel free to contact us should you have any fu rther questions ( /


Wertheim, March 10th, 2020