Conflict Minerals Disclosure
New Brunswick Plating, Inc. ("NBP") is furnishing this report to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The term "conflict mineral" is defined to include cassiterite, columbite-tantalite, gold, wolframite, and their derivatives (tin, tantalum and tungsten and gold), unless the Secretary of State determines that additional minerals or their derivatives are financing conflict in the Democratic Republic of Congo or an adjoining country. The Rule imposes reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products.
Reasonable Country of Origin Inquiry. Individuals with primary responsibility for purchasing materials and components at NBP's conducted a reasonable country of origin inquiry with respect to services NBP performed. The scope of the inquiry included all suppliers from whom NBP purchased in excess of a minimum value threshold of materials and components during the Reporting Period. Supplier engagement included, among other efforts, delivery of (A) an introductory email requesting information concerning the presence of conflict minerals in the supplier's goods and (B) subsequent emails and phone calls intended to prompt non-responsive suppliers to respond.
Conflict Minerals Disclosure. Based on the results of its reasonable country of origin inquiry, NBP has determined that, with respect to necessary conflict minerals in products, NBP has no reason to believe its necessary conflict minerals may have originated in the Democratic Republic of Congo or an adjoining country.