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Conflict Minerals Policy

Purpose

GCTs Conflict Minerals Policy reflects its commitment to comply with legal, customer and industry requirements. It is GCTs intention to not directly or indirectly engage with any supplier where GCT has identified a reasonable risk that they are sourcing from any party committing human rights or related abuses.

Scope

This policy applies to all GCT entities and all suppliers who provide materials that contain tin, tantalum, tungsten, or gold. Note that at this time GCT does not use tantalum or tungsten in any of its products.

Policy – Effective as of 20th November 2012

GCT recognizes that any mineral export from conflict affected and high risk areas may result in human rights issues and that it has a responsibility to neither aid nor abet any organization that may contribute to these issues.

GCT is committed to supporting any policy that restricts and/or eliminates such conflict such as the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502.

GCT commits to incorporate into relevant supplier contracts and agreements the requirement for responsible sourcing of minerals and will suspend or discontinue engagement with suppliers where GCT identifies that these requirements are not being met.
In order to achieve these goals, GCT’s supply chain will only be authorized to use smelters/refiners who are compliant with the EICC/GeSI Conflict-Free Smelter Program.

GCT will monitor its supply chain with regard to its smelters/refiners and will require smelters/refiners to participate in the EICC/GeSI Conflict-Free Smelter Program until such time as smelters/refiners are audited and published as compliant.
Open Policy Download Declaration

Reference Documents

USAH. R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502
OECD Due Diligence Guidance - See www.oecd.org
EICC/GESI Conflict Free Smelter Program - See www.conflictfreesmelter.org

Definitions

Conflict Materials (where sourced from conflict affected mines and high risk areas)
Defined in this circumstance as:
Columbite-tantalite (coltan) and its derivatives, Cassiterite and its derivatives, Wolframite and its derivatives, Gold
Conflict Affected Mines and High Risk Areas
Conflict-affected mines and high-risk areas are mines or areas in the Democratic Republic of the Congo and its neighboring countries with the identified presence of armed conflict, widespread violence, or other risks of human harm.
Smelter
A smelter is a processor who obtains minerals and extracts metals (including tin, tungsten and tantalum).
Refiner
A refiner is a processor who improves the purity of a metal from its original state.

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