ACR's Commitment With Regard to Conflict Minerals

The Securities and Exchange Commission (“SEC”) has adopted a new rule and form, as mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), to require companies to publicly disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together with the DRC, “Covered Countries”).

Section 1502 of the Dodd-Frank Act amends the Securities Exchange Act of 1934 to direct the Commission to issue rules requiring certain companies to disclose their use of “conflict minerals” if those minerals are “necessary to the functionality or production of a product” manufactured by those companies or contracted by those companies to be manufactured. Under Section 1502, the term “conflict minerals” includes tantalum, tin, gold, or tungsten. Congress enacted Section 1502 because of concerns that the exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the DRC region and is contributing to an emergency humanitarian crisis.

While ACR Electronics, Inc. (ACR), a privately held corporation, is not subject to the Conflict Minerals rules and reporting requirements, we understand that some of our customers may be. ACR is committed to supporting our customers’ compliance efforts with their Conflict Minerals reporting requirements.

In order to comply with the intent of the Conflict Mineral requirements, ACR sources from suppliers who have performed their due diligence with their products and associated supply chains. ACR sources electronic materials from OEM franchised or licensed distributors, who do not engage directly with smelters. ACR does require reasonable due diligence in accordance with the Electronic Industry Citizenship Coalition (EICC) and the Conflict-Free Sourcing (CFS) Initiative from approved suppliers of materials for our products.

ACR is therefore able to represent that, to the best of our knowledge, our products do not contain Conflict Minerals. We will continue to work with our suppliers to ensure that we are able to identify the presence of Conflict Minerals within our supply chain, and the representations made within this Conflict Minerals Compliance Statement remain accurate.

Should your company have any questions associated with this Conflict Minerals Compliance Statement, please contact ACR’s Quality Department.