Conflict Minerals Policy
Policy: It is the policy of Curtis Industries, Tri-Mag, LLC and Filter Networks, Curtis Industries Companies, (together
the “Company”), all wholly owned by Powers Holdings, Inc., to comply as required by law with all rules
and regulations governing “Conflict Minerals”.
In 2010, the U.S. Dodd-Frank Act was passed concerning “Conflict Minerals” originating from the
Democratic Republic of the Congo (DRC) or adjoining countries. The SEC has published final rules
associated with the disclosure of the source of Conflict Minerals by U.S. publicly traded companies (see
the rules at https://www.sec.gov/rules/final/2012/34-67716.pdf). The rules reference the OECD Due
Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Compliance Program: The Company has established a “Conflict Minerals” Compliance Program, and it
is the policy of the Company to continuously maintain the Compliance Program as a part of its
commitment to the above Policy, which as a minimum includes:
1. A policy in place that includes DRC conflict-free sourcing
2. The policy is in the process of being publicly available on our website
3. Direct suppliers to be DRC conflict-free
4. Direct suppliers to source from smelters validated as compliant to a CFS protocol using the CFS
Compliant Smelter List
5. Due diligence measures for conflict-free sourcing
6. Our suppliers are required to fill out a Conflict Minerals Reporting Template, or provide equivalent
information in similar form
7. Smelter names from our suppliers
8. Verifying due diligence information received from our suppliers
9. A verification process that include corrective action management
As the Company moves forward with its Compliance Program, and until such time as all points listed
above are completed and established within the Company, the Company will, during this interim period,
provide Conflict Minerals documentation on a product line specific basis upon requests received from
appropriate entities and/or their representatives.
Neither the Company nor Powers Holdings Inc. is a publicly traded company based upon SEC definition.
The Company is diligent in conforming with the requirements of law regarding “Conflict Minerals” and is
not subject to the SEC Conflict Minerals Disclosure Requirement rule.