Rule 13p-1 under the Securities
Exchange Act of 1934, as amended, generally provides that a company must file this specialized disclosure report if it manufactures
or contracts to manufacture products for which one or more of the following minerals are necessary to the functionality or production
of the company’s products: cassiterite; columbite-tantalite (coltan); and wolframite; their derivatives tantalum, tin and
tungsten; and gold (collectively, “3TGs”). These are considered “conflict minerals” under Rule 13p-1
regardless of their geographic origin and whether or not they fund armed conflict in the Democratic Republic of the Congo or its
neighboring countries (the “covered countries”).