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Fehr Bros. Industries

Supply Chain Policy

Introduction

Fehr Bros. Industries is committed to the responsible and ethical sourcing of materials used in the manufacturing process of the products we supply. We recognize that sourcing materials from “conflict-affected” and “high-risk” 1 areas can potentially contribute to conflict and have deleterious impact on fundamental human rights. In compliance with ethical standards and applicable law, we will not knowingly source materials from, or operate in, conflict-affected or high-risk areas. Specifically, we will comply with our obligations (and assist our partners with their compliance obligations) under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd Frank”) regarding “conflict mineral” disclosure and the Uyghur Forced Labor Prevention Act (“UFLPA”) regarding goods mined, produced or manufactured, wholly or in part, in China’s Xinjiang Uyghur Autonomous Region (“XUAR”).

1As such terms are defined in OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris. https://www.oecd.org/corporate/mne/mining.htm

Since Fehr Bros. Industries is not a manufacturer, it is not possible for us to dictate to our suppliers how they run their business and we understand that it may be difficult to identify the source materials used in, or indeed the origin of, scrap metals which may be used in manufacturing. We do however have the expectation that our partners operate their business according to applicable law and in an ethical manner consistent with the needs and expectations of Fehr Bros. Industries and our customers. We will continue our ongoing process of fostering solid long term relationships with the highest quality vendors and mills.

Dodd-Frank

Dodd-Frank requires U.S. public companies to disclose the use of conflict minerals necessary to the functionality or production of a product that it manufactured or contracted to manufacture. The minerals in question are Tantalum, Tin, Gold and Tungsten (“3TG”) sourced from the Democratic Republic of Congo and nine (9) internationally recognized border countries. As a private company, Fehr Bros. Industries is not technically subject to these disclosures. We do however recognize that our partners may be required to supply this information. We therefore request information from our suppliers and mills, both domestic and import, on the existence of 3TG conflict minerals in their supply chain and to advise which if any of our products is affected.

UFLPA

The UFLPA is intended to strengthen the existing prohibition against the importation of goods into the U.S. made with forced labor. Specifically, the Act is intended to address what it describes as gross violations of human rights in the XUAR. Under UFLPA, any goods mined, produced or manufactured in the XUAR are presumed to have been produced using forced labor and therefore not entitled to entry at U.S. ports. As an importer of goods into the U.S., Fehr Bros. Industries is subject to the provisions of UFLPA. In order to comply with the UFLPA, we request information from our foreign and domestic suppliers and mills as to the existence of their activities in XUAR and the origin of their goods.

In the event there are any questions regarding this policy please contact your account manager or submit your question(s) to info@fehr.com with your company name and contact information.