Cicero Mfg. & Supply Company, Inc. (Cicero Supply) Conflict Minerals Policy

As part of its on-going business policies and in its continued efforts to be a good corporate citizen in compliance with the laws and policies of the United States and internationally, Cicero Supply promotes, values and respects the human rights of all individuals and groups. In addition to complying with legal requirements, we promote our values and polices with our suppliers (“Suppliers”) in accordance with our Cicero Supply Code of Conduct made available to Suppliers for review and to ensure compliance. As such, Cicero Supply is committed to supporting responsible sourcing of its materials from its Suppliers and Cicero Supply does not accept “Conflict Minerals” (or any metals) from the “DRC” “Conflict Minerals Regions” (each term as defined below).

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and the Conflict Minerals rules that the U.S. Securities and Exchange Commission adopted (“Conflict Minerals Rules”) requires many companies to make public disclosures regarding whether minerals used to manufacture their products originated in the Democratic Republic of Congo (“DRC”) or adjoining countries (collectively, together with the DRC, the “Conflict Minerals Region”). These “Conflict Minerals” are defined as tin, tantalum, tungsten and gold (3TG), used in their products that are sourced from mines controlled by non-government or unlawful military groups within the Conflict Minerals Region.

These Conflict Minerals Rules do not directly apply to Cicero Supply; however, they may apply to our Suppliers and customers and we strive to assist our customers in their efforts to comply with their legal requirements, including SEC obligations. Cicero Supply does not knowingly purchase any Conflict Minerals and we require our Suppliers that use materials which may contain minerals potentially from the Conflict Minerals Regions necessary for the functionality or production of their materials to only use Conflict Free sources.

Our Suppliers should: (i) not include any Conflict Minerals in any products sold to us; and (ii) develop Conflict Minerals policies and compliance systems and processes of their own to ensure compliance with US legislation on the sourcing and supply of Conflicts Minerals. If required by the SEC or Cicero Supply or Cicero Supply’s customers, Suppliers of certain materials may be required to provide written confirmation of its Conflicts Minerals Free status. In the event Cicero Supply becomes aware of Suppliers who do not reasonably comply with this policy, such Suppliers will be reviewed for determination of next steps, including ending our business relationship and transition of their business to sources that do comply.

Last Updated Date: August, 2017