Policy Statement on Conflict Minerals

Clover Imaging Group (“CIG”) supports the humanitarian goal of ending violent conflict in Central Africa (the Democratic Republic of Congo (DRC) and surrounding countries of Republic of Congo, Central Africa Republic, South Sudan, Zambia, Angola, Tanzania, Burundi, Rwanda and Uganda) by adopting a policy on Conflict Minerals.

In response to the conflict, the U.S. Securities and Exchange Commission (SEC) promulgated the Conflicts Minerals rule to help end violence and human rights abuses by armed militant groups in the DRC Region by denying revenue to those groups that derive their funding from the control of mines in the region that product Conflict Minerals. In August of 2012 the SEC approved the final rule regarding the sourcing of Conflict Minerals as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. Under this rule, publicly traded companies must report annually to the SEC the presence of Conflict Minerals originating from the DRC in either the products they manufacture or contract to manufacture, or use in the production process. Conflict minerals are defined as the minerals tin, tungsten, tantalum and gold.

CIG is not a publicly traded company nor do we directly purchase raw minerals that may be used in the manufacture of our products from smelters or mines. We do, however, use suppliers whose products may contain these minerals. In order to commit to responsible sourcing of Conflict Minerals throughout our supply chain we require our suppliers to submit certain information about any Conflict Minerals in the products or components they supply to CIG including, if known, the country of origin and the smelter(s) or refiner(s) used to process the Conflict Minerals.

CIG establishes compliance requirements for our direct suppliers regarding Conflict Minerals and provides them with the tools to facilitate reporting to the SEC. We will continue to evaluate our policies to ensure compliance and make adjustments where necessary.


Policy Statement on Conflict Minerals

Slavery and Human Trafficking Statement

UK Modern Slavery Act of 2015

The Modern Slavery Act of 2015, establishes transparency in supply chains by requiring commercial organizations to prepare a slavery and human trafficking statement. Clover Technologies Group ("Clover'') is committed to ensuring that its employees and suppliers take appropriate steps to mitigate the risk of human trafficking and slavery from occurring in any aspects of its supply chain and within its own business. In accordance with the Act, Clover makes the following disclosures regarding its steps to ensure that slavery and human trafficking are not taking place:

Verification of Supply Chain
Clover verifies product supply chains through several methods, including requiring suppliers to complete a Social Accountability Form and audits for larger suppliers.

Evaluation of Supplier Compliance
Clover conducts audits of larger suppliers to ascertain that they are in compliance with our Social Accountability statement. Included onthis form are disclosure requirements regarding human rights laws and prohibitions against forced or compulsory labor.

Supplier Certification
Clover requires all suppliers to comply with applicable laws and regulations

Internal Accountability Standards
Clover maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. In furtherance of the foregoing the pol icy identifies specific principles, including:

  • promoting fair employmentpractices,
  • providing fair and competitivewages,
  • prohibiting harassment, retaliation and discrimination,

Training
Clover is currently providing ongoing training for company employees and management, who have direct responsibility for supply chain management, on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

Europe and Asia
All local suppliers must provide proof that they are legal entities compliant withall local laws and regulations within their countryor origin.


Slavery and Human Trafficking Statement
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