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The expert opinion of LINDY-Elektronik GmbH [a limited liability company], and LINDY International Ltd. on the use of conflict materials

The American (Dodd-Frank Act) Dodd-Frank Wall Street Reform and Consumer Protection Act has been in effect since July 2010. First and foremost, this reform serves the US financial market rights. It details the disclosure and reporting obligations for companies publicly traded in the US regarding the use of certain raw materials which originate from the Democratic Republic of Congo or their neighbouring nations. These “conflict materials” are tantalum, tin, gold and tungsten. The goal is to contain the handling of “conflict materials” which originate from the mines in these countries and the financing of the local armed conflicts. These disclosure obligations must first take place by May 31, 2014 for products which were manufactured in the year 2013.

LINDY-Elektronik GmbH, LINDY Electronics Ltd. and LINDY International Ltd. are not subject to the registration and disclosure obligations of the Dodd-Frank Act. Even so, we are striving to support our customers directly affected by the Dodd-Frank Act.

At the moment, it is not possible for us to make a practical statement due to complex supply chains; nevertheless, we are concerned about fair handling with our suppliers.

Furthermore, a decision of the Federal Court of Justice of the District of Columbia has existed since April 14, 2014 which nullifies a portion of the “Security and Exchange Commission” regulation on disclosure obligations (opinion of the court ($file/13-5252-1488184.pdf))

In Connection with a renewed hearing by the Federal Court of the district of Columbia, this decision has been confirmed once more on August 18th 2015 (see here: ($file/13-5252-1568402.pdf)).

The impact the decision will have on the demands and the implementation of the Dodd-Frank Act and, consequently, on indirectly affected European companies have yet to be seen. Therefore, we appreciate your understanding that in this current situation we have not filled out a questionnaire or are able to complete entries in the corresponding customer portal. We ensure you that we will earnestly pursue this topic further and will remain in contact.


LINDY-Elektronik GmbH, LINDY Electronics LTD & LINDY International Ltd.

Mannheim and Stockton-on-Tees, December 2015

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