Conflict Materials Policy

At Octavo Systems LLC (“Octavo”), we apply our core values to our business activities every day, including the sourcing of components and materials.

Electronics components contain various metals – including tantalum, tin, tungsten and gold (“3TG”).  These 3TG metals are sourced worldwide, including in areas of conflict, known as the “Conflict Region,” where armed militias profit from the trade of these metals, and thus are referred to as “Conflict Minerals.”

In the U.S., Section 1502 of the 2010 Dodd-Frank Act requires all publicly traded companies to file an annual special disclosure with the U.S. Securities and Exchange Commission indicating if their products include Conflict Minerals.  Although Octavo is not a public traded company, we understand and support this objective and strive for transparency and awareness in our supply chain.

Octavo, as a purchaser, is many steps removed from the mining of the metals used in our products.  Octavo does not directly purchase any Conflict Minerals from any source and does not knowingly procure any product containing Conflict Minerals from the Conflict Region.  Octavo does manufacture/assemble various products that contain the 3TG metals which are necessary to the functionality or production of the product.  Octavo is committed to working with our supply chain and investigating the OEM manufacturer to assess the potential for Conflict Minerals.  Octavo’s due diligence is based on:

1.    Establishing strong company systems;
2.    Assessing OEM manufacturers to determine if they have an active Conflict Minerals policy in place; and
3.    Developing a strategy to respond to identified risks.

We encourage our suppliers to adopt similar policies and management systems with respect to Conflict Minerals and to drive those efforts throughout their supply chain to ensure that the specified metals are being sourced only from mines and smelters outside the “Conflict Region” or mines and smelters within the Conflict Region which have been certified by an independent third party as “Conflict Free.”