Conflict Minerals Policy

1. Purpose

Infraeo Inc. is committed to the responsible sourcing of minerals used in its products. This policy addresses the sourcing of tin, tantalum, tungsten, and gold (collectively, “3TG” or “conflict minerals”), which can originate in conflict-affected and high-risk areas (CAHRAs) under conditions that finance armed conflict or involve human-rights abuses. Infraeo’s products (including high-speed transceivers and copper cable assemblies) may contain 3TG.

2. Commitment

Infraeo is committed to sourcing materials from suppliers that share its commitment to human rights, ethics, and environmental responsibility, and to avoiding the use of 3TG that directly or indirectly finances or benefits armed groups. Infraeo aligns its due diligence with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

3. Scope and Operating Model

As a fabless, joint-design-manufacturing (JDM) company, Infraeo does not smelt, refine, or directly procure 3TG. Infraeo implements this policy through its manufacturing and supply partners, who are required to source responsibly, to provide traceability information to the smelter/refiner level, and to incorporate responsible-minerals criteria into their own supplier evaluation and flow equivalent requirements to their sub-tier suppliers.

4. Due Diligence (aligned with OECD 5-step framework)

• Establish management systems: maintain this policy, assign responsibility, and communicate expectations to suppliers.
• Identify and assess risk: require the JDM partner and suppliers to complete the Conflict Minerals Reporting Template (CMRT) identifying smelters/refiners of 3TG in the supply chain.
• Design and implement a risk-mitigation strategy: assess declared smelters against the RMI Responsible Minerals Assurance Process (RMAP) conformant-smelter list; engage suppliers on any non-conformant or unidentified smelters.
• Support independent third-party audit of smelters/refiners: rely on the RMI/RMAP independent smelter audit program.
• Report: maintain records of due diligence and provide conflict-minerals information to customers on request.

5. Supplier Requirements

Infraeo requires its manufacturing and supply partners to: (a) adopt a responsible-minerals-sourcing policy consistent with this policy; (b) exercise due diligence on the source and chain of custody of 3TG; (c) complete and maintain a current CMRT for the products they supply to Infraeo; (d) source 3TG only from RMAP-conformant smelters/refiners; and (e) flow equivalent requirements to their own sub-tier suppliers. Conformance is assessed through Infraeo’s supplier qualification process and through periodic monitoring and re-qualification.

6. Governance and Review

Executive management is accountable for this policy; a designated owner maintains it and coordinates CMRT collection and review. This policy is reviewed at least annually or upon significant change.