Conflict Minerals Policy

The purpose of this policy is to provide an understanding of our commitment to sourcing ‘conflict minerals’ from conflict affected and high-risk areas in line with our legal obligations and international standards.

Varlink Ltd is committed to ensuring that certain minerals (tin, tungsten, tantalum and gold) contained in the products we distribute are sourced with due respect for human rights and the need to avoid contributing to conflict.

The Securities and Exchange Commission (SEC) has adopted rules regarding disclosure and reporting requirements with respect to conflict minerals under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rules require companies to disclose whether the products they manufacture contain conflict minerals that are necessary to the functionality or production of those products.

Varlink Ltd supports the goal of the rules to end violence and human rights abuses in the Democratic Republic of the Congo and surrounding countries that may be financed by proceeds from trade in these minerals.

Varlink Ltd expect our suppliers to support us in complying with these rules.