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Conflict Minerals Policy


Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires companies subject to rules of the U.S. Securities and Exchange Commission to disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together with the DRC, “Covered Countries). The term “conflict minerals” includes gold, tantalum, tin or tungsten. Together they are referred to as 3TG.

RTD is a downstream company in the supply chain and, being several tiers removed from Smelters or Refiners (“SOR”), has no direct relationship or visibility with SORs or mines of origin. To support its customers in providing the necessary disclosures of the Dodd-Frank Act, RTD has adopted practical guidelines for downstream companies as outlined by The Conflict-Free Sourcing Initiative (“CFSI”) and the Organization for Economic Cooperation and Development (“OECD”). These guidelines suggest surveying the reporting of relevant first-tier suppliers to determine existence of a conflict minerals policy and disclosure of SORs in the supply chain. Most of RTD’s first-tier suppliers have implemented the same practical guidelines Conflict Minerals Policy that supports DRC conflict-free sourcing initiatives as well as SOR disclosure by way of a Conflict Minerals Reporting Template (“CMRT”) or in a United States Securities and Exchange Commission “Form SD” (Specialized Disclosure Report).

To aid our customers in complying with the Dodd-Frank Act we have aggregated supply chain SORs in RTD’s CMRT which is available on request.