Conflict Minerals
Policy Statement

PowerSecure, Inc.

Conflict Minerals Policy Statement
Revised May 24, 2021

PowerSecure, Inc. (“PowerSecure”) has adopted the following Conflict Minerals Policy Statement.

In 2012, the Securities and Exchange Commission (“SEC”) adopted final rules under Section 1502 of Dodd-Frank Wall Street Reform and Consumer Protection Act relating to “Conflict Minerals.” Section 1502 of the Dodd-Frank Act was adopted because Conflict Minerals originating from the Democratic Republic of Congo (the “DRC”) and adjoining countries (together with the DRC, the “Covered Countries”) may directly or indirectly be funding or benefitting illegal armed groups committing human rights atrocities in that region. These Conflict Minerals from the Covered Countries – tantalum, tin, tungsten and gold – are making their way into the supply chain of companies in the United States of America.

Under these Conflict Minerals rules and regulations, publicly-traded companies must report annually to the SEC if they use any Conflict Minerals from the Covered Countries in the products they manufacture or contract to manufacture if the Conflict Minerals are necessary to the functionality or production of those products.

While PowerSecure does not source any Conflict Minerals from the Covered Countries directly, such Conflict Materials may exist in the products, materials and components that PowerSecure sources from its suppliers. PowerSecure is committed to working with its suppliers to responsibly source the materials and components PowerSecure uses in its products.

To facilitate compliance with these Conflict Minerals rules, PowerSecure follows the internationally recognized framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), and related Supplements on Tin, Tantalum, Tungsten, and Gold, specifically as it relates to PowerSecure’s position in the supply chain as a “downstream” company. Pursuant to this framework, PowerSecure conducts inquiries of its supply chain in an effort to determine the source of any Conflict Minerals from the Covered Countries and to assist in the reporting of the results of its inquiries. In order for PowerSecure to accomplish this, PowerSecure requests its relevant suppliers to respond to information requests regarding the uses and sources of Conflict Minerals from the Covered Countries in their products, including information about minerals that are recycled or scrapped.

  • In addition, PowerSecure expects the following support activities of its suppliers:
    Assisting PowerSecure in its compliance with the SEC rules and regulations relating to Conflict Minerals and providing certain related representations, declarations or certifications if requested to do so;
  • Undertaking reasonable due diligence within their supply chain to determine the source and chain of custody of their Conflict Minerals, including developing policies and systems to avoid the use of Conflict Minerals that directly or indirectly finance or benefit armed groups in the Covered Countries; and
  • Expecting the same support activities from their suppliers and distributors through the supply chain and requiring them to do the same through the supply chain.

PowerSecure’s relationships with its suppliers are evaluated on an ongoing basis with a view towards enhancing compliance with this Policy Statement.

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