Policy for the Conflict Minerals Issue

In the Democratic Republic of the Congo (DRC), the environmental destruction and inhumane acts against local residents perpetrated by armed anti-government militia forces have become a major international issue.

Minerals such as tantalum, tin, tungsten and gold mined illegally in the DRC and adjoining countries have become a source of financing for the armed anti-government militias, and hence, these minerals are called "conflict minerals." With the establishment of the conflict minerals provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act in the US in July 2010 and the declaration of the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas by the OECD, companies that use these minerals for the manufacture or functionality of their products are being strongly urged to conduct their activities appropriately, in an effort to cut off funding to such armed forces.

As a member of the global community, Dynabook is conducting appropriate measures guided by the basic policy outlined below.

In order to ensure compliance with this Policy, Dynabook requires our suppliers to source materials from smelters determined to be conflict-free under the Responsible Minerals Assurance Process (RMAP), established by the Responsible Minerals Initiative (RMI), or other equivalent mechanisms. In addition, Dynabook conducts appropriate measures with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or other internationally-recognized due diligence framework.

Addressing the Conflict Minerals Issue

Dynabook Inc. and its subsidiaries developed and implemented a policy prohibiting use of tin, coltan, wolframite, tantalum, tungsten, and gold, whose extraction or trade supports conflict in the Democratic Republic of the Congo or adjoining countries, and/or contributes to inhumane treatment, including human trafficking, slavery, forced labor, child labor, torture and war crimes in the region.

• We follow the OECD Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High Risk Areas to investigate our supply chain and engage with suppliers.
• We identify the factual circumstances involved in the extraction, transport, handling, process, smelting refining and alloying, manufacturing or selling of products that contains minerals originating from conflict-affected and high-risk areas.
• We expect our suppliers to have policies and due diligence practices in place to assure that products and components supplied to Dynabook Inc. are not sourced from conflict mines.
• We identify and assess any actual or potential risk by evaluating the factual circumstances against standards set out in the company's policy for the Conflict Minerals Issue.
• We prevent or mitigate the identified risks by adopting and implementing a risk management plan. These may result in a decision to temporarily suspend trade through the course of risk mitigation process, or disengage with a supplier.
• We participate and support Responsible Minerals Assurance Process (RMAP). The RMAP program allows Dynabook Inc. to use only conflict-free compliant smelters.
• We request our suppliers to provide us, due diligence information on the sourcing of the tin, tantalum, tungsten and gold in our supply chain.

We conduct conflict minerals survey for our supply chain as part of its due diligence using the Conflict Minerals Reporting Template (CMRT) developed by RMI (Responsible Materials Initiative).