Conflict Mineral Policy
Rev01 February 21, 2017

Seats Incorporated Conflict Minerals Policy

Seats Incorporated is a Wisconsin corporation that designs, manufactures and markets seating and accessories for operators of vehicles with wheels or tracks. Since Seats Incorporated’s inception in 1952, Seats has become a World Class Leader in Seating Products. Product diversification, innovative design and manufacturing combined with advanced technology generates world class seating.

In July 2010, President Barack Obama signed into law the Wall Street Reform and Consumer Protection Act, also known as the Dodd-Frank Act. This law directed the U.S Securities and Exchange Commission (SEC) to enact rules requiring certain publically traded manufacturing companies to disclose the use of conflict minerals if those conflict minerals are “necessary to the functionality or production of a product” manufactured or contracted to be manufactured by the company.

The definition of “conflict minerals” refers to, tantalum (colton), tin (cassiterite), gold, or tungsten (wolframite), (known as 3TG) regardless of where they are sourced, processed or sold. The U.S. Secretary of State may designate other minerals in the future. Seats Incorporated supports the humanitarian goal of ending violent conflict in the Democratic Republic of the Congo (DRC) or surrounding countries (Sudan, Central Africa Republic, Congo Republic, Angola, Zambia, Tanzania, Uganda, Rwanda and Burundi).

Seats Incorporated is not a publically held company; however Seats Incorporated does supply Seats Products, Accessories, and Service Parts to publically traded companies who are required to file Conflict Mineral Information with the SEC.

Seats Incorporated does not directly purchase raw metal ores that may be used in the manufacturing of our products from smelters or mines. Seats Incorporated’s core business is based off purchasing materials several tiers removed from mining and processing of the 3TG materials. Seats Incorporated must rely on each and every supplier for information pertaining to the potential sourcing of items containing any of the 3TG minerals and whether they are from the DRC or surrounding countries.

Beginning in January 2016 Seats Incorporated will require all suppliers who supply components to Seats Incorporated to submit the industry standard Conflict-Free Sourcing Initiative (CFSI) Reporting Template. The Conflict Minerals Reporting Template (CMRT) can be found at http://www.conflictfreesourcing.org/conflict-minerals-reporting-template/.

As Seats Incorporated customers request Conflict Minerals compliance information Seats will report out based on its findings by each supplier. Seats Incorporated will report out to its customer as requested using the CMRT or other accepted forms by the customer. Seats Incorporated reserves the right to report out on a product by product basis or as a company.

Seats Incorporated is committed to ethical practices and compliance with applicable laws. As a company we will continue to monitor any changes to the Conflict Mineral ruling.

Respectfully,

Nathan Braun- PE
Director of Product Compliance
Seats Incorporated
Reedsburg, WI 53959