HOWMET CONFLICT MINERALS POLICY
The Securities and Exchange Commission (“SEC”) has adopted annual disclosure requirements in connection with the conflict minerals provision (Section 1502) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, requiring publicly traded companies to perform due diligence and file annual disclosures containing information about certain minerals necessary to the functionality or production of products manufactured or contracted to be manufactured by such companies. These certain minerals referred to as “conflict minerals” include tantalum (columbite-tantalite), tin (cassiterite), tungsten (wolframite) and gold (“3TGs”), and the diligence required includes investigation into the origins of 3TGs with a humanitarian aim of discouraging sourcing of conflict minerals that would finance conflict in the Democratic Republic of Congo and its nine neighboring countries (the “DRC”) and other conflict-affected or high-risk areas (“CAHRAs”).
Howmet Aerospace Inc. (“Howmet”) supports the humanitarian goal of ending the violence and human rights violations in the DRC and other CAHRAs, which are believed to have been partially financed by the exploitation and trade of conflict minerals. Howmet is also committed to complying with the conflict mineral requirements under the Act as well as all applicable rules and regulations issued by the SEC and other governing bodies. Howmet strives to maintain a conflict-free supply chain and is committed to working with its suppliers to increase transparency regarding the origin of minerals contained in its products. Howmet has published its expectations for suppliers of conflict minerals in its Supplier Code of Conduct which among other things requires Howmet suppliers to undertake reasonable due diligence with their own suppliers to identify whether any of the products supplied to Howmet contain 3TGs sourced from the DRC or other CAHRAs and, if so, whether the mines and smelters identified are certified as “conflict free” by an independent third party.