SMART Technologies ULC Conflict Minerals Policy

SMART Technologies ULC and its affiliates (“SMART”) are committed to sourcing components and materials from companies that share our values on human rights, ethics and environmental responsibility. SMART’S due diligence process follows the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains for Minerals from Conflict-Affected and High-Risk Areas and endorses Section 1502 of the Dodd-Frank Act which aims to prevent the use of tin, tantalum, tungsten, and gold (“3TG”) that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or in adjoining countries.

SMART’s suppliers are evaluated on their commitment to source only from conflict-free smelters. Each supplier to SMART must provide a completed Conflict Minerals Reporting Template (CMRT) from the Responsible Minerals Initiative (RMI) as part of SMART’s Reasonable Country of Origin Inquiry (RCOI) for the 3TG in our supply chain. SMART works with our suppliers to identify and remove conflict-supporting minerals from our supply chain.