Conflict Minerals Policy

The Securities and Exchange Commission (the “SEC”) adopted a conflict minerals rule (the “Conflict Minerals Rule”) as mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. “Conflict minerals” are defined in the Conflict Minerals Rule as cassiterite, columbite-tantalite (coltan), gold, wolframite and three specified derivatives: tin; tantalum; and tungsten. Revenue from the mining and transport of these conflict minerals is believed to be financing or benefiting groups that are responsible for human rights violations.

IES takes its obligations under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding conflict minerals seriously. To that end, IES is taking steps to determine the origin and status of any conflict minerals that may be necessary to its products’ functionality or production. IES does not directly source conflict minerals from mines, smelters or refiners, and is in most cases several levels removed from these market participants. IES therefore requires the cooperation of its private label suppliers in the implementation and execution of its processes to comply with the rule.

IES seeks to work with suppliers who will share its commitment in working towards compliance with this policy. IES reserves the right to request from any supplier at any time such information, certifications, and documentation as it shall deem necessary to monitor or assess compliance with this policy.

 

 

Adopted March 28, 2018