This policy sets forth the Company’s expectations that its applicable suppliers complete annual training on the policy, submit an annual conflict minerals survey, and source from a smelter or refiner that has obtained a “conflict-free” designation with an independent private-sector audit, such as those from the Conflict-Free Smelter Program, the “Good Delivery” list of the London Bullion Market Association and the Responsible Jewellery Council’s Chain-of-Custody Standard.