Conflict Minerals Policy

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Background

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In August 2012, the U.S Securities and Exchange Commission (“SEC”) adopted conflict minerals rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule”). Conflict Minerals include gold, cassiterite, columbite-tantalite (coltan), wolframite and their three derivatives: tin, tantalum and tungsten. The trade and exploitation of Conflict Minerals originating from the Democratic Republic of the Congo (DRC) and surrounding countries is believed to help finance armed groups that are violating human rights . It is required by the SEC for companies that manufacture or use conflict minerals to provide annual disclosures regarding the origin and status of the conflict minerals.

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Policy Statement

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Lita Trading Corporation, with its subsidiaries, is committed to develop sustainable, practical solutions that create transparency in the supply chain and promote responsible sourcing of minerals. Lita Trading Corp. expects each metal supplier to:

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• Only source the effected minerals from refiners outside of the DRC or from refiners on the LBMA good delivery list, EICC/GeSI conflict – free compliant smelter list, certified member of the Responsible Jewelry Council or refiners that have been certified by an independent third party as “conflict free”.

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• Complete the EICC-GeSI Conflict Minerals reporting template.

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• Develop their own Conflict Minerals Policies and perform due diligence to determine the source of any conflict minerals

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• Cooperate with Lita Trading Corp. in its efforts to comply with any reporting requirements of governmental agencies including, but not limited to, the SEC Conflict Minerals Disclosure Rule.