Conflict Minerals Policy

Conflict Minerals Policy

1. Introduction

1.1 Objectives

Checkpoint Systems, Inc. is committed to complying with recent amendments to the Dodd-Frank Wall Street Reform and Consumer Protection Act and related U.S. Securities and Exchange Commission (SEC) rules, which aim to prevent the use of minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or adjacent countries (Sudan, Uganda, Rwanda, Burundi, United Republic of Tanzania, Zambia, Angola, Congo, Central African Republic).

The Dodd-Frank Act and SEC rules require publicly traded companies to disclose whether they use tantalum, tin, tungsten, or gold that originated in the DRC or an adjacent country. If so, companies must submit a report identifying the products that are not conflict free, as well as their due diligence efforts to determine the source and chain of custody of the minerals.

“Conflict free” means the products do not contain tantalum, tin, tungsten, or gold that directly or indirectly finances or benefits armed groups in the DRC or adjacent countries.

1.2 Scope

Checkpoint and all subsidiaries worldwide.

2. Conflict Minerals Policy

2.1 Checkpoint’s Policy Statement

As a manufacturer of electronic components and embedded technology, Checkpoint is committed to sourcing components and materials from suppliers that share our values regarding respect for human rights, integrity, and environmental responsibility.

Accordingly, Checkpoint will not tolerate any direct or indirect support for armed groups from the DRC; criminal networks or perpetrators of serious human rights abuses; and/or sanctioned individuals or entities through the extraction, trade, processing and consumption of minerals. Checkpoint will require all suppliers to use only metals that have been procured through a validated supply chain, so as to ensure that they have not, at any point, financed conflict.

2.2 Responsibilities of Employees

In pursuit of a conflict-free supply chain, Checkpoint employees will use their best efforts in determining the source and mapping of the chain of custody of our minerals.

Employees in engineering and research and development are prohibited from sourcing materials or components from the DRC or adjacent countries and must properly document compliance. In addition, all Checkpoint employees engaged in sourcing third party products or components, regardless of department, shall install controls to ensure DRC-Conflict Free products and engage supply chain teams for each line of business in the screening process.

Employees are required to obtain reliable representations from suppliers that its conflict minerals did not originate from the DRC or adjacent countries.

Employees should apply reasonable skepticism and judgment when assessing statements from suppliers and be aware of any red flags that could be counter indicative to the suppliers’ statements, such as the pricing of materials, location of the supplier, purity/quality of materials used for products, etc.

Employees are explicitly prohibited from procuring parts or materials from suppliers sourcing metals either known to be derived from conflict regions or designated as not DRC-Conflict Free.

Employees must use commercially reasonable means including determining alternative sources of supply, cease sourcing from suppliers where they identify a reasonable risk that suppliers are sourcing from, or linked to any party committing human rights violations in the DRC or adjacent countries.

2.3 Employee Acknowledgement

Checkpoint employees responsible for the process of engineering, research and development, manufacturing or sourcing products shall execute an acknowledgement as determined by Legal in its sole discretion on at least an annual basis certifying compliance with this policy.