Ecomass’ Signed Dodd Frank Declaration

(Follow the link above to view Ecomass Technologies’ signed Dodd Frank Declaration).

Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act

The Securities and Exchange Commission has adopted a rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”) to require companies to publicly disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (DRC) or an adjoining country.

Under the final rule, companies will file their first specialized disclosure report on May 31, 2014 (for the 2013 calendar year) and annually on May 31 every year thereafter.

Policy

By policy, Ecomass Technologies will not source any tantalum, tin, gold or tungsten originating from the DRC or an adjoining country and will comply with the letter and spirit of Section 1502 of the Dodd-Frank Act.

Declaration

Ecomass Technologies has contracted with certain suppliers and producers of tin and tungsten to produce certain tin and tungsten-based products. Employees of Ecomass Technologies have conducted reasonable country-of-origin inquiries and on-site inspections of the facilities where its tin and tungsten-based products are produced and, as a result, know that the minerals referenced in the Dodd-Frank Act did not originate in the covered countries or are from scrap or recycled sources.

Although Ecomass Technologies is not required to file SEC Form SD annually, as it is not required to file reports with the SEC under the Exchange Act, we trust that this declaration will provide our customers with the knowledge and assurance that we and they are in full compliance with Section 1502 of the Dodd-Frank Act.

Background

In 2010, Congress passed the Dodd-Frank Act, which directs the Commission to issue rules requiring certain companies to disclose their use of conflict minerals if those minerals are “necessary to the functionality or production of a product” manufactured by those companies. Under the Act, those minerals include tantalum, tin, gold or tungsten.

Congress enacted Section 1502 of the Act because of concerns that the exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the DRC region and is contributing to an emergency humanitarian crisis. Section 1502 of the Act amends the Securities and Exchange Act of 1934 to add Section 13(p).

The Rule

The final rule applies to a company that uses minerals including tantalum, tin, gold, or tungsten if:

• The company files reports with the SEC under the Exchange Act; and
• The minerals are “necessary to the functionality or production” of a product manufactured or contracted to be manufactured by the company.

The final rule requires a company to provide the disclosure on a new form to be filed with the SEC (Form SD).

Determining Whether Conflict Minerals Originated in the DRC or Other Covered Countries

Under the final rule, a company that uses any of the designated minerals is required to conduct a reasonable ‘country of origin’ inquiry that must be performed in good faith and be reasonably designed to determine whether any of its minerals originated in the covered countries or are from scrap or recycled sources.

If the inquiry determines either of the following to be true:

• The company knows that the minerals did not originate in the covered countries or are from scrap or recycled sources.
• The company has no reason to believe that the minerals may have originated in the covered countries or may not be from scrap or recycled sources.

Then the company must disclose its determination, provide a brief description of the inquiry it undertook and the results of the inquiry on Form SD.

The company also is required to:

• Make its description publicly available on its Internet website.
• Provide the Internet address of that site in the Form SD.