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Dodd-Frank Conflict-Free

In July 2010 the US Dodd-Frank Act required new reporting requirements of SEC listed companies in respect of their use of "conflict minerals", including gold, which might originate from the Democratic Republic of Congo or adjoining countries and which could be directly or indirectly funding armed conflict in that region. The SEC is due to issue specific guidance in respect of these requirements by mid April 2011. Meanwhile a number of industry bodies including the Responsible Jewellery Council, the World Gold Council, and the Electronics Industry Citizenship Coalition are developing "known origin" compliance systems which take account of the specific complexities of the gold supply chain. Metalor, as a leading gold refiner, is actively participating in these initiatives and is fully committed to support its customers, suppliers and agents in being "Dodd-Frank DRC Country Conflict-Free" compliant by implementing appropriate "known origin" systems once guidance is finalized.

It is already the policy and practice of Metalor Technologies SA to maintain high standards of ethical conduct, to comply with all applicable laws, and to do business only with persons who themselves abide by laws and ethical principles. In particular, when dealing in precious metals, we will operate only with transparency by all parties and with assurances of legitimacy in all transactions. In Switzerland Metalor is subject to the Precious Metals Control Act and the Money Laundering Act, and we apply the same principles, expressed through our compliance and ethics policy, throughout the world, wherever Metalor Technologies operates and does business. In January 2011, Metalor became only the fourth certified member of the Responsible Jewellery Council having passed an audit which provides evidence of Metalor's responsible business practices in compliance with the Responsible Jewellery Council's Code of Practices.

Metalor has been sensitive to the issues surrounding DRC gold for a number of years and since 2005 has no longer sourced any gold from Uganda, the only DRC adjoining country Metalor did source from. We believe that the relatively small amount of gold being mined in the DRC, estimated at less than 1 % of the world's annual production, is probably finding its way into less regulated markets where Metalor is not active. To the best of our knowledge, we believe that already today, it is certain that Metalor's gold is not sourced either directly or indirectly from sources in the DRC or its neighbouring countries. Nevertheless, the group is currently conducting additional specific due diligence of its business partners to explicitly confirm this.

If any parties have information that would suggest gold from DRC or its neighbouring countries is being supplied to Metalor we would appreciate to be informed at [email protected].

Response to the SEC

Metalor Technologies USA has submitted comments to the SEC on this topic.

Other known origin enquiries

Metalor has also received known origin enquiries with respect to certain other elements it handles but which are not within the scope of conflict minerals as defined by Dodd-Frank: palladium [1], cobalt [2].

1. Metalor refines palladium and produces palladium plating salts and processes. All of Metalor's palladium is refined from precious metals secondary scrap alloys containing palladium and is only sourced from reputable and vetted suppliers.

2. Metalor uses very small quantities of cobalt in the formulation of some its gold plating processes for decorative and connector applications (less than 0.2 % by weight in the gold deposit). Metalor sources its cobalt salts from reputable suppliers in Switzerland and the USA.

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