2015.01.22 Conflict Minerals Control Policy

The A.L.M.T. Group will respect human rights and avoid direct or indirect involvement with inhumane acts, with respect to use, business, handling, and export, of conflict minerals delivered from the conflict-affected areas, namely the Democratic Republic of Congo and its nine surrounding countries.
The A.L.M.T. Group will perform risk control on conflict mineral procurements and will immediately stop any transaction if it is found to be originating from conflict-affected areas.

1. Control System and Responsibility
Of the four minerals listed as “Conflict Minerals”, the A.L.M.T. Group engages only in the smelting of Tungsten, and is not engaged or involved in the smelting of Tin, Tantalum, or Gold. A.L.M.T. Corp. handles all procurement transactions for tungsten materials supplied to A.L.M.T. TUNGSTEN Corp. for smelting. A.L.M.T. TUNGSTEN Corp. does not procure any tungsten raw feedstock independently.
The A.L.M.T. Group will elect a compliance officer, control associated posts, build a system of administration, and promote conflict minerals management.

2. Judgment Criteria for Material Procurement from High-risk Countries
The A.L.M.T. Group considers the procurement of tungsten raw feedstock from the conflict-affected area, the Democratic Republic of the Congo and its nine neighboring countries, as high risk material procurement.

3. Due Diligence relating to Material Suppliers
The A.L.M.T. Group will implement due diligence and perform risk assessments for all suppliers of tungsten raw feedstock to the A.L.M.T. Group. The A.L.M.T. Group will discontinue material purchase transactions that the manager with responsibility for the control of conflict minerals deems to involve high risk as a result of the risk assessment.

4. Monitoring Materials Purchased by A.L.M.T. Corp.
Materials purchased by A.L.M.T. Corp. are supplied to A.L.M.T. TUNGSTEN Corp., which checks the actual goods of every lot to examine its consistency with the information provided from the suppliers in advance. The findings are then reported back to A.L.M.T. Corp.

5. Education
The compliance officer will periodically provide education and training to all related sections of the A.L.M.T. Corp. and A.L.M.T. TUNGSTEN Corp. (A.L.M.T. Group) when it is deemed necessary to do so.

6. Audit implementation by independent third-party
The A.L.M.T. Group will conduct regular internal audits to ensure due diligence for suppliers is executed soundly. The A.L.M.T. Group will also undergo independent third-party audits.

7. Retention of Records
The manager responsible for the control of conflict minerals will stipulate the records that must be retained concerning conflict minerals control, establish the period of retention, and manage the records.

The compliance officer:
- Elected at compliance committee

Scope of management:
- A.L.M.T. Corp. Purchasing Department
– A.L.M.T. Corp.’s’ conflict minerals control manager
- A.L.M.T. Corp.’s purchasing department manager
- A.L.M.T. TUNGSTEN Corp.’s conflict minerals control manager
- President of A.L.M.T. TUNGSTEN Corp.

Control items:
- Due Diligence of suppliers providing tungsten materials
: Procedures to check input and output records
: Retention of Records

November 28, 2014