Conflict Minerals Policy

Federal Refining supports and abides by the SEC Regulations Conflict Minerals initiative and has either obtained, or is in the process of obtaining, information from our current metal suppliers concerning the origin of the metals that are refined by Federal Refiners. Based upon information provided by our suppliers, Federal Refining does not knowingly refine Gold, Silver, Platinum or Palladium derived from the Conflict Region.

Suppliers of scrap metals (specifically gold) must demonstrate that they understand the conflict minerals laws and will not knowingly procure specified metals that originate from the Conflict Region.

Suppliers must review and agree in writing to the following conflict minerals contractual language:

• Supplier represents and warrants that it is in full compliance with conflict minerals laws, including, without limitation, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 as it may be amended from time to time and any regulations, rules, decisions or orders relating thereto adopted by the Securities and Exchange Commission or successor governmental agency responsible for adopting regulations relating thereto (collectively, (“Dodd-Frank Section 1502”).

• Supplier must cooperate with Federal Refining to make available to Federal and/or its agents, full material declarations that identify the sources of and amount of all substances contained in the scrap lots submitted to Federal Refining.

• Supplier must declare each Product’s compliance to all applicable hazardous material legislation and identify any substances that are banned or must be declared under applicable laws. In addition, Supplier will make available any documentation that supports the declaration. Without limiting the generality of the foregoing, Supplier agrees to disclose to Federal Refining, upon Federal Refining request, to the extent known or discoverable by Supplier following inquiry, the original source of all minerals contained in the scrap materials.

• If Supplier does not know the original source of the minerals, Supplier agrees to cooperate with Federal Refining including disclosing from whom Supplier purchased the minerals and urging others to disclose such information, so that the original source of minerals can be accurately determined and reported. Supplier shall comply with all laws regarding the sourcing of minerals, including, without limitation, laws prohibiting the sourcing of minerals from mines controlled by combatants and Dodd-Frank Section 1502.

• Without any further consideration, Supplier shall provide such further cooperation as Federal Refining may reasonably require in order to meet any obligations it may have under conflict minerals laws, including, without limitation, under Dodd-Frank Section 1502.