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I.	Introduction

A.	Company

B.	Supply Chain Overview

C.	Conflict Minerals Policy

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D.	Production Description

II.	Due Diligence Performed

A.	Design of Due Diligence Measures

B.	Due Diligence Measures Implemented

•	maintaining a conflict minerals policy (publicly available in the Investors - Corporate Governance portion of the Company’s website at www.iongeo.com);

•	maintaining an internal, cross-functional team to support supply chain due diligence, including the selection of any new suppliers;

•	implementing internal measures to strengthen company engagement with suppliers;

•	engagement of a third-party vendor, Source Intelligence, to contact the identified suppliers via email and telephone, manage responses and identify the SORs in the supply chain;

•	designed and implemented a strategy to respond to supply chain risks;

•	report findings to senior management; and

•	report annually on supply chain due diligence.

C.	Steps to Improve Due Diligence

•	continue to assess the presence of 3TG in its supply chain;

•	clearly communicate expectations with regard to supplier performance, transparency and sourcing, and target increased response rate for the Reasonable Country of Origin Inquiry (“RCOI”) process;

•	undertake additional fact and risk assessments for risks requiring mitigation, as needed; and

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•	compare RCOI results to information collected via independent conflict free smelter validation programs such as the CFSI’s Conflict-Free Smelter Program as appropriate.

III.	Conflicts Minerals Disclosure

a)	The Company manufactured products for which “conflict minerals” (as defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act) are necessary to the functionality or production thereof.

b)	Based on a RCOI and subsequent due diligence, the Company does not have concrete findings on whether its sourcing practices directly or indirectly funded armed groups in the Covered Countries.

IV.	Independent Private Sector Audit

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