Carrara, May 16th, 2025

Dear Customer:

On August 22nd, 2012 the Securities and Exchange Commission (SEC) published regulations implementing the conflict minerals reporting obligations of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer protection Act of 2010. The regulations apply to companies required to report to the SEC. On May 17th, 2017, following this legislation, the European Parliament published the EU Conflict Minerals Regulation (EU) 2017/821 with the purpose of preventing the minerals trade from financing conflict or human rights abuses. Such companies are required to determine whether Tin, Tungsten, Tantalum and Gold (3T&G) are necessary to the production or functionality of their products, and if so, to report to the authorities whether these minerals in their products (i) originated from sources in the Democratic Republic of the Congo, India, Madagascar or adjoining countries and (ii) directly or indirectly financed or benefited armed groups in those countries, (iii) including child labor and unsafe working conditions in mining. We refer to these as conflict sources.

While our due diligence program focuses on Tin, Tantalum, Tungsten, and Gold (3TG) in accordance with the Dodd-Frank Wall Street Reform and Consumer protection Act of 2010 and the EU Conflict Minerals Regulation (EU) 2017/821, we also acknowledge growing expectations to address other materials that may constitute similar human-rights or environmental risks. Therefore, our responsible sourcing efforts are being expanded to include Cobalt, Copper, Graphite, Lithium, Mica, Nickel, and Zinc, among others, following the OECD Due Diligence Guidance, on which the cited rules are based. We choose to do deeper control over these minerals, even if the cited rules do not cover explicitly them, because they are necessary to the functionality of AvMap products.

AvMap does not purchase minerals directly from smelters or refiners (SORs).
We are aware about the complexity of this matter due to the extremely diffused presence of Tin, Tungsten, Tantalum, Gold, Cobalt, Copper, Graphite, Lithium, Mica, Nickel and Zinc (in particular in Electronics) and wide potential mineral sources both as smelters and refiners.
We are doing everything we can according with our program to comply with Conflict Mineral related regulations, working to assess the status of our supply chain and, if identified, to avoid the use of supplier materials from conflict related sources.

Simone Lazzarini
Managing Director
AvMap S.r.l.