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Conflict Minerals

Armed groups engaged in mining operations in the Democratic Republic of the Congo and adjoining countries are believed to be subjecting workers to serious human rights abuses and are using proceeds from the sale of conflict minerals (tantalum, tin, tungsten, and gold, or “3TG”) to finance regional conflicts. In response to these concerns, the US Congress enacted Section 1502 of the Dodd‐Frank Wall Street Reform and Consumer Protection Act aimed at preventing the use of conflict minerals that finance or benefit these armed groups. The legislation requires US publicly traded companies using conflict minerals in their products to disclose the source of such minerals.

For more information on Conflict Minerals and Section 1502 of the Dodd‐Frank Wall Street Reform and Consumer Protection Act, please access the final rule on the SEC website: http://www.sec.gov/rules/final/2012/34-67716.pdf

ASSA ABLOY Americas Position on Conflict Minerals

While ASSA ABLOY Americas is not a US publicly traded company subject to SEC reporting, ASSA ABLOY Americas fully supports avoiding the use of conflict minerals and will act responsibly to ensure that our products meet the needs of our customers and to support the aim of this legislation.

Electromechanical products from ASSA ABLOY Americas brands, like most electronic products, use some of the 3TG materials as they are required for the functional performance of the products. However, ASSA ABLOY Americas does not purchase these materials directly from smelters or mines, so we must rely on information provided by our suppliers to determine the origin of the materials. ASSA ABLOY Americas is currently in the process of engaging its supply chain, both directly and through the use of a third party database, to ensure that used materials are DRC conflict free. Until this supply chain audit can be completed, ASSA ABLOY Americas' conflict mineral status is “DRC conflict undeterminable.”

In order to help issuers address some of the burdens and costs of compliance associated with conflict mineral reporting and to allow the necessary traceability systems in the covered countries to be established, the final implementation of Section 1502 allows all issuers to declare “DRC conflict undeterminable” for the first two reporting periods. ASSA ABLOY Americas expects to have information available for the reporting requirements of our customers prior to the May 31, 2015 reporting date when “DRC conflict undeterminable” is no longer acceptable. Updates to ASSA ABLOY Americas’ conflict minerals status and policy will be posted on our sustainability website: www.assaabloydss.com/sustainability.

If you have specific questions regarding ASSA ABLOY Americas' products and Conflict Minerals please contact Mr. Aaron Smith at Contact.