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Policy on Conflict Minerals

Methode Electronics fully supports the goals and objectives of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), which aims to reduce violent conflict in the Democratic Republic of the Congo and certain adjoining countries (“Conflict Region”), by providing transparency regarding the use of certain minerals that finance or benefit armed groups in the region. These minerals include columbite-tantalite (coltan) (i.e., tantalum), cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives (“Conflict Minerals”) and could expand to include other minerals or their derivatives, as determined by the U.S. Secretary of State.

Under Section 1502 of the Act, as well as the related rules issued by the U.S. Securities and Exchange Commission, Methode Electronics is required to annually report to the SEC the presence of any Conflict Minerals, originating in the Conflict Region, in the products it manufactures or contracts to manufacture, if the Conflict Minerals are necessary to the functionality or production of the products. Methode Electronics has initiated a due diligence review of our supply chain, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, to meet these regulatory requirements. In connection with our due diligence review of our supply chain, Methode Electronics will utilize the Electronic Industry Citizenship Coalition due diligence reporting template to obtain information from our suppliers.

The worldwide supply chain for Conflict Minerals is complex and Methode Electronics does not directly source raw materials from smelters of refiners. In order to address the goals and requirements of the Act, Methode Electronics will use a reasonable documented process to assess the use, source and origin of Conflict Minerals in our global product portfolio across our business segments. We will work with our suppliers to determine the potential use of Conflict Minerals in our supply chain and, where appropriate, work with them to remediate issues and source more responsibly. We will expect our suppliers to conduct the necessary inquiry and, where appropriate, additional due diligence to provide us with confirmation of the source of the materials used in their processes and ultimately contained in our products.

As a leading global manufacturer of components and subsystems, Methode Electronics is committed to supporting efforts to reduce violence and human rights violations in the Conflict Region.


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