Garan Incorporated Conflict Minerals Policy

November 17, 2015

As a subsidiary of Berkshire Hathaway Inc., Garan is required to report to Berkshire Hathaway Inc. a complete report of our Reasonable Country of Origin Inquiry (RCOI) and complete details of our due diligence in determining where the 3TG’s used in the manufacturing of our products were mined and provide the names and addresses of the smelters used to process the minerals.

In 2010, Congress enacted the Conflict Minerals provisions of the Dodd - Frank Wall Street Reform and Consumer Protection Act (Dodd - Frank Act). The act was enacted because of concerns that the exploitation and illegal trade in Conflict Minerals (Tin, Tantalum, Tungsten and Gold), (3TG’s) by armed groups is helping to finance conflict in the DRC region and is contributing to a humanitarian crisis. The goal is to cut the funding of armed groups in the Democratic Republic of the Congo (DRC) and its neighboring countries, Angola, Burundi, Central African Republic, The Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia that have directly or indirectly contributed to human rights abuses. Section 1502 of the Dodd - Frank Act requires publicly traded companies to report to the U.S. Securities and Exchange Commission (SEC) whether any of the 3TG’s in the products they manufacture or contract to manufacture originated from the DRC Region and the due diligence steps taken to determine if the sale of the minerals finance or benefit armed groups in the conflict region.

Garan is not a publicly traded company but we share in the responsibility to source responsibly when using any of the 3TG’s in the products we manufacture or contract to manufacture.

Garan’s Commitment to Responsible Sourcing

Garan is committed to operating and sourcing in an ethically socially responsible manner, ensuring our principles are honored in all our business decisions, including those with our customers, manufacturers, suppliers and licensees. We are committed to taking the necessary steps needed to ensure the products we manufacture, purchase from other manufacturers and suppliers, as well as those manufactured by our licensees are sourced from companies that share our human rights, ethics, social, and environmental responsibility. Garan is dedicated to preventing the sale of products produced at the expense of communities and workers in the Conflict Region.

Due to the limited use of the 3TG’s in the production of our products, where possible, we will avoid using any components made from minerals sourced in the DRC Region. When it is necessary to use a component that contains Tin, Tantalum, Tungsten or Gold, we are committed to working with our suppliers to increase the transparency regarding the origin and traceability of the minerals used in our products to ensure our products do not contain unethically sourced minerals.

Garan’s Expectation of Suppliers

Garan is committed to responsible sourcing of materials for our products, including the sourcing of Conflict Minerals, and expect our suppliers to also be committed to responsible sourcing. We expect our relevant suppliers to provide a chain of custody declaration taking steps to identify the origin of the Tin, Tantalum, Tungsten and/or Gold contained in their products and to support efforts to stop the use of Conflict Minerals that directly or indirectly finance or benefit armed groups in the covered countries. In addition, we require the following from our suppliers:

If there are any questions concerning Garan’s Conflict Minerals Policy they can be addressed to ConflictMinerals@Garan.com.

Conflict Minerals Management System

Overview

Garan is not a publicly traded company and is therefore not required to report to the Securities and Exchange Commission concerning any applicable minerals in our products but as we are owned by Berkshire Hathaway Inc. and they are a publicly traded company, we are required to report to Berkshire Hathaway Inc. information concerning any Conflict Minerals used in our products or components of our products.

The Dodd-Frank Act requires disclosure of certain information when a company manufactures or contracts to manufacture products and Tin, Tantalum, Tungsten and/or Gold (3TG’s) is necessary to the functionality or production of those products. If products or components of products contain even trace amounts of the 3TG’s, due diligence must be used to determine where the minerals were mined. If the minerals are determined to originate in the Democratic Republic of Congo or adjoining countries consisting of Angola, The Republic of Congo, Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania or Zambia, the minerals are considered Conflict Minerals and are subject to the reporting rule. This requires the company to trace the mineral used in the component back to the mine, the route of transporting to the smelter and provide the actual smelter/refinery name and address where the mineral was processed where possible. Due to the serious abuses associated with the extraction, transport and trade of the minerals in the High Risk area of the Democratic Republic of Congo and adjoining countries, the minerals extracted from this region are considered Conflict Minerals.

Step 1: Establish Strong Company Management Systems:

Step 2: Identify and assess risks in the supply chain:

Step 3: Design and implement a strategy to respond to identified risks:

Step 4: Carry out independent third - party audit of smelter/refiner’s due diligence practices:

Step 5: Report annually on supply chain due diligence:


Download PDF