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Section 1 – Materials Reference Data & Information

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“Dear Valued Customer,

With regard to the above directive, to the best of KITCO Fiber Optics knowledge and belief, our products do not contain cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs). Threshold limits for these materials are still set at 1,000ppm with the exception of Cadmium and Mercury at 100ppm. Also, in accordance with RoHS Directive (2015/863) referred to as RoHS 3, to the best of KITCO Fiber Optics knowledge and belief, KITCO’s products do not contain Bis(2-Ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), and Di-isobutyl phthalate (DIBP). The threshold limits for these materials are set at 1,000ppm.”

“Dear Valued Customer:

In November 1986, California approved a referendum initiative (“Proposition 65”) requiring warnings about exposures to toxic chemicals. This initiative became known as The Safe Drinking Water and Toxic Enforcement Act of 1986. This Act is found in Sections 25249.5 – 25249.13 of the California Health and Safety Code. The law is intended to prevent contamination of water and to inform residents and workers about exposures of listed chemicals.

Proposition 65 required the Governor of California to publish a list of chemicals that are “known to the State of California” to cause cancer, birth defects or other reproductive harm. The list is updated quarterly. There are hundreds of chemicals on this list. A firm is required to provide a warning before knowingly and intentionally exposing a person to a listed chemical and a firm must not knowingly discharge or release a listed chemical into water or onto land where it passes or probably will pass into a source of drinking water. Listed chemicals include: acrylonitrile, antimony trioxide, arsenic, 1,3 butadiene, cadmium, carbon tetrachloride, carbon black extracts, chlorinated parafins, chloroform, vinyl chloride, hexavalent compounds of chromium, ethyl acrylate, ethylene thiourea, lead and lead compounds, lead acetate, lead phosphate, lead subacetate, nickel, di(2ethylhexyl)phthalate, toluene. The only listed material present in any product used by KITCO is antimony trioxide. This material is present in several polyethylene and PVC insulation and jacket compounds in wire and cable we purchase.

KITCO products that do contain antimony trioxide would be considered exempt from warning labels based on the Proposition 65 wire and cable settlement taking the form of a Consent Judgment submitted to the court in San Francisco. In this judgement it was agreed that Cords and Covered Products which, because of their size, weight or function, are infrequently handled (such as upon their installation in a setting where they are not typically plugged and unplugged). A list of over 200 of these types of infrequently handled products was created in Exhibit F of the Settlement Agreement. Some examples of infrequently handled cords: building wire, printer cables, riser/plenum cable, speaker wire, telecom data cable, telecom power cable, telephone power and data cords, thermostat cable, utility cable, signal cable, power control, instrumentation cable, utility wire, and cable. Also exempt: cords that are internal components not normally accessible to consumers during ordinary use. It is incumbent on the end user to determine if a warning is required and, if so, to provide the required warning.”

“Dear Valued Customer:

REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) is a European Union (EU) initiative also known as EC Directive No. 1907/2006. This directive requires that companies register chemical substances in products being shipped into the EU.

Article 7 (Registration and Notification of Substances in Articles) states the following:

1. Any producer or importer of articles shall submit a registration to the Agency for any substance contained in those articles, if both of the following conditions are met:

(a) The substance is present in those articles in quantities totaling over 1 ton per producer or importer per year;

(b) The substance is intended to be released under normal or reasonable foreseeable conditions of use.

Based on the above statement from the Directive, we have concluded that we are exempt from registering. While it may be possible on rare occasions KITCO Fiber Optics ships more than 1 ton of material into Europe, our products are not intended to be released to the environment under any conditions.

Article 33 of the Regulations also requires the company to disclose if our products contain any of the chemicals on the list of Substances of Very High Concern (SVHC). Neither products, nor any components, contain greater than 0.15% by weight any Substance of Very High Concern”

“Dear Valued Customer,

To the best of KITCO Fiber Optics knowledge and belief, the following substances are not present in the products supplied:

antimony and its compounds, ethylene glycol ethers, organic tin compounds, organophosphate compounds, other phthalates and perfluorooctanoic acid (PFOA).”

“Dear Valued Customer,

KITCO Fiber Optics manufactures products for the aerospace and defense industries. Most products manufactured by KITCO are defined as “Articles” by 29CFR1910.1200(c). Under normal use, our manufactured products will not release or result in any exposure to hazards or hazardous chemicals. Such “Articles” are exempted from SDS labeling and notification requirements by 29CFR1910-1200(b)(6)(iv).

Safety Data Sheets for other products, that include a requirement to be covered by a Safety Data Sheet, will be provided on a case-by-case basis.”

Section 2 – Material Policies and Requirements

Conflict Minerals, as defined by the Dodd-Frank Wall Street Reform and Consumer Protection Act, are:

Columbine
Tantalite (Tantalum)
Cassiterite (Tin)
Wolframite (Tungsten)
Gold

KITCO Fiber Optics does not use any conflict minerals in their raw form. Tin, however, is used as a plating material over bare copper to make un-insulated conductors. Our partner company, Marmon Aerospace & Defense, uses this kind of un-insulated conductors in some of its products, and it purchases such un-insulated conductor from a variety of suppliers. Our conductor suppliers have supplied written statements to us that they do not use conflict minerals in their products. Therefore, to the best of our knowledge, KITCO Fiber Optics does not use conflict minerals in our products or our manufacturing processes.

As used herein, the term “Seller” refers to the person or entity selling goods or services to KITCO Fiber Optics, herein “Buyer”.

POLICY Overview:

Through our ongoing analysis of industry standards and our Quality Management System (QMS) we have aligned ourselves to the industry standards and follow our internal Work Instructions.

1. Our proactive processes:

A. Maximize availability of authentic parts by procuring from reliable sources
B. When it is not possible to buy from OEMs and franchised distributors, develop risk
assessment plans for material procured from non-franchised distributors
C. Ensure adequate testing from approved test houses on material procured from non-franchised distributors to determine suspect part status based on criticality of device, application, and supplier
D. Improve receiving and inspection requirements of non-franchised procured parts to prevent counterfeit parts from entering the supply chain
E. We are continuing to partner and communicate with our customers and suppliers to assure compliance
F. In the case where a change of supply requires customer updating (as required by a contract), KITCO Fiber Optics will contact the customer and solicit approval of new source and/or material choices

Requirements of Seller:

1. Seller represents and warrants each of the following to Buyer:

A. That only new and authentic materials are used in goods delivered to Buyer
B. That the goods or services delivered or sold to Buyer contain no Counterfeit Items
C. That Seller shall only purchase materials or goods for resale to Buyer from authorized Sources such as OEM/OCM’s or authorized Distributors

These representations and warranties shall apply regardless of the source of such goods or materials and irrespective of whether Buyer has approved such source in advance.

2. Seller agrees to provide Buyer with notice in writing prior to acceptance of an order from Buyer if Seller is not an original or franchised source for any item listed on such order.

3. Buyer shall have the right to inspect and test all goods sold or otherwise provided to Buyer, at all times and places before or after acceptance.

4. Seller agrees at all times to maintain, and make available to Buyer upon request, a documented system, policy, procedure, or other documented approach that is intended to prevent counterfeit parts from reaching Buyer. At a minimum, such approach must require prior written approval from Buyer prior to the procurement of any good intended for resale to Buyer from a source other than the original manufacturer or such manufacturer’s authorized distributors.

5. Seller agrees, upon request for up to 7 years from Buyer’s receipt of a good from Seller, to promptly provide Buyer with documentation authenticating traceability of all goods sold to Buyer to the applicable original manufacturer.

6. If Seller sells or otherwise furnishes Buyer with any Counterfeit Item, Buyer shall have the right to impound such items, and Seller shall promptly replace such items with items acceptable to Buyer. In such case, Seller shall be liable to Buyer for all costs relating to impoundment, removal, replacement and proof of physical destruction. Buyer may withhold payment for any Counterfeit Items and may turn such items over to governmental authorities for investigation. Furthermore, Buyer shall notify any affected customers of any violations of our Counterfeit Product Policy and where appropriate Buyer can request an issuing of a GIDEP (Government Industry Data Exchange Program) against the product. Methods to return and/or destroy such nonconforming parts will be handled IAW GIDEP guidelines.

7. Seller acknowledges that any willful act to falsify, conceal or alter a material fact, or any false, fraud or fictitious statement or representation in connection with goods or services provided to Buyer may be punishable in accordance with applicable law and, in some circumstances, could result in criminal penalties.

8. Each of the rights and remedies reserved by Buyer in this Policy shall be cumulative and additional to any other or further remedies provided in law or equity or in any contract between Seller and Buyer. A waiver of a breach of any provision hereof shall not constitute a waiver of any other breach.

9. Seller agrees to include the requirements of this Policy in any subcontract at any tier for the performance of the document incorporating this Policy.

Definitions:

For purposes of this Policy, the following terms shall have the meanings given to them below:

“Authentic” shall mean (i) genuine, (ii) from the legitimate source claimed or implied by the marking and design of the product offered; and (iii) manufactured by, or at the behest and to the standards of, the manufacturer that has lawfully applied its name and trademark for that model/version of the material or good.

“Authorized Source” means (i) the original manufacturer, (ii) the original manufacturer’s authorized distributor, or (iii) any other source where KITCO Fiber Optics has approved of such source in writing and in advance of Seller’s purchase from such source.

“Counterfeit Item” shall mean a good, component, part, module, or assembly whose origin, material, source of manufacture, performance, or characteristics are misrepresented. This term includes but is not limited to, (i) items which have been re-marked to disguise them or falsely represent the identity of the manufacturer, (ii) defective parts and/or surplus material scrapped by the original manufacturer, and (iii) previously used parts pulled or reclaimed and provided as “new.”

Section 3 – Regulations Reference Data and Information

KITCO Fiber Optics complies with EAR (Export Administration Regulations) and ITAR (International Traffic in Arms Regulations). KITCO Fiber Optics is sub-registered with the Department of State as a manufacturer of defense articles under Marmon Group LLC #M21682.