Conflict Minerals Policy

Glines & Rhodes, Inc. is aware of the allegations of illegal precious metals mining occurring in the Democratic Republic of the Congo (DRC) and other
internationally recognized conflict areas, and that profits thereof may be fuelling human rights violations.

Glines & Rhodes, Inc. opposes all activities which deny basic human rights and is firmly opposed to all activities which finance or contribute to the
abuses of human rights. In response to these concerns, Glines & Rhodes, Inc. has implemented a protocol to help ensure that our supply chain, both
upstream and downstream, remains responsible and compliant with establishedindustry standards for Conflict-Free Mineral trading.  As part of this
protocol, Glines & Rhodes, Inc. has introduced a Conflict Minerals Supplier Reporting Program, aimed at identifying and validating the chain of custody of incoming gold-bearing material.

Glines & Rhodes, Inc. is committed to meeting its social responsibilities, and encourages its refining customers to do their part in ensuring that their materials are not sourced from illegitimate mining operations in either the DRC or other internationally recognized conflict areas, by participating in the Glines & Rhodes, Inc. Conflict Minerals Supplier Reporting Program.

Glines & Rhodes, Inc. is in compliance with the current legislation in regard to the Dodd-Frank Act and is in adherence with the policy to refuse to refine materials from “conflicted areas.”  Glines & Rhodes, Inc. will continue to review the legislation as it evolves to maintain our compliance with the bill and any reporting requirements.