Conflict-Free Minerals Policy

Responsible sourcing and funding

Stern Brands, Inc., dba Trinetics Group and Just in Time are committed to ensuring that we are not sourcing minerals (tin, tantalum, tungsten, gold) that fund armed groups in the Democratic Republic of Congo and adjoining countries. We do not ban sourcing of minerals from this region because such a policy may harm legitimate miners.

We’re taking steps within our entire supply chain to confirm our sourcing does not fund armed groups in the DRC and adjoining countries. As part of this program, we continue to carry out a reasonable country of origin inquiry on the products we manufacture and perform supply chain due diligence following the processes and procedures set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Our Chief Ethics and Compliance Officer, Sara Stern, also identified as CEO, is responsible for the efforts of our team.

We expect suppliers to have a policy in place and implement a system to trace the origin of tin, tantalum, tungsten, and gold supplied to the Company, following the template developed by the Responsible Minerals Initiative. Suppliers are encouraged to report any ethical concerns or policy violations to: Sara Stern, CEO, Stern Brands, Inc., dba Trinetics Group and Just in Time at sara.stern@trineticsgroup.com.

If any external business partner has challenges in complying with our expectation, we’ll attempt to work to address these challenges. If compliance cannot be achieved, we will terminate the relationship with the external business partner.