Policy on Conflict Minerals

FOCtek Photonics,Inc. ('' FOCtek '') are committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity and environmental responsibility.

FOCtek is also committed to complying with Section 1502, in particular by complying with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (http://www.oecd.org/daf/inv/mne/mining.htm) (the ''OECD Guidance''), which provides guidance to suppliers in establishing policies, due diligence frameworks and management systems.

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