NextComputing, LLC – Conflict Minerals Policy

This document contains NextComputing policy regarding the use of conflict minerals in its products. This policy will be reviewed and updated as needed.

In July 2010, President Obama signed into law the Wall Street Reform and Consumer Protection Act, also known as the Dodd-Frank Act. On August 22, 2012, the Securities and Exchange Commission (the “SEC”) adopted a conflict minerals rule (the “Conflict Minerals Rule”) as mandated by Section 1502 of the Dodd-Frank Act. The Conflict Minerals Rule is intended to reduce a significant source of funding for armed groups that are committing human rights abuses in the Democratic Republic of the Congo (the “DRC”) and its adjoining countries.

To the extent that “conflict minerals” are necessary to the functionality or production of products that NextComputing manufactures or contracts to manufacture, we are required to conduct supply chain diligence to determine whether the conflict minerals originated in the DRC or one of the other “covered countries.”

“Conflict minerals” are defined in the Conflict Minerals Rule as cassiterite, columbite-tantalite (coltan), gold, wolframite and three specified derivatives: tin; tantalum; and tungsten. In addition to the DRC, the “covered countries” are defined in the Conflict Minerals Rule.

Even though NextComputing is not obligated to file under SEC, we seriously intend to the extent possible, to comply with both the letter and spirit of the Conflict Minerals Rule. NextComputing further commits to refrain from, directly or indirectly, supporting any action which contributes to the financing of armed groups that are committing human rights abuses in the DRC and other covered countries.

NextComputing has adopted this policy as part of our efforts to encourage our suppliers to respect human rights and not contribute to conflict. We are promoting the institution of our policy to achieve ultimately the objective of providing to our customers the reasonable types of assurances that they may require that our products are conflict free.

NextComputing does not typically source conflict minerals directly from mines, smelters or refiners; we are removed from these market participants. We require the cooperation of our suppliers in the implementation of this policy and in enabling us to meet its compliance.

To ensure compliance with these requirements, we ask our suppliers to undertake reasonable due diligence with their supply chains to assure that specified metals are being sourced only from mines and smelters outside the “Conflict Region” or mines and smelters which have been certified by an independent third party as “conflict free” if sourced within the “Conflict Region” and provide written evidence documenting of this.

If we discover the use of these minerals produced in facilities that are considered to be “non-conflict free”, in any material, parts or components we procure, we will take appropriate actions to transition product to be “conflict free”.