Conflict Minerals Policy

This document contains the policy of Shadow-caster LED Lighting, LLC (“Shadow-caster”) regarding the use of conflict minerals in its products. This policy will be reviewed and updated as needed.

Regulatory Overview

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. Shadow-caster is a private company and does not file with the SEC, therefore has no legal obligation under this rule. However to any extent that “conflict minerals” are necessary to the functionality or production of products that Shadow-caster manufactures or contracts to manufacture, Shadow-caster will conduct supply chain due 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 as: (1) Angola; (2) Burundi; (3) Central African Republic; (4) the Republic of the Congo; (5) Rwanda; (6) South Sudan; (7) Tanzania; (8) Uganda; and (9) Zambia.

Shadow-caster Policy Statement

While Shadow-caster is not legally obligated, it takes this SEC regulation seriously and intends to comply with the Conflict Minerals Rule. Shadow-caster is committed to avoiding the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. Shadow-caster has adopted this policy as part of our efforts to encourage our suppliers to respect human rights and not contribute to conflict.


Shadow-caster performed a reasonably thorough investigation into the content of all purchased and contract manufactured materials to determine whether or not any of these contain gold, tin, tungsten or tantalum. Results showed that only the following materials consisted of one or more of the defined conflict minerals:  (1) gold plating with a thickness of .00002-.00008 inches on circuit boards, and (2) small amounts of solder containing tin.