CONFLICT MINERALS POLICY

TrakItNow is a unique player in IoT (Internet of Things) space with solutions catering to Automotive industry, Safety of transit passengers and food quality in Cold Storages. TrakItNow's approach to safety is very innovative and uses TRUE IoT to make your family and friends safe while they are in transit or improve operational efficiencies with cost savings in Automotive or Cold Storage solutions. We strongly believe that safety is everyone's responsibility. TrakItNow safety transit solutions involve various stakeholders like family, friends, community, city police, drivers, and Transit vehicle owners to make the world a safer place.

Policy

TrakItNow Technologies Private Limited is committed to corporate social responsibility and sourcing materials for its products in a socially and environmentally responsible way.

As part of the corporate social responsibility, TrakItNow Technologies Private Limited has been working very closely with our suppliers in understanding our supply chain for several metals commonly used in the electronics industry. The metals of interest are gold (Au), tantalum (Ta), tungsten (W), and tin (Sn). All of our hardware products contain at least one of them.

It is the company’s goal to use the Minerals (Tantalum, Tin, Tungsten, and Gold) that do not directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or adjoining countries (together, the “DRC”) while continuing to support responsible mineral sourcing in the region. The Company expects its suppliers to conduct their business in alignment with the Company’s supply chain responsibility expectations.

The Company has initiated and is in the process of refining its due diligence program for Conflict Minerals consistent with the framework promulgated by the Organization for Economic Cooperation and Development (“OECD”) and its "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" and evaluating its internal controls for Control Minerals, and encourages its suppliers to do the same with their respective suppliers.

The Company will:

provide, and expects its suppliers to cooperate in providing, due diligence information, to assist us in confirming that any Conflict Minerals in our supply chain are “conflict free”;
(a) encouraging its suppliers to purchase materials from smelters who are listed on the Conflict-Free Smelter Program Compliant Smelter List and have been certified as conflict-free by an independent auditor through the Conflict-Free Smelter Program administered by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”); and (b) supporting industry efforts to expand the smelter certification program; and
make available reports on our progress to relevant stakeholders and the public.

Questions and Concerns:

Concerns about, and violations of, this Policy should be reported to the Company’s Compliance Officer.

You can call +91 (40) 6900 0333 in India.

Questions about this Policy should be directed to our Compliance Officer Ms. Sathya Nagasri Rajanala, Project Manager, and Embedded Systems. The Compliance Officer may be reached at +91 9490105442 or at SathyaNagasri.Rajanala@TrakItNow.com.

Suppliers and other external parties are encouraged to contact their regular procurement or business contact at the Company if they wish to seek guidance on this Policy.

7th March 2017