Conflict Minerals (3TG) Position Statement

For Our Publicly Listed Customers and Partners

We are a privately held company and therefore not directly subject to SEC filing requirements under Section 1502 of the U.S. Dodd-Frank Act. However, because many of our customers are publicly listed and must comply with the SEC’s conflict-minerals rule, we fully support them by conducting supply-chain due diligence on tin, tantalum, tungsten, and gold (3TG) in line with the OECD Due Diligence Guidance and the Responsible Minerals Initiative (RMI) protocols. We provide any additional documentation our customers require so they can meet their legal obligations with confidence. That cooperation, however, does not mean we endorse the law itself.

We are deeply troubled by the way Section 1502 indiscriminately brands the Democratic Republic of the Congo and all nine countries that share a border with it as “covered countries,” without regard for their vastly different realities. Peaceful, well-governed nations such as Rwanda, Tanzania, Zambia, Uganda, and Burundi — countries that have built responsible, traceable, and often exemplary mining sectors — have been unfairly stigmatised by a U.S. law that paints them with the same brush as actual conflict zones.

This blanket approach is discriminatory in its effect and neo-colonial in its design. It has driven many international buyers to simply disengage from legitimate suppliers across East and Southern Africa rather than navigate an overly broad and punitive regulation. The result has too often been lost jobs, reduced government revenues, and hardship for mining communities that have nothing to do with violence.

We source responsibly because it is the right thing to do — not because a flawed U.S. statute forces our customers to demand it. We are proud to stand with our partners and friends in Africa’s peace-loving nations and will continue supporting their world-class traceability systems and sustainable development efforts.

Until Section 1502 is reformed to distinguish clearly between conflict-affected areas and stable, responsible neighbours, we will keep providing our customers with the transparency they are legally required to obtain — while making it unequivocally clear that we reject the current law’s unfair and counterproductive regional scope.

CubePilot Global Pty Ltd December 2025