The U.S. Conflict Minerals Law (Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act) and the Securities and Exchange Commission Rules adopted in connection therewith, require certain corporations to report the use of “Conflict Minerals” in the manufacture of their products. Generally, Conflict Minerals collectively refer to cassiterite, columbite-tantalite, gold, wolframitic, or their derivatives, including tantalum, tin and tungsten, which originate from the Democratic Republic of the Congo or specified adjoining countries (referred to herein as “Covered Countries”).

While we as a privately held company are not subject to the Conflict Minerals rules and reporting requirement, we understand that our customers may be, and we are committed to helping our customers comply with their reporting requirements.

In order to determine if our manufactured products contain Conflict Minerals, we have conducted a survey of our current key suppliers as of June 1, 2014 to ascertain their use of any Conflict Minerals in the materials they supply to us. The results of that survey demonstrate that based upon our reasonable and good faith inquiry, our key suppliers do not use any of these minerals as additives in any of their processes and therefore, consequently to the best of our knowledge, none of our steel products have used any Conflict Minerals.

We will continue to work with our key suppliers to ensure that we are able to identify the use of Conflict Minerals in our supply chain and the representations made in this compliance statement remain accurate. To that end, we reserve the right to amend this statement at any time based on subsequent development or information.

Should you have any questions or concerns regarding this statement, please do not hesitate to contact us.

McDonald Steel Corporation