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Orbital Research Ltd is very concerned with the violence and exploitation of human rights and abuses. We are a company that takes full responsibility of our own working environment, to be respectful of Human Rights, Ethics and our Environment.

The United States Securities and Exchange Commission (US SEC) recently adopted Section 1502, Conflict Minerals of the Dodd-Frank Act. This rule requires that SEC Registrants annually disclose whether Conflict Minerals necessary to the functionality or production of their products, are sourced from the Democratic Republic of Congo (DRC) or adjoining countries.

The goal of the act is to eliminate funding of any mines in the DRC that are controlled by armed militias responsible for humanitarian harm, including abuses against women and children.

While Orbital Research Ltd is not subject to the Final Rule because the company is privately held and not subject to SEC regulation, we understand that our customers may be, and we are committed to helping our customers comply with their reporting requirements. We will comply and exercise due diligence in respect of the exploitation and trading of designated minerals.

We do not intentionally add any of the four conflict minerals subject to the Final Rule to the products that we supply to you, our customers.

Like many companies in electronic product industries, we use some of these materials in the manufacturing of its products as they are required for the functional performance of the products. Orbital does not purchase these minerals directly from smelters or mines, so we must rely on the source information provided by our suppliers. We will continue to work with our suppliers to take reasonable measures to ensure that our products are free of minerals subject to the final rule. We will continue developing and conducting reasonable country-of-origin inquiry and due diligence.

We also reserve the right to amend this statement at any time based on subsequent developments or information that we may receive.

Ian MᶜEachern
Orbital Research Ltd

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