January 01, 2015

17 CFR 249b.400 Section 1, Item 1.01(d)(3) defines “conflict mineral” as “columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, unless the Secretary of State Determines that additional derivatives are financing conflict in the Democratic Republic of the Congo or an adjoining country.” As of the date of this letter, the Secretary of State has not made any additional determinations.

Commercial Fluid Power’s steel tubing and bar products do not contain the minerals or their derivatives as defined above, other than trace impurity levels that are not necessary to the functionality of the product, obviating the need to further investigate Commercial Fluid Power’s supply chain to determine country of origin.

Michael D. Sims
VP/GM
Commercial Fluid Power