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BDI Global Conflict Minerals Statement

In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law. The Dodd-Frank Act and related U.S. Securities and Exchange Commission (SEC) rules mandate assessment and reporting requirements for public companies to disclose the extent to which the products they manufacture or contract to manufacture contain so called conflict minerals -- tin, tantalum, tungsten and gold, sourced from mines in the Democratic Republic of the Congo or adjoining countries.

BDI is committed to helping our customers comply with the reporting requirements, where applicable.

BDI distributes over five million products from more than 6,000 industrial product manufacturer-suppliers. Our products are predominantly used primarily in industrial MRO operations with some OEM applications. Therefore, BDI is not typically within the rule’s scope. While BDI cannot certify to the contents of all the five million products we distribute, BDI integrates conflict minerals compliance into our supply chain management processes as described below.

Supplier Communications
BDI is in contact with our primary manufacturer-suppliers about the rule and have requested they provide certification about the existence and origin of conflict minerals in their products. BDI encourages suppliers to provide documentation confirming possible existence and origin of conflict minerals in their products provided to BDI. If we discover inaccurate information, incomplete documentation, or utilization of smelters or refiners that are not conflict mineral free, we take the appropriate step under OECD guidance. BDI is committed to enhancing our ability to track and trace conflict minerals in our supply chain.

Integration with Supplier Requirements
Suppliers of BDI who manufacture products containing tantalum, tin, tungsten or gold are expected to implement their own conflict mineral policies and procedures throughout their supply chains.

Customer Communications
BDI communicates to our customers about conflict minerals through our website where applicable and through communications including email and post.

Grievance Mechanism and Reporting
BDI employees, suppliers, customers and other parties can report concerns about this Statement or our actions in respect of conflict minerals:

Phone: (216) 642-9100
Email: cjames@bdi-usa.com

Reports can be made anonymously and will be kept confidential to the extent practicable and allowed by law. We will not take retaliatory action against our employees because of making a report in good faith. Our suppliers are encouraged to contact their regular sourcing contact if they wish to seek guidance on the application of this Statement.

We will investigate and, where appropriate, take remedial action to address reported incidents.