ROHS Letter

Dear Valued Customer,

With respect to Directive 2011/65/EU of European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (the “RoHS2 Directive”), American Metal Group on issues the following statement:

Except to the extent subject to an exemption under the RoHS2 Directive, including that for lead in certain steel grades where lead is intentionally added as an alloying element, American Metal Group confirms that our products comply with the RoHS2 Directive and do not contain any of the restricted substances above the currently proposed general limits.

Lead in the referenced steel grades will exceed the 0.1% by weight general limit, but will, however, meet the RoHS2 Directive limit of 0.35% by weight maximum content for “lead as an alloying element in steel.” (Such steel grades are commonly identified by the letter “L” following the second numeral of the grade designation, for example, 12L14).

Therefore, all our cold finish products are compliant with the threshold requirements of the RoHS2 Directive. This conclusion is based on information received from our suppliers and knowledge of our manufacturing process.

Please contact your local American Metal Group representative if you have any questions or need further information. Thank you for your continued support American Metal Group.

REACH Compliance

Dear Valued Customer,

Re: European REACH Regulation Compliance Letter

This letter establishes the opinion of American Metal Group regarding the status, under the current European Union (“EU”) Regulations on Registration, Evaluation, Authorization, and Restriction of Chemical Substances (“REACH”)1 , of the product American Metal Group supplies to your organization in the United States, with the understanding that your organization may subsequently send this product to the EU. We have no hesitation in concluding that, under these circumstances, the products we provide to your organization meet the criteria for an “Article” under REACH.

American Metal Group is not required by REACH to register or pre-register the substances used in “preparations” that are sold outside of the EU. In addition, Articles are exempt from the REACH requirements if (a) the Article does not contain a substance of very high concern or candidate substance in an amount exceeding 0.1% weight by weight, and (b) if substances present in the Article in excess of 1 ton per year per importer are not expected nor intended to be released.3 Neither of these conditions apply to American Metal Group products or similar Articles. Therefore REACH does not require American Metal Group to register, preregister, notify, or communicate the substances contained within the Articles that American Metal Group supplies to your company.

We trust that you will find this letter fully responsive to your request. Should you have any further questions, or if we may be of assistance in any other way, please, do not hesitate to contact us.

Thank you for your continued support of American Metal Group.

Proposition 65 Warning

Proposition 65 requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects or other reproductive harm. These chemicals can be in the products that Californians purchase, in their homes or workplaces, or that are released into the environment. By requiring that this information be provided, Proposition 65 enables Californians to make informed decisions about their exposures to these chemicals.

The raw materials that American Metal Group uses to manufacture its products all contain nickel, antimony, arsenic, beryllium, chromium, cobalt, cadmium, and those with an “L” in the product number, lead, which are listed under Proposition 65 by California as chemicals (metals) known to the state to cause cancer or reproductive toxicity. American Metal Group does not add any of these substances to its products through its manufacturing processes.

For further information regarding our products, please refer to the Material Safety data Sheet for the applicable product.

LEED Statement

Dear Valued Customers,

In an effort to provide information on American Metal Group’s products and their contribution to the environment, we are proud to share the following information with you. As you know, steel has long been recognized and considered one of the most recycled building products with a high reclamation rate. Recent interest in recycling has been driven by the US Green Building Council’s Leadership in Energy and Environmental Design (LEED) rating system. The LEED rating system only promotes the use of materials with high levels of recycled content.

We process steel bars from a number of hot roll steel bar producers who use both electric arc furnace (EAF) and basic oxygen furnace (BOF) steel manufacturing methods. The EAF method typically uses between 95-100 percent old steel to make new while the BOF process typically uses between 25-35 percent old steel to make new. Which original material process we choose to use is driven by not only economic considerations but also application specifications of the end user.

In either case, our methods of cold finishing bars leaves no waste; any scrap produced in our cold finishing process is reclaimed and 100 percent recycled back to the steelmaking processes described. We hope this information is helpful. Should you have any questions please do not hesitate to contact your American Metal Group sales representative. Thank you for your continued support of American Metal Group.

Conflict Minerals Compliance

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 refers to cassiterite, columbite-tantalite, gold, wolframite, 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 corporation, are not subject to the Conflict Minerals rules and reporting requirements, 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 key suppliers, as of January 1, 2020, to ascertain their use of any Conflict Minerals in the materials they supply to us. The results of that survey demonstrate that our key suppliers (i) do not use Conflict Minerals in the materials they supply to us, (ii) have no reason to believe the Conflict Minerals they use may have originated in the Covered Countries, and/or (iii) reasonably believe that the Conflict Minerals they use are from recycled or scrap sources. Consequently, we can in turn represent that, to the best of our knowledge, our manufactured products either do not contain Conflict Minerals, or to the extent they may, such products are “DRC conflict free” as defined by paragraph (e)(4) of Section 1502.

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 developments or information.

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

American Metal Group