Conflict Mineral Policy

On August 22, 2012, the U.S. Securities and Exchange Commission (“SEC”) issued the final conflict minerals rule under Section 1502 the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule”). The Conflict Minerals Rule requires companies to report annually the presence of conflict minerals (tin, tungsten, tantalum and gold, or “3TG”) originating in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”).

Newtop supports the goal of ending violence, human rights violations and environmental devastation in the Covered Countries. We are committed to complying with requirements applicable to our Company under Conflict Minerals Rule.

Newtop aims at discouraging the purchase of DCR Conflict Minerals whose revenue may be used to finance or support, both directly or indirectly, armed forces in the Democratic Republic of Congo or in neighbouring countries, regardless of their country of origin.

Newtop requires all suppliers to provide us with complete conflict minerals declarations using the Conflict Minerals Reporting Template. We may reconsider our willingness to cooperate with suppliers that fail to comply with this Policy.