•	Step 1A - Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas.

◦	Implemented a conflict minerals policy;

◦	Publicized the policy at https://www.hamiltonbeach.com/social-accountability-policy; and,

◦	Communicated the policy directly to suppliers as part of RCOI process.

•	Step 1B - Structure internal management to support supply chain due diligence.

◦	Maintained an internal cross functional team to support supply chain due diligence;

◦	Appointed a member of senior staff with the necessary competence, knowledge and experience to oversee supply chain due diligence; and

◦	Invested the resources necessary to support the operation and monitoring of these processes, including internal resources and external consulting support.

•	Step 1C - Establish a system of transparency, information collection and control over the supply chain.

◦	Implemented a process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data-gathering are included in the RCOI and due diligence sections of this CMR.

•	Step 1D - Enhance company engagement with suppliers.

◦	Engaged suppliers directly during RCOI process;

◦	Reviewed supplier responses as part of RCOI process;

◦	Added conflict minerals compliance to new supplier contracts and HBB’s supplier code of conduct; and

◦	Implemented a plan to improve the quantity and quality of supplier and smelter responses year-over-year.

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•	Step 1E - Establish a company and/or mine level grievance mechanism.

◦	Recognized the RMAP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances; and

◦	HBB’s ethics violations reporting system allows employees to voice confidentially without any fear of retribution, any concerns with suspected violations of HBB’s conflict minerals policy

•	Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance); and

•	Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance).

•	Developed a list of suppliers providing 3TG containing components to HBB;

•	Contacted each supplier and requested the industry standard Conflict Minerals Reporting Template (“CMRT”) including smelter information;

•	Reviewed supplier responses for accuracy and completeness; and

•	Amalgamated supplier provided smelters into a single unique list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols.

•	Identify the scope of the risk assessment of the mineral supply chain (OECD Step 2B);

•	Assess whether the smelters/refiners have performed all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Step 2C); and,

•	Perform joint spot checks at the mineral smelter/refiner’s own facilities, as necessary, through participation in industry-driven programs (OECD Step 2D).

•	Direct engagement of the smelter to determine whether the smelter sourced from the DRC or surrounding countries;

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For smelters that declared directly (e.g., email correspondence, publicly available conflict minerals policy, or information available on their website) or through their relevant industry association that they did not source from the DRC or surrounding countries, and were not recognized as conflict free by the RMAP, HBB reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration. The sources reviewed included:

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◦	Public internet search (Google) of the facility in combination with each of the Covered Countries;

◦	Review of specific Non-Governmental Organizations (“NGO”) publications. NGO publications reviewed included:

▪	Enough Project;

▪	Global Witness;

▪	Southern Africa Resource Watch;

▪	Radio Okapi; and

▪	The most recent UN Group of Experts report on the DRC.

•	For smelters that did not respond to direct engagement, HBB reviewed publicly available sources to determine if there was “any reason to believe” that the smelter may have sourced from the Covered Countries during the reporting period.

◦	HBB reviewed the same sources as those used to compare against smelter sourcing declarations.

•	For “high-risk smelters” (i.e., smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries and not conformant to the RMAP), HBB communicates the risk to a designated member of senior management (OECD Step 3A) and conducts risk mitigation on the smelter according to OECD Step 3B.

•	Including a conflict minerals provision in all new and renewing supplier contracts;

•	Including Conflict Minerals compliance to HBB’s supplier code of conduct;

•	Continuing to encourage suppliers to obtain current, accurate and complete information about the smelters in their supply chain; and

•	Encouraging smelters sourcing from Covered Countries to be conformant to the RMAP.

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