Conflict Mineral Policy Statement

Graybar supports our customers' and suppliers' efforts to comply with section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Conflict minerals have been identified as those originating from the "Conflict Region," which includes the Democratic Republic of Congo and surrounding countries that were outside of the supply chain prior to January 31, 2013. The minerals in question are tin, tantalum, tungsten and gold.

Graybar does not manufacture or contract to manufacture any products. However, in our role as a distributor, some of our customers purchase products to be used for the manufacturing of other products, and thus, have their own reporting obligations under the conflict minerals rules. While we cannot certify the country of origin of the minerals contained in the products we sell, Graybar will work to obtain available information from our suppliers for products that are used as components of our customers' products.

Graybar will ask suppliers of these products to engage in a reasonable country of origin inquiry or to perform due diligence of their supply chains. These suppliers will be asked to identify the source of the metals used to manufacture their products and to confirm whether or not the producing mines and smelters have been certified by an independent third party as "DRC conflict free".

Graybar is committed to providing our customers with responsibly sourced products that meet their needs. We encourage our suppliers to source materials that are free from conflict minerals originating in the covered countries and, where appropriate, will work with our customers to obtain DRC conflict free sources of the products they need.