Compliance

Compliance Material

On July 21, 2010, Congress passed the Dodd-Frank Act (the “Act”). The Act directs the U.S. Securities and Exchange Commission (the “SEC”) to adopt rules requiring certain companies to provide disclosures regarding the use of specified “conflict materials” emanating from the Democratic Republic of Congo and nine (9) adjoining countries. On August 22, 2012, the SEC adopted rules regarding conflict minerals disclosure. The rules only apply to companies that file reports with the SEC pursuant to Sections 13(a) or 15(d) of the Securities Exchange Act of 1934.

Werner Electric Supply, as a privately held company, does not file, and is not required to file with the SEC. However, we fully support the ethical goals of the Conflict Minerals legislation. We will also support our customers, as needed, in their efforts to become compliant.

• Dodd-Frank Act letter concerning Conflict Materials Compliance

For more information on the conflict materials compliance, please visit the Conflict Minerals Reporting Template.

Buy American Act / ARRA

The Buy American Act or ARRA restricts the purchase of supplies that are not domestic end products for use in the United States.

Two Part Test to Define a Domestic End Product:

Must be manufactured in the United States.

The cost of domestic products must exceed 50% of the cost of all components.

A foreign end product may be purchased if the contracting officer determines that the price of the lowest domestic offer is unreasonable or if other exceptions apply. Generally, the dollar value of the acquisition determines which of the trade agreements apply.

When using funds appropriated under the American Recovery and Reinvestment Act of 2009, the definition of “domestic manufactured construction material” requires that the product was manufactured in the United States, but has no requirement regarding the origin of the components. If the construction material is entirely or predominantly iron or steel, the iron or steel must have been produced in the United States.