Ballard Power : Conflict Minerals Policy

	Ballard Power Systems	Revision: 0A
	Corporate	Page: 1 of 3
	Policy - POL5100162	Department: Supply Chain
	TITLE: Conflict Minerals Policy

Revision Record

Rev	CO		Description	Revised by	Date
0A	CO21713	Initial release		K. Layegh	May 20, 2014

Created by: Karm Layegh	Date: May 20, 2014
Approved by: Paul Cass	Date: September 4, 2014
Approved by: David Whyte	Date: September 4, 2014
Approved by: Kerry Hillier	Date: September 4, 2014

THIS DOCUMENT, SUBMITTED IN CONFIDENCE, CONTAINS PROPRIETARY INFORMATION WHICH SHALL NOT BE REPRODUCED OR TRANSFERRED TO OTHER DOCUMENTS OR DISCLOSED TO OTHERS OR USED FOR MANUFACTURING OR ANY OTHER PURPOSE WITHOUT PRIOR WRITTEN PERMISSION OF BALLARD POWER SYSTEMS.

THIS DOCUMENT IS VALID ONLY AT TIME OF PRINTING. ANY COPIES MADE ARE CONSIDERED UNCONTROLLED UNLESS STAMPED OTHERWISE IN RED.

Commercial Confidential

Printed on: Thursday, September 04,

2014

TEMPLATE FRM5000215 0A

	Ballard Power Systems	Revision: 0A
	Corporate	Page: 2 of 3
	Policy - POL5100162	Department: Supply Chain
	TITLE: Conflict Minerals Policy

1.0 Purpose

To ensure Ballard Power Systems is taking all reasonable steps to avoid purchasing and using conflict minerals in its manufactured products.

2.0 Scope

The policy described herein is applicable to all products manufactured by Ballard Power Systems or any of its subsidiaries.

3.0 Definitions

BPS: Ballard Power Systems Inc.

DRC: Democratic Republic of Congo

SEC: US Securities and Exchange Commission

4.0 Policy

The mining of certain minerals from the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries has financed armed conflict, resulting in violence and human rights violations in the region. In July 2010, the US Congress passed legislation requiring the US Securities and Exchange Commission (SEC) to adopt rules that all US publicly traded companies must disclose their use of conflict minerals. The SEC defines "conflict minerals" as cassiterite, columbite-tantalite, gold, wolframite, or their derivatives (specifically, tin, tantalum, and tungsten), or any other minerals or their derivatives determined by the US Secretary of State to be financing conflict in this region.

Ballard is committed to avoiding the use of conflict minerals which directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. Ballard is committed to complying with the reporting obligations required by the SEC, including the requirement that Ballard conduct inquiries into the source of any conflict minerals included in its products.

Ballard does not directly purchase or source the raw metals used in our products and tracing the path of minerals throughout our supply chain is a complex process. Although we do not have complete visibility into the sources of all component minerals, we actively engage with our suppliers to promote responsible sourcing practices, and we conduct due diligence to determine whether the materials provided by our suppliers contain conflict minerals.

Ballard suppliers are required to acknowledge Ballard's Code of Conduct, which includes requirements regarding conflict minerals and responsible sourcing. Suppliers are also responsible for passing the same requirements on to their suppliers.

Suppliers will be required to declare that all products supplied either:

• Do not contain tantalum, tin, tungsten or gold that are necessary to their production or functionality, or,

THIS DOCUMENT IS VALID ONLY AT TIME OF PRINTING. ANY COPIES MADE ARE CONSIDERED UNCONTROLLED UNLESS STAMPED OTHERWISE IN RED.

Commercial Confidential

Printed on: Thursday, September 04,

2014

TEMPLATE FRM5000215 0A

	Ballard Power Systems	Revision: 0A
	Corporate	Page: 3 of 3
	Policy - POL5100162	Department: Supply Chain
	TITLE: Conflict Minerals Policy

• If they do contain these minerals that they originate from non-conflict areas or from smelters that have been validated by an independent private sector party to be conflict free.

Ballard will evaluate its relationships with its suppliers on an ongoing basis to ensure continued compliance with this policy. Ballard reserves the right to request additional documentation from its suppliers regarding the source of any conflict minerals included in its products. In addition, suppliers must maintain and provide to Ballard upon request traceability data for a minimum of five years. Suppliers who do not comply with these requirements shall be reviewed by Ballard's supply chain organization for future business.

5.0 References

MAN5100058 BALLARD Supplier Manual

FRM5102095 Declaration of Compliance with Ballard Supplier Conduct Principles

THIS DOCUMENT IS VALID ONLY AT TIME OF PRINTING. ANY COPIES MADE ARE CONSIDERED UNCONTROLLED UNLESS STAMPED OTHERWISE IN RED.

Commercial Confidential

Printed on: Thursday, September 04,

2014

TEMPLATE FRM5000215 0A