CONFLICT MINERALS POLICY

Magellan is committed to maintaining the highest ethical and legal standards in all of our business endeavors.  As part of this commitment, we comply with all applicable laws and initiatives that are designed to promote the advancement of human rights and to end the exploitation and trade of “conflict minerals” that finance armed conflict.  We work with our suppliers to create a system of controls to insure supply chain transparency and traceability.  We endeavor to engage in all appropriate and necessary due diligence to ensure the responsible sourcing of materials, particularly with respect to the minerals we purchase that are considered to be potential conflict minerals.