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Dodd-Frank Act - Conflict Minerals

For years, there has been increasing concern about human rights and environmental abuses in the mining industry in the Democratic Republic of Congo (DRC) and other parts of Africa, where warlords engage in human rights violations and use mining proceeds to fuel regional conflicts. In July of 2010, Congress enacted the Conflict Minerals provisions of the Dodd-Frank Street Reform and Consumer Protection Act (Dodd-Frank Act) with the goal of cutting the funding to these armed groups in the DRC and its neighboring countries that are also engaged in human rights and environmental abuses. In August of 2012, the Securities and Exchange Commission (SEC) issued its final rules. Conflict minerals are defined as gold, tin, tantalum and tungsten, and Section 1502 of the Dodd-Frank Act requires SEC registrants to report to the SEC and disclose on their website whether any of the conflict minerals in the products they manufacture or contract to manufacture originate in the DRC and its neighboring countries, as well as the due diligence conducted to determine their conclusion.

Conflict Mineral Policy

Belk places business with vendors and supply chain partners whose practices are compatible with Belk's brand values and our values define our actions. Our Core Values are:

1. Be encouraging of growth and change.
2. Be proud of our rich heritage.
3. Be involved in our communities.
4. Be relentless with customer care.
5. Be committed to the success of our associates.
6. Be the best at what we do.

In accordance with these values, Belk strives to ensure compliance with legal, human rights, and environmental standards and in particular Belk requires that Belk vendors and supply chain partners comply with the Dodd-Frank Act. Belk mainly purchases finished goods directly from manufacturers, so there is no purchase of any conflict minerals from any source. However, in very limited quantities, Belk will manufacture custom gold fine jewelry pieces. In either circumstance, we are committed to working towards increasing the transparency of our supply chain with regard to the origin and traceability of the minerals contained in our products.

Our goal is to ensure all products sold by Belk are from non-conflict areas, such as the DRC and its neighboring countries. To meet this goal, we have implemented the Organization for Economic Cooperation and Development (OECD) Five-Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain, which includes 1) establishing strong company management systems, 2) identifying and assessing risks in the supply chain, 3) designing and implementing strategies to respond to those identified risks, 4) carrying out independent third-party audits of the supply chain due diligence at those identified points in the supply chain and 5) reporting on the supply chain due diligence.

Belk's expectations of suppliers are included in the Vendor Code of Conduct. Belk's current Form SD can be accessed here.

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