I. Policy Statement and Core Objectives

The Company strictly complies with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, relevant regulations of target markets (such as EU Regulation 2017/821) and Responsible Minerals Initiative (RMI) standards. We resolutely prohibit the procurement of four types of minerals—Tantalum (Ta), Tin (Sn), Tungsten (W), and Gold (Au) (collectively referred to as “3TG”)—sourced from conflict-affected and high-risk areas (CAHRAs, such as the Democratic Republic of the Congo, Yemen, etc.).

Core Objectives:

1. Ensure that 3TG minerals in the supply chain do not directly or indirectly fund armed groups;
2. Eliminate human rights abuses such as modern slavery, forced labor, and child labor in the production process;
3. Achieve traceable and verifiable sources of 3TG minerals to avoid legal risks and damage to brand reputation.

II. Scope of Application

1. Internal Departments: Procurement Department, Supply Chain Management Department, Legal & Compliance Department, R&D Department, Quality Department;
2. External Parties: All suppliers providing 3TG-related materials and components (such as tantalum capacitors, tin solder, gold-plated connectors, tungsten alloy electrodes, etc.);
3. Full Process Coverage: The entire supply chain from supplier onboarding, material procurement, production and use to finished product delivery.

III. Core Internal Requirements
(I) Mandatory Actions for Procurement

1. Procure exclusively from the compliant supplier list; new suppliers must be reviewed by the Compliance Department;
2. Attach the “Conflict-Free Minerals Commitment Letter” to procurement contracts, and collect CMRT reports (version ≥ 6.5) from key suppliers once a year.

(II) Supplier Audit Criteria

1. Able to provide the name of the upstream smelter and RMI compliance ID (or official compliance certificate);
2. Provide a written commitment that materials are not sourced from conflict areas and are free from forced labor, child labor, or other related issues.

(III) Risk Disposal

1. Unclear material sources or lack of compliance certificates: Immediately suspend procurement, seal up inventory, and report to the Compliance Department within 24 hours;
2. Provision of falsified reports/certificates: Immediately terminate cooperation and add the supplier to the blacklist.

(IV) Supplier Responsibilities

1. Commit that supplied 3TG materials are conflict-free and free from illegal labor practices;
2. Provide CMRT reports and smelter compliance information as required, and cooperate with inspections;
3. Violations will result in a 20%-30% order value penalty; serious cases will be referred to regulatory authorities.

(V) Implementation

The Procurement Department confirms that the supplier is included in the compliant supplier list, collects and verifies documents such as the “Conflict-Free Minerals Commitment Letter”, and may initiate the procurement process only after obtaining the signature confirmation from the Compliance Department.
Once a year, led by the Compliance Department, jointly with the Procurement Department and Quality Department, conduct a review of suppliers’ compliance status, update smelter compliance information, identify human rights risks, and adjust the “Compliant Supplier List” accordingly.

Version V1.0