Commitment to Responsible Sourcing

Conflict minerals means minerals from the Democratic Republic of the Congo (DRC) and surrounding conflict areas, where their mining and trading may finance armed conflicts or human rights violations. Zhen Ding ensures that the sources of raw materials comply with international standards, promoting the sustainable development of the supply chain through a systematic management framework by proposing policies, setting goals, and enhancing management practices. In response to global conflict mineral control measures, Zhen Ding has incorporated conflict minerals into our supplier management policy. In 2024, Zhen Ding has removed total of 54 non-compliant and customer disapproved smelters based on RMI RMAP certification and customer requirements, including 43 were moved in accordance with customers requirements and 11 not certified from RMI RMAP qualification. The Company continuously monitors smelters to ensure 100% compliance with regulations and customer requirements. VIEW <RIM MEMBER LIST>

Conflict Mineral Management Objectives

Achieved to use qualified smelters by whole supply chain in accordance with conflict mineral regulations and customer requirements, and promoted to improve continuously.
1. Compliance rate of suppliers who signed the “Declaration of Non-use of Conflict Minerals”: 100%
2. Supplier response rate of the conflict minerals survey: 100%
3. Compliance rate of using qualified smelters and refineries for raw materials and products: 100%
VIEW CONFLICT MINERALS MANAGEMENT REPORT

Conflict Mineral Management Policy

• Commit to sourcing minerals only from smelters that are conformant with the Responsible Minerals Initiative (RMI) or otherwise approved by customers.
• Commit to following the OECD Due Diligence Guidance when conducting supply-chain due diligence.
• Refrain from directly or indirectly purchasing conflict minerals that finance or benefit armed groups.
• Permit sourcing qualified, conflict-free minerals from the Democratic Republic of the Congo and its adjoining countries.
• Require suppliers to apply the same conflict-minerals management requirements on their upstream suppliers.

Conflict Mineral Management Practices

• When selecting suppliers of materials that may involve conflict minerals, Zhen Ding prioritizes suppliers that can provide 100% traceable minerals. We utilize the Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT) for investigating conflict minerals. For other special minerals (e.g., nickel, zinc, copper, and aluminum), the Additional Mineral Reporting Template (AMRT) is used for investigation. At the same time, Zhen Ding regularly evaluates suppliers to ensure that they always comply with Zhen Ding’s Conflict Mineral Management Policy.
• Follow customer requirements and the list of conformant smelters provided on the RMI website for identification. If a non-compliant smelter is identified, the supplier will be required to provide a response plan.
• Require suppliers to proposed the same conflict mineral management on their upstream suppliers.
• Zhen Ding provides education and training to employees and suppliers to raise their awareness of conflict mineral issues.
• Zhen Ding requires suppliers to sign a Declaration of Conflict-Free Minerals.
• In accordance with its Responsible Mineral Sourcing Policy, Zhen Ding is committed to reducing reliance on minerals sourced from conflict-affected and high-risk areas. The Company proactively investigates and evaluates alternative mineral sources. Through supplier engagement and questionnaire surveys, we prioritize the use of minerals from low-risk countries and qualified smelters that are both verified under the RMI’s RMAP program and approved by our customers. In parallel, we explore compliant alternative sources across different suppliers and regions. For certain products, we also conduct technical feasibility assessments to evaluate the substitution of 3TG minerals with other materials or processes, aiming to reduce risk and enhance supply chain resilience.