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Zhen Ding Tech. Group

RESPONSIBLE MINERALS SOURCING

Commitment to Responsible Sourcing

Conflict minerals refer to minerals mined in areas of armed conflict or under conditions that violate human rights, specifically precious metal minerals mined by the Democratic Republic of the Congo and adjoining countries. Conflict minerals include gold (Au), tin (Sn), tantalum (Ta), tungsten (W), Cobalt (Co), and mica, which are mainly used in electronic parts. In response to global control measures for conflict minerals, the Company has incorporated conflict minerals into its supplier management policies, and proposed policies, objectives and management practices to meet international trends and customer requirements. In 2023, Zhen Ding promoted the elimination of 43 smelters that did not pass or meet customer specifications, and monitored them at all times to ensure 100% compliance with regulations and customer requirements. VIEW <RIM MEMBER LIST>

Minerals Sourcing Target

The Company continues to promote supply chain improvement as required by laws and customers in order to eliminate the use of conflict minerals in its supply chain.
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

• The Company promises that the smelters from which it responsibly purchases minerals are Responsible Minerals Initiative (RMI) certified smelters or customer-approved smelters.
• The Company promises to follow the OECD due diligence guidelines to conduct due diligence on its supply chain.
• The Company promises to not directly or indirectly purchase conflict minerals that directly or indirectly finance armed conflict groups.
• The company should allow to purchase the certified minerals from the Democratic Republic of the Congo and adjoining countries.
• Suppliers shall impose the same conflict mineral management requirements on their upstream suppliers.

Conflict Mineral Management Practices

• Conduct investigation to trace conflict minerals in gold salts, electronic parts, tri-tin, and all products and materials in PCB that mainly contain gold, tantalum, tin, tungsten, cobalt, and mica through CMRT (Conflict Minerals Reporting Template) and EMRT (Extended Mineral Reporting Template). At the same time, we conduct investigations on special minerals requested by customers (such as nickel, zinc, copper, aluminum, etc.) by using the PRT (Pilot Report Template).
• Use the list of conformant smelters provided on the RMI website. If a smelter is not on the list, request for a response plan from the supplier.
• Require suppliers to impose the same conflict mineral management on their upstream suppliers.
• Require suppliers to sign a Declaration of Conflict-Free Minerals.

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