Conflict Minerals Policy‌

1. Conflict Minerals Definition‌
We define conflict minerals as tin (Sn), tungsten (W), tantalum (Ta), and gold (Au) originating from the Democratic Republic of the Congo (DRC) and adjoining countries, as identified by international bodies.

‌2. Policy Statement‌
We are committed to responsible sourcing and will not use conflict minerals that directly or indirectly finance armed groups in the DRC region.

‌3. Supplier Requirements‌
All suppliers must:

• Complete and submit a Conflict Minerals Reporting Initiative (CMRT) form annually.
• Cooperate with audits and provide documentation to trace mineral origins upon request.
• Immediately cease sourcing from non-compliant smelters or refiners.

‌4. Due Diligence Process‌
We will:

• Conduct risk assessments using recognized frameworks (e.g., OECD).
• Engage with suppliers to improve traceability and remediate risks.
• Publish an annual Conflict Minerals Report on our website.

‌5. Compliance & Enforcement‌
Non-compliance may result in suspension of business until remediation. We reserve the right to terminate contracts for repeated violations.