Chapter ONE Conflict Mineral Policy

As a participant in responsible procurement within the global value supply chain, Megmeet takes global social responsibility as a corporate objective, implements responsible procurement practices, and advances the sustainable development of the industrial chain.

Megmeet hereby declares its strict adherence to the principles of the Responsible Minerals Initiative (RMI). In alignment with requirements including the EU Conflict Minerals Regulation, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and the China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters (CCCMC) Guidelines for Responsible Mineral Supply Chain Due Diligence, the Company firmly refuses to source or endorse the use of any conflict minerals that directly or indirectly fund armed groups in conflict-affected regions. In accordance with relevant standards, Megmeet conducts supply chain due diligence on conflict mineral usage via the Conflict Minerals Reporting Template (CMRT). For smelters or refineries that fail to comply with the Responsible Minerals Assurance Process (RMAP), Megmeet mandates suppliers to either bring such facilities into RMAP compliance within a specified timeframe or eliminate them from the supply chain.

Meanwhile, Megmeet requires all suppliers to establish responsible mineral procurement policies. These policies shall prevent minerals incorporated into manufactured goods from originating, directly or indirectly, in conflict-affected or high-risk regions. This mitigates risks that the Company’s procurement activities may provide financial or material benefits to entities engaged in severe human rights violations, grave environmental damage, critical occupational health and safety hazards, systemic social corruption, money-laundering and other illegal activities. Megmeet obliges suppliers to trace the origins of mineral materials contained in their purchased products and complete responsible mineral due diligence, and to share due diligence findings with customers. This ensures full alignment of supply chain policies with applicable regulations and guidance, while progressively boosting supply chain transparency and compliance levels.

Tin, Tungsten, Tantalum and Gold (collectively referred to as 3TG) are widely deployed in consumer and industrial products ranging from mobile phones and automobiles to jewelry. Megmeet commits to collaborating with industry associations, customers and suppliers to collectively advance responsible mineral sourcing and drive sustainable development across the entire mineral supply chain.

Chapter TWO Reference to Conflict-affected or High-risk Regions

In line with international consensus, conflict-affected and high-risk areas typically exhibit some or all of the following characteristics:  

2.1 Presence of armed conflict (armed conflicts take various forms, such as international or non-international conflicts involving two or more countries, as well as wars of liberation, insurgencies, civil wars, etc.);  

➤  Widespread violence, including violence perpetrated by criminal networks;  

➤  Fragile post-conflict zones;  

➤  Areas with weak or absent governmental governance and public security;  

➤  Regions marked by widespread and systematic violations of international law, including human rights abuses;

➤  Areas with systematic discrimination against certain population groups;

➤ Regions plagued by pervasive corruption;  

➤ Areas where sexual violence is prevalent.  

2.2 The European Commission commissions an external panel of experts to draw up and regularly update the list of  
Conflict-Affected and High-Risk Areas (CAHRAs). For full details, please refer to https://www.cahraslist.net/cahras#COD/  

Chapter THREE Eligible Smelter List  

Megmeet only sources materials from smelters/facilities that hold Active or Conformant status under RMI assessment  
standards (or equivalent standards), or comply with the RMI Cross-Recognition Policy. Please refer to:  
https://www.responsiblemineralsinitiative.org/facilities-lists/active-conformant-facilities-list/  

Chapter FOUR Mineral Procurement Risk Management  

In accordance with Annex II of the OECD Guidance, risks fall under three overarching criteria: human rights, conflict and good governance, covering the following aspects: severe abuses linked to mineral extraction, transportation or trade; direct or indirect support to non-state armed groups; public or private security forces; bribery and fraud involving  
misrepresentation of mineral origins; money laundering; and evasion of government taxes, fees and royalties.  

The Company establishes risk management measures tailored to the industrial relevance of its mineral procurement supply  
chain as follows:  

➤ Distinguish high-risk and low-risk suppliers for mineral procurement;  

➤ Require high-risk suppliers to formulate responsible mineral procurement policies;  

➤ Conduct regular CMRT surveys on high-risk suppliers;  

➤ Follow up on identified mineral procurement risks of suppliers, urge timely corrective actions or remove such  
suppliers from the supply chain;  

➤ Publish supply chain due diligence reports on a regular basis.