In the process of purchasing raw materials, the Company recognizes that mining, trading, processing and exporting minerals in conflict-affected and high-risk areas carries risks of significant adverse effects, and that we have obligations to respect human rights, not to promote conflict, and not to negatively impact the environment and society,  We commit to adopt and widely promote the following responsible mineral procurement policies for conflict-affected and high-risk regions and incorporate them into contracts and/or agreements with suppliers.  This policy provides a basic reference for the whole process of mineral resource supply chain, conflict-sensitive procurement activities and suppliers' risk awareness.  We commit to abide by the relevant UN sanctions resolutions, abide by the applicable domestic laws that enforce such resolutions, and refrain from participating in any action that would aid or facilitate the conflict.  To this end, we undertake to identify and avoid the following risks in our business activities:

①. Gross violations of human rights

We neither tolerate nor in any way profit from, facilitate, assist or facilitate the implementation of:

1. Any form of torture, cruel, inhuman and degrading treatment; 

2. Any form of forced or compulsory Labour.  "Forced or compulsory Labour" means Labour or services not voluntarily provided by any individual who is extorted under threat of punishment; 

3. The worst forms of child Labour;  

4. Other serious violations and abuses of human rights, such as widespread sexual violence; 

5. War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide. 

Risk mitigation: We will immediately suspend or discontinue cooperation with an upstream supplier if we have reasonable grounds to believe that the upstream supplier is engaged in procurement by or associated with any party that has committed serious human rights violations.

②. Direct or indirect support to illegal organized armed groups and public or private security forces

We will not tolerate any direct or indirect support to non-state organized armed groups through the exploitation, transportation, trading, processing or export of mineral resources.  Providing "direct or indirect support" to non-state organized armed groups through mining, transportation, trading, processing or export of mineral resources includes but is not limited to purchasing resources, making payments to, or otherwise providing logistical support or equipment to, illegal organized armed groups or their affiliates.  These armed groups or affiliates:

1. Illegally controlling minerals or otherwise controlling transport routes, trading points of mineral resources and upstream actors in the supply chain;

2. Illegally collecting taxes or extorting money or mineral resources at the entrance to the mine site, along the transportation route or at the trading point of mineral resources;

3. Illegal taxation or extortion of middlemen, export enterprises or international traders. 

We will put an end to the illegal control mine site, transport routes and upstream supply chain participants, the entrance of the mine site, transportation routes or mineral resources trading posts along the tax illegal or extort money or mineral resources, or to middlemen, export enterprises or international traders illegal tax or extortion of public or private security forces to provide direct or indirect support. 

We recognize that the role of public or private security forces at mine sites, in the surrounding areas and along transport roads is solely to uphold the rule of law, including safeguarding human rights, protecting miners, equipment and facilities, and protecting mine sites or transport routes from influence and interference with legitimate mining and trade.

In the event that we or any of our corporate or commercial relationships in the supply chain contract with public or private security forces, we commit or will require that such security forces be recognized by recognized international standards and guidelines for dealing with public or private security forces.  In particular, we will support or take steps to use screening policies to ensure that individuals or security forces known to have committed human rights violations are not recruited.

We will support or take steps to work with local governments, international organizations, and civil society organizations to develop feasible solutions to improve transparency, proportionality, and accountability in the cost of armed security for public safety.

We will support or take measures, with local governments, international organizations and civil society organizations, in the supply chain by small workshops or small-scale mining mining of mineral resources, avoid or minimize public or private security forces are stationed in mine site to the negative influence of vulnerable groups, especially for the negative impact of the small miners. 

Risk mitigation: We will immediately suspend or discontinue cooperation with an upstream supplier if we have reasonable grounds to believe that the supplier purchases from or is associated with any party that provides direct or indirect support to organized armed groups that are not state owned.

We will immediately work with suppliers and their stakeholders to develop, adopt and implement risk management plans to prevent or mitigate the risks of providing direct or indirect support to public or private security forces, depending on where we are in the supply chain.  These security forces illegally control mine sites, transport routes and upstream participants in the supply chain, and illegally levy taxes or extort money at the entrance to mine sites, transport routes or trading points of minerals. We have reason to believe that there is a risk.  In this case, if the risk management plan is not effective for six months, we will suspend or discontinue the cooperation with the supplier.

③. Corruption, money laundering and payments to the government

We do not offer, promise, give or demand any bribes, and resist the temptation of corruption. We will not offer bribes in order to cover up or falsify the origin of mineral resources and falsely state the taxes, fees and concession fees payable to the government for mining, trading, processing, transportation and export of mineral resources. 

We prohibit bribery in all business activities and transactions, including bribery by agents and other third parties, and establish standards and approval procedures for giving and receiving gifts.  Best efforts to promote responsible business practices with all business partners. 

If we have reason to believe that there is due to mining, trading, processing, transportation and export, transport along the route, the entrance of the mine site or upstream suppliers sold mineral resources tax illegal or extortion of mineral resources caused by or related to money laundering risk, we will support and take measures to do contribution for effective elimination of money laundering.

We commit to take effective measures to prevent involvement in money laundering or terrorist financing, such as monitoring transactions of unusual or suspicious activity by identifying and publishing suppliers, customers and actual ownership, and maintaining records of cash transactions above the amount limits set forth in applicable laws and regulations.

 We will ensure that all legitimate taxes, fees and royalties related to the exploitation, trading and export of mineral resources in conflict-affected and high-risk areas are paid to governments and commit to disclosing such payments based on the location of the company in the supply chain. 

Risk reduction: according to the enterprise on the supply chain of the location, we promise with the supplier, the central or local governments, international organizations, civil society and affected by the third party cooperation at its discretion, within a reasonable time span in measurable measures are taken, the purpose of prevent or reduce the risk of adverse effects, to improve or tracking performance.  If risk mitigation measures fail to work, we will temporarily suspend or suspend cooperation with upstream suppliers.   

④. Land rights, emissions and small workshops

We do not participate in, condone, or benefit from the exploitation of resources on land without the consent of indigenous and aboriginal people, including those who hold legal title, leasehold, concession or permit.  We also do not participate in, tolerate or benefit from mining operations where the culture and heritage of the local people and indigenous people are not respected and protected or where the traditional culture of the local people is damaged.  We do not participate in, condone, or benefit from the exploitation of resources on land illegally acquired by legal title, leasehold, concession, or permit, or in violation of domestic law, and we ensure that we avoid significant pollution of the surrounding soil, air, and water conditions in serious violation of the relevant local laws and regulations.  This includes the manufacture, trade in, or use of chemicals and hazardous substances that have been internationally banned because of their high toxicity to organisms, environmental persistence, or potential irreversible ecological effects. 

We agree to ensure compliance with the requirements of applicable laws and regulations governing the management of chemicals and toxic substances.  Avoid using for manufacturing, trading and biology high toxicity, environmental persistence, or potentially irreversible ecological impact under the international ban on chemicals and hazardous substances, including in accordance with the highest international standards of strict control of arsenic and mercury emissions, cyanide, ensure no leakage, no spill in the process or released into the environment by any other means.

We prohibit the exploitation of resources in World Heritage sites or statutory protected areas and the consequent threat to the outstanding universal value of those heritage sites.

We will closely monitor the potential risks of small workshops and small-scale miners, including the risk of forced Labour, child Labour, unsafe working conditions, uncontrolled chemical use and other significant environmental impacts, and seek to establish production relationships with small workshops or small-scale miners in the mining areas.

Lower risk: if we have a reasonable reason to think that the risk of such we will according to the enterprise's position in the supply chain, immediately with suppliers and other stakeholders, adopt and implement the risk management plan together, so as to prevent or down low, such as the abuse of land rights, cause significant adverse environmental impact, or other risks associated with small workshops and small-scale miners.

⑤. Transportation

We will strictly comply with the international transportation standards for 7 categories of substances, and we ensure that the disposal, storage and transportation of hazardous substances comply with relevant laws and regulations.  We guarantee that there will be no leakage during transportation and production, so as to prevent adverse effects on the environment and human body. 

Risk reduction: In accordance with international standards, we will strictly distinguish category 7 goods and non-category 7 goods. If it is category 7 goods, we will pack, transport and declare them according to such substances to ensure no leakage and no harm to human body and environment.