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JIANGXI TUO HONG NEW MATERIAL CO.,LTD				DOC NO.	RMAP-D－012
				VERSION NO.	The third edition
RESPONSIBLE MINERAL SUPPLY CHAIN POLICY				effective date	2020-06－30
DRAFTER	HUANG YAN	AUDITOR	HUANG SHUIGEN	APPROVER	LENG WEIMIN

Our company recognizes that mining, trading, processing, and exporting minerals in conflict-affected and high-risk areas may have major negative impacts. We also recognize that we have the obligation to respect human rights and not contribute to conflict. We are committed to adopting and widely promoting The following policies for responsible sourcing of minerals in conflict-affected and high-risk areas are included in the contracts and/or agreements signed with suppliers. This policy provides a basic reference for conflict-sensitive procurement activities and suppliers’ risk awareness in the entire process from mining to end users. We promise not to engage in any activities that will fund conflicts, and we promise to comply with relevant UN sanctions resolutions or, where applicable, to comply with domestic laws that implement such resolutions. The company follows the "Responsible Mineral Inspection Process Tin and Tantalum Inspection Standards", and has established a complete responsible mineral supply chain management system, combined with the OECD guidelines on tin, tantalum, and tungsten supplements, combined with the OECD guidelines five steps The applicability of the framework includes monitoring risks and events in the supply chain, and institutionally ensuring that the raw materials purchased and used by the company are traceable. To this end, we promise to identify and avoid the following risks in our business activities, and review them every year, and make improvements in time if there are changes:

A.Serious infringements related to mining, transportation, or trade of minerals:

When carrying out procurement or business activities in conflict-affected and high-risk areas, we will neither tolerate nor in any way benefit, help, assist or facilitate the implementation of any party:

i) Any form of torture, cruel, inhuman and degrading treatment;

ii) Any form of forced or compulsory labor. Forced or compulsory labor refers to any labor or service that is squeezed out of any individual under the threat of punishment and is not provided voluntarily by that person;

iii) The worst forms of child labor;

iv) Other serious violations and violations of human rights, such as widespread sexual violence;

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

B. Risk management of serious infringements

If we have reasonable grounds to believe that the risk exists, that is, the upstream supplier is purchasing from or is associated with any party that has committed serious infringements as specified in Article 1, we will immediately suspend or interrupt the cooperation with that supplier .

C. Regarding direct or indirect support for non-state armed groups:

We will not tolerate any direct or indirect support for non-state armed groups through mineral mining, transportation, trade, processing or export. Providing “direct or indirect support” to non-state armed groups through mining, transportation, trade, processing or export of minerals includes but is not limited to the purchase of minerals from non-state armed groups or their affiliates4, payment to them, or in other ways Provide logistical support or equipment for it. These armed groups or related parties:

i) Illegal control of mine sites, or other means of controlling transportation routes, mineral transaction points, and upstream actors in the supply chain; 5 and/or

ii) Illegal taxation or extortion of 6 money or minerals at the entrance of the mine site, along the transportation route or at the mineral trading point; and/or

iii) Illegal taxation or extortion of middlemen, export companies, or international traders.

D. Risk management for providing direct or indirect support to non-state armed groups:

If we have reason to believe that the upstream supplier purchases from or has a relationship with any party that provides direct or indirect support to non-state armed groups (see definition in paragraph 3), we will immediately suspend or interrupt the supplier’s Cooperation.

E. Regarding public or private security forces:

1. We agree to prohibit illegally controlling mining sites, transportation routes, and upstream actors in the supply chain, illegally levying taxes or asking for money or minerals at the entrance of the mine site, along the transportation route or at the mineral transaction point in accordance with the provisions of paragraph 10 Public or private security forces that illegally levy taxes or extortion by intermediaries, export companies or international traders provide direct or indirect support.

2. We recognize that the role of public or private security forces along the mining site and/or its surrounding areas and/or transportation roads is only to maintain the rule of law, including the protection of human rights, protection of miners, equipment and facilities, and protection of mining sites or transportation routes So that legal mining and trade are not disturbed.

3. When we or any company in our supply chain has signed a contract with public or private security forces, we promise or will stipulate that we will comply with the "Voluntary Principles of Security and Human Rights in the process of cooperating with such security forces." "Provisions. In particular, we will support or take measures to apply screening policies to ensure that individuals or security armed units who are known to have committed serious human rights violations are not hired.

4. We will support or take measures to cooperate with central or local governments, international organizations and civil society organizations to jointly find feasible solutions for how to improve the transparency, proportionality and accountability of public security armed security costs.

5. We will support or take measures to interact with local governments, international organizations and civil society organizations to avoid or minimize the negative impact of public or private security forces stationed at mine sites on vulnerable groups, especially for small workshops The negative impact of miners, in this case, the minerals in the supply chain are small workshops that are mined through small workshops or small-scale mining.

6. Risk management of public or private security forces:

If we find that such risks exist to a certain extent, we will immediately formulate, adopt and implement risk management plans for upstream suppliers and other stakeholders based on the company’s specific position in the supply chain, so that the The aforementioned risks of providing direct or indirect support to public or private security forces are contained or reduced. If the risk management plan does not work for six months, we will temporarily suspend or suspend cooperation with upstream suppliers. 8 We find that there may be behaviors that violate the contents of paragraphs 8 and 9 to a certain extent, and we will take the same response measures.

G. Fraudulent misrepresentation regarding bribery and the origin of minerals:

We will not offer, promise, conduct or demand any bribes, and resist the temptation. We will not falsely report the taxes, fees and concessions paid to the government for activities such as mining, trading, processing, transportation, and export in order to conceal or falsify the origin of minerals. Bribery for mining fees.

H. About money laundering

If we have reason to believe that there are minerals caused by or related to mining, trading, processing, transportation or exporting illegally taxed or extorted at the entrance of the mine site, along the transportation route, or the upstream supplier’s mineral transaction place Money laundering risks, we will support or take measures to contribute to the effective elimination of money laundering.

I. Regarding taxes, fees and royalties paid to the government:

We will ensure that all legal taxes, fees and royalties related to mining, trade, and export of minerals in conflict-affected and high-risk areas are paid to the government, and we are committed to comply with the "Extractive Industry Transparency Action Plan" based on the company's position in the supply chain The principles in (EITI) disclose such payments.

J. Risk management of bribery and fraudulent misrepresentation of the origin of minerals, money laundering, and taxes, fees, and royalties paid to the government:

According to the company's specific position in the supply chain, we promise to cooperate with suppliers, central or local government agencies, international organizations, civil society, and affected third parties as appropriate, and take significant measures within a reasonable time span The purpose of preventing or reducing risks with negative impacts, and improving or tracking performance. If risk reduction measures do not work, we will temporarily suspend or suspend cooperation with upstream suppliers.

K. Transportation

We will strictly abide by the international transportation standards of 7 types of substances, and we ensure that the handling, storage, and transportation of hazardous substances comply with the requirements of relevant laws and regulations. We guarantee that there will be no leakage during transportation and production, thereby preventing adverse effects on the environment and humans. Risk reduction: Strictly distinguish 7 types of goods and non-7 types of goods in accordance with international standards. If it is 7 types of goods, we will package, transport, and declare according to such substances to ensure that there is no leakage and no harm to humans and the environment.

Risk reduction measures: Strictly distinguish 7 types of goods and non-7 types of goods in accordance with international standards, and do not purchase 7 types of goods (the content of a single radioactive element exceeds 10Bq/g).

L.Responsible mineral supply chain appeal contact information:

relevant parties received in the work regarding the responsible mineral supply chain

Information on concerns related to mining, trade, processing and export conditions.

Contact: Huang Yan Complaint Tel: 0795-3259660 Email: [email protected]

Huang Yan reports to the general manager as soon as he receives the complaint. After the report is completed, he investigates and feedbacks the complaint, and continues to track the investigation results and follow-up whether they happen again.