1、 Policy objectives

This policy aims to ensure that Shanxi Zhongxing Meide Trading Co., Ltd. (hereinafter referred to as "Zhongxing Meide Trading Co., Ltd.")The company follows responsible business practices in mineral procurement activities, including complying with relevant laws and regulations, respecting human rights, protecting the environment, and promoting sustainable development of the supply chain.

Scope of Application

This policy applies to all business activities of the company involving mineral procurement worldwide, including but not limited to direct procurement, indirect procurement, and cooperation with suppliers.

3、 Definition

1. Responsible Mineral Resources

·Refers to mineral resources that comply with internationally recognized human rights, environmental, labor, and governance standards during mining, processing, and trade processes, such as copper, cobalt, tin, tungsten, tantalum, etc. that comply with relevant international standards.

2. Conflict Minerals

·According to relevant international definitions, originating from the Democratic Republic of the Congo and its neighboring countries (referred to asMineral resources such as cassiterite, wolframite, columbite, and gold that may provide funding for armed conflicts or exacerbate human rights violations through mining and trade in conflict affected and high-risk areas.

4、 Policy principles

（1） Comply with laws and regulations

The company will strictly comply with domestic and international laws and regulations on mineral procurement, including but not limited to import and export controls, environmental regulations, labor regulations, etc.

Continuously monitor changes in laws and regulations, adjust the company's procurement policies and operational procedures in a timely manner, and ensure compliance at all times.

（2） Respect for human rights

Ensure that suppliers do not use child labor, forced labor, or other forms of human rights violations during the procurement process.

Require suppliers to provide a safe and healthy working environment, safeguard the basic rights and interests of employees, such as reasonable wages, working hours, and working conditions.

（3） Environmental Protection

Encourage suppliers to adopt environmentally friendly mining and processing technologies to reduce pollution to the environment, including water, soil, and air pollution.

Promote suppliers to make rational use of resources, improve the utilization rate of mineral resources, and reduce waste.

（4） Supply chain transparency

Establish a comprehensive supplier management system and conduct due diligence on suppliers, including but not limited to their mineral sources, production processes, labor and environmental policies.

Require suppliers to provide necessary information to ensure transparency in the mineral supply chain and traceability to the source of minerals.

（5） Conflict mineral management

The company will take reasonable measures to avoid purchasing conflict minerals.

For minerals from conflict affected and high-risk areas, procurement can only be carried out after ensuring that they comply with international responsible mineral standards (such as third-party certification, etc.).

Require suppliers to provide relevant documents such as certificates of origin to prove that their mineral sources are legal and compliant, and not related to armed conflict.

5、 Supplier Management

（1） Supplier selection

When selecting suppliers, in addition to considering conventional factors such as price and quality, the focus will be on evaluating the supplier's social responsibility performance.

Priority should be given to those who have obtained relevant international or domestic social responsibility standard certifications (such asSuppliers of ISO 14001 environmental management system certification, SA8000 social responsibility standard certification, etc.

（2） Supplier evaluation

Regularly evaluate suppliers, including but not limited to their compliance with laws and regulations, implementation of human rights and labor policies, environmental protection measures, and supply chain transparency.

According to the evaluation results, classify and manage suppliers. Provide more cooperation opportunities for suppliers with excellent performance; For suppliers with problems, they are required to rectify within a specified period of time. If the rectification is not effective, the cooperation relationship may be terminated.

（3） Supplier training

Provide necessary training to suppliers to help them understand and comply with the company's responsible mineral procurement policy.

Share the latest international standards and best practices for responsible mineral mining, processing, and trade, and enhance suppliers' social responsibility awareness and management level.

6、 Internal management

（1） Employee training

Provide regular training for employees involved in mineral procurement, including policy interpretation, legal and regulatory learning, due diligence skills, etc.

Enhance employees' awareness and understanding of responsible mineral procurement, ensuring that they can implement company policies in their work.

（2） Supervision and Audit

Establish an internal supervision mechanism to regularly inspect the company's mineral procurement activities and ensure the effective implementation of policies.

Conduct internal audits irregularly to check whether the procurement process is compliant and whether supplier management is in place. Promptly rectify problems and hold relevant personnel accountable.

7、 Communication and Reporting

Maintain active communication with suppliers, customers, industry associations, and other stakeholders, and promptly respond to their questions and concerns regarding the company's responsible mineral procurement policy.

Regularly report to the company's management and stakeholders on the progress of responsible mineral procurement, including policy implementation, supplier management achievements, challenges faced, and solutions.

8、 Policy Review and Update

Regularly review this policy to ensure its alignment with the company's business development, market changes, and updates to international and domestic laws, regulations, and standards.

Based on the review results, update policy content in a timely manner and communicate policy changes to suppliers, employees, and other stakeholders in a timely manner.