Responsible Mineral Procurement Policy

Simplo had committed to carrying out supply chain due diligence on purchase of Tantalum, Tin, Tungsten, Gold (hereinafter referred to as 3TGs), Co and Mica contained in the products in accordance with the Guidelines of Organization for Economic Cooperation and Development (OECD). At the same time, SMP also announced to the supplier and required the supplier to purchase all 3TGs, Co and Mica contained in the product, which must be conflict-free minerals approved by a specific third-party international organization such as the Responsible Business Alliance (RBA) and certified by Responsible Minerals Initiative (RMI, formerly known as the Conflict-Free Sourcing Initiative). Simplo will also instruct suppliers to actively urge smelters and refiners not yet RMI accredited to undergo the Responsible Minerals Assurance Process (RMAP).

Responsible Mineral Management and Due Diligence

 

 Simplo Technology implemented the Responsible Business Alliance (RBA) Responsible Minerals Initiative (RMI) program to conduct RCOI to identify smelters/refiners. All records were maintained in the system database. Long-term relationships with most suppliers are established for leverage and compliance. The Company has not purchased virgin refined ore from the Democratic Republic of the Congo (DRC), Covered Countries (CC), or any other country/area.
 Suppliers are required to sign the “Conflict Minerals Declaration”. The Company declares and requires suppliers that all 3TGs, cobalt and mica contained in products must be conflict-free minerals that have been reviewed and certified by the approved RMI (Responsible Minerals Initiative, former Conflict-Free Sourcing Initiative) recognized by specific third-party international organizations such as the Responsible Business Alliance (RBA). This requirement has been incorporated into the Regulations of Hazardous Substances Management. As of 2023, the signing rate of the Conflict Minerals Declaration by key suppliers was 92.39%.

 Simplo Technology adopts guidelines from the Organization for Economic Co-operation and Development (OECD) and implements measures including establishing management systems, identifying and assessing risks, and designing/implementing response strategies. In accordance with the OECD guidelines, due diligence is conducted on the procurement of all conflict minerals including Tantalum, Tin, Tungsten, Gold (collectively known as 3TGs), as well as Cobalt, and Mica. This process applies to all minerals present in the Company’s products sourced from the supply chain. In 2023, due diligence was conducted on 184 direct suppliers, achieving a 100% response rate. The management and due diligence results of conflict minerals in the supply chain have identified 223 3TGs smelters, 50 cobalt mines, and 2 mica smelters. The smelter/refinery list announced by the RMI is subject to change, with entities sometimes being removed from the qualified list. Therefore, we have introduced RPA automation to regularly monitor the latest smelter information published on the RMI's official website. This ensures that our system maintains the most complete and up-to-date first-hand information. We also employ rolling automation management to restart the supplier survey for those that no longer meet the criteria, ensuring that the submitted data from vendors complies with the latest regulations and customer requirements. Together, we uphold corporate responsibility to prevent inhumane and human rights-violating incidents, thereby creating a sustainable enterprise.