Dongguan Huachuang Power Supply Co., Ltd. Responsible Mineral Procurement Policy for the Supply Chain

Dongguan Huachuang Power Co., Ltd. (hereinafter referred to as the Company) is a legally established entity under Chinese law. It specializes in manufacturing and providing high-performance lithium-ion battery electrode materials (aluminum tabs and nickel tabs). The Company maintains a rigorous management system and a strong corporate culture, enjoying an excellent social reputation and corporate credibility.

The company commits to and diligently implements the responsible procurement requirements outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. It establishes a standardized, scientific, and effective internal management system for responsible procurement (covering nickel and aluminum, and applicable to the supply chain management of these minerals), conducts identification and assessment of supply chain risks, and ensures that response strategies are developed and implemented for identified risks.

The company fully recognizes the risks of significant negative impacts associated with mining, trading, processing, and exporting minerals in conflict-affected and high-risk areas, and acknowledges our obligation to respect human rights and not contribute to conflict. We commit to adopting and widely promoting the following Responsible Procurement Policy for Minerals from Conflict-Affected and High-Risk Areas, and to incorporating it into contracts and/or agreements with suppliers. This policy provides a fundamental reference for conflict-sensitive procurement activities throughout the entire process from extraction to end-user, as well as for supplier risk awareness. We commit to refraining from any activities that could finance conflict, and pledge to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

Serious violations related to the extraction, transportation, or trade of minerals:

1. When conducting procurement or business activities in conflict-affected and high-risk areas, we will neither tolerate nor in any way profit from, aid, assist, or facilitate any party in committing: i) Any form of torture, cruel, inhuman, or degrading treatment; ii) Any form of forced or compulsory labor. Forced or compulsory labor means any work or service extracted from an individual under threat of punishment and not voluntarily offered by that individual; iii) the worst forms of child labor; iv) other serious violations and abuses of human rights, such as widespread sexual violence; v) war crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide.

Risk Management for Serious Infringement:

2. If we have reasonable grounds to believe that such a risk exists—namely, that an upstream supplier is procuring from or associated with any party committing the serious infringements specified in Article 1—we will immediately suspend or terminate cooperation with that supplier.

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

3. We will not tolerate any direct or indirect support provided to non-state armed groups through the mining, transportation, trade, processing, or export of minerals. Such support includes, but is not limited to, purchasing minerals from non-state armed groups or their affiliates, making payments to them, or otherwise providing logistical support or equipment. These armed groups or their affiliates: i) illegally control mining sites, or otherwise control transportation routes, mineral trading points, and upstream actors in the supply chain; and/or ii) illegally levy taxes or extort money or minerals at mining site entrances, along transportation routes, or at mineral trading points; and/or iii) illegally levy taxes or extort intermediaries, export companies, or international traders.

Risk Management for Direct or Indirect Support to Non-State Armed Groups:

4. If we have reason to believe that an upstream supplier procures from or maintains relationships with any party providing direct or indirect support to non-state armed groups (as defined in paragraph 3), we will immediately suspend or terminate cooperation with that supplier.

Regarding public or private security forces:

5. We agree to eliminate, in accordance with the provisions of paragraph 10, any direct or indirect support provided to public or private security forces that illegally levy taxes or demand money or minerals from entities operating at mining sites, along transportation routes, or in upstream supply chain activities—whether at mine entrances, along transport routes, or at mineral trading points—or that illegally tax or extort intermediaries, export enterprises, or international traders.

6. We recognize that the role of public or private security forces at mining sites and/or their surrounding areas and/or along transportation routes is solely to uphold the rule of law, including safeguarding human rights, protecting the safety of miners, equipment, and facilities, and securing mining sites or transportation routes to ensure lawful extraction and trade proceed unimpeded.

7. Where any enterprise within our supply chain has contracted with public or private security forces, we commit to ensuring compliance with the Voluntary Principles on Security and Human Rights throughout our engagement with such security forces. Specifically, we will support or implement screening policies to prevent the hiring of individuals or security units known to have committed serious human rights violations.

8. We will support or take measures to collaborate with central or local governments, international organizations, and civil society organizations to jointly identify viable solutions for enhancing the transparency, proportionality, and accountability of public security armed protection costs.

9. We will support or take measures to engage with local governments, international organizations, and civil society organizations to avoid or minimize the negative impacts of public or private security forces stationed at mining sites on vulnerable groups, particularly artisanal miners. In such cases, minerals in the supply chain are sourced from artisanal or small-scale mining operations.

Risk Management for Public or Private Security Forces:

10. Should we identify such risks to any degree, we will promptly develop, adopt, and implement risk management plans for upstream suppliers and other stakeholders based on the company's specific position within the supply chain. This will ensure that risks described in paragraph 5—involving direct or indirect support for public or private security forces—are mitigated or reduced. If a risk management plan proves ineffective after six months of implementation, we will temporarily suspend or terminate cooperation with the upstream supplier. We will take the same measures when we identify a potential risk of non-compliance with paragraphs 8 and 9.

Regarding Fraudulent Misrepresentations Concerning Bribery and the Origin of Mineral Resources:

11. We will not offer, promise, make, or solicit any bribes, and we will resist any temptation to bribe in order to conceal or falsify the origin of minerals, or to misrepresent taxes, fees, and royalties owed to governments for mining, trading, processing, transporting, or exporting minerals.

Regarding Money Laundering:

12. If we have reason to believe that there exists a risk of money laundering arising from or related to minerals obtained through illegal taxation or extortion at mine entrances, along transportation routes, or at mineral trading locations of upstream suppliers—whether through mining, trade, processing, transportation, or export—we will support or implement measures to contribute to the effective elimination of money laundering.

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

13. We will ensure payment of all lawful taxes, fees, and royalties to governments related to the extraction, trade, and export of minerals from conflict-affected and high-risk areas. We commit to disclosing such payments in accordance with the principles of the Extractive Industries Transparency Initiative (EITI), based on the company's position within the supply chain.

Risk management for bribery and fraudulent misrepresentation of mineral origin, money laundering, and taxes, fees, and royalties payable to governments:

14. Based on the specific position of the enterprise within the supply chain, we commit to collaborating with suppliers, central or local government agencies, international organizations, civil society, and affected third parties as appropriate. This collaboration aims to improve or track performance with the objective of taking significant measures within a reasonable timeframe to prevent or mitigate risks of negative impacts. Should risk mitigation measures prove ineffective, we will temporarily suspend or terminate cooperation with upstream suppliers. This policy applies to Dongguan Huachuang Power Supply Co., Ltd. and all metal strip suppliers of the company. By signing the above Huachuang Supply Chain Responsible Mineral Procurement Policy, the supplier enters into a legally binding agreement with Huachuang.