Supply chain due diligence report

Zhuzhou Gaoli New Material Co., Ltd.

Responsible Mineral Supply Chain Due Diligence Report

　　1. Company information

　　Zhuzhou Gaoli New Material Co., Ltd. ("Company") was established in 2006, and the company's CID number is CID002505. The company is located in Jiulong Industrial Zone, Yanling County, Zhuzhou City, Hunan Province. Mainly produce and process tantalum, niobium and its non-ferrous metal products.

　　2. RMAP assessment summary

　　The company has been actively supporting and participating in the annual audit of RMAP (Responsible Minerals). As of 2019, it has accepted the independent third-party RMAP audit commissioned by RMI for seven consecutive times and successfully passed the 2018-2019 annual audit. The evaluation period is one year. The evaluation period is from August 29, 2019 to August 29, 2020. The evaluation is performed independently by a third party. The company's 2019-2020 annual RMAP audit evaluation is scheduled to be conducted in October 2020.

　　 The evaluation summary report is available for public inspection at www.chiantanb.com.

　　3. Company supply chain policy

The company has always strictly followed and fully complied with the OECD’s due diligence guidelines for responsible supply chain of minerals in conflict-affected and high-risk areas, in order to avoid the use of conflict minerals and/or involved in directly or indirectly funding or benefiting armed groups In high-risk and conflict-affected areas, the company has formulated a supply chain policy for conflict minerals that have seriously violated human rights. This supply chain policy covers all the risks identified in Appendix II of the OECD Guidelines and is applicable to the world. The company promises to deal with any risks in Appendix II immediately upon discovery. This policy has been reviewed and approved by the senior management, and the management is committed to supporting the implementation of this policy. This policy has been widely disseminated to relevant stakeholders (suppliers, customers, employees, etc.) and can be viewed on the company's website www.chiantanb.com.

　　 4. Company management system

The company has a very strict management system for the supply chain and has formulated a series of complete supply chain control systems. The following measures and procedures are adopted to ensure that raw materials from conflict-affected areas are not purchased and used, to prevent any conflicting raw materials and unknown raw materials from entering the company, and to prevent minerals The exploitation and trade of the country have become sources of conflict, human rights violations and insecurity. The company abides by its commitments in the supply chain policy and has established due diligence internal procedures:

　　The company’s deputy general manager is responsible for overseeing the design and implementation of the due diligence plan and risk management.

　　The company has appointed a due diligence plan manager to coordinate the work of relevant departments (including the procurement department, quality supervision department and other related functional departments and production units) to ensure that each department performs due diligence, executes the due diligence plan and reports any warning signs and potential risks found.

　　In accordance with the requirements of the due diligence plan, the company conducts a due diligence management system training for key personnel of all relevant departments every year. If the plan is updated, the company will carry out additional training as needed.

　　The company requires records related to the due diligence plan to be kept for at least five years, and requires correct use and safe storage in our company data.

　　5. Internal control system

　　5.1 The company has updated its due diligence management system to make it consistent with the OECD guidelines and RMAP.

　　5.2 The company has communicated the latest supply chain policy and procurement requirements to all upstream suppliers.

　　5.3 The company adopts an open and transparent procurement policy.

　　5.4 The responsible mineral supply chain policy was published on the company's website, so that every supplier has a clear understanding of our procurement policy.

　　5.5 The company’s annual due diligence report has been published on the company’s website, so that all sectors of society can understand the measures and performance we have taken in the practice of responsible mineral procurement.

　　5.6 The company issued the "Responsible Mineral Supply Chain Management System Document" to various departments within the company, so that every employee was aware of and implemented it accordingly.

　　5.7 The company regularly trains its employees to enable them to fully understand the "OECD Due Diligence Guidelines for the Responsible Supply Chain of Minerals in Conflict-affected Areas and High-risk Areas" and the latest requirements of the Responsible Business Alliance on the tantalum supply chain verification standard And the requirements for transparency in the responsible mineral supply chain.

　　5.8 In accordance with the OECD guidelines and the audit requirements of the Responsible Minerals Initiative, the company conducts due diligence on raw material suppliers every year, and re-examines and verifies the legality, quality assurance level and compliance of the suppliers as a means of adopting or disqualifying the supplier. in accordance with. If any non-conforming items are found, the company will require them to rectify. If the rectification does not meet the requirements, we will immediately stop purchasing from the company and return the purchased non-conforming materials.

　　 6. Risk identification

　　6.1 The company has designed a set of know-supplier (KYS) procedures, including the legal status, identity information and business scope of the supplier, and collected relevant supporting documents. All our suppliers have completed and returned the KYS form. The company's due diligence program manager and the procurement team reviewed the information provided and the UN sanctions list. As long as inconsistencies, errors or incomplete information are found in the KYS form, the company will request improvements. During the reporting period, no warning signs related to the submitted KYS form were found.

　　6.2 The company has identified three risk assessment tools as the company's risk assessment methods. When assessing the risk level, if a region is assessed as a non-high-risk region through these three tools, the region is suitable for low-risk source management, otherwise it is applicable For high-risk source management.

　　6.3 For the purpose of identifying any warning signals, discrepancies or discrepancies related to suppliers or raw materials, the collected raw material categories and source information were reviewed.

　　6.4 For each transaction, the company requires suppliers to provide origin information and a complete set of traceability documents, and to ensure that they can understand the source of the transaction, the transportation route, and the name and address of the direct supplier.

　　6.5 The company reviews all information collected against CAHRA, sanctions lists, local laws and internal procurement requirements. Record the countries and/or regions identified as CAHRA and refer to the RMI official website to learn and update more information about CAHRA identification in time.

　　7. Risk assessment

　　7.1 The company has carried out enhanced due diligence for the raw materials and supply chains identified as "high risk". This includes:

　　Assess the qualifications of upstream suppliers and purchase raw materials with upstream guarantee mechanisms;

　　Identify the location and quantitative conditions of ore mining, trade, processing and export;

　　Conduct differentiated risk assessment.

　　For areas that are defined as conflict-affected and high-risk areas after evaluation, and the country of origin is Congo and neighboring countries, only raw materials certified by the third-party evaluation system recognized by RMI, such as iTSCI system, BSP system, etc., are purchased. Without the evaluation and certification system, the procurement activities will be stopped.

　　7.2 Compare the actual situation with the risks in the model supply chain policy in Appendix II of the OECD Guidelines to assess whether there are risks and their severity in the supply chain. Before the contract is officially signed for each raw material procurement transaction, based on the supplier’s Information and data, using risk assessment tools to conduct risk assessment on the source country or region of the raw materials. If actual or potential risks are identified in the supply chain, they should immediately report to the senior manager and take corresponding measures.

　　 8. Risk reduction

　　 In response to the high-risk supply chain assessment results, the company requires relevant departments to take the following risk mitigation measures in a timely manner for risk management and control:

　　Report the high-risk supply chain survey and evaluation results to the company's senior management, and explain the relevant information, actual and potential risks of the high-risk supply chain.

　　 According to the company's supply chain policy risk management strategy, formulate and implement a risk management plan. Implement effective mitigation measures for existing risks, and negotiate with suppliers and affected parties to reach an agreement. Risk mitigation strategies include: continuing trade throughout the process of measurable risk management, temporarily suspending trade while reducing risks, and suspending cooperation with suppliers when risk reduction measures are not feasible or acceptable.

　　 Continue to monitor risks, and reassess after the risk situation changes.

　　 If the supplier's risk level changes after the reassessment, the supplier shall be notified immediately, and the cooperation with the supplier shall be suspended until the supplier provides document support in accordance with the management requirements.

Zhuzhou Gaoli New Material Co., Ltd.

May 12, 2020

Zhuzhou Gaoli New Material Co., Ltd.

Responsible Mineral Supply Chain Appeal Procedure

　　Article 1: Purpose

　　In order to discover and deal with various supply chain risks and hidden dangers in a timely manner, ensure smooth communication between internal and external stakeholders and the company, and improve the quality of participation and interaction with stakeholders, so as to establish harmonious and mutually beneficial stakeholder relationships and safeguard all interests The legitimate rights and interests of related parties and the company optimize the internal and external environment for enterprise development. This management system is formulated in accordance with the requirements of the "Responsible Mineral Inspection Process".

　　Article 2: Scope of Application

　　To ensure the effective operation of this system, the following conditions must be met:

　　1. Risks associated with the company's supply chain;

　　2. Gaps and deficiencies in the company's supply chain due diligence management system and measures;

　　3. Other relevant suggestions and opinions related to the supply chain supported by sufficient evidence.

　　Article 3: Appeal Channel

　　Any complaints about the above-mentioned scope, please email to our company's supply chain management department, email address: tang396919@hotmail.com.

　　Article 4: The principle of appeal

　　The complainant submits a complaint to the company, and the company accepts and handles the complaint shall follow the following principles:

　　1. Principle of fact: the complainant should provide evidence and materials based on facts based on specific facts and fully and completely. When the company accepts and handles the complaint, it should take the investigation facts as the basic starting point and deal with it according to the investigation facts;

　　2. Principle of association: The complainant can file a complaint for himself or on behalf of other individuals, groups or organizations. As long as the complaint meets the scope of application, the company will not accept or process complaints that are not associated with the company;

　　3. Procedural principles: The complainant should strictly follow the procedures and procedures stipulated in this management system for appeals and participation in appeals, and the company's acceptance and handling of appeals should also strictly follow the requirements of this management system;

　　4. Confidentiality principle: Both the complainant and the company should conduct the process under the principle of confidentiality, and handle the complaint seriously. During the appeal processing, the complainant and the relevant personnel of the company should keep confidential, before the end of the processing procedure No public disclosure of the appeal process and content;

　　5. The principle of timeliness: the complainant should promptly file an appeal within a reasonable time after knowing or ought to know the relevant facts for investigation and handling. After the company receives the appeal, it should deal with it and give a reply in time.

　　Article 5: Appeal procedure

　　All appeals should strictly follow the following procedures:

　　1. When making a complaint, the complainant must fill in the "Supply Chain Complaint" (Annex 1) in accordance with the company's regulations, and explain the relevant facts and appeal;

　　2. After receiving a complaint, the Supply Chain Management Department shall first determine whether the complaint meets the acceptance conditions of this management system, and confirm receipt of the complaint with the complainant within 5 working days. If the conditions for acceptance are not met, the complainant shall be informed that the complaint does not meet the conditions for acceptance at the same time as the complainant has received the complaint, and the complaint shall be terminated, and the "Supply Chain Appeal Record" shall be filled in (refer to Appendix 2);

　　3. If the complaint meets the acceptance conditions, after receiving the complaint, the Supply Chain Management Department shall discuss and study with relevant departments or personnel, conduct investigations and collect evidence, and obtain the opinions and support of the company’s senior management when necessary, and shall, after receiving the complaint Reply and handling opinions to the complainant within 15 working days from the date. If the complainant accepts the reply, the complaint can be terminated; if the complainant does not accept the company's reply and handling opinions, the relevant situation should be reported to the company's senior management within 5 working days;

　　4. If the complainant is still unacceptable to the company's final solution, he can seek solutions outside the company, including but not limited to third-party mediation, review and negotiation, and judicial channels;

　　5. If the same complainant or a different complainant filed another complaint on the same complaint that has been dealt with in each paragraph of this article, the company that has filed another complaint will not accept the complaint; however, if the complainant is not satisfied with the execution of the complaint, he may In this regard, appeal again.

　　Article 6: Appeal results

　　After the complainant accepts the reply, handling opinion or solution, he shall cooperate with the company to fill in the “Appellant Confirmation” section of the “Supply Chain Appeal”, promise to accept the appeal results listed in the “Appeal”, and no longer appeal on the same issue, and Signature confirmation.

　　The results of the appeal handling should be recorded in duplicate "Supply Chain Appeals Handling Opinions" (Annex 2), one for the appellant to keep, and the other for file by the Supply Chain Management Department.

　　Annex 1: Supply Chain Appeal

　　Annex 2: Supply chain appeal handling opinion letter (supply chain appeal record)