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Conflict Minerals Management

1. General 

Having recognized the major adverse impacts that may arise from mineral extraction, trade, processing, and export in conflict-affected and high-risk areas, and being fully aware of the obligations to respect human rights and not fuel conflicts, Raytron Technology Co., Ltd. and its subsidiaries (hereinafter referred to as "the Company") are committed to implementing responsible minerals procurement (not supporting or using metals illegally extracted through armed conflicts, violence, or any means that violating human rights, i.e. "conflict minerals”). The Company has developed risk management measures in response to the possible risks in commercial activities, making sure that the Company complies with the EU Conflict Minerals Regulations, the US Dodd Frank Act, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the Responsible Minerals Initiative (RMI), and the China Due Diligence Guidance for Mineral Supply Chain. 

1.1 Conflict Minerals 

Metal minerals such as gold, tantalum, tungsten, and tin (the 3TG) or their derivatives; 

Any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or an adjoining country. 

1.2 High-Risk Areas 

Countries on the EU CAHRAs (Conflict-Affected and High-Risk Areas) list: CAHRAs (; 

Conflict-affected and high-risk areas defined in the U.S. Dodd-Frank Act, namely the DRC+9 (Democratic Republic of Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia). 

2. Corporate Policy 

The Company has well established internal management institutions for conflict minerals, formulated and issued the Conflict Minerals Management System. The Company has identified materials involving conflict metals used by the group and all subsidiaries, and signed the Conflict Minerals Agreement with corresponding suppliers, making sure that suppliers are informed of and comply with the Company’s conflict minerals policy. The Company requests suppliers to fill in the Conflict Minerals Information Collection Form to establish a list of smelters/refineries. The Company evaluates supplier information changes on a regular basis to ensure that minerals from conflict-affected and high-risk areas are not used in the entire mineral supply chain. 

If a smelter/refinery is found to be not on the RMI compliance list during an investigation or inspection, the Company will immediately review the time, batch, and volume of materials supplied, control the products that have been produced, and notify the supplier to provide a third-party audit report showing that the smelter/refinery meets the requirements. If such a document cannot be provided within the specified time, material supply from the supplier must be stopped, a new source with valid certifications should be identified, and preventive measures must be formulated for future operation; otherwise, the Company will suspend cooperation with this supplier. The Company will monitor and track the effectiveness of risk mitigation measures. If the mitigation measures fail to take effects in six months, the Company will terminate cooperation with the supplier. 

The Company will follow the OECD Due Diligence Guidance to promote the due diligence practice throughout the mineral supply chain. 

3. Current Situation of the Company 

As of today, none of the materials used by the Company involves conflict minerals.