Responsible Minerals Sourcing Policy

Guangdong HuiXinPu Circuit Co., Ltd (HXP Circuit) is committed to sustainable and responsible sourcing of goods and services throughout our supply chain, including the various extracted minerals from around the world that ultimately become incorporated into our goods or services. Responsible sourcing is an increasingly important part of our commitment. We recognize the importance of mitigating any inadvertent adverse impact that HXP Circuit demand for minerals may cause to the environment, society, and people in regions where the minerals are extracted or processed.

HXP Circuit understands that certain minerals predominantly originate from Conflict Affected and High-Risk Areas (CAHRA)1, including the Democratic Republic of Congo (“DRC”) and its adjoining countries, where there are heightened concerns that proceeds from minerals could be used to contribute to armed conflict or human 

rights abuses. In particular, the minerals tin, tungsten, tantalum, and gold (“3TG Minerals”) that are extracted or processed in certain geographies and contribute to 

armed conflict in DRC and its adjoining countries have become commonly referred to as “conflict minerals.” Similar concerns exist with additional minerals identified in Appendix A to this policy. 

Consistent with our company values, HXP Circuit’s goal is to avoid sourcing minerals in a way that contributes to armed conflict or human rights abuses. HXP Circuit’s goal is also to continue to support the communities in those areas that depend on the mining industry through the sustainable sourcing of minerals in accordance with this policy. We are adopting this policy and have designed our program and due diligence practices in accordance with the OECD Due Diligence Guidance for 

Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas(OECD Due Diligence Guidance) in order to address responsible mineral sourcing. 

As an organization, we have committed to: 

I. Exercise due diligence with relevant suppliers in accordance with the OECD Guidance.

II. Collaborate with customers, suppliers, and industry associations to help develop long term solutions to enable responsible sourcing.

III. Support sourcing initiatives to improve the upstream communities in our supply chain.

IV. Encourage smelters and refiners in our supply chain to successfully complete the Responsible Minerals Assurance Process (RMAP).

What we require of our suppliers: 

I. Create and maintain a publicly available responsible minerals policy consistent with the OECD Guidance.

II. Establish due diligence frameworks and management systems consistent with the OECD Guidance.

III. On an annual basis, complete reporting templates for the minerals identified in Appendix A. 

IV. Utilize smelters and refiners that conform to an independent third-party responsible minerals sourcing program.

V. Extend these requirements and expectations to all their sub-tier suppliers. 

If we determine that a supplier in our supply chain violates one of these responsible sourcing requirements, we will endeavor to obtain an acceptable remediation of the 

violation, including without limitation directly communicating with suppliers and making available compliance education and training. We may also reassess our business relationship with a supplier if identified violations are not remedied. 

1. OECD definition of conflict-affected and high-risk areas: “Conflict-affected and high-risk areas are identified by the presence of armed conflict, widespread violence or other risks of harm to people. Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc. High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.”