Etica formulates the conflict minerals policy and the management process of responsible minerals procurement to achieve the goal of responsible and sustainable procurement. Moreover, Etica promises that the source of the used minerals conforms to the standards of the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or the standards set out in equivalent recognized due diligence frameworks. Regarding the procurement, We conduct due diligence, and we also determine which smelting plants and refinery plants can be verified as having the systems conforming the current global standards of responsible mineral sourcing. Consequently, we purchase through smelters or refineries with 100% execution and third-party verification. Also, conflict minerals originating from high-risk areas are prohibited. Conflict minerals reporting templates are provided to help the company disclose and communicate with smelting plants in their supply chain.

We follow the findings of the Responsible Minerals Initiative (RMI). In 2020, it is clearly regulated in the supplier's social responsibility management - "Conflict Minerals Management Procedures" to avoid inadvertently obtaining metals from conflict minerals*. We and our suppliers are explicitly required that the supply chains should have policies in place to reasonably assure the source and the chain of custody of Gold (Au), Tantalum (Ta), Tungsten (W), Tin (Sn), Cobalt (Co) and Mica contained in the products they manufacture with the conduct of due diligence. Their sources are ensured to comply with the OECD Guidelines, or the sources of the minerals have been excluded from the conflict-affected and the high-risk areas as defined by the equivalent recognized organizations.

Every year, Etica re-evaluates the current list of smelting plants/ refinery plants used in Etica products in accordance with the conformant smelters list announced on the RBA official website. In addition, conflict minerals investigations are carried out through the Etica SQP (Supplier questionnaire platform) questionnaire system and the audits. The content of the questionnaire is systematically managed and recorded and tracked. In addition, Etica fully implements due diligence to understand the source of the suppliers' minerals with the RMI's Conflict Minerals Investigation Template and Conflict Minerals Reporting Template, and Extended Minerals Reporting Template (hereinafter referred to as CMRT and EMRT) as the investigation. In addition, our suppliers are required to disclose the source of minerals and to sign the declaration of non-use of conflict minerals while they are subject to a policy of not using conflict minerals. Meanwhile, Etica also further manages to ensure that the suppliers' procurement sources are not from conflict-affected areas and high-risk areas, which also meet the requirements of the customers and the regulations.

The above survey methods are all in accordance with the process of the conflict minerals management process defined by Etica. During the process, Etica shall confirm with the supplier for the reason and necessity of the conflict minerals used. If it is not necessary, the supplier shall be required to stop purchase and use the conflict minerals. Also, new mineral sources shall be reselected. Moreover, effective evidence needs to be provided to prove that the new minerals are conflictfree minerals that meet RBA requirements. If it is necessary, the supplier shall be required to propose a removal plan or improvement measures.

* Conflict Minerals refers to minerals mined in situations of armed conflict and human rights violations. Gold (Au), Tantalum (Ta), Tungsten (W), Tin (Sn), Cobalt (Co) and Mica are the main objects of regulation. Not limited to the eastern provinces of the Democratic Republic of the Congo controlled by the Congolese government forces and many other armed rebel groups in and around the nine countries. The mines used to extract resources are controlled by these countries including Angola, Burundi, the Central African Republic, the Republic of Congo, Uganda, Sudan, Tanzania, Rwanda and Zambia. Minerals from conflict-affected and high-risk areas as defined by the OECD or an equivalent recognized organization are also included.