Kaipeng Mining Co., Ltd. (hereinafter referred to as "KAIPENG" or "we") recognizes that significant social and environmental risks may arise from the mining, trading, processing, and export of copper raw materials, and acknowledges the company's responsibility to respect human rights, eliminate, and control related risks. To this end, we have formulated our company's "Responsible Supply Chain Management Policy for copper" (hereinafter referred to as the "Policy") based on the "China Responsible Mineral Supply Chain Management Guidelines" released by the China Chamber of Commerce for Import and Export of Minmetals and Chemicals (CCCMC), and with reference to the "Responsible Supply Chain Management Guidelines for Minerals from Conflict Affected and High Risk Areas, Third Edition" of the Organization for Economic Cooperation and Development (OECD). And incorporate it into the contracts or agreements signed with suppliers, this policy provides reference for conflict sensitive procurement activities and suppliers' risk awareness throughout the entire process of mineral resource supply chain. We promise to abide by relevant United Nations sanctions resolutions, comply with domestic laws applicable to the implementation of such resolutions, and not engage in any behavior that would provide assistance or convenience for conflicts.

Trading and handling minerals from high-risk areas, and recognising that we have the responsibility to respect human rights and not contribute to adverse impacts to society, KAIPENG commits to adopt and widely disseminate the Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains (Chinese Guidance), Edition 2 published by the China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters (CCCMC) ,and incorporate it into its contracts and agreements with suppliers. This policy provides a reference for conflict-sensitive procurement activities throughout the mineral supply chain. KAIPENG commits not to engage in any activity that would contribute to the conflict and to abide by relevant UN sanctions, Or, where applicable, comply with domestic laws implementing such resolutions and respect the recommendations of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Edition 3 published by the OECD (OECD Guidance) on disclosure of information. KAIPENG commits to conducting supply chain due diligence using the six-step framework of Chinese Guidance (second edition) and the five-step framework of the OECD Guidance (third edition).

The objective minerals of due diligence for KAIPENG: Copper

This Policy is applicable for Kaipeng Mining Co., Ltd.

Regarding serious abuses associated with the extraction, transport or trade of minerals:

While sourcing from, or operating in high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:

the worst forms of child labour (Hazardous work is one of the worst forms of child labour);

any forms of torture, cruel, inhuman and degrading treatment;

any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;

other gross human rights violations and abuses such as widespread sexual violence;

war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

Regarding risk management of serious abuses:

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined in paragraph 1.

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

We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling or export of minerals includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:

illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or

illegally tax or extort money or minerals resources at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or

illegally tax or extort intermediaries, export companies or international traders.

Regarding risk management of direct or indirect support to non-state armed groups:

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups.

Regarding bribery and fraudulent misrepresentation of the origin of minerals:

We will not offer directly or indirectly, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export, or failing to follow relevant international standards and conventions for anticorruption.

Regarding money laundering:

We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

Regarding the payment of taxes, fees and royalties due to governments:

We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with internationaly recognised transparency standards.

Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments:

In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organisations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measureable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation of 6 months.

Regarding occupational health and safety:

While sourcing from, or operating in high-risk areas, we will not profit from, assist with, or facilitate or source from, or be linked to, any party providing life threatening occupational health and safety conditions to direct and / or indirect employees and / or any person present on the party's operations.

Regarding risk management of occupational health and safety:

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing life threatening occupational health and safety conditions as defined in previous paragraph.

Regarding child labour:

While sourcing from, or operating in high-risk areas, we will not employ, profit from, assist with, or facilitate, or source from, or be linked to, any party employing, profiting from, assisting with, or facilitating the employment of children under the minimum working age which is legally prescribed by the host country laws and regulations. If there is no relevant host country law or regulation, the minimum working age shall be 16 years.

Regarding risk management of child labour:

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party employing children as defined in paragraph 17.

Regarding Environmental Protection:

While sourcing from, or operating in high-risk areas, we will not profit from, assist with, or facilitate significant adverse impacts regarding ambient soil, air and water conditions, or source from or be linked to any party with gross violation of local laws and regulations. Wewill support or take actions to evaluate periodically to minimize the adverse impacts of extraction regarding soil, air and water. Environment, climate, and human health, considering direct, induced, indirect, and cumulative impacts, including:

Air pollution, including greenhouse gas emissions;

Water, including the seabed and marine environment, and including water pollution, water use, water quantity (floods or droughts), and access to water;

Soil, including soil pollution, soil erosion, land use, and land degradation;

Biodiversity, including the destruction of habitats, wildlife, plants, and ecosystems, including ecosystem services;

Harmful substances;

Noise and vibration;

Factory safety;

Energy usage;

Waste and residues;

Regarding Exploitation of Resources:

We do not participate in, tolerate, or profit from the exploitation of resources from land where the free, prior and informed consent of local and indigenous peoples has not been obtained, a legal title, lease, concession, or license has been obtained illegally , or national laws have been violated.

Regarding Culture, Heritage Protection and Legally Protected Areas:

We do not participate in, tolerate, or profit from extracting or sourcing resources from mining operations where the culture and heritage of local and indigenous peoples have not been respected and protected, or where traditional cultures and heritage of local peoples have been harmed.

Regarding Risk Management of Environment, Culture, Heritage:

If we have proper reasons to believe that such a risk exists, we will immediately work with suppliers and other stakeholders to develop, adopt and implement risk management plans based on where the enterprise’s specific position in the supply chain is. In order to prevent or mitigate the specific risks related to infringement of land rights, leading to significant adverse environmental impact or local cultural heritage damage. If the risk mitigation measures do not work, we will suspend or terminate our cooperation with upstream suppliers. 

Kaipeng Mining Co., Ltd.

December, 31st, 2024