Conflict Minerals Policy

Democratic Republic of Congo and its neighboring countries. These metals are also referred to as the 3TG. Trading 3TG from the Democratic Republic of Congo and its neighboring states enables armed conflict and human rights abuses. The U.S. Dodd‐Frank Wall Street Reform and Customer Protection Act, Section 1502 and SEC regulations require disclosure of the use of 3TG and transparency within the supply chain. The idea behind this is to end armed conflicts and heed international law.

In line with the requirements of the Dodd‐Frank Act, G.Tech is aware of its responsibility and is contributing at various levels to sustainably protect human rights. G.Tech is committed to ensuring the health, safety and protection of the people who extract and mine 3TG. It is our responsibility to demand high social, environmental and human rights standards from our suppliers too.

Our Contribution

G.Tech is constantly working on further increasing transparency in the supply chain and ensuring conflict‐free mining of the 3TG that we use in our products. We are thus committed to:

 Identify in good time which G.Tech products are affected by the conflict minerals, legislation and orientate our compliance measures accordingly;

 Source conflict minerals exclusively from compliant melts (in accordance withResponsible Minerals Initiative).

 Contribute to conflict‐free trade by encouraging our suppliers to use compliant 3TG sources.

Actions Taken

G.Tech has defined the following measures to fulfil our responsibility and ensure transparency in the supply chain:

 Program for the fulfilment of due diligence in accordance with the OECD Due Diligence, Guidance for Responsible Mineral Supply Chains, which is supported by G.Tech management.

Communication with our suppliers for timely receipt of their feedback on the use of 3TG.

 Advising our suppliers regarding their disclosure obligations.  

 Risk assessment with regards to existing suppliers.

 Observation of US and European conflict minerals legislation.

Responsible raw material purchasing report

G.Tech is committed to implementing responsible mineral management, integrating responsible minerals as part of the procurement management system into supplier certification, supervision and audit, identifying suppliers involved in six responsible minerals, including tin, tantalum, tungsten, gold (3TG), cobalt and mica, and adopting the Conflict Minerals Reporting Template (CMRT)/Cobalt and mica Reporting Template (EMRT) responsible mineral questionnaire every year. Suppliers are required to identify smelters on a level by level basis. In 2022, G.Tech’s supply chain survey collected the responsible mineral questionnaire of 103 suppliers and shared the results of responsible mineral due management with a number of customers.

Key statistics show:

Supplier response rate: 100%

The smelters and refineries identified were compliant.

Limitations of due diligence measures:

As a downstream purchaser of conflict minerals, our due diligence measures can only provide reasonable, but not absolute, assurance as to the source and supplier of the required conflict minerals. Because we do not have direct contractual relationships with smelters and refiners, we rely on direct suppliers to collect and respond to specific information, and we rely heavily on information collected and provided by an independent third party audit programs, which may result in inaccurate or incomplete information being obtained.

Goals:

1. Continue to ask suppliers to reply to CMRT/EMRT, maintain the existing 100% response rate.

2. Ensure that all qualified suppliers sign the "Non-use of Conflict Minerals" declaration.

3. Verify supplier due diligence and include this process as part of the supplier evaluation process.

4. Design and provide more training programs for suppliers to raise their awareness of conflict minerals and help strengthen their conflict minerals management capabilities.

5. Continuously improve conflict minerals management capabilities to meet customer needs.

6. Actively cooperate with upstream and downstream suppliers to improve business partnerships and reduce potential conflict mineral risks.