Conflict Minerals Policy

Established in August 1996, G.TECH TECHNOLOGY LTD. is a high-tech enterprise specializing in computer peripheral hardware products, integrating R&D, production, and sales. Through years of development, the company has accumulated robust R&D capabilities and production management expertise. Guided by a philosophy of technological innovation and product leadership, G.TECH has achieved continuous growth in business performance and expanded its operations. It has become a leading manufacturer for numerous multinational corporations and renowned enterprises worldwide. G.TECH strictly prohibits any activities that cause conflict or violate human rights in its operations. We conduct supply chain due diligence to ensure that gold (Au), tantalum (Ta), tin (Sn), tungsten (W), cobalt (Co), and mica used in our products do not originate from conflict-affected mines or regions within the Democratic Republic of the Congo (DRC) and its neighboring countries and regions, including the Central African Republic, Sudan, South Sudan, Zambia, Angola, the Republic of the Congo, Burundi, Rwanda, Tanzania, and Uganda, or from illegal trade taxation controlled by non-governmental military organizations or illegal military factions. G.TECH TECHNOLOGY LTD. is committed to respecting human rights and the environment in accordance with all recognized international conventions and standards, such as the United Nations Global Compact. G.TECH strive to ensure all materials used in our products originate from socially and environmentally responsible sources. G.TECH absolutely do not tolerate any involvement in activities that contribute to environmental degradation or human rights violations stemming from conflict. G.TECH TECHNOLOGY LTD. is not listed on the New York Stock Exchange (NYSE) and is therefore not subject to the U.S. Securities and Exchange Commission's Conflict Minerals Rule. To ensure the accuracy and professionalism of our reporting, G.TECH TECHNOLOGY LTD.'s Conflict Minerals Report is prepared in accordance with the Dodd-Frank Act or SEC Form 1502. The reporting period covered in this report is from 1st,January 2025, to 31st, December 2025.

Reasonable Country of Origin Inquiry（RCOI）

Through material content analysis, G.TECH found trace amounts of tungsten, tin, tantalum, gold, cobalt, and mica present in most production components. Therefore, G.TECH conducted due diligence on countries of origin to determine whether the conflict minerals contained in our products originate from the Democratic Republic of the Congo and adjacent conflict-affected areas. One primary method for confirming country of origin is utilizing the CMRT/EMRT created by the RMI. The list of smelters or refiners collected through the CMRT/EMRT will be compared against the RMAP list to determine whether these smelters or refiners have been verified as conflict-free. Additionally, RMAP has agreed to mutually recognize audit results for gold refiners with LBMA and RJC, which are reflected in RMI's list of verified smelters or refiners. http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/ Based on reasonable country-of-origin inquiries, G.TECH have determined that the conflict minerals contained in our products may originate from the Democratic Republic of the Congo or adjacent conflict-affected areas. Therefore, we have established our own conflict minerals due diligence process in accordance with the five-step framework outlined in the OECD Due Diligence Guidance to determine whether the conflict minerals used in our products are “conflict-free.”

Conflict Minerals Program Design

G.TECH has designed and developed a conflict minerals due diligence program to monitor and identify risks associated with conflict minerals, thereby better assisting in avoiding responsibility for causing or participating in conflict through minerals. G.TECH supports and recognizes smelters and refiners certified through the RMAP. G.TECHconducts investigations into all suppliers within the scope of its inquiries, performs focused follow-up investigations on high-risk suppliers, and assesses the reasonableness of their mineral sourcing practices. G.TECH 's Conflict Minerals Due Diligence Program is grounded in the internationally recognized OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) framework to ensure accuracy and compliance. G.TECH is committed to delivering the most authentic and precise due diligence procedures for conflict minerals.

Below is an overview of the G.TECH Conflict Minerals Due Diligence Program framework:

1. Establish and Strengthen Management SystemsDevelop supply chain policies to enhance management structures, establish internal management teams for oversight, and create management systems to identify and manage risks. Collaborate with suppliers to better understand their risks and develop plans to assist them. Implement grievance mechanisms and anti-bribery policies to ensure management transparency.

2. Identify and Manage Risks in the Supply ChainInvestigate and identify smelters or refiners within the supply chain, determine and establish the scope of mineral supply chain risk assessments. Evaluate the completion rate of due diligence for projects and determine project risks.

3. Address Identified RisksIdentified risks will be confirmed by the team and reported to senior management. Management will convene meetings to summarize a risk management plan and establish a working group for follow-up. If a supplier cannot provide valid and credible evidence of risk assessment and management policies, it must undergo a comprehensive third-party audit. Should a supplier fail to conduct the recommended comprehensive third-party audit, refuse to implement improvements, or fail to cooperate with improvement efforts, the company will terminate the cooperation contract in accordance with internal policies.

4. Publication and Reporting of Due Diligence FindingsDue diligence findings and related disclosures will be published in the G.TECH Sustainability Report or independently as public information.

Description of Conflict Minerals Process Implementation

1. G.TECH Conflict Minerals Management System
OverviewG.TECH has established a Conflict Minerals Policy and Guidelines to demonstrate our commitment to respecting human rights and protecting the environment, and to implement conflict minerals management procedures. The Conflict Minerals Management Policy aligns with industry and internationally recognized principles, including the United Nations Global Compact. This policy is publicly available on G.TECH official website: https://www.gtech.com.cn/development/48.html

GovernanceG.TECH 's conflict minerals management is guided by a management team led by the Management Representative. The executive team comprises designated representatives from departments including Quality and Supply Chain Procurement. The management team oversees the overall management and implementation of the policy to ensure its applicability, transparency, and effectiveness in monitoring conflict minerals risks within the supply chain. The management team reports regularly to the Management Representative. The executive team, equipped with relevant capabilities and experience, coordinates with stakeholders to execute the conflict minerals management approach outlined in the policy, including the annual conflict minerals risk assessment. Identified risks or opportunities are promptly reported by the management team to senior management to enable the formulation of company strategy related to conflict minerals.

Supplier Requirements and EngagementG.TECH aims to establish long-term cooperative relationships with suppliers. Through continuous communication and understanding of their expectations, G.TECH provides ongoing support and capacity building to drive supplier improvement. G.TECH requires all relevant suppliers to ensure materials are sourced from environmentally and socially responsible origins. Conflict mineral requirements and specifications are included in the supplier's Conflict-Free Statement of Compliance. All suppliers must sign this statement to commit to and comply with G.TECH 's conflict mineral policies and requirements. This includes annually submitting 3TG report templates/cobalt and mica report templates, and participating in relevant training and due diligence activities.

2. Supply Chain Risk Identification and AssessmentG.TECH does not directly purchase raw materials or refined minerals from smelters or refiners. This means ensuring a conflict-free supply chain involves additional complex risks. OECD guidelines acknowledge the difficulty downstream companies face in identifying upstream suppliers. Nevertheless, we make every effort to achieve a conflict-free supply chain. G.TECH conducts annual conflict minerals due diligence using CMRT/EMRT, requiring our direct suppliers to provide information on the smelters or refiners from whom they source. Upon receiving responses, we consolidate supplier replies based on the types of conflict minerals used (3TG, Co, and mica). We then cross-reference results against the RMI's list of known conflict-affected smelters/refiners and RMAP or other external lists to verify whether smelters/ and their countries of origin are associated with conflict minerals.

3. Management Strategy for Supplier Risk IdentificationAs a responsible company, G.TECH does not immediately terminate business relationships with high-risk suppliers. Instead, we actively collaborate with suppliers to implement tailored mitigation measures based on their conflict mineral risk levels, optimizing their conflict mineral management. We encourage suppliers to establish their own conflict-free mineral policies to regulate procurement activities. We also require suppliers to ensure their upstream smelters/refineries obtain valid conflict-free third-party certifications as part of their risk mitigation plans. Additionally, suppliers must provide corrective action plans for non-compliance within two weeks. Verification of these actions typically occurs during the next supplier-specific audit. Non-cooperative suppliers or those failing to meet requirements after corrective actions may face necessary penalties, potentially leading to termination of business relationships. By 2025, G.TECH will have no suppliers terminated due to conflict minerals issues.

4. Independent Third-Party Certification for Supply Chain Due DiligenceAlthough we have no direct relationship with upstream smelters or refiners, we recognize the importance of third-party conflict-free certification at the smelter or refineries holds significance for downstream enterprises. Therefore, we require all G.TECHdirect suppliers to provide a detailed list of upstream partner smelters/refineries obtained through supply chain due diligence. We cross-reference this list with verified smelter/refinery lists from RMAP or other external organizations to assess their conflict-free status.

G.TECH 's Due Diligence Measures and Results for 2025

The scope of direct suppliers subject to supply chain investigations was determined by the Quality Department. Following preliminary screening, 163 suppliers were identified as involving conflict minerals. The investigation format required completion of CMRT and EMRT forms.

Key Statistical Data:
(1) Supplier response rate: 100%
(2) 103 smelters and refiners were identified within the supply chain, all listed on the RMI Qualified Smelter List.
(3) Two suppliers utilized tin metal sourced from a smelter in Rwanda (CID003387). Upon verification against the RMI's published list of approved smelters, this facility was confirmed as an RMI-approved smelter.

Details of the 2025 Reasonable Country of Origin Inquiry:

Conflict Minerals	Tantalum (Ta)	Tin (Sn)	Gold (Au)	Tungsten (W)	Cobalt (Co)	Mica	Total
Number of smelters/refineries	7	27	54	7	8	0	103
Recognition or Activity Level	100%	100%	100%	100%	100%	0.00%	100%

Inherent Limitations of Due Diligence Measures

As a downstream purchaser of conflict minerals, our due diligence measures can only provide reasonable, not absolute, assurance regarding the origin and supply chain of conflict minerals as required. Owing to the absence of direct contractual relationships with smelters and refiners, we rely on direct suppliers to gather and provide specific information. Furthermore, this process is heavily dependent on information collected and supplied by independent third-party audit programmes. Such sources may yield inaccurate or incomplete information and may contain fraudulent data. on information gathered and provided by independent third-party audit programmes. Such sources may yield inaccurate or incomplete information and could potentially contain fraudulent data.

Next Steps

G.TECH will undertake the following measures to enhance its due diligence procedures and mitigate the risk of conflict minerals financing human rights abuses by armed groups:

1. Design and deliver training programmes for suppliers to heighten their awareness of conflict minerals and strengthen their management capabilities in this area;

2. Actively collaborate with upstream and downstream suppliers to improve business partnerships and mitigate potential conflict minerals risks;

3. Continuously enhance conflict minerals management capabilities to meet customer requirements;

4. Maintain the current 100% response rate by continuing to require suppliers to complete CMRT/EMRT submissions;

5. Ensure all qualified suppliers sign the Declaration of Non-Use of Conflict Minerals;

6. Collaborate with suppliers, stakeholders and peers to further enhance conflict minerals awareness and due diligence capabilities;

7. Establish and strengthen management frameworks in accordance with MSCI ESG rating requirements and standards;

8. Ensure steady improvement in both internal and external conflict minerals management.