1. Conflict Minerals Policy:

For minerals such as 3TG (Tantalum Ta,Tin Sn, Tungsten W, Gold Au) from conflict or high-risk areas, metal minerals controlled by smuggling trade, controlled by non-government forces or illegal military factions are all conflict minerals. Odeco Ltd. requires suppliers to comply with the Responsible Business Alliance Code of Conduct (RBA), purchase materials only from environmentally and socially responsible suppliers, prohibit suppliers from purchasing minerals from Congo and its neighboring countries, from the Responsible Mineral Guarantee Process (RMAP) certified smelters and refineries confirmed by the Responsible Mineral Initiative (RMI), and all suppliers shall purchase metals from smelters and refineries certified to meet conflict metal requirements through RMAP. Smelters and refineries that do not have RMAP certification or do not meet customer requirements must be removed from the supply chain and committed to perform due diligence under the Organization for Economic Cooperation and Development (OECD) requirements.

2. Conflict mineral survey background

 Since the late 1990s, the ongoing internal armed conflict in the Democratic Republic of the Congo (DRC) has claimed the lives of more than 5.4 million people. Local mineral mining and international trade have directly or indirectly provided financial support for the armed conflict and contributed to extreme levels of violence in the region..

 European and American consumers and the international community call on companies that import and use minerals from conflict areas to take action to investigate the use of conflict minerals in the supply chain, limit or ban the use of conflict minerals, and reduce financial support for conflict areas, thereby reducing armed conflicts and human rights disasters.

 In 2010, the U.S. Congress added Section 1502 to the Dodd-Frank Act, requiring U.S. listed companies to disclose the use of conflict minerals (tin, tungsten, tantalum, gold, 3TG) from Congo and nine surrounding countries. Conduct supply chain due diligence and publish annual reports. In 2017, the European Parliament passed the Conflict Minerals Act, requiring all companies to assess the compliance of suppliers trading in tin, tungsten, tantalum, gold (3TG), etc.

The Conflict Minerals Act not only affects U.S. listed companies and their supply chains, but has also become a new topic in the global CSR field and an integral part of industry standards such as RBA/JAC/AIAG..

3. List of qualified smelters

Please ensure that the smelters used in the CMRT provided to Odeco Ltd. are all qualified smelters, that is, they are all in the list of qualified smelters updated regularly by RMI.

Download address for the latest version of the list of qualified smelters: http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/smelters-refiners-lists/export-all-conformant/

Since the list of Qualified Smelters (Conformant list) is changing dynamically, please make a comparison and confirmation of your company before submitting your CMRT to Odeco Ltd. to ensure that all smelters submitted by your company are qualified smelters.

If the smelter used is not on the Conformant list, please immediately adopt one of the following methods and provide supporting information::

1) Promote the supplier to stop using the raw materials provided by the unqualified smelters;

2) Promote unqualified smelters to actively rectify and then be certified as qualified smelter