Responsible Mineral Procurement Policy

Simplo Technology is committed to conducting due diligence across its supply chain in accordance with the Organization for Economic Cooperation and Development (OECD) Guidelines for the responsible sourcing of minerals. This applies to ten specific minerals contained in our products: Tantalum (Ta), Tin (Sn), Tungsten (W), and Gold (Au) — collectively known as 3TGs — as well as Cobalt (Co), Mica, Copper (Cu), Natural Graphite (Gr), Lithium (Li), and Nickel (Ni).We have formally communicated to our suppliers that the procurement of the above 10 minerals must be exclusively sourced from conflict-free smelters and refiners that have been certified by internationally recognized third-party organizations, such as the Responsible Business Alliance (RBA) through the Responsible Minerals Initiative (RMI), formerly known as the Conflict-Free Sourcing Initiative. In alignment with our responsible sourcing strategy, Simplo Technology will also assist and encourage suppliers to actively engage with smelters and refiners not yet recognized by RMI to undergo verification under the Responsible Minerals Assurance Process (RMAP). This initiative reflects our long-term commitment to ethical sourcing, risk management, and building a sustainable, transparent, and accountable supply chain ecosystem.

Starting in 2025, Simplo Technology will initiate the Additional Minerals Reporting Template (AMRT) survey for suppliers of critical raw materials, focusing on due diligence for four additional minerals: Copper (Cu), Graphite (Gr), Lithium (Li), and Nickel (Ni). This initiative is aimed at enhancing supply chain transparency and advancing responsible sourcing practices.

Simplo Technology implements the Responsible Minerals Initiative (RMI) under the framework of the Responsible Business Alliance (RBA) to support Reasonable Country of Origin Inquiry (RCOI) efforts in identifying smelters and refiners. All related records are systematically maintained within our internal database, and long-term partnerships have been established with the majority of our suppliers. Suppliers are required to sign the Conflict Minerals Declaration and are further mandated to ensure that all sourcing of 3TGs (Tantalum, Tin, Tungsten, and Gold), as well as Cobalt, Mica, Copper, Natural Graphite, Lithium, and Nickel, is exclusively from smelters and refiners certified by internationally recognized third-party organizations such as RBA through the RMI. This requirement has been formally integrated into our Hazardous Substance Management Specifications. In 2024, Simplo Technology conducted due diligence on 200 raw material suppliers, identifying 226 3TG smelters, 53 cobalt refiners, and 3 mica processors. As the list of qualified smelters and refiners published on the RMI official website is dynamic—subject to changes due to smelter closures, withdrawal from the RMAP (Responsible Minerals Assurance Process), or production suspensions—ongoing monitoring is critical to maintaining compliance and stakeholder alignment on conflict minerals issues.

To address this, we have implemented Robotic Process Automation (RPA) to regularly monitor updates to the RMI smelter and refiner list, ensuring real-time access to the most up-to-date and complete information. Our system automatically reinitiates supplier surveys for any non-compliant submissions, using a rolling update mechanism to guarantee all data complies with the latest regulations and customer requirements. Through these robust governance measures, Simplo Technology remains committed to upholding corporate responsibility, preventing human rights violations, and fostering a sustainable, ethically sourced supply chain.