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Cobalt supply chain responsible management policy and commitment (3rd edition)

(Summary description)Nanjing Hanrui Cobalt Co., Ltd.(hereinafter referred to as "the company") has long been committed to creating win-win value added space for its partners, striving to contribute to economic growth and promote sustainable and inclusive development in the exploitation and utilization of Cobalt resources. The company recognizes that there are many challenges to achieving this goal, and that operating in high-risk areas such as cobalt mining, trading, processing, and exporting may run the risk of significant negative impact on local communities. We believe that companies should respect human rights and assume the responsibility to avoid or mitigate negative impacts on society.

Cobalt supply chain responsible management policy and commitment (3rd edition)

(Summary description)Nanjing Hanrui Cobalt Co., Ltd.(hereinafter referred to as "the company") has long been committed to creating win-win value added space for its partners, striving to contribute to economic growth and promote sustainable and inclusive development in the exploitation and utilization of Cobalt resources. The company recognizes that there are many challenges to achieving this goal, and that operating in high-risk areas such as cobalt mining, trading, processing, and exporting may run the risk of significant negative impact on local communities. We believe that companies should respect human rights and assume the responsibility to avoid or mitigate negative impacts on society.

Information

Nanjing Hanrui Cobalt Co., Ltd.(hereinafter referred to as "the company") has long been committed to creating win-win value added space for its partners, striving to contribute to economic growth and promote sustainable and inclusive development in the exploitation and utilization of Cobalt resources. The company recognizes that there are many challenges to achieving this goal, and that operating in high-risk areas such as cobalt mining, trading, processing, and exporting may run the risk of significant negative impact on local communities. We believe that companies should respect human rights and assume the responsibility to avoid or mitigate negative impacts on society.

To this end, the company committed to adopt the China chamber of commerce of metals, minerals and chemicals importers and exporters (CCCMC) issued

Responsible for the China mineral responsible supply chain management guidelines, and refer to the organization for economic cooperation and development (OECD) issued by weaving on the ore from affected by conflict and high-risk areas responsible for a responsible supply chain management guide and other internationally recognized standards, will be based on the principle of continuous improvement, by setting a clear policy, establishing the suitable organization structure, set up several measures, such as multilateral communication and report system responsible for the procurement requirements of supply chain management system, the company in order to achieve the goal of sustainable supply chain management.

In order to achieve the above objectives, the company solemnly promises and will take the following measures:

I. commitment to responsible procurement practices

Companies realize that promote sustainable supply chain management is a long-term and arduous task, therefore, the company has invested sufficient manpower, material resources and financial resources, set up a specialized supply chain governance committee and the supply chain management, formulate the measures for the administration of "supply chain management committee, efforts will cobalt resources responsible in the daily management of the procurement practice system and integrated into the company.

The company also recognizes that the goal of sustainable supply chain governance cannot be achieved without joint action from upstream and downstream of the supply chain. To this end, the company will actively participate in the industry governance action

And the upstream and downstream of the supply chain should take joint actions to formulate supplier codes of conduct and standards, seek communication and cooperation with suppliers, and actively communicate with downstream enterprises, so as to improve the transparency and traceability of the cobalt supply chain by improving governance performance and information transmission.

Ii. Commitment to control supply chain risks

Promise that it will in accordance with the CCCMC (CCCMC) released the China responsible mineral responsible supply chain management guide "five steps", and refer to the organization for economic cooperation and development (OECD) on the ore from affected by conflict and high-risk areas responsible for a responsible supply chain management guide, in the supply chain risk assessment and control, risk including but not limited to:

1. Risks related to serious infringement activities related to mining, transportation or trading of mineral resources. Cobalt raw materials mining, transportation, trading, processing and export operations in high-risk areas

The company will neither tolerate nor in any way directly or indirectly support the following activities:

(1) any form of cruel, cruel, inhuman or degrading behavior;

(2) any form of forced or compulsory Labour, such as the threat of punishment or the imposition of all Labour or services on the involuntary part of others;

(3) the worst forms of child labor;

(4) other serious violations and abuses of human rights;

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

Risk management for the above serious infringement:

If we have reasonable grounds to believe that the upstream supplier purchases from or is associated with any party that commits serious human rights violations, we will immediately suspend or suspend our cooperation with that supplier.

If child labor is misused due to the authenticity of the materials, the company shall immediately terminate the relationship with the child labor

If the termination of the labor relationship affects the family economy, the company will arrange other adults in the family to work for the company until the child becomes an adult.

Risks associated with direct or indirect support to non-state armed groups

We do not tolerate any direct or indirect support for organized armed groups that are not state owned through the exploitation, transportation, trading, processing or export of mineral resources. Providing "direct or indirect support" to non-state organized armed groups through the exploitation, transportation, trading, processing or export of mineral resources, including but not limited to the purchase of resources, payment to, or otherwise provision of logistical support or equipment to illegal organized armed groups or their affiliates. These armed groups or related parties:

(1) illegally control mining areas, or otherwise control transportation routes, trading places of mineral resources and upstream actors of supply chains;

(2) illegal taxation, extortion of money or plunder of resources at the entrance of the mining area, transportation route of the mining area and trading place of mineral resources, or money-laundering risks related thereto;

(3) extorting middlemen, export enterprises or international traders or imposing illegal taxes on them.

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

If we have reasonable grounds to believe that an upstream supplier is purchasing from or associated with any party that provides direct or indirect support to a non-state organized armed group, we will immediately suspend or suspend our cooperation with that supplier.

3. Risks associated with public or private security forces

The company recognizes that the role of public or private security forces in and around the mine area and along transport roads is only to protect rights and interests according to law, including respecting human rights, protecting miners, maintaining the safety of equipment and facilities, and protecting the legitimate operation of the mine area and the transport routes from illegal interference. Therefore, the company undertakes, supports or takes measures to ensure that no serious human rights violations are committed by employees

Public or private security forces. The company will work actively with local governments, international organizations and civil society teams to avoid or minimize the adverse impact of public or private security forces employed by the company on local communities or vulnerable groups.

Risk management related to public or private security forces:

We will immediately work with suppliers and other stakeholders to develop, adopt and implement risk management plans to prevent or reduce the risk of providing direct or indirect support to public or private security forces, based on the specific location of the enterprise in the supply chain. There is reason to believe that there is a risk that these security forces illegally control participants upstream of mine sites, transport routes and supply chains, illegally tax or extort money or mineral resources at mine entrances, transport routes or mineral trading points, or illegally tax or extort middlemen, export companies or international traders. In this case, if the risk management plan does not work for six months, we will suspend or suspend our cooperation with the supplier.

4. Risks associated with corruption, money laundering and fees paid to the government

We do not offer, promise, give or ask for any bribe, and we will resist bribery and will not falsely report taxes, fees and royalties payable to the government for mining, trading, processing, transportation and export of mineral resources in order to cover up or falsify the origin of mineral resources.

If we have reason to believe that there is due to mining, trading, processing, transportation and export in mine site entrance, transportation route, along the upstream supplier or native mineral resources tax illegal or extortion of mineral resources caused by or related to money laundering risk, we will support and take measures to contribute to the effective elimination of money laundering.

We will ensure payment to the government of all lawful taxes, fees and licensing fees related to the exploitation, trading and export of mineral resources in conflict-affected and high-risk areas and undertake to disclose such payments based on the location of the enterprise in the supply chain.

Risk management related to corruption, money laundering and fees paid to the government:

According to the specific location of the enterprise in the supply chain, we are committed to the central supplier

Or cooperate, as appropriate, with local governments, international organizations, civil society and affected third parties to improve or track performance for the purpose of taking measurable measures within a reasonable time span to prevent or reduce the risk of adverse impacts. If risk reduction measures do not work, we will suspend or suspend cooperation with upstream suppliers.

5. Risks associated with land rights, emissions and small workshops

We do not participate in, tolerate or benefit from the exploitation of resources, including miners holding legal title, leases, concessions or licenses, on land without the free, prior and informed consent of local and indigenous people. We do not participate in, tolerate or benefit from mining operations in which the culture and heritage of local and indigenous people are not respected and protected, or in which the traditional culture of the local people is compromised.

We do not participate in, tolerate, or benefit from the exploitation of resources on land that is illegally granted legal title, leasehold, concession, or permit, or in violation of national law. We make sure to avoid the status of the surrounding soil, air and water have significant adverse effects, a serious violation of the local relevant laws and regulations, including manufacturing, trading, use for the biology high toxicity, environmental persistence, or potentially irreversible ecological impact under the international ban on chemicals and hazardous substances, or discharge of arsenic and mercury.

We commit to regularly assess and reduce the adverse impacts of mining on soil, air and water. Taking into account the conditions of the surrounding soil, air and water resources, adopting pollution prevention methods and technologies that are technically and financially feasible and applicable, and making every effort to avoid, reduce and control pollution; Monitor the major pollutants discharged by enterprises in accordance with the relevant laws and regulations of the host country, keep abreast of the pollution status of enterprises, and clearly record and publicize the monitoring results; Adopt control and emission reduction strategies.

We agree to ensure compliance with applicable legal requirements for the management of chemicals and toxic substances and to avoid the manufacture, trade and use of chemicals and hazardous substances subject to international bans due to their high toxicity to organisms, environmental durability, or potentially irreversible ecological effects, including in the highest countries

International standards strictly control the discharge of arsenic and mercury, manage cyanide, ensure that hazardous substances are treated, stored and transported in accordance with relevant laws and regulations, and ensure that no leakage, spillage or other release into the environment occurs during the process.

We prohibit the exploitation of resources in world heritage sites or statutory protected areas and thereby threaten the outstanding universal value of those heritage sites.

We are particularly concerned with forced Labour, child Labour, unsafe working conditions, uncontrolled use of hazardous chemicals and other risks of significant environmental impact associated with small workshops or small-scale miners and seek to establish business relationships with small workshops or small-scale miners in mining areas.

Risk management related to land rights, emissions and small workshops

If we have a reasonable reason to think that there is such a risk, we will according to the enterprise in the supply chain of the location, immediately together with suppliers and other stakeholders, adopt and implement the risk management plan, so as to prevent or reduce the abuse of land rights, cause significant adverse environmental impact or specific risks associated with small workshops or small-scale mining.

6. Risks related to occupational health and safety

The company undertakes not to directly or indirectly support, participate in or be associated with any behavior that may seriously threaten personal safety or occupational health, including but not limited to:

(1) violating relevant laws and regulations;

(2) use unsafe buildings or workplaces;

(3) contact with hazardous machinery, equipment and/or substances without guarantee of safety. Risk management related to occupational health and safety:

If we have reasonable grounds to believe that an upstream supplier provides or is associated with any party purchasing a life-threatening oh&s environment as described above, we will immediately suspend or discontinue our cooperation with that supplier.

The company also recognized the risk of child labor in hand mining and small-scale mining

Insurance is closely related to the level of local economic development, public governance capacity and the source of community livelihood. We cannot support the problem of child Labour in hand mining, nor can we simply refuse to purchase raw materials from hand mining to prevent any improper action from exacerbating the negative impact of local communities' livelihoods.

Based on the risks identified above, the company undertakes to strengthen the construction of the cobalt supply chain responsible management system based on the principle of continuous improvement, cooperate with the upstream and downstream of the supply chain and stakeholders, and jointly promote the solution of high-risk issues represented by child labor in the supply chain.

The company also recognizes that risks in the supply chain are dynamic and complex. Therefore, the company undertakes to gradually expand the scope of risk identification and improve risk control measures in the principle of continuous improvement, so as to achieve the goal of promoting the joint development of upstream and downstream of the supply chain.

3. Commitment to improve the transparency of supply chain

The company promises to actively participate in multi-stakeholder communication, establish appeal mechanism, actively respond to stakeholder expectations (demands) and regularly disclose the company's supply chain responsible management performance in various practices of cobalt supply chain governance. Please refer to the complaint mechanism of cobalt supply chain responsible management for details.

The company also undertakes to regularly conduct supplier accountability performance reviews under the leadership of the supply chain governance committee, organize the company team and external experts to develop specific solutions to major and/or common supply chain problems, so as to meet the challenges with the principles of responsibility and continuous improvement

Nanjing Hanrui Cobalt Co., Ltd.

In January 2019

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