Conflict Minerals

Responsible Minerals Supply Chain Policy

Responsible Minerals Supply Chain Policy

Responsible Minerals Supply Chain Management

HYUNWOO Industrial Co., Ltd. (hereinafter the "Company")

is keenly aware of social issues that may arise during the product manufacturing process, including human rights violations, environmental destruction, and the flow of funds to armed groups in conflict-affected areas.
Accordingly, in order to respect universal human values and build a sustainable supply chain, the Company hereby declares that it has established, and will thoroughly comply with, a Responsible Minerals Supply Chain Policy
based on the OECD "Due Diligence Guidance for Responsible Supply Chains of Minerals."

Basic Principles & Declaration

  • 01

    The Company does not procure or use unethical minerals that are directly or indirectly linked to armed groups that perpetrate serious human rights abuses such as child labor, forced labor, and sexual violence, or that finance conflicts within conflict-affected and high-risk areas (CAHRAs), including the Democratic Republic of the Congo (DRC) and adjoining countries.

  • 02

    The Company complies with international laws and regulations related to responsible minerals, including Section 1502 of the U.S. Dodd-Frank Wall Street Reform Act, the EU Conflict Minerals Regulation, and the EU Battery Regulation.

  • 03

    The Company requires all suppliers within its supply chain to support and comply with its Responsible Minerals Policy, and supports their active participation in a transparent supply chain traceability process.

Managed Minerals

The Company conducts origin tracing and risk assessments for the minerals listed below that are used within its supply chain,
and continuously expands the scope of managed minerals in line with global regulations and customer requirements.

Classification of Managed Minerals
Classification Target Minerals Key Management Objectives & Templates
Conflict Minerals (3TG) Tin, Tantalum, Tungsten, Gold Blocking fund flows to armed groups
in conflict-affected areasCMRT : Conflict Minerals Reporting Template
Extended Responsible Minerals Cobalt, Mica Preventing child labor and environmental
damage in the supply chainEMRT : Extended Minerals Reporting Template
Other Critical Minerals Copper, Nickel, Lithium, Graphite, Aluminum, etc. Proactively responding to expanding
global ESG regulations & due diligencePRT : Pilot Reporting Template

Managed Minerals

Supplier Operating Guidelines

All suppliers that provide raw and subsidiary materials and components for the Company's product manufacturing must fulfill the following requirements.

  • 01

    Policy Compliance & Dissemination

    Suppliers must be fully familiar with this Responsible Minerals Policy and must ensure that their own sub-tier suppliers (second tier and below) likewise establish and apply a responsible minerals policy of the same standard.

  • 02

    Supply Chain Due Diligence & Data Submission

    Through the responsible minerals reporting templates required by the Company (CMRT, EMRT, PRT, etc.), suppliers must accurately investigate smelter information and country-of-origin data annually or as needed, and submit it within the designated deadlines.

  • 03

    Use of RMAP-Certified Smelters

    Suppliers must continuously transition and manage the smelters within their supply chain so that minerals are procured from smelters certified under the RMAP (Responsible Minerals Assurance Process) recognized by the Responsible Minerals Initiative (RMI).

Corrective Actions & Penalties for High-Risk Supply Chains

If a high-risk supply chain using smelters linked to armed groups in conflict-affected areas or non-certified smelters is identified during the due diligence process, the Company will require the relevant supplier to take immediate corrective action (such as changing smelters or pursuing RMAP certification).
If a supplier is uncooperative with improvement measures without justifiable cause or deliberately submits false information, the Company may take strict measures such as restricting transaction volumes, withholding new 4M approvals, and ultimately suspending transactions.

Internal Monitoring & Process

All suppliers that provide raw and subsidiary materials and components for the Company's product manufacturing must fulfill the following requirements.

  • 01

    Procurement & Quality Integration System

    The Company includes responsible minerals verification as a mandatory step when registering new suppliers and approving components (such as 4M changes).

  • 02

    Stakeholder Communication

    The collected supply chain data and due diligence results are regularly verified to respond to customer requirements in a timely manner, and related reports are shared transparently.

"This Policy is a core commitment for the Company's sustainable value creation and the fulfillment of its social responsibility,
and the Company will continue to make its best efforts to build a clean and transparent supply chain ecosystem."

The CEO and All Employees of HYUNWOO Industrial Co., Ltd.