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Responsible Mineral Supply Chain Policy

As a professional tantalum smelting enterprise, F&X Electro -Materials Ltd. is committed to supplying high-quality tantalum products to global customers at all times. Adhering to rational and ethical production and operation principles, we actively promote the construction of a responsible tantalum mineral supply chain system. We are fully aware that mineral mining, trading, processing, export and other related activities carried out in conflict-affected and high-risk areas may bring about significant negative impacts. Meanwhile, we clearly understand our social responsibility to respect human rights and refrain from fuelling regional conflicts. To this end, we solemnly commit to adopting and fully promoting this Responsible Sourcing Policy for Minerals from Conflict-Affected and High-Risk Areas, and will incorporate it into various contracts and agreements signed with suppliers. This Policy serves as a guideline for conflict-sensitive procurement activities throughout the entire process of tantalum minerals from mining to end users, as well as a fundamental standard for risk management of supply chain partners, regulating operational behaviors across the entire supply chain. We shall refrain from any and all activities that finance or contribute to conflicts, and strictly abide by the relevant sanction resolutions of the United Nations. If the domestic laws stipulate the implementation of such resolutions, we will comply with them in full.

This Policy applies to all our business activities related to the tantalum supply chain, including but not limited to: the procurement, transportation, processing and sales of tantalum ores, tantalum intermediate products; the entire process of screening, evaluation, management and cooperation with supply chain partners; the identification, evaluation, control and continuous improvement of supply chain risks; and activities such as employee training, information disclosure and stakeholder communication related to the supply chain.

This Policy also applies to all our employees and all supply chain partners that provide us with tantalum-niobium mineral-related products or services. Partners shall commit to complying with the relevant requirements of this Policy and transmitting it to their own upstream supply chains.

We strive continuously to build a responsible tantalum supply chain, and commit to following the five-step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the supplementary requirements for tin and tantalum. We identify and avoid the following risks in business activities, and formulate and implement targeted risk management measures, as detailed below:

1. Regarding serious abuses associated with the extraction，transport or trade of minerals：

While sourcing from, or operating in, conflict-affected and high-risk areas，we will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of：

（1）Any forms of torture, cruel, inhuman and degrading treatment；

（2）Any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily；

（3）The worst forms of child labor；

（4）Other gross human rights violations and abuses such as widespread sexual violence；

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

### Regarding risk management of serious abuses：

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined above.

2. Regarding direct or indirect support to non-state armed groups：

We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction，transport, trade, handling or export of minerals includes, but is not limited to，procuring minerals from making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:

（1） illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or

（2）illegally tax or extort6 money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or

（3） illegally tax or extort intermediaries, export companies or international traders.

### Regarding risk management of direct or indirect support to non-state armed groups：

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups；

3. Regarding public or private security forces：

We agree to eliminate, in accordance with the policy, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.

We recognize that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.

Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.

We will support efforts, or take steps, to engage with central or local authorities, international organizations and civil society organizations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.

We will support efforts, or take steps, to engage with local authorities, international organizations and civil society organizations to avoid or minimize the exposure of vulnerable groups, in particular, artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.

### Regarding risk management of public or private security forces：

In accordance with the specific position of the company in the supply chain, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private

security forces as described in the first paragraph of this Article, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan. Where we identify a reasonable risk of activities inconsistent with the last two paragraphs of this Article, we will respond in the same vein.

4. Regarding bribery and fraudulent misrepresentation of the origin of minerals：

We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.

Regarding Money Laundering：

We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

Regarding the payment of taxes, fees and royalties due to governments:

We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance

with the principles set forth under the Extractive Industry Transparency Initiative (EITI).

### Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments:

In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organizations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measureable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.

We strictly abide by the relevant domestic and international laws and standards for the transportation of goods containing tantalum, such as the transportation regulations applicable to Class 7 radioactive substances.

For mineral procurement activities we identify as involving conflict-affected and high-risk areas (CAHRAs), we will not conduct relevant transactions if a recognized upstream traceability mechanism from the Responsible Minerals Initiative (RMI) is not in place.

Any party with questions or concerns regarding the Company’s supply chain policy and its actual implementation may provide feedback through the following channels：

Contact Person: Ms Zhao

E-mail address: sales@fxelectro.com

Effective Date: 05 January 2026

Responsible Minerals Supply Chain Grievance Process(Revised A1 Edition, March 15, 2026)

1. Purpose

F&X Electro-Materials Ltd. (hereinafter “the Company”) recognizes significant adverse impact risks associated with mineral extraction, trading, processing, and export in Conflict-Affected and High-Risk Areas (CAHRAs). The Company is committed to respecting human rights, refraining from contributing to conflict, and fulfilling legal and social obligations to protect the environment and society.

The Company adopts and promotes a Responsible Minerals Supply Chain Policy, integrates it into supplier contracts/agreements, complies with relevant UN sanctions resolutions and applicable domestic laws, and prohibits any act that assists or facilitates conflict. To this end, the Company has established this Responsible Minerals Supply Chain Grievance Process and opened public supervision and complaint channels to accept oversight from all sectors of society regarding the Company’s tantalum raw material sources and the entire mineral supply chain.

As a core part of supply chain risk assessment, the grievance mechanism helps the Company effectively identify, assess, and mitigate significant risks in mineral extraction, trading, and other stages. This Process applies to all grievances related to responsible minerals management for the Company’s tantalum raw material sources.

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2. Basis and Principles

2.1 Basis for Formulation

- Responsible Minerals Assurance Process – Tin and Tantalum Standards

- F&X Responsible Minerals Management Procedure

- F&X Responsible Minerals Supply Chain Policy

- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

2.2 Grievance Principles

2.2.1 Fairness

2.2.1.1 The grievant and the Company shall have equal rights throughout the grievance handling process. The Company shall not apply differentiated handling standards based on the grievant’s identity (supplier, social organization, individual, etc.).

2.2.1.2 A conflict-of-interest recusal system shall apply to members of the grievance panel; persons with direct or indirect interests in the grievance shall not participate in investigation or adjudication.

2.2.1.3 The grievant shall have the right to present statements, provide evidence, submit supplementary evidence, and raise objections to investigation findings. The Company shall provide full and equal opportunity for response.

2.2.2 Transparency

2.2.2.1 The Company publicly discloses detailed grievance procedures, handling timelines, responsible parties, contact information, and a grievance flowchart via its official website to ensure stakeholders clearly understand the grievance path.

2.2.2.2 Written records shall be maintained for all stages (receipt, registration, classification, investigation, adjudication, feedback). Except where trade secrets or confidentiality requests apply, key points and results may be communicated to the grievant upon request. Outcomes of material grievances may be disclosed to the public (after redaction).

2.2.2.3 If a grievance is rejected, a specific, clear written explanation shall be provided to the grievant, stating the grounds and relevant clauses; summary dismissal is prohibited.

2.2.3 Rights Compatibility

2.2.3.1 Grievance handling shall balance the Company’s supply chain compliance rights, the grievant’s legitimate oversight rights, and suppliers’ operational rights, without harming the human rights of supply chain stakeholders (e.g., worker rights, local community development rights).

2.2.3.2 Grievance investigations and remedies shall not violate UN sanctions resolutions, domestic laws, or international human rights norms, nor impose unreasonable harm on supply chain parties.

2.2.3.3 The confidentiality rights of anonymous grievants are strictly protected. Whistleblower information and grievance evidence are securely managed to prevent leakage. The respondent’s right to defend itself shall be upheld, and its statements and evidence shall be heard during investigation.

2.2.4 Prohibition of Retaliation

2.2.4.1 The Company strictly prohibits any entity or individual from retaliating, discriminating, coercing, intimidating, isolating, demoting, dismissing, terminating cooperation, disclosing information, or taking any other adverse action against grievants, whistleblowers, witnesses, or persons assisting investigations.

2.2.4.2 Grievants shall not suffer retaliation, harassment, or negative consequences for filing grievances, providing information, or cooperating with investigations.

2.2.4.3 The Company maintains strict confidentiality of grievant identities, grievance content, and evidence; attempts to identify anonymous grievants are prohibited.

2.2.4.4 Verified retaliation shall result in serious disciplinary action up to legal liability. The Company shall promptly provide protection, redress, and remedy to persons subjected to retaliation.

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3. Grievance Scope, Requirements and Handling Measures

3.1 Scope

This Process applies to grievances covering the entire tantalum raw material supply chain under the Company’s Responsible Minerals Management Procedure, including mineral extraction, trade, processing, export, and transportation. It focuses on grievances related to supply chain human rights protection, compliant operation, and risk prevention, to help identify potential human rights abuses, conflict links, and policy violations.

3.2 Responsibilities

- Responsible Minerals Management Team: The competent department for grievance management, responsible for centralized collection, classification, distribution, tracking, and archiving of grievance information. It maintains both electronic and paper grievance logs to ensure full traceability and verifiability; objectively assigns responsible departments and informs grievants of progress; tracks outcomes and corrective actions to ensure closure; manages grievance files with tiered confidentiality to prevent leakage of sensitive information.

- Relevant Responsible Departments: Impartially and thoroughly analyze and investigate assigned grievances without bias or delay; develop implementable, verifiable corrective and preventive actions for verified issues and submit to the General Manager and Management Team; cooperate in supplementary investigations for special/material grievances; implement corrections and promptly provide completion evidence.

- Business Department: The sole receiving department for grievances, ensuring 24/7 availability of complaint channels; accepts all named and anonymous grievances without pre-screening or identity barriers; registers grievances immediately and transfers complete information to the Management Team within 1 working day; assists in evidence collection and maintains strict confidentiality of grievant identities and evidence; attempts to identify anonymous grievants are prohibited.

- Grievance Panel: Chaired by the General Manager, composed of independent members from the Management Team, Business Department, and other non-interested parties. Responsible for investigation, review, and adjudication of special/material grievances; conducts investigations within required timelines; ensures equal rights to be heard and present evidence; issues impartial rulings based on objective evidence; implements corrections and remedies; addresses violations in the grievance process.

3.3 Procedures

3.3.1 Grievance Receipt and Publicized Channels

The Company prominently publicizes long-term grievance contact information via its official website and corporate notice boards for easy access by all stakeholders. Grievance channels operate 24/7 without barriers:

- Contact Person: Ms. Zhao

- Tel: +86-750-6436998

- Email: sales@fxelectro.com

The Business Department immediately receives all grievances, inquiries, and concerns submitted through these channels, registers key details (time, method, content) without differentiation, and forwards all information to the Responsible Minerals Management Team within 1 working day after registration.

3.3.2 Grievance Content Requirements

The Company maintains low barriers for submission and accepts named and anonymous grievances to balance verifiability and protection:

- Named Grievances: Require written submission (mail or scanned copy) including: grievant name/entity and valid contact details (entity stamp for organizations, signature for individuals; no additional manager signature required); specific grievance matter, supply chain stage involved, and core reasons; relevant written evidence or verifiable clues (objective and authentic); prior steps taken and outcomes (optional).

- Anonymous Grievances: No identity information required; only specific grievance matter, core reasons, and verifiable clues/evidence needed. Anonymous grievances receive equal acceptance, investigation, and handling without extra barriers.

3.3.3 Grievance Classification

The Management Team classifies all grievances impartially within 2 working days of receipt. Classification results are notified in writing to named grievants (excluding anonymous) and recorded in the grievance log with clear justification. Grievances are divided into three categories:

3.3.3.1 **General Information**: Inquiries about policy/process/standards, supplier responsible minerals questionnaires, feedback without clear grievance claims. Forwarded to relevant departments within 3 working days; departments respond and verify within 5 working days; the Management Team replies to stakeholders and files records.

3.3.3.2 **Special/Material Grievances**: Grievances involving significant supply chain risks, human rights protection, or compliance violations, including but not limited to:

- Non-conformity of the responsible minerals system with RMAP requirements;

- Purchasing from identified high-risk areas with red flags under OECD Guidance (serious abuses, non-state armed group involvement, misuse of force by security, bribery, origin fraud, money laundering, tax violations);

- Violations of supply chain policy, UN sanctions, or domestic law;

- Child labor, forced labor, or worker rights abuses.

Such grievances are immediately transferred to the Grievance Panel for special investigation.

3.3.3.3 **Inadmissible Information**: Trivial, malicious, or vexatious complaints; complaints filed to gain unfair competitive advantage; complaints without objective, credible evidence or clues; repeated complaints on the same matter with no new evidence or grounds after full resolution.

For inadmissible items, the Management Team issues a written **Grievance Rejection Notice** to named grievants, stating detailed grounds, clauses, and appeal rights; summary or oral rejection is prohibited. Records are logged in the grievance register.

3.3.3.4 **Anonymous Grievance Special Handling**:

The Business Department forwards anonymous complaints immediately to the Management Team, which completes initial screening within **1 working day** to determine relevance to tantalum compliance and human rights protection. Accepted anonymous complaints are recorded in an **Anonymous Grievance Log** with separate encrypted files managed by dedicated staff. A special independent investigation panel chaired by the General Manager conducts inquiries; the Business Department collects evidence objectively.

If verified, corrective and preventive actions are taken immediately under laws and policies, with effective remedies for verified abuses or violations and disciplinary measures for responsible parties. If unsubstantiated, the case is noted and filed. Outcomes are communicated to RMI via the official website (redacted) or designated email within **5 working days** after closure and included in the annual responsible minerals report.

Throughout the process, attempts to identify anonymous grievants are prohibited. Retaliation (discrimination, isolation, threats, penalties, etc.) is strictly forbidden. Verified retaliation triggers independent investigation, disciplinary action, and protection/redress for affected persons.

3.3.4 Grievance Handling

3.3.4.1 **Acceptance/Rejection Confirmation**: The Grievance Panel completes review and confirms acceptance or rejection within **7 working days** of receiving a named grievance. If accepted, a **Grievance Acceptance Notice** is issued, stating panel members (conflict-free), investigation timeline, and the grievant’s rights. If rejected, a **Grievance Rejection Notice** is issued with detailed grounds and appeal rights. All documents are filed.

3.3.4.2 **Special/Material Grievance Investigation**: The Grievance Panel launches formal investigation within 7 working days of acceptance. Measures may include expert consultation, information requests, and on-site verification (if needed). Equal rights to statement, evidence, and defense are guaranteed; priority is given to vulnerable groups (workers, local communities). The investigation aims to conclude within 30 working days. Extensions up to 15 working days may be granted with written notice of reasons and a new deadline.

Proceedings may only be suspended if the grievant refuses cooperation without valid reason or new evidence, with unanimous panel agreement and written notification. Non-cooperation by the respondent constitutes waiver of the right to defend; the panel may rule based on available evidence without suspension.

3.3.4.3 **Adjudication and Written Notification**: Upon completion, the Grievance Panel issues a written **Grievance Award** based on objective evidence and consensus, specifying: case summary and findings; ruling (upheld/partially upheld/dismissed); date and key grounds (UN norms, OECD Guidance, company rules); corrective/preventive actions, responsible parties, and timelines; specific remedies for aggrieved parties; appeal rights, paths, and timelines.

The Award is delivered to the grievant and relevant parties by the Management Team within 3 working days.

3.3.4.4 **Corrective Action Implementation and Tracking**: Responsible departments implement corrections and remedies per the Award and submit a **Corrective Action Completion Report** with verifiable evidence. The Management Team tracks progress and requires rework for incomplete actions. Outcomes and evidence are communicated to the grievant within **5 working days** of full completion. Redacted outcomes of material grievances are published on the official website and reported to RMI for public oversight.

3.3.4.5 **Review and External Assistance**: Grievants may submit a **Request for Review** with new evidence/grounds to the Grievance Panel within **15 working days** of receiving the Award or corrective outcome. A second review is conducted by independent conflict-free personnel, with a written **Review Award** issued within **20 working days** as the final internal decision. If the grievant remains dissatisfied, external avenues are provided (market regulation, judicial authorities, RMI, human rights bodies).

3.3.4.6 **Grievance Recording and Archiving**: Full, complete records are maintained for all grievances in both electronic and paper **Grievance Logs**. A separate file is created for each case, including: all submissions (named/anonymous); full process records; formal notices and awards; communications, evidence, expert opinions, and feedback.

Files are managed by dedicated staff of the Management Team and retained for **at least 5 years**; files involving material human rights abuses or conflict links are retained permanently. Strict confidentiality applies to grievant identities, evidence, and anonymous clues. Non-confidential records may be accessed by named grievants upon request. All records serve as input for risk identification in responsible procurement.

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4. Attachments

Responsible Minerals Supply Chain Grievance Process Flowchart

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Responsible Minerals Supply Chain Grievance Process Flowchart

**START**

→ Establish grievance mechanism (Responsible Minerals Management Team)

→ Receive grievance information (Business Department, immediate receipt)

→ Classify grievance information

(Responsible Minerals Management Team, within 2 working days)

├─ Inadmissible Information → Issue Grievance Rejection Notice

(Management Team)

├─ General Information → Hand over to responsible department

(resolved within 5 working days)

└─ Special/Material Grievance → Acceptance

(Grievance Panel, within 7 working days)

→ Launch formal investigation (Grievance Panel, within 7 working days after acceptance)

→ Issue written Grievance Award (Grievance Panel)

→ Feedback & Disclosure

├─ Named grievance: Written feedback (Management Team)

└─ Anonymous grievance: Redacted public disclosure + report to RMI

(Management Team + Business Department)

→ Archive grievance documents (Responsible Minerals Management Team)

**END**

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2025 Due Diligence Report on Responsible Mineral Supply Chain

Report Period: January 1, 2025 – December 31, 2025

1. Company Profile

F&X Electro-Materials Ltd. (English abbreviation: F&X) was founded in 1999. The company’s CID number is CID000460. F&X operates one tantalum smelter located at Yamen, Xinhui District, Jiangmen City, Guangdong Province, China (Postal Code: 529152).

F&X specializes in processing and producing tantalum, one of the 3TG minerals. With over 20 years of development, F&X has become one of the world’s leading manufacturers of capacitor-grade tantalum powder with stable and high-quality products. F&X is a member of the Tantalum-Niobium International Study Center (TIC) and a full member of iTSCi. The company strictly abides by Chinese laws and regulations as well as international rules, actively fulfills corporate social responsibility, and upholds the values of fairness and justice.

2. RMAP Assessment Summary

RMI Smelter ID: CID000460 (Tantalum)

Assessed Material: Tantalum

Assessment Cycle: March 1, 2024 – February 28, 2025

Assessment Date: March 14, 2025

Assessment Body: SGS

Assessment Result: F&X complies with the RMAP Tin & Tantalum Standard (2017)

Assessment Report Link: www.responsiblemineralsinitiative.org/media/docs/Public%20Reports/F&X%20Electro-Materials%20Public%20Report.pdf

Next Assessment Date: March 12, 2026

3. Responsible Mineral Supply Chain Policy

F&X strictly follows the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and has formulated and publicized its responsible mineral supply chain policy (available on the official website: www.fxelectro.com). The company classifies raw materials from different countries/regions by risk level. Led by the General Manager, a cross-functional responsible mineral management team covers operations, production, quality control, and audit functions to fully implement the OECD 5-Step Due Diligence Framework.

4. Company Management System

F&X has established a complete responsible mineral supply chain management system to ensure full compliance in the procurement, production, and sales of tantalum raw materials. The General Manager oversees the implementation of due diligence plans and risk management; a dedicated manager coordinates cross-departmental execution; and annual company-wide due diligence training is conducted. F&X honors its supply chain policy commitments and has developed responsible mineral management procedures as follows:

4.1 Internal Control System

4.1.1 F&X has updated its due diligence management system to align with OECD Guidance and RMAP requirements.

4.1.2 F&X has communicated the latest supply chain policies and procurement requirements to all identified suppliers.

4.1.3 Open and transparent procurement policies:

Publish the responsible mineral supply chain policy on the F&X website for full supplier awareness.

Publish the annual due diligence report on the F&X website to disclose practices and performance to the public.

Issue tantalum raw material procurement statements to all suppliers, stating policies and requirements with grievance channel information, and require corresponding commitments from suppliers.

Distribute the Responsible Mineral Management Procedure internally to ensure all employees understand and comply.

4.1.4 F&X has established 10 core control procedures to block non-compliant and unidentified materials from entering the supply chain:

Responsible Mineral Management Procedure

Specification for Procurement & Use of Responsible Minerals (Tantalum Raw Materials)

Incoming Inspection Process for Tantalum-Bearing Materials

Inventory Accounting Work Instruction

Internal Numbering Rules for Tantalum-Niobium Raw Materials

Records Management Procedure

Product Identification and Traceability Management Procedure

Responsible Mineral Supply Chain Risk Identification Procedure

Responsible Mineral Supply Chain Grievance Handling Process

Due Diligence Planning and Risk Control Process

4.1.5 Implemented full-process traceability for raw materials via the Product Identification and Traceability Management Procedure.

4.1.6 Complies with international regulations for the transport of hazardous substances (including 7 categories) and radiation safety.

4.1.7 Supplier qualification: Prior to engagement with new suppliers (including sub-suppliers), the Raw Material Compliance Department and Procurement conduct thorough checks to identify risks per OECD Annex II and EU regulations. This process is also used for annual re-qualification of active suppliers and sub-suppliers.

4.1.8 Regular communication with iTSCi, Better Mining, and other institutions to obtain mine and regional risk intelligence.

4.1.9 Submits Conflict Minerals Reporting Template (CMRT) to downstream customers per RBA requirements and maintains a public grievance and supervision channel.

4.1.10 Employee training: All staff (including senior management) are trained on OECD Guidance, RBA tantalum supply chain audit standards, supply chain transparency requirements, and the principles and standards of the Extractive Industries Transparency Initiative (EITI).

4.1.11 F&X actively fulfills social responsibility to build a compliant and responsible corporate image. The company integrates economic development with social responsibility, and fulfills comprehensive social responsibility through technological innovation, safe production, employee rights protection, environmental protection, and energy conservation under legal and ethical operation.

4.2 Records Retention System

F&X has established and implemented the Records Management Procedure to fully retain records related to responsible mineral procurement and usage, properly managed in multiple formats. Records are retained for at least 5 years, including transport records, customs clearance records, re-inspection quality/weight records, official compliance documents, and mine-associated tags. Authorized personnel may access records during the retention period.

5. Risk Identification

5.1 Supplier Identification

F&X implements Know Your Customer (KYC) procedures with a dedicated KYC form. All direct and indirect suppliers (companies, managers, owners, and beneficial owners) must complete KYC as the first step of qualification. F&X uses supplier and third-party information for verification. For suppliers under the BETTER MINING due diligence system, KYC is performed both by BETTER MINING and F&X (covering legal status, business scope, origin, and supporting documents).

The Due Diligence Planning Manager and Procurement Team review supplier information against government-verified or public data. Inconsistent, incorrect, or incomplete information requires correction; suppliers with identified risks, refusal to complete KYC, or refusal to provide documents are excluded from the approved supplier list.

During the reporting period, all suppliers completed and returned KYC forms and supporting documents with no red flags identified.

5.2 CAHRAs Identification Tools & Criteria

F&X has adopted three risk assessment tools, together with the indicative list of CAHRAs provided by the Dodd‑Frank Act and Article 14.2 of EU Regulation 2017/821, as its approaches for supply chain risk assessment.

The three risk assessment tools are:

Conflict risk: Heidelberg Global Conflict Barometer

Human rights risk: Global Slavery Index

Governance risk: Knowyourcountry Country Risk Ranking

The assessment covers the Democratic Republic of the Congo (DRC) and its nine adjoining countries/regions, as well as all countries of origin and transit involved in our tantalum procurement.

A region is classified as low‑risk only if all three tools, the Dodd‑Frank Act, and the indicative list of CAHRAs under EU Regulation 2017/821 confirm it as non‑high‑risk. Otherwise, the region is managed as a high‑risk source.

5.3 2025 CAHRAs Identification Results

During the reporting period, the tantalum ore procured by the company was sourced from Rwanda and Sierra Leone, and tantalum intermediates were obtained from domestic smelters in China.

Ore from Rwanda was transported via Tanzania, while ore from Sierra Leone was shipped directly to Chinese ports.

High-risk areas: Rwanda (country of origin), Tanzania (transit country)

Low-risk areas: Sierra Leone (country of origin), China (source of tantalum intermediates)

The identification results have been documented in a report, which was approved by the General Manager (or authorized delegate) before implementation.

5.4 Supply Chain Risk Assessment Conclusions

Red flags were identified for suppliers of tantalum materials from high-risk areas in 2025.

The upstream traceability system for tantalum materials from CAHRAs fully adopts the BETTER MINING framework.

Enhanced due diligence was conducted per OECD Guidance for high-risk materials and suppliers with red flags.

No material violations listed in OECD Annex II were identified through enhanced due diligence.

6. Risk Management & Mitigation Strategies

6.1 During the reporting period, all raw materials were assessed for conflict, human rights, and governance risks using defined tools. High-risk regions/suppliers without RMI-recognized upstream assurance are not approved for cooperation.

6.2 Transactions in high-risk areas use the BETTER MINING traceability system with additional risk verification to ensure supply chain credibility and compliance. F&X collects and reviews documents/reports from BETTER MINING, iTSCi, RMI, and third-party audits, and cross-checks via online sources with no discrepancies found to date.

6.3 All purchased tantalum raw materials were fully certified during the 2024–2025 RMAP audit cycle.

F&X ELECTRO-MATERIALS LIMITED

January 5th, 2026

Support Extractive Industries Transparency Action Plan Initiativ

It is in the common interests of resource-rich countries, extractive industry companies and the international community to support the EITI to promote transparency and strengthen accountability. As a member of the tantalum industry, F&X has made a commitment to the domestic and international communities to increase transparency, and strengthen accountability systems in public life as well as government management and business practices in order to reduce and eventually prevent conflicts related to the oil, gas and mining industries.

F&X promises to cooperate with suppliers, central and local Governments, international organizations, civil societies and affected third parties to take significant risk reduction measures to prevent or reduce risks in a reasonable certain time. In that way we can measure the progress and make improvement. If the risk reduction measurements do not work, we will temporarily suspend or terminate the cooperation with upstream suppliers.

F&X ELECTRO-MATERIALS LIMITED

January 1st,2025

What is EITI?

What the EITI does: Building trust through transparency

A country’s natural resources, such as oil, gas, metals and minerals, belong to its citizens. Extraction of these resources can lead to economic growth and social development. However, poor natural resource governance has often led to corruption and conflict. More openness and public scrutiny of how wealth from a country’s extractive sector is used and managed is necessary to ensure that natural resources benefit all.

The EITI is a global standard to promote transparent and accountable management of natural resources. It seeks to strengthen government and company systems, inform public debate and promote understanding. In more than 50 implementing countries, the EITI is supported by a coalition of government, companies, and civil society.

The information found in EITI Reports helps governments monitor and forecast revenues from their extractive sector. Countries can use this information to verify that they are receiving the amount due to them. The EITI alone does not enable such verification. EITI Reports must be comprehensible, actively promoted, publicly accessible, and contribute to public debate. Implementing countries are also required to publish “electronic data files” and are encouraged to move towards online disclosure of payments and income. More and more EITI Reports also include information on how revenues are distributed nationally, including in budgets and sovereign wealth funds, which have a vital role to play in supporting any fluctuation in the budgets and currencies of resource-rich countries.

The impact of the EITI is evident when governments decide to implement the recommendations that have emerged from EITI reporting. In some countries, EITI Reports have been a useful tool highlighting weaknesses in government systems. In other cases, the report recommendations have been aimed at addressing such weaknesses and improving sector management, thus making an important contribution to policy reform and change.

EITI standard

The Extractive Industries Transparency Initiative (EITI) is the global standard to promote the open and accountable management of oil, gas and mineral resources. At the EITI London Conference 2005, participants in the EITI adopted the implementation criteria. The EITI Standard was launched on 18 June at the Paris Global Conference.

THE EITI STANDARD 2023 download （https://eiti.org/sites/default/files/2024-04/2023%20EITI%20Standard_Parts1-2-3.pdf）

The EITI Principles

1. We share a belief that the prudent use of natural resource wealth should be an important engine for sustainable economic growth that contributes to sustainable development and poverty reduction, but if not managed properly, can create negative economic and social impacts.

2．We affirm that management of natural resource wealth for the benefit of a country’s citizens is in the domain of sovereign governments to be exercised in the interests of their national development.

3．We recognise that the benefits of resource extraction occur as revenue streams over many years and can be highly price dependent.

4．We recognise that a public understanding of government revenues and expenditure over time could help public debate and inform choice of appropriate and realistic options for sustainable development.

5．We underline the importance of transparency by governments and companies in the extractive industries and the need to enhance public financial management and accountability.

6. We recognise that achievement of greater transparency must be set in the context of respect for contracts and laws.

7．We recognise the enhanced environment for domestic and foreign direct investment that financial transparency may bring.

8．We believe in the principle and practice of accountability by government to all citizens for the stewardship of revenue streams and public expenditure.

9．We are committed to encouraging high standards of transparency and accountability in public life, government operations and in business.

10．We believe that a broadly consistent and workable approach to the disclosure of payments and revenues is required, which is simple to undertake and to use.

11．We believe that payments’ disclosure in a given country should involve all extractive industry companies operating in that country.

12． In seeking solutions, we believe that all stakeholders have important and relevant contributions to make including governments and their agencies, extractive industry companies, service companies, multilateral organisations, financial organisations, investors and non governmental organisations.

THE EITI Principles download （https://eiti.org/documents/eiti-principles）