Ⅰ. Principles and Boundaries：
We are committed to zero funding conflicts, zero tolerance for serious human rights abuses, and due diligence on mining, processing, storage, loading and pre-delivery transportation within controlled or custody areas. Carry out special verification on high-risk situations when necessary. Five-step Due Diligence (Disclosure Level) Step 1 Screening:
Regularly screen mining sites and transport routes for locations in/through conflict affected or high-risk areas (CAHRA). The frequency and basis of screening are publicly available in Policies and Reports. Step 2 Assessment:
Context-based assessment is carried out around personal and community safety, security behavior, transportation control, abnormal payment and major events, and risk classification is formed. Step 3 Mitigation:
set a hard red line for "zero funding conflicts and zero tolerance for serious violations"; Standardize the code of conduct, training and supervision of security; Implement access, performance review and suspend cooperation when necessary for transportation and outsourcing. Step 4 Tracking:
Establish incident reporting mechanism and transportation ledger, perform spot check and review at key touch points. Anomalies will trigger investigation and corrective action. Step 5 Reporting:
Disclose due diligence methods, main risks and improvement progress every year to achieve transparency on the premise of protecting personal safety and trade secrets.
Ⅱ. Supply chain and contractor requirements：
The contractor will be required to sign the relevant policy and be audited. Major non-compliance will be required to be corrected or withdrawn. For high-risk routes and operation points, qualified independent institutions shall be entrusted for verification as necessary. Ⅲ. What we disclose：
Disclose the scope of application of due diligence, summary of methods, distribution of major risks and progress of improvement, as well as the disposal conclusions of major events (anonymized). Complete policies, reports and forms can be found in Policies and Reports.
