Wuxi Dongheng New Energy Technology Co., Ltd.

Responsible Mineral Supply Chain Due Diligence Management Policy (2021)

Wuxi Dongheng New Energy Technology Co., Ltd. recognizes that there are risks that may cause significant negative impacts in mining, trading, processing and exporting minerals in conflict affected and high-risk areas, and that we have the obligation to respect human rights and not contribute to conflicts, We commit to adopt the China Responsible Mineral Supply Chain Due Diligence Management Guide (hereinafter referred to as the China Guide) issued by the China Chamber of Commerce for the Imports and Exports of Minerals and Chemicals (CCCMC) and the Organization for Economic Cooperation and Development (OECD) Responsible Supply Chain Due Diligence Management Guide for Minerals from Conflict Affected and High Risk Areas (hereinafter referred to as the OECD Guide) issued by the Organization for Economic Cooperation and Development (OECD), Adopt and widely promote the following responsible procurement policies for ores in conflict affected and high-risk areas, and incorporate them into contracts and/or agreements with suppliers. This policy provides a basic reference for conflict sensitive procurement activities and suppliers' risk awareness in the whole process from mining to end users. We promise not to engage in any activities that will finance conflicts, and we promise to abide by the relevant UN sanctions resolutions, or, where applicable, the domestic laws implementing such resolutions. Relevant responsible minerals include tin, tungsten, tantalum, gold, cobalt, lithium, graphite, etc.

No1. Serious infringement related to mineral exploitation, transportation or trade:

1. When conducting procurement or business activities in conflict affected and high-risk areas, we will neither tolerate nor accept

To benefit from, help, assist or facilitate the implementation of:

i) Any form of torture, cruel, inhuman or degrading treatment;

Ii) Any form of forced or compulsory labour. Forced or compulsory labor refers to the labor or service that is not voluntarily provided by any individual under the threat of punishment;

Iii) The worst forms of child labour;

Iv) Other serious violations and abuses of human rights, such as widespread sexual violence;

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

Risk management：

If we have reasonable grounds to believe that the risk exists, that is, the upstream supplier is purchasing from or associated with any party who has committed the serious infringement specified in Article 1, we will immediately suspend or discontinue the cooperation with the supplier.

No2.With regard to direct or indirect support to non State armed groups:

2. We will not tolerate any direct access to non state armed groups through mining, transportation, trade, processing or export

Direct or indirect support. Providing "direct or indirect support" to non-state armed groups through mining, transportation, trade, processing or export of minerals includes but is not limited to purchasing minerals from non-state armed groups or their affiliates, making payments to them, or providing logistical support or equipment to them in other ways. These armed groups or related parties:

i) Illegal control of mine sites, or other means of controlling transportation routes, mineral trading points and upstream actors in the supply chain; And/or

Ii) Illegal taxation or extortion of money or minerals at the entrance of the mine site, along the transportation route or at the mineral trading point; And/or

Iii) Illegal taxation or extortion against middlemen, export enterprises, or international traders. Risk management of direct or indirect support to non State armed groups.

Risk management：

If we have reason to believe that upstream suppliers provide direct or indirect support to non State armed groups

In case of purchase or existing relationship with the supplier, we will immediately suspend or discontinue the cooperation with the supplier.

No3. With regard to public or private security forces:

3. We will prevent illegal control of the mine site, transportation routes and upstream actors of the supply chain from entering and transporting the mine site

Provide direct or indirect support to public or private security forces along the route or at mineral trading points that illegally levy taxes or ask for money or minerals, or illegally levy taxes or extort from intermediaries, export enterprises or international traders.

4. We recognize the role of public or private security forces at the mine site and/or its surrounding areas and/or along the transport road

It is only to safeguard the rule of law, including safeguarding human rights, protecting the safety of miners, equipment and facilities, and protecting mine sites or transport routes so that legitimate mining and trade are not disrupted.

5. When we or any enterprise in our supply chain has signed a contract with public or private security forces, we

Commit or will stipulate that in the process of cooperation with such security forces, the provisions of the Voluntary Principles on Security and Human Rights will be observed. In particular, we will support or take measures to apply the screening policy to ensure that individuals or security armed units known to have committed serious human rights violations are not recruited.

6. We will support or take measures to cooperate with central or local governments, international organizations and civil society organizations

Find feasible solutions for how to improve the transparency, proportionality and accountability of public security and armed security costs.

7. We will support or take measures to interact with local governments, international organizations and civil society organizations to avoid or maximize

Minimize the negative impact of public or private security forces stationed at the mine site on vulnerable groups, especially for small workshops

In this case, the minerals in the supply chain are mined by small workshops or small-scale mining.

Risk management：

If we find such risks to some extent, we will immediately formulate, adopt and implement risk management plans for upstream suppliers and other stakeholders according to the specific position of the enterprise in the supply chain, so as to curb or reduce the risk of providing direct or indirect support for public or private security forces. If the risk management plan fails to work for six months, we will temporarily stop or interrupt the cooperation with upstream suppliers.

No4. Bribery and bribery, fraudulent misrepresentation of the origin of minerals, money laundering and taxes, fees and royalties paid to the government

8. We will not propose, promise, carry out or ask for any bribes, and we will resist the temptation to bribe in order to cover up or forge the origin of minerals and falsely report the taxes, fees and royalties payable to the government for mineral mining, trade, processing, transportation, export and other activities.

9. If we have reason to believe that there are money laundering risks arising from or related to the illegal taxation or extortion of minerals obtained from mining, trading, processing, transportation or export at the entrance of the mine site, along the transportation route, or at the upstream supplier's mineral trading place, we will support or take measures to contribute to the effective elimination of money laundering.

10. We will ensure that all legal taxes, fees and royalties related to mining, trade and export of ores in conflict affected and high-risk areas are paid to the government, and we promise to disclose such payments according to the position of enterprises in the supply chain.

Risk management：

According to the specific position of the enterprise in the supply chain, we promise to cooperate with suppliers, central or local government authorities, international organizations, civil society and affected third parties as appropriate, and improve or track performance for the purpose of taking significant measures to prevent or reduce risks with negative impacts within a reasonable time span. If the risk reduction measures do not work, we will temporarily stop or interrupt the cooperation with upstream suppliers.

No5. Land rights, emissions and small workshops

11. We do not participate in, tolerate or benefit from the exploitation of resources on land without the free, prior and informed consent of local people and indigenous people, including those who hold legal ownership, lease, concession or license. We do not participate in, tolerate, or benefit from mining operations where the culture and heritage of the local people and indigenous people are not respected and protected, or damage the traditional culture of the local people. We do not participate in, tolerate, or benefit from the exploitation of resources on lands that have been illegally acquired with legal ownership, leases, concessions, or licenses, or that violate national laws.

12. We ensure that we do not cause significant adverse effects on the surrounding soil, air and water, and seriously violate relevant local laws and regulations, including manufacturing, trading, and using chemicals and hazardous substances subject to international ban due to high toxicity to organisms, environmental persistence, or potential irreversible ecological effects, or discharging arsenic and mercury.

13. We promise to regularly assess and reduce the adverse effects of mining on soil, air and water. Considering the conditions of surrounding soil, air and water resources, adopt pollution prevention methods and technologies with technical and financial feasibility and applicability to avoid, reduce and control pollution as much as possible; In accordance with the relevant laws and regulations of the host country, monitor the main pollutants discharged by enterprises, keep abreast of the pollution status of enterprises, and clearly record and publicize the monitoring results; Adopt emission control and reduction strategies.

14. We agree to ensure compliance with the applicable legal requirements for the management of chemicals and toxic substances, and avoid manufacturing, trading, and using chemicals and hazardous substances subject to international ban due to high toxicity to organisms, environmental persistence, or potential irreversible ecological impact, including strict control of arsenic and mercury emissions according to the highest international standards, management of cyanide, and ensuring the disposal of hazardous substances The storage and transportation shall comply with relevant laws and regulations to ensure that there is no leakage, spill or other forms of release to the environment during the process.

15. We prohibit the exploitation of resources in world heritage sites or legally protected areas, and thus pose a threat to the outstanding universal value of these heritage sites.

Risk management：

If we have reasonable reasons to believe that such risks exist, we will immediately formulate, adopt and implement risk management plans with suppliers and other stakeholders according to the specific position of the enterprise in the supply chain, so as to prevent or reduce specific risks related to infringement of land rights, significant adverse environmental impacts or small workshops or small-scale miners.

Complaint mechanism for violation of prohibited conflict minerals and compliance with the Responsible Cobalt Initiative policy:
Please send your complaints and suggestions to: yu.xingfei@dhnano.com