I. Policy Background

As a responsible global corporate citizen, Shenzhen Hopewind Electric Co., Ltd. (hereinafter referred to as "the Company") is fully aware that the procurement of mineral resources may have significant impacts on regional security, human rights, the environment, and social order. To fulfill its social responsibilities, the Company formulated this Conflict Minerals Procurement Management Policy (hereinafter referred to as "this Policy") in accordance with the Chinese Due Diligence Guidelines for Responsible Supply Chains, and with reference to the relevant principles and standards of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition), Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act in the United States and the EU Conflict Minerals Regulation. 

II. Scope of Application

This Policy applies to the Company, all its controlled subsidiaries, and branches, and requires all the Company’s suppliers, subcontractors, and business partners to abide by this Policy.

III. Definitions

The "conflict minerals" referred to in this Policy include, but are not limited to:

Cassiterite

Tantalite

Wolframite

Gold

Copper

Nickel

Cobalt

Lithium

Graphite (Natural)

Mica

and their derivatives. If the aforementioned minerals originate from the Democratic Republic of the Congo (DRC) and its neighboring countries (including Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia), and the proceeds from their mining, transportation, and trade are used to fund armed conflicts, illegal armed organizations, or serious human rights violations, they shall be deemed as "conflict minerals".

IV. Core Commitments

1. Refrain from purchasing or using conflict minerals

The Company hereby commits not to intentionally procure or use conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo and its neighboring countries.

2. Support responsible procurement

The Company encourages and prioritizes the procurement of minerals sourced from certified conflict-free smelters/refineries (such as those holding the Responsible Minerals Initiative (RMI) RMAP certification) and mines that are legal, transparent, and free from human rights violations.

3. Supply chain due diligence

The Company will establish and implement a supply chain due diligence management system in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas issued by the Organization for Economic Co-operation and Development (OECD), to identify, assess, mitigate, and avoid conflict mineral risks.

4. Supplier cooperation requirements

All suppliers who provide the Company with raw materials, parts, components, or finished products that contain or may contain "conflict minerals" must:

o Sign and adhere to this Policy;

o Provide information on the sources of conflict minerals in the supplied products, and disclose such information using standard formats such as CMRT (Conflict Minerals Reporting Template) and EMRT (Extended Minerals Reporting Template);

o Cooperate with the Company to conduct due diligence, including but not limited to document review, on-site audit, third-party audit, etc;

o Ensure that its upstream supply chain also adheres to the requirements of this Policy.

5. Continuous Improvement and Transparency

The Company will regularly evaluate the effectiveness of this Policy and disclose the Company’s measures and progress in conflict minerals procurement management through channels such as the Company’s official website and social responsibility reports.

V. Handling of Violations

If any of the following violations is found in the supplier, the Company will require it to rectify within a specified period. Failure to rectify within the specified period or the commission of severe violations, shall result in the suspension or termination of the cooperation:

· Deliberate concealment or falsification of information regarding the source of minerals;

· The minerals supplied are directly sourced frommines or trading parties that finance armed conflicts;

· Refusal to cooperate with due diligence;

· Other major violations of this Policy.

VI. Grievance and Reporting Mechanism

If any employee, supplier, or member of the public identifies any conflict mineral-related risks or violations in the Company’s supply chain, they may submit reports anonymously or in their real name through the following channels:

· Whistleblower email: scc-ts@hopewind.com

The Company hereby commits to strictly maintain the confidentiality of whistleblowers' information and protect them from any form of retaliation.

VII. Policy Publicity and Effectiveness

This Policy shall come into effect from the date of its issuance and will be permanently published in the "News" section of the Company's official website. The Company hereby reserves the right to revise this Policy in accordance with changes in laws, regulations, and industry standards, and the revised version will be promptly published on the Company’s official website.