Recognizing the risks of potentially significant adverse impacts associated with the mining, trading, processing, and export of mineral resources in conflict-affected and high-risk areas, and recognizing the obligation of enterprises to respect human rights, not to contribute to conflict, and to avoid negative environmental and social impacts, Hubei Wanrun New Energy Technology Co., Ltd. (hereinafter referred to as "Wanrun New Energy") commits to adopting and widely disseminating the "Guidelines for Responsible Management of Mineral Supply Chains in China" issued by the China Chamber of Commerce for Import and Export of Minerals, Metals & Chemicals (CCCMC) and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas issued by the Organisation for Economic Co-operation and Development (OECD), and incorporating them into contracts and agreements with suppliers. This policy provides guidance on conflict-sensitive procurement activities throughout the mineral resource supply chain and on risk awareness among suppliers. Wanrun New Energy is committed to complying with relevant UN sanctions resolutions, complying with domestic laws applicable to the enforcement of such resolutions, and not participating in any activities that would assist or facilitate conflict.

This policy applies to all materials containing lithium, cobalt, nickel, and manganese purchased by the company.

This policy applies to Hubei Wanrun New Energy Technology Co., Ltd. and all its subsidiaries under the Wanrun Group (including Hubei Yuhao High-tech New Materials Co., Ltd., Lubo Wanrun Smart Energy Technology (Shandong) Co., Ltd., Anqing Derun New Energy Materials Co., Ltd., Hubei Hongmai High-tech New Materials Co., Ltd., Hubei Honghrun High-tech New Materials Co., Ltd., and Hubei Wanrun New Energy Technology Co., Ltd. Yunyang Branch) and suppliers providing lithium, cobalt, nickel, and manganese raw materials. This policy is effective immediately upon promulgation.

Identify and avoid the following risks in business activities:

1. Serious human rights abuses related to mineral extraction, transportation, or trade:

When conducting procurement or business activities in conflict-affected and high-risk areas, we will neither tolerate nor in any way profit from, assist, facilitate, or enable any party to commit:

1. Any form of torture, cruel, inhuman, or degrading treatment;

2. Any form of forced or compulsory labor. Forced or compulsory labor refers to any work or service extracted from any individual under the threat of penalty, which is not voluntarily provided by that person;

3. The worst forms of child labor;

4. Other serious human rights abuses and violations, such as widespread sexual violence;

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

2. Risk management of serious human rights abuses

If we have reasonable grounds to believe that such a risk exists, i.e., that an upstream supplier is sourcing from or is associated with any party committing the serious human rights abuses set out in paragraph 1, we will immediately suspend or terminate our cooperation with that supplier.

3. Regarding direct or indirect support for non-state armed groups:

We will not tolerate any direct or indirect support for non-state armed groups through the mining, transportation, trade, processing, or export of minerals. "Direct or indirect support" for non-state armed groups through the 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 otherwise providing them with logistical support or equipment. These armed groups or affiliates:

1. Illegally control mine sites, or otherwise control transportation routes, mineral trading points, and upstream actors in the supply chain;

2. And/or illegally levy taxes or extort money or minerals at mine entrances, along transportation routes, or at mineral trading points;

3. And/or illegally levy taxes or extort money from intermediaries, exporters, or international traders.

4. Risk management of direct or indirect support for non-state armed groups:

If we have reason to believe that an upstream supplier is sourcing from or has a relationship with any party providing direct or indirect support to non-state armed groups, we will immediately suspend or terminate our cooperation with that supplier.

5. Regarding public or private security forces:

We agree to prohibit, in accordance with regulations, the provision of direct or indirect support to public or private security forces that illegally control mine sites, transportation routes, and upstream actors in the supply chain, illegally levy taxes or extort money or minerals at mine entrances, along transportation routes, or at mineral trading points, or illegally levy taxes or extort money from intermediaries, exporters, or international traders.

1. We acknowledge that the role of public or private security forces at and/or around mine sites and/or along transportation routes is solely to uphold the rule of law, including protecting human rights, protecting miners, equipment, and facilities, and protecting mine sites or transportation routes to ensure that legitimate mining and trade are not disrupted.

2. In cases where we or any enterprise in our supply chain has entered into contracts with public or private security forces, we commit to or will stipulate that the Voluntary Principles on Security and Human Rights will be adhered to in the course of cooperation with such security forces. In particular, we will support or take measures to implement screening policies to ensure that individuals or security force units known to have committed serious human rights abuses are not employed.

3. We will support or take measures to cooperate with central or local governments, international organizations, and civil society organizations to find viable solutions on how to improve the transparency, proportionality, and accountability of public security force security costs.

4. We will support or take measures to interact with local governments, international organizations, and civil society organizations to avoid or minimize the negative impacts of public or private security forces stationed at mine sites on vulnerable groups, especially on artisanal miners, in cases where minerals in the supply chain are extracted through artisanal or small-scale mining.

6. Risk management of public or private security forces:

If we find that such risks exist to a certain extent, we will, based on the specific position of the enterprise in the supply chain, immediately formulate, adopt, and implement risk management plans for upstream suppliers and other stakeholders to curb or mitigate the risks of directly or indirectly supporting the arming of public or private security. If the risk management plan does not work after six months of implementation, we will temporarily suspend or terminate cooperation with upstream suppliers. We will take the same countermeasures if we find that there may be violations of the above content to a certain extent.

VII. Regarding bribery and fraudulent misrepresentation of mineral origin:

We will not offer, promise, make, or solicit any bribes, and will resist the temptation to bribe in order to conceal or falsify the origin of minerals, or to underreport taxes, fees, and royalties payable to the government for mineral extraction, trade, processing, transportation, and export activities.

VIII. Regarding money laundering

If we have reason to believe that there is a risk of money laundering arising from or related to minerals obtained through illegal taxation or extortion during mining, trade, processing, transportation, or export at the mine entrance, along transportation routes, or at the mineral trading locations of upstream suppliers, we will support or take measures to contribute to the effective elimination of money laundering.

IX. Regarding taxes, fees, and royalties paid to the government:

We will ensure that all legal taxes, fees, and royalties related to the mining, trade, and export of minerals from conflict-affected and high-risk areas are paid to the government, and we are committed to disclosing such payments in accordance with the principles of the Extractive Industries Transparency Initiative (EITI) based on the enterprise's position in the supply chain.

X. Risk management of bribery, fraudulent misrepresentation of mineral origin, money laundering, and taxes, fees, and royalties paid to the government:

Based on the specific position of the enterprise in the supply chain, we are committed to cooperating with suppliers, central or local government agencies, international organizations, civil society, and affected third parties, as appropriate, with the aim of taking significant measures to prevent or mitigate risks with negative impacts within a reasonable timeframe, and to improve or track performance. If risk mitigation measures are ineffective, we will temporarily suspend or terminate cooperation with upstream suppliers.

Hubei Wanrun New Energy Technology Co., Ltd.

August 17, 2023