TOPSUN Conflict Minerals Procurement Policy
Policy Purpose
TOPSUN is committed to ensuring that its supply chain does not involve minerals that directly or indirectly fund armed conflicts, human rights abuses, or environmental destruction (i.e., "conflict minerals"). We pledge to avoid sourcing minerals from high-risk regions in the Democratic Republic of Congo (DRC) and adjoining countries (CAHRA), including tin (Sn), tantalum (Ta), tungsten (W), gold (Au), cobalt (Co), and mica, and promote ethical collaboration across global supply chains.
Scope
This policy applies to TOPSUN and all suppliers, contractors, and subcontractors ("supply chain partners"), covering:
• Minerals: Tin, tungsten, tantalum, gold (3TG), cobalt, mica, and derivatives.
• Geographic Scope: High-risk regions in the DRC and adjoining countries (e.g., Rwanda, Uganda), and areas with armed conflicts, forced labor, or severe environmental degradation.
• Products: All raw materials, components, and finished products containing conflict minerals.
Supplier Requirements
1. Zero Tolerance & Transparency
• Strictly prohibit the procurement or use of minerals linked to high-risk regions. Suppliers must declare that their products do not contain conflict minerals from DRC or adjoining high-risk areas.
• Suppliers must disclose mineral sourcing information traceable to smelters, prioritize RMI-certified facilities, and provide smelter details and third-party certifications (e.g., RMAP).
2. Mandatory Compliance & Penalties
• All suppliers must sign the No-Use of Conflict Minerals Commitment Letter before contract execution, pledging non-use of conflict minerals and acceptance of TOPSUN’s audits. If violations are identified, cooperation will be terminated immediately and TOPSUN will be notified.
• Suppliers using conflict minerals must provide non-conflict proof (e.g., ICGLR/BGR certification) and a remediation plan within 30 days; those failing to comply within 90 days will be removed from the approved supplier list.
3. Due Diligence & Documentation
• Conduct at least one annual review, requiring suppliers to trace minerals back to smelters. Prioritize suppliers with RMI’s Conflict-Free Smelter Program (CFSP) certification; non-certified suppliers must rectify or replace smelters within 90 days.
• Suppliers must submit CMRT and EMRT reports, accurately filling in mineral origin and supply chain information.
Implementation Measures
1. Supply Chain Traceability & Data Management
• Maintain a mineral database tracking smelter information and RMAP status to ensure supply chain traceability.
• Apply OECD’s Five-Step Framework (Identify, Assess, Respond, Audit, Report) for risk management, conducting regular supply chain risk assessments.
2. Transparency & Reporting
• Publish a Conflict Minerals Due Diligence Report detailing compliance progress and supply chain traceability, subject to internal and external oversight.
• Share traceability data with customers to assist them in meeting ESG obligations and promote sustainable industrial development.
3. Training & Continuous Improvement
• Conduct quarterly training sessions for procurement and supply chain teams on regulations and CMRT reporting processes to enhance compliance awareness and operational capabilities.
• Provide bilingual Conflict Minerals Policy Guidelines to help suppliers understand policy requirements and cooperate with implementation; review and update the policy annually to align with international regulations (e.g., Dodd-Frank Act, EU Conflict Minerals Regulation) and operational feedback.
Anti-corruption
Topsun adheres to integrity-based operation, upholds business ethics and complies with all applicable laws and regulations, maintaining a zero-tolerance policy toward bribery and corruption.
Topsun requires all business partners, including suppliers, service providers, subcontractors, distributors, agents, consultants, ecosystem partners and other relevant parties, to abide by applicable anti-corruption laws, prevailing industrial ethical norms and the Topsun Partner Anti-Corruption Policy (hereinafter referred to as this Policy). When delivering services, performing contractual obligations for Topsun, or acting on Topsun’s behalf to serve customers and other third parties, partners shall comply with the following provisions:
1. Refrain from engaging in any form of bribery and corrupt conduct.
2. Avoid improper acts that may impose joint liability on Topsun, and prohibit affiliated parties from conducting such liable behaviors.
3. Maintain authentic, accurate and complete books and records, and prohibit false, inaccurate, incomplete, forged or misleading entries.
4. Establish a sound compliance management system, and implement anti-corruption requirements throughout all business activities and procedures. Partners shall disseminate Topsun’s anti-corruption rules to their employees and sub-partners, and conduct regular compliance reviews.
5. Cooperate with Topsun’s supervision work. Topsun reserves the right to conduct due diligence and implement regulatory procedures on partners to ensure full legal and ethical compliance. Partners shall submit truthful, complete, legal and valid documents, and disclose no information that may impair Topsun’s legitimate interests.
Should any partner violate this Policy, make false or fraudulent representations and warranties, or be reasonably suspected of committing aforesaid violations, Topsun may suspend or terminate the partnership immediately upon written notice, and reserve the right to pursue corresponding legal liabilities.
For the purpose of this Policy, Topsun refers to Shenzhen Topsun Technology Co., Ltd. and all its directly and indirectly held subsidiaries worldwide.
In case of discrepancies between this Policy and local laws and regulations, the stricter provisions shall prevail.
Enterprise Policy and Objectives
Quality Policy:
Swift innovation, shares value. outstanding quality, Continuous improvemen
----Swift innovation
The core of swift innovation lies the ability to swiftly launch and refine products or services by building agile organizational structures and business processes, all while deeply understanding and meeting customer needs—thus adapting to market changes and evolving customer demands. At the same time, rapid innovation requires companies to embrace a spirit of bold experimentation, acceptance of failure, continuous learning, and relentless improvement, thereby driving ongoing innovation and growth within the organization.
----Shares value
Value sharing is an all-round philosophy of value creation and distribution, covering customer demands, employee development, supplier collaboration and other key dimensions. Continuous optimization and improvement of every link across the value chain drives overall value growth and sustainable development.
----Outstanding Quality
Exceptional quality refers to products or services provided by a company that demonstrate outstanding performance in terms of quality, functionality, safety, reliability, and availability, thereby meeting customers’ high-end needs and expectations and earning their trust and loyalty.
----Continuous Improvement
Continuous improvement is an ongoing philosophy and practice dedicated to pursuing excellence. It encompasses management, quality assurance, environmental compliance, manufacturing processes and customer services. Strategies are routinely reviewed and revised to adapt to evolving customer requirements. Driven by continuous improvement, the company steadily enhances core competitiveness and operational performance, so as to fulfill and surpass customer expectations.
Environmental Policy:
All product-related activities comply with laws, regulations and stakeholder requirements. We prioritize employee health and safety, cut costs and waste, optimize resource utilization, prevent pollution and pursue continuous improvement.
Occupational Health and Safety Policy:
Raise awareness of occupational health safety and legal compliance, mitigate occupational health and safety hazards, and continuously optimize the occupational safety management system.
HSF Policy:
Comply with legal and regulatory requirements to meet customers’ environmental protection needs. Select environmentally friendly materials and emphasize pollution prevention and control. Continuously improve the management system to protect the human living environment.
Business Ethics
General Provisions
Purpose：
To uphold the company’s integrity in business operations, prevent moral risks such as commercial bribery and conflicts of interest, and ensure compliance with the requirements of the Anti-Unfair Competition Law, the Criminal Law, and the RBA Code of Conduct (Chapter 8: Ethical Standards), this policy is hereby established.
Scope of application:
Applicable to all employees, directors, shareholders, suppliers, contractors, and business partners of the company.
Core Policy
1. Prohibition of Bribery and Corruption: Any form of bribery, kickbacks, or improper transfer of benefits is strictly prohibited.
2. Conflict of Interest Management: Employees must not exploit their official positions to seek personal or affiliated-party benefits.
3. Gift and Hospitality Guidelines: No gifts or hospitality that could influence impartial judgment shall be provided.
4. Fair Competition and Information Disclosure
• obtain a competitive advantage through improper means such as commercial defamation, bid-rigging, and false advertising.
• Ensure the accuracy of information such as financial reports and product promotions, and prohibit misleading investors or customers.
5. Confidentiality and Privacy Protection：
• Prohibition of disclosing the company’s trade secrets, customer data, and employees’ personal information;
• he collection and use of personal information must be authorized and comply with the requirements of the Personal Information Protection Law.
6. Supply Chain Extended Responsibility:
• Require suppliers/contractors to sign the “Anti-Corruption Commitment Letter” and undergo regular compliance audits. Implement a blacklist mechanism for suppliers found to have engaged in corrupt practices, terminate cooperation, and hold them accountable.
• Implement a blacklist mechanism for suppliers found to have engaged in corrupt practices, terminate cooperation, and hold them accountable.
