Conflict Minerals Procurement Policy.docx

Conflict Minerals Procurement Policy

Lens Technology Co., Ltd. and its subsidiaries and branches (hereinafter referred to as “the Company”) firmly oppose any form of armed conflict, illegal mining, forced labor, child labor, and environmental degradation The Company commits to and endeavors to promote, in accordance with its supply chain investigation mechanism and related management requirements, that suppliers procure mineral raw materials used in production—including tin, tantalum, tungsten, and gold (3TG), as well as cobalt, mica, nickel, and lithium—in a responsible manner. Pursuant to the Company’s supply chain investigation mechanism and related management requirements, the Company conducts verification of conflict minerals source information from key suppliers, identifies and manages potential risks that may exist, and promotes the development of policies and mechanisms by suppliers to refrain from using minerals sourced from conflict-affected or high-risk areas.

Ⅰ. Scope of Application

This policy applies to the Company and all of its subsidiaries and branches. The controlled minerals include tin, tantalum, tungsten, and gold (3TG), as well as cobalt, mica, nickel, lithium, and other minerals sourced from conflict-affected and high-risk areas (hereinafter referred to as “conflict minerals”).

Ⅱ. Core Commitments and Management Requirements

1､Conflict-Free Sourcing Commitment

The Company publicly commits that, in accordance with its supply chain investigation mechanism and related management requirements, it will not procure or support the use of minerals sourced from conflict-affected or high-risk areas, and firmly opposes mineral materials involved in violations such as human rights abuses, armed group financing, severe environmental damage, forced labor, and child labor.

2､Supply Chain Traceability System

The Company is committed to establishing a supply chain traceability system, requiring suppliers to truthfully declare the types and quantities of minerals used, provide information on upstream smelters, and submit mineral source declaration forms in accordance with the Company’s unified template. The Company also encourages suppliers to cascade these requirements to their upstream suppliers, progressively achieving full-chain source traceability.

3､Supplier Admission and Contractual Obligations

The Company has incorporated conflict minerals compliance requirements into its Supplier Code of Conduct and the Supplier Social Responsibility Commitment Letter, making them a prerequisite for supplier admission. New suppliers must sign the Supplier Social Responsibility Commitment Letter and submit complete conflict minerals declaration information upon admission.

4. Annual Investigation

In accordance with the Company’s supply chain investigation mechanism and related management requirements, the Company conducts conflict minerals screening of key suppliers, and collects and verifies conflict minerals information. Following the Company’s investigation procedures, the Company identifies, assesses, and manages conflict minerals risks of key suppliers, and continuously improves the traceability management from the origin of minerals to the final products.

Ⅲ.Supply Chain Risk Assessment and Disposal

The Company will regularly evaluate the conflict minerals verification status of key suppliers, and clarify the number of high-risk suppliers identified and the specific types of risks involved. For suppliers with high conflict minerals risks, the Company will track and follow up on their corrective actions, requiring them to complete the replacement of non-compliant smelters or to advance compliance certification. Suppliers that refuse to cooperate with corrective actions may lose their qualified supplier status.

Ⅴ. Information Disclosure and Reporting
The Company will specifically disclose its conflict minerals management status in its annual ESG report. In addition, we will submit dedicated conflict minerals reports in a timely manner in accordance with customer requirements and applicable laws and regulations.

Ⅵ. Grievance and Supervision Mechanism
The Company has established a comprehensive feedback mechanism for stakeholders and set up dedicated reporting channels to accept supervision and reports from the public regarding conflict minerals issues within our supply chain.

Reporting Email: [tousu@hnlens.com]