Hunan Bangpu Recycling Co., Ltd. is a renewable resource high-tech enterprise specializing in the recycling and processing of various waste nickel-metal hydride, nickel-cadmium, lithium ion and other secondary batteries, waste nickel, and waste cobalt.

We recognize that mining, trading, processing, and exporting minerals in conflict-affected and high-risk areas may have major negative impacts, and recognize that we have the obligation to respect human rights and not contribute to conflicts. We promise to adopt and widely promote the following Responsible sourcing policies for minerals in areas affected by conflict and high-risk areas, and incorporate them into contracts and/or agreements signed with suppliers. This policy provides a basic reference for conflict-sensitive procurement activities and suppliers’ risk awareness in the entire process from mining to end users. We promise not to engage in any activities that will fund conflicts, and we promise to comply with relevant UN sanctions resolutions, or, where applicable, to comply with domestic laws that implement such resolutions.

Serious violations related to mining, transportation, or trade of minerals:

1. When carrying out procurement or business activities in conflict-affected and high-risk areas, we will neither tolerate nor in any way benefit, help, assist or facilitate any party's implementation:

I) Any form of torture, cruel, inhuman and degrading treatment;

Ii) Any form of forced or compulsory labor. Forced or compulsory labor refers to any labor or service that is not provided voluntarily by any individual who uses punishment as a threat to squeeze;

Iii) The worst forms of child labor;

Iv) Other serious violations and violations 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 of serious infringements

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

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

3. We will not tolerate any direct or indirect support for non-state armed groups through mineral mining, transportation, trade, processing or export. 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 the purchase of minerals from non-state armed groups or their affiliates4, payment to them, or other means Provide logistical support or equipment for it. These armed groups or related parties:

I) Illegal control of mine sites, or other means to control transportation routes, mineral trading points, and upstream actors in the supply chain;

Ii) Illegal taxation or extortion of 6 money or minerals at the entrance of the mine site, along the transportation route or at the mineral transaction point;

Iii) Illegal taxation or extortion of middlemen, export companies, or international traders.

For risk management of providing direct or indirect support to non-state armed groups:

       4. If we have reason to believe that the upstream supplier purchases from or has a relationship with any party that provides direct or indirect support to non-state armed groups (see the definition in paragraph 3), we will immediately suspend or interrupt the supply Business cooperation.

Regarding public or private security forces:

   5. We agree to stop illegally controlling mine sites, transportation routes, and upstream actors in the supply chain, illegally levying taxes or asking for money or minerals at the entrance to the mine site, along the transportation route, or at the mineral transaction point in accordance with the provisions of paragraph 10 Public or private security forces that illegally levy taxes or extortion by intermediaries, export companies or international traders provide direct or indirect support.

6. We recognize that the role of public or private security forces along the mine site and/or its surrounding areas and/or transportation roads is only to maintain the rule of law, including the protection of human rights, protection of miners, equipment and facilities, and protection of mine sites or transportation routes. So that legal mining and trade are not disturbed.

7. When we or any company in our supply chain has signed a contract with a public or private security force, we promise or will stipulate that in the process of cooperating with such security force, we will comply with the "Voluntary Principles of Security and Human Rights" "Provisions. In particular, we will support or take measures to apply screening policies to ensure that individuals or security armed units who are known to have committed serious human rights violations are not hired.

8. We will support or take measures to cooperate with central or local governments, international organizations and civil society organizations to jointly find feasible solutions for how to improve the transparency, proportionality and accountability of public security armed security costs.

9. We will support or take measures to interact with local governments, international organizations and civil society organizations to avoid or minimize the negative impact of public or private security forces stationed at mine sites on vulnerable groups, especially for small workshops The negative impact of miners, in this case, the minerals in the supply chain are small workshops mined through small workshops or small-scale mining.

Risk management of public or private security forces:

10. If we find that such risks exist to a certain extent, we will immediately formulate, adopt and implement risk management plans for upstream suppliers and other stakeholders based on the company’s specific position in the supply chain, so as to make the fifth paragraph The risks of providing direct or indirect support to public or private security forces as described in the article have been contained or reduced. If the risk management plan does not work for six months, we will temporarily suspend or suspend cooperation with upstream suppliers. 8 We find that there may be behaviors that violate the contents of paragraphs 8 and 9 to a certain extent, and we will take the same countermeasures.

Fraudulent misrepresentation regarding bribery and the origin of minerals:

11. We will not offer, promise, make or solicit any bribes, and resist the temptation. We will not falsely report the taxes paid to the government for mining, trading, processing, transportation, export and other activities in order to conceal or falsify the origin of minerals. Bribes for fees and concession fees.

About money laundering:

12. If we have reason to believe that there are minerals caused by or related to illegal taxation or extortion at the entrance of the mine site, along the transportation route, or the upstream supplier’s mineral transaction site. Regarding money laundering insurance, we will support or take measures to contribute to the effective elimination of money laundering.

Regarding taxes, fees and royalties paid to the government:

13. We will ensure that all legal taxes, fees and royalties related to the mining, trade, and export of minerals in conflict-affected and high-risk areas are paid to the government, and we promise to comply with the "Extractive Industry Transparency Action" based on the company’s position in the supply chain. The principles in the Plan (EITI) disclose such payments.

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

14. According to the company’s specific position in the supply chain, we promise to cooperate with suppliers, central or local government agencies, international organizations, civil society, and affected third parties as appropriate, and take actions within a reasonable time span. The purpose of significant measures to prevent or reduce risks with negative impacts, and to improve or track performance. If risk reduction measures do not work, we will temporarily suspend or suspend cooperation with upstream suppliers.

About child labor and life health and safety:

        15. We promise not to employ any form of child labor;

16. We are committed to complying with the relevant requirements of ISO18001:2007.

二、 Policy dissemination and implementation:

1. We inform our upstream suppliers of this policy by email, and require upstream suppliers to communicate this policy to their upstream to ensure that there is no violation of human rights, especially children's rights, in the Bangpu Cobalt supply chain. We also incorporate this policy into contracts and agreements signed with suppliers.

2. We call on all companies engaged in cobalt mining, processing, trading, and export or companies using cobalt-related products to establish a responsible supply chain due diligence management system to avoid violations of human rights, especially children's rights.