Conflict Minerals Policy

Conflict Minerals：Minerals and their derivatives originating from conflict-affected or high-risk regions (mainly covering 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, Zambia, etc.), whose mining, trade or transportation may directly or indirectly finance armed conflicts and terrorism, or be accompanied by severe human rights abuses and environmental damage. The core categories include four metallic minerals: Tin (including derivatives such as cassiterite), Tantalum (Ta, including derivatives such as coltan), Tungsten (including derivatives such as wolframite), and Gold, which are commonly referred to as 3TG minerals in the industry.

XDC and its subsidiaries do not directly engage in the procurement or use of raw mineral ores. However, materials and components essential to our production may potentially contain mineral components such as 3TG. We comply with international standards and initiatives including the Responsible Business Alliance (RBA) Code of Conduct and OECD Due Diligence Guidance. The Company shall not directly or indirectly procure 3TG minerals that benefit armed groups committing severe human rights abuses or cause environmental damage in the DRC or its adjacent countries. We ensure all materials used in our products are sourced from socially and environmentally responsible supply channels. Meanwhile, we require our suppliers to source materials only from environmentally and socially responsible channels. Suppliers are not prohibited from sourcing minerals from the DRC and its neighboring countries, but such procurement must be limited to smelters and refiners certified under the Responsible Minerals Assurance Process (RMAP) as recognized by the Responsible Minerals Initiative (RMI). Smelters and refiners that are not RMAP-certified or fail to meet customer requirements must be removed from the supply chain. The Company commits to conducting due diligence in accordance with OECD requirements.

The Company welcomes and encourages internal employees, suppliers, and external stakeholders to report any issues, concerns, or violations related to the conflict minerals process through public channels.