The exploitation of tantalum (Ta), tin (Sn), gold (Au) and tungsten (W) in Congo and its adjoining countries and regions has caused serious issues of human rights and peace. Most of the mining activities in these areas are related to (funded by) the armed groups in the conflict, leading to long-term instability in the area.

 

A.     columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives; or

B.     any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.

 

Adjoining countries: internationally recognized countries sharing the border with the Democratic Republic of Congo, including Rwanda, Uganda, Burundi, Tanzania, South Sudan, Zambia, Angola and Central African Republic.

 

The Group actively responds to the policy aiming to prohibit the use of conflict minerals to fulfil its corresponding social responsibilities. We have published the relevant summary and regulations of the Conflict Minerals Management (《衝突礦產管理》) on the sustainable development section of the Company’s website and promised not to endorse and to use conflict metals from conflict regions and without a third-party certification. We transmit the relevant requirements of Dodd-Frank Wall Street Reform and Consumer Protection Act (《多德－弗蘭克華爾街改革和消費者保護法》) to suppliers, and require them to comply with the regulations on conflict-free metals, strictly implement
the relevant standards of international organizations and industries, and sign the Undertaking for Non-Use of Conflict Minerals (《不使用衝突礦產承諾書》), the Corporate Social Responsibility Commitment (《企業社會責任承諾書》), the Environmental Safety Requirement Notification (《環境安全要求告知書》) and other relevant agreements. We also investigate suppliers whose products contained tantalum, stannum, gold, tungsten and cobalt to ensure that these metals come from qualified smelters.
 

 Subsidiaries of the Company have formulated the Regulations on the Administration of Green Substance (《綠色物質管理規定》), the Technical Standards on Environmental Management of Products (《環境管理物質技術標準》), Regulations for the Recognition of Parts (《部品承認規範》) and other policies. In addition, Sunny Opotech has also formulated the Management Measures for Mineral Control Related to Social Responsibility (《社會責任相關礦產控制管理辦法》) and the annual audit plan to manage and conduct on-site audit on suppliers.Sunny Zhejiang Optics, Sunny Opotech and Sunny Optical Intelligence (Yuyao) have conducted due diligence of metals involved in the supply chain using conflict minerals questionnaires such as the Conflict Minerals Reporting Template (《衝突礦產報告模板》) (“CMRT”) and the Extended Minerals Reporting Template (《擴展礦產報告模板》) (“EMRT”) developed by the Responsible Minerals Initiative (“RMI”). If a supplier is involved in conflict minerals and without a third-party certification, it will be prohibited from supplying goods to the Group. 

 

So far, raw materials used by the Group are not involved with conflict minerals or from smelters have been included in the third-party certification lists such as RMI.