Changsha Southern Tantalum and Niobium Co., Ltd. recognizes the risk of a significant negative impact on the mining, trading, processing and export of minerals affected by conflicts and high-risk areas, and recognizes that we have the obligation to respect human rights, not to encourage conflicts, and not to have a negative impact on the environment and society. We require that all the raw materials containing tantalum intermediate products (including tantalum oxide, tantalum powder, tantalum ingot, etc.) shall be purchased from certified RMI compliance. For secondary raw materials, we do not purchase any smelter waste, only purchase and process recycled materials (end users or products after consumption), and require all secondary raw material suppliers have a fixed business premises, all raw material sources legal compliance. We are committed to abiding by the relevant UN sanctions resolutions, abiding by the domestic laws that apply and implement such resolutions, and promising not to participate in any action that will help or facilitate the conflict.

CSTN has consistently adhered to and fully complied with the OECD Guidelines on Responsible Supply Chain Due Diligence for minerals from conflict-affected and high-risk areas, and has developed its own responsible mineral supply chain policies to avoid direct or indirect conflict minerals that fund or benefit armed groups and conflict minerals involving / or other serious human rights violations in high-risk and conflict-affected areas. This policy is contained in the Southern Tantalum-niobium website:www.csnftn.cn, According to the OECD guidelines, we have developed management methods for different levels of raw materials and different risk levels to ensure that we comply with the five-step framework of the OECD guidelines. To this end, southern tantalum and niobium has established a special management team, which is led by the general manager, and the team members include all the senior executives, the head of the purchasing department, the head of the quality department and the factory director.

To this end, we undertake to identify and avoid the following risks in business activities and review annually and improve in time:

1. Serious violations of human rights

We will not tolerate nor in any way benefit, facilitate, assist or facilitate any party:

---Any form of torture, cruel, inhuman and degrading treatment;

---Any form of forced or forced labor. Forced or forced labour refers to labour or services not voluntarily provided by any individual exploited by punishment as a threat;

---The worst form of child labor;

---Other serious violations and violations of human rights, such as widespread acts of sexual violence;

---War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

Risk Reduction Measures:

If we have reasonable reasons to believe that any party of the upstream supplier has purchased or been associated with the above serious human rights violations, we will immediately suspend or interrupt the cooperation with the supplier.

2. Direct or indirectly support illegal organized armed groups and public or private security forces

We will not tolerate any upstream suppliers providing direct or indirect support to non-state organized armed groups through the exploitation, transportation, trading, processing or export of mineral resources. The provision of "direct or indirect support" to non-state organized armed groups through the mining, transportation, trading, processing or export of mineral resources includes, but is not limited to, the purchase of minerals from non-state organized armed groups or their affiliates, payment, or otherwise providing logistical support or equipment. These armed groups or related parties:

---Illegally control mine sites, or by other means control transportation routes, mineral resources trading points and upstream actors of the supply chain;

---Illegally levying taxes or extorting money or mineral resources along the entrance and transportation routes of mine sites or at mineral resources trading points;

---Illegal taxation or extortion against middlemen, exporters, or international traders.

We will put an end to illegal control site, transport routes and supply chain upstream participants, along the site entrance, transport route or mineral resources trading illegal tax or ask for money or mineral resources, or to middlemen, export enterprises or international traders illegal tax or blackmail public or private security forces to provide direct or indirect support.

We recognize that the role of public or private security forces along the mine site and / or its surrounding areas and / or transport roads is only to uphold the rule of law, including the protection of human rights, miners, equipment and facilities, and the protection of mine sites or transport routes to protect legitimate mining and trade from influence and interference.

We will support or take measures, cooperate with local governments, international organizations and civil society organizations, mineral resources on the supply chain through small workshops or small-scale mining way, avoid or minimize public or private security armed stationed in the adverse effects to vulnerable groups, especially the negative impact of small workshop miners.

Risk Reduction Measures:

If we have reasonable reasons to believe that upstream suppliers provide direct or interval to non-state organized armed groups

If any party purchases or associated with it, we will immediately suspend or interrupt the cooperation with the supplier. When we identify the existence of such risks, we will immediately follow the specific location of the company in the supply chain

Upstream suppliers and other stakeholders work together to develop, adopt and implement risk management plans to prevent or reduce the risk of providing direct or indirect support to public or private security forces. These security forces involve:

--- Illegal control of mine sites, transport routes and upstream supply chain;

--- Illegally levying taxes or extorting money or mineral resources along the entrance or transportation routes of the mine site or at mineral resources trading points;

--- Illegal taxation or extortion of middlemen, exporters, or international traders.

In this case, if the risk management plan does not work for six months, we will suspend or interrupt the cooperation with the upstream suppliers.

3. On bribery and fraudulent fraud, corruption, money laundering and fees paid to the government

We do not provide, promise, give or claim any bribes, and resist the temptation of corruption. We will not offer bribes to cover up or forge the origin of mineral resources, or falsely report the taxes, fees and franchise fees payable to the government in the mining, trading, processing, transportation and export of mineral resources.

We prohibit all bribery in all business activities and transactions, including bribery by agents and other third parties, and set standards and approval procedures for gifts and accepting gifts.

If we have reason to think that there are mining, trading, processing, transportation or export in the entrance, transportation route, or upstream suppliers mineral resources trading illegal tax or extortion of mineral resources caused or associated with money laundering risk, we will support or take measures to effectively eliminate money laundering behavior.

Changsha Southern Tantalum and Niobium Co., Ltd. recognizes the risk of a significant negative impact on the mining, trading, processing and export of minerals affected by conflicts and high-risk areas, and recognizes that we have the obligation to respect human rights, not to encourage conflicts, and not to have a negative impact on the environment and society. We require that all the raw materials containing tantalum intermediate products (including tantalum oxide, tantalum powder, tantalum ingot, etc.) shall be purchased from certified RMI compliance. For secondary raw materials, we do not purchase any smelter waste, only purchase and process recycled materials (end users or products after consumption), and require all secondary raw material suppliers have a fixed business premises, all raw material sources legal compliance. We are committed to abiding by the relevant UN sanctions resolutions, abiding by the domestic laws that apply and implement such resolutions, and promising not to participate in any action that will help or facilitate the conflict.

CSTN has consistently adhered to and fully complied with the OECD Guidelines on Responsible Supply Chain Due Diligence for minerals from conflict-affected and high-risk areas, and has developed its own responsible mineral supply chain policies to avoid direct or indirect conflict minerals that fund or benefit armed groups and conflict minerals involving / or other serious human rights violations in high-risk and conflict-affected areas. This policy is contained in the Southern Tantalum-niobium website:www.csnftn.cn, According to the OECD guidelines, we have developed management methods for different levels of raw materials and different risk levels to ensure that we comply with the five-step framework of the OECD guidelines. To this end, southern tantalum and niobium has established a special management team, which is led by the general manager, and the team members include all the senior executives, the head of the purchasing department, the head of the quality department and the factory director.

To this end, we undertake to identify and avoid the following risks in business activities and review annually and improve in time:

1. Serious violations of human rights

We will not tolerate nor in any way benefit, facilitate, assist or facilitate any party:

---Any form of torture, cruel, inhuman and degrading treatment;

---Any form of forced or forced labor. Forced or forced labour refers to labour or services not voluntarily provided by any individual exploited by punishment as a threat;

---The worst form of child labor;

---Other serious violations and violations of human rights, such as widespread acts of sexual violence;

---War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

Risk Reduction Measures:

If we have reasonable reasons to believe that any party of the upstream supplier has purchased or been associated with the above serious human rights violations, we will immediately suspend or interrupt the cooperation with the supplier.

2. Direct or indirectly support illegal organized armed groups and public or private security forces

We will not tolerate any upstream suppliers providing direct or indirect support to non-state organized armed groups through the exploitation, transportation, trading, processing or export of mineral resources. The provision of "direct or indirect support" to non-state organized armed groups through the mining, transportation, trading, processing or export of mineral resources includes, but is not limited to, the purchase of minerals from non-state organized armed groups or their affiliates, payment, or otherwise providing logistical support or equipment. These armed groups or related parties:

---Illegally control mine sites, or by other means control transportation routes, mineral resources trading points and upstream actors of the supply chain;

---Illegally levying taxes or extorting money or mineral resources along the entrance and transportation routes of mine sites or at mineral resources trading points;

---Illegal taxation or extortion against middlemen, exporters, or international traders.

We will put an end to illegal control site, transport routes and supply chain upstream participants, along the site entrance, transport route or mineral resources trading illegal tax or ask for money or mineral resources, or to middlemen, export enterprises or international traders illegal tax or blackmail public or private security forces to provide direct or indirect support.

We recognize that the role of public or private security forces along the mine site and / or its surrounding areas and / or transport roads is only to uphold the rule of law, including the protection of human rights, miners, equipment and facilities, and the protection of mine sites or transport routes to protect legitimate mining and trade from influence and interference.

We will support or take measures, cooperate with local governments, international organizations and civil society organizations, mineral resources on the supply chain through small workshops or small-scale mining way, avoid or minimize public or private security armed stationed in the adverse effects to vulnerable groups, especially the negative impact of small workshop miners.

Risk Reduction Measures:

If we have reasonable reasons to believe that upstream suppliers provide direct or interval to non-state organized armed groups

If any party purchases or associated with it, we will immediately suspend or interrupt the cooperation with the supplier. When we identify the existence of such risks, we will immediately follow the specific location of the company in the supply chain

Upstream suppliers and other stakeholders work together to develop, adopt and implement risk management plans to prevent or reduce the risk of providing direct or indirect support to public or private security forces. These security forces involve:

--- Illegal control of mine sites, transport routes and upstream supply chain;

--- Illegally levying taxes or extorting money or mineral resources along the entrance or transportation routes of the mine site or at mineral resources trading points;

--- Illegal taxation or extortion of middlemen, exporters, or international traders.

In this case, if the risk management plan does not work for six months, we will suspend or interrupt the cooperation with the upstream suppliers.

3. On bribery and fraudulent fraud, corruption, money laundering and fees paid to the government

We do not provide, promise, give or claim any bribes, and resist the temptation of corruption. We will not offer bribes to cover up or forge the origin of mineral resources, or falsely report the taxes, fees and franchise fees payable to the government in the mining, trading, processing, transportation and export of mineral resources.

We prohibit all bribery in all business activities and transactions, including bribery by agents and other third parties, and set standards and approval procedures for gifts and accepting gifts.

If we have reason to think that there are mining, trading, processing, transportation or export in the entrance, transportation route, or upstream suppliers mineral resources trading illegal tax or extortion of mineral resources caused or associated with money laundering risk, we will support or take measures to effectively eliminate money laundering behavior.