A statement on the non-use of conflict minerals
Nov 01, 2022

Fujian Nanping NANFU Battery Co., LTD. (hereinafter referred to as "NANFU") and its subsidiaries follow the requirement of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas : Third Edition, Universal Declaration of Human Rights, Guiding Principles on Business and Human Rights, Responsible Business Alliance Code of Conduct, Chinese Due Diligence Guidelines for Mineral Supply Chain, does not procure or use coltan (tantalum), cassiterite (tin), wolframite (tungsten), and gold or their derivatives (collectively referred to as "conflict minerals") from the Democratic Republic of the Congo and its adjoining countries or from areas controlled by any armed forces within those countries.

NANFU has incorporated the non-use of "conflict minerals" into its supplier green product policy for supply chain management and ensures that the products supplied by the company do not use the above-mentioned "conflict minerals".

At the same time, NANFU promises:

  1. Jointly fulfill the responsibility of social and environmental protection with supply chain partners, continue to pay attention to the issue of "conflict minerals", and strive to investigate the supply chain in detail.

  2. Not to accept "conflict minerals" from the Democratic Republic of Congo and its surrounding countries and regions.

  3. Work with suppliers to trace the source of cobalt (Co), gold (Au), palladium (Pd), tantalum (Ta), tin (Sn) and tungsten (W) in all products to ensure that these metals are not from "conflict minerals".

  4. Recommend that suppliers convey this requirement to their upstream suppliers.

Position statement

The US Congress has linked the mining and trade of tin, tungsten, tantalum and gold (collectively known as "conflict minerals") to human rights abuses in the Democratic Republic of the Congo and surrounding countries (collectively known as the DRC). NANFU is committed to sourcing conflict minerals used in its products in a responsible manner. NANFU will not knowingly support, donate, assist or facilitate the armed groups of the DRC with respect to the mining and trade of conflict minerals. NANFU will not intentionally provide any direct or indirect support to non-state armed groups or security forces or to upstream actors in the supply chain that illegally control mining areas, transport routes, trade points. NANFU will also adopt a comprehensive policy against corruption and bribery by its employees. We expect all parties in NANFU's supply chain to follow the same principles. NANFU will follow due diligence procedures related to conflict minerals that are consistent with nationally or internationally recognized due diligence frameworks, which may include OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas : Third Edition. Suppliers are encouraged to source materials from conflict-free sources and, where reasonably practicable, from accredited smelters. NANFU has no intention of preventing its suppliers from responsibly sourcing from legitimate mines within DRC, as this may also be detrimental to local economic and demographic development, resulting in prolonged poverty.

Requirements for suppliers

Where applicable, NANFU will incorporate the principles of responsible procurement of conflict minerals into the terms of our contracts with suppliers and will work with suppliers, customers and others in the supply chain to raise awareness of these issues. We will explain our position to our suppliers and expect them to adopt similar positions or policies with respect to their own supply chains. For suppliers who manufacture components, parts or products containing conflict minerals, NANFU encourages them to purchase these materials from conflict-free sources. We expect suppliers to adopt and implement positions and policies on conflict minerals and to communicate with their subordinate suppliers and, where possible, require their downstream suppliers to adopt and implement similar positions and policies. Suppliers should work with subordinate suppliers to trace conflict minerals at least to the smelter level and encourage the use of standard reporting procedures (e.g., conflict minerals reporting templates). NANFU reserves the right to request further evidence of its conflict minerals supply chain from its suppliers, tracing back to the mine level if necessary. We expect suppliers to retain such traceability data for five years and to complete and submit questionnaire forms as required by the Conflict Minerals Survey Report (CMRT). NANFU aims to build long-term relationships with suppliers and seek sustainable solutions where feasible, while working with suppliers to drive improvements. Suppliers that violate conflict minerals requirements must commit to and implement corrective action plans within a reasonable time. NANFU reserves the right to request suppliers to provide evidence of the effectiveness of corrective and preventive actions and to conduct supply chain assessments. If the supplier continues to fail to comply with the conflict minerals regulations and fails to take corrective action, NANFU may take additional action, even including termination of the business relationship.


The ongoing internal armed conflict in the Democratic Republic of the Congo (DRC) has claimed more than 5.4 million lives since the late 1990s, with mining and international trade directly or indirectly financing the conflict and contributing to extreme levels of violence in the region. European and American consumers and the international community are calling on companies that do not import or use minerals from conflict zones to take action to investigate the use of conflict minerals in their supply chains, restrict or ban their use, and reduce financial support to conflict zones, thereby reducing armed conflict and human rights disasters. In 2010, Congress added Section 1502 to the Dodd-Frank Wall Street Reform and Consumer Protection Act, requiring publicly traded U.S. companies to disclose their use of conflict minerals (tin, tungsten, tantalum, gold, 3TG) from Congo and nine neighboring countries, conduct supply chain due diligence investigations, and issue annual reports. The U.S. Securities and Exchange Commission (SEC) issued a resolution on the tracking of conflict minerals on August 22, 2012. The resolution imposes due diligence and reporting requirements on U.S. -listed companies to track product functionality or the source of tin, tantalum, tungsten, and gold needed for production. The Conflict Minerals Act passed by the European Parliament in 2017 requires all companies to assess compliance of suppliers trading in tin, tungsten, tantalum and gold (3TG). The Conflict Minerals Act not only affects US listed companies and their supply chains, but also becomes a new issue in the global CSR field, becoming an integral part of industry standards such as RBA/JAC/AIAG.

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