Conflict Minerals

Minerals Development History

Increasing awareness of human rights risks in the supply chain has led to more calls for investigations into minerals such as mica. Primarily sourced from India, the mining of mica heavily relies on illegal operations involving child labor. Mica is often used in electronic product coatings. To protect human rights, Accton has initiated due diligence investigations, including the EMRT for mica.

100% Non-Use of Conflict Minerals in Accton Group Components

Respecting international human rights and corporate social responsibility, Accton Group avoids using minerals from areas affected by armed conflict and human rights abuses. Through regular due diligence as part of the Responsible Minerals Initiative (RMI), suppliers are required to source raw materials that do not originate from Conflict-Affected and High- Risk Areas (CAHRAs). This is to prevent indirect human rights violations and ensure compliance with national and international laws.

Accton’s Responsible Conflict Minerals Management Process

Step 1:

Establishment

of Conflict

  • Accton has published its responsible procurement policy on the company website.

  • New qualified suppliers are required to sign a “Product Procurement Agreement,” guaranteeing that the goods supplied to Accton Group do not contain gold (Au), tantalum (Ta), tin (Sn), tungsten (W), cobalt(Co), mica, or other metal substances that directly or indirectly fund or assist high-risk areas identified by the OECD. Suppliers must implement due diligence on the origin and chain of custody of these materials and provide Accton with their due diligence measures upon request.

Step 2:

Risk

Identification

  • Accton identifies the scope of suppliers and conducts investigations using the CMRT/EMRT templates.

  • Review the surveys completed by suppliers and compile findings into the Accton Group’s Conflict Minerals Report (CMRT/EMRT).

Step 3:

Due Diligence

  • Accton only accepts metals from smelters and refiners that are certified through 3 Due Diligence the Responsible Minerals Assurance Process (RMAP) and confirmed by the RMI.

Step 4:

Investigation

and Review

  • At least once per quarter, Accton audits the list of completed investigations against the compliance list on the RMI website.

Step 5:

Open Disclosures

  • Accton updates its due diligence reports at least once annually, publishes these reports on the company website, and provides the investigation results upon customer request.

Distribution and Proportion of Qualified Smelters

To ensure responsibility for conflict minerals at the source, Accton annually conducts risk assessments to screen suppliers that need further investigation. This process utilizes the CMRT and EMRT templates from the Responsible Minerals Initiative (RMI) and the latest compliant smelter lists published by the RMI to identify overall risks. According to the 2024 survey results, Accton’s supply chain used a total of 201 qualified smelters. The distribution of these smelters is primarily in Asia, followed by Europe.