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KEY POLICIES & ACTIVITIES

Conflict Minerals Management

Conflict Minerals Management Targets and Scope of Application

To prevent the use of minerals associated with international conflicts and human rights violations, MOTREX defines responsible and conflict minerals management targets as follows and applies the same standards to all suppliers and sub-tier supply chains.

CMRT Target (3TG) Tin, Tantalum, Tungsten, Gold
EMRT Target Cobalt, Natural Mica
Expanded Management Minerals Copper, Nickel, etc.
Other Minerals Additional management may be applied in accordance with international standards and customer requirements

Conflict Minerals Governance and Responsibility Structure

MOTREX has established an internal management system in which the Purchasing, Quality, ESG, and Compliance departments collaborate on conflict minerals management. When major risks are identified, corrective actions are determined through internal review and decision-making procedures.

Policies, supplier management, and inspection results related to conflict minerals management are reviewed and updated at least once a year.

Conflict Minerals Policy

MOTREX has established the “Conflict Minerals Regulations” to systematically implement conflict minerals management and clarify internal procedures and responsibilities. In addition, the “Conflict Minerals Management Guidelines” are reviewed annually, and operational processes—such as CMRT/EMRT submission management, identification of high-risk components, and supplier remediation procedures—are continuously refined.

Conflict Minerals Ban Declaration

MOTREX declares its commitment to strictly excluding the use of conflict minerals, complying with the requirements of the international community and global customers, and making every effort to implement responsible supply chain management.

Conflict Minerals
Ban Declaration

MOTREX declares its commitment to strictly excluding the use of conflict minerals, complying with the requirements of the international community and global customers, and making every effort to implement responsible supply chain management.

MOTREX prohibits the use of 3TG minerals (tin, tantalum, tungsten, and gold) mined in Conflict-Affected and High-Risk Areas (CAHRAs), including the Democratic Republic of the Congo and nine neighboring countries, as well as cobalt and mica associated with human rights violations or the financing of armed conflict. The Company ensures that only minerals refined at smelters certified under the Responsible Minerals Assurance Process (RMAP) are used within its supply chain.

These principles apply equally to all business partners, and the Company continuously strives to foster a culture of responsible procurement.

MOTREX mandates the collection and review of Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) disclosures for cobalt and mica from business partners with potential direct or indirect exposure to conflict minerals.

MOTREX is committed to complying with international standards such as the OECD Due Diligence Guidance and the Responsible Minerals Initiative (RMI), and to transparently disclosing its management status through its Sustainability Report.

In addition, the Company continuously manages supply chain risks through its Cyber Reporting System, an anonymous grievance channel through which stakeholders may report concerns related to conflict minerals.

MOTREX declares its commitment to implementing robust management across the entire supply chain to advance ESG management.

December 3, 2025
Lee Hyung-hwan, CEO, MOTREX Co., Ltd.

Conflict Minerals Monitoring Process

MOTREX operates a phased monitoring and management process to prevent the use of conflict minerals across its supply chain and to establish a transparent procurement system.

(Step 01)

Risk Identification

- Scope : All new and existing business partners

- Conduct annual assessments of potential supply chain risks.

- Mandate pre-risk assessments upon new partner registration.

- Designate and manage high-risk categories : FPCs, connectors, electronic components, etc.

(Step 02)

Written Investigation and Reporting

- Conduct written evaluations on an annual basis.

- Key suppliers : CMRT (for conflict minerals)

- Suppliers handling cobalt and mica : EMRT (for extended minerals)

- Ensure verification of the use of RMAP-certified smelters.

(Step 03)

Corrective Action

- Corrective Action Request : Submission of a remediation plan within 30 days

- Re-verification : Verification of implementation within 3 months

- Sanctions : Restrictions on business transactions or contract termination may be imposed in cases of repeated non-compliance or failure to implement corrective actions.

(Step 04)

Disclosure and Annual Reporting

- Report supplier pledges, CMRT submission rates, corrective actions, and related outcomes in the Sustainability Report.

- Provide supply chain reports upon customer request, with updates at least once per year.

Conflict Minerals Management Activities

CMRT and EMRT Management

To ensure responsible mineral sourcing, we require the use of smelters and refiners validated under the Responsible Minerals Assurance Process (RMAP) of the Responsible Minerals Initiative (RMI) as a core sourcing principle.

The Company requires key suppliers to submit CMRT annually and suppliers handling cobalt and mica to submit EMRT annually.

Suppliers must notify MOTREX within 30 days of any changes to the country of origin or smelter information and must also report whether RMAP-certified smelters are used.

If non-certified smelters are identified, the Company will require a corrective action plan. Failure to demonstrate improvement may result in restrictions on business transactions or other corrective measures.

Collection of Compliance Pledges

The Company ensures the collection of a "Conflict Minerals Non-Use Compliance Pledge" from suppliers supplying components and materials likely to contain conflict minerals.

The responsible department reviews submission status and any changes, incorporates them into the management system, and regularly checks supplier compliance.

Submitted CMRTs and EMRTs are reviewed against data quality criteria, such as missing required fields or inconsistencies in smelter information. Resubmission may be required if the criteria are not met.

Conflict Minerals Grievance

All stakeholders of MOTREX may anonymously raise concerns regarding suspected use of conflict minerals, incorrect country-of-origin information, or use of non-certified smelters. All reported concerns are reviewed in accordance with internal procedures and managed under whistleblower protection principles to ensure that reporting parties are not disadvantaged. The results of such investigations are reflected in the continuous improvement of the conflict minerals management system.

How to Submit Concerns
All reports may be submitted through the MOTREX Online Cyber Reporting System. Go to Cyber Reporting System