SungEel HiMetal complies with a responsible mineral supply chain policy.

SungEel HiMetal will fulfill its roles and responsibilities in the global gold supply chain by not providing funds or benefits directly or indirectly to armed groups in high-risk and conflict-affected regions and preventing the use of gold for other serious human rights abuses in accordance with the OECD Due Diligence Guidance. In support of the above, we will comply with the third edition of the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas, and our due diligence will cover all risks identified in Annex II of the OECD Guidance and be global in scope. This policy is reviewed, approved and implemented by the company’s management. The policy is shared with concerned stakeholders such as suppliers, customers and employees, and declared on the company’s website. In addition, we will make efforts to address the below Annex II risks if identified.

• Any forms of torture, cruel, inhuman and degrading treatment;
  • Any forms of forced or compulsory labor;
  • The worst forms of child labor;
  • Other gross human rights violations and abuses such as widespread sexual violence;
  • War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
• Direct or indirect support to non-state armed groups.
• Direct or indirect support to public or private security forces.
• Bribery and fraudulent misrepresentation of the origin of minerals.
  • Money laundering.
  • Non-payment of taxes, fees and royalties to governments.

In order to support this policy, we practice the following:

▶ We have established a corporate management system, an internal control system and a record management system for our supply chain policy.

▶ We have a strong process for identifying risks in the supply chain.

▶ We perform due diligence on our suppliers in accordance with the OECD Due Diligence for Responsible Supply Chain for Minerals and encourage them to do the same for their upstream suppliers. We provide due diligence information to demonstrate that we do not support conflicts or human rights abuses and we expect cooperation from our suppliers in gathering of needed information.

▶ Suppliers who do not cooperate with the above expectations or pose a reasonable risk will be managed according to the below risk management strategy.

• Continue transactions if the supplier implements risk management efforts.
• Temporarily halt transactions if the supplier fails to implement risk mitigation efforts.
• Discontinue trade relationship with the gold supplier if the supplier’s risk mitigation efforts are not feasible or unacceptable.

▶ All of our employees comply with the Anti-Money Laundry Act in accordance with domestic laws and anti-money laundering and anti-terrorist financing policies pursuant to the Financial Action Task Force (FATF) Standards. We fulfill our responsibilities in accordance with applicable laws and regulations.

▶ A public report is written according to Step 5 of the OECD Due Diligence Guidance and published on our website to be seen by our customers, relevant stakeholders, etc., to increase the transparency of the implementation of this policy.

Effective Date: November 1, 2019 CEO of SungEel HiMetal