Conflict Minerals Policy

Tsuen Lee Group and its subsidiaries and affiliates (Tsuen Lee) won’t purchase, use and ship the parts/components/finished goods with Conflict Minerals.

As defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, “Conflict Minerals” (3TG) include gold; cassiterite and its derivative tin; columbite-tantalite and its derivative tantalum; and wolframite and its derivative tungsten, which help fund armed groups in the Democratic Republic of Congo (“DRC”) and adjoining countries.
The adjoining countries are Angola, Burundi, Central African Republic, Congo Republic, Rwanda, Sudan, Tanzania, Uganda, Zambia.
The SEC Conflict Minerals disclosure requirements apply to US exchange-traded companies that are subject to the US Securities Exchange Act.

To this end, Tsuen Lee has developed due diligence processes and procedures to identify:
(1) parts/components that contained any of the above four minerals. These minerals are intentional added and necessary to the parts/components’ functionality.
(2) the smelters of those minerals
(3) whether the smelter is an active and conformant
The latest smelter list can be found on the RMI website http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/exports/cmrt-export.

As part of the Conflict Minerals due diligence program, Tsuen Lee expects our suppliers to utilize the widely-used CMRT (Conflict Minerals Reporting Template) to provide the above four minerals information to us and encourage their suppliers to also do so.
CMRT is developed by the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative.

Recognizing that suppliers are still developing programs and systems necessary to obtain the requested information regarding the source of specific minerals, Tsuen Lee commits to working with our suppliers to ensure that all parties are able to comply with the requirements.