Conflict Minerals Policy

Principles Statement: East Rise Corporation Limited must have a statement of principles related to the supply chain of tantalum raw materials.

• The statement must be included in the company mission statement
• The statement must be included in the company purchasing policy
• The statement must be referenced in the company quality manual
• Principles must include the following elements or references:
  • While sourcing from, or operating in , conflict- affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, or facilitate the commission by any party of:
    • Any forms of torture, cruel, inhuman and degrading treatment;
    • Any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
    • The worst forms of child labour;
    • 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.

Risk Management: East Rise will operate a risk management system for the supply chain of tantalum raw materials.

• Seven Concepts: The following seven concepts are used in the Risk management system: Risk, Event, Standards, Severity (of a Risk), Probability (of a Risk), Mitigation (of a Risk), and Measures (taken to Mitigate Risk):
• Risk shall be determined for every Event that occurs in the supply chain.
• Risk is determined for each Event by comparing the Event to applicable Standards to produce an assessment of the Severity and Probability of each Risk.
• The records of Events and the associated Risk assessments for each Event shall be maintained in a company database for review by management.
• Mitigation of Risk shall be defined as Measures taken to reduce the Severity and/or the Probability of each Risk

Fact based assessment of Risk requires data on all Events:

• Identification of all mines supplying ore to East Rise Corporation Limited
• Identification of all players in the supply chain for East Rise
• Obtain copies of all tax and fees receipts from governments and security agencies at mines and along routes of transport
• Identification of all contracts with supply chain players
• Evidence of training given to security forces to comply with V.P.S.H.R.

Mitigation of Risk

• Management shall review the Risk database each month as part of the monthly quality review meeting
• CARs shall be opened to mitigate identified risks
  • East Rise shall take measures to minimize the severity and/or probability of risks
  • Measures may involve Modifying the relationship between East Rise and the other players in the supply chain
  • Measure may involve Discontinuing use of recalcitrant players in the supply chain

Standards

Events in the supply chain shall be compared against all Standards used in the industry for the purpose of calculating the Risk to East Rise Corporation Limited caused by the interplay of Events with Standards

As noted above the records of Events and Risks derived from Standards shall be maintained in the company database for storage and routine review by management

Executive Order: East Rise shall issue an Executive Order to all East Rise Corporation Limited employees requiring:

All employees are required to be aware of, be trained to and must support the supply chain policy

All employees must immediately communicate any suspicious behavior of players in the supply chain to upper management

Visits and Audit of the Supply Chain:

East Rise shall establish a Team of East Rise employees to conduct routine on-the-ground visits to all players in the supply chain

East Rise Corporation Limited shall arrange for third party audits of all players in the supply chain

Audits shall include the mine and supply routes from mine to other players in the supply chain

All countries must be visited

All sites must be audited

East Rise Team must train the players at all sites to the East Rise principles and policy regarding the supply chain

If there are any issues of concern you would like to raise regarding the due diligence procedures of East Rise Corporation Limited, or that of its suppliers, please e-mail : whistleblowing@eastrise.hk