Nantong Foremost Garments & Accessories Co., Ltd.
Nantong Foremost Garments & Accessories Co., Ltd.

Conflict Minerals Procurement Policy Program files

Nantong Foremost Garments & Accessories Co., Ltd. Updated Jan. 13,2024

I. Purpose

This policy and procedure aims to standardize the management of conflict minerals involved in the company's procurement activities, ensure that the company's supply chain does not involve any illegal, high-risk or anti-human rights mining activities, and safeguard the company's reputation and interests.

II. Scope of application

This policy procedure applies to all activities involving the procurement of conflict minerals by the company and its subsidiaries.

III. Definitions

Conflict minerals: Refers to minerals mined illegally, at high risk, or in anti-human rights ways in the Democratic Republic of Congo (DRC) and its surrounding countries, including tin, tungsten, cobalt, tantalum, and rare earth elements.

IV. Responsibilities and Division of Labor

1. Supply Chain Management Department: Responsible for setting supplier access standards to ensure that suppliers meet the company's compliance requirements for the procurement of conflict minerals; responsible for regularly reviewing suppliers to ensure their continued compliance.

2. Procurement department: Responsible for identifying products involving conflict minerals during the procurement process and ensuring that they are sourced from compliant suppliers; responsible for communicating with suppliers and requesting relevant supporting documents.

3. Legal department: responsible for providing legal support to ensure compliance with the company's conflict mineral procurement requirements; responsible for reviewing the supporting documents provided by suppliers.

4. Quality department: responsible for quality inspection of purchased products to ensure that the products meet the company's quality requirements.

V. Conflict Mineral Procurement Management Procedure

1. Supplier access stage: During the supplier access review stage, the supply chain management department should incorporate conflict mineral compliance into the evaluation criteria to ensure that new suppliers meet company requirements. For existing suppliers, regular reviews should be conducted to ensure their continued compliance.

2. Procurement phase: The procurement department should identify products involving conflict minerals during the procurement process and ensure that they are sourced from compliant suppliers. Before signing the procurement contract, the procurement department should clearly agree with the supplier on the handling of conflict minerals and require the supplier to provide relevant supporting documents.

3. Certification document management: The supplier should provide certification documents, such as third-party audit reports, within a certain period of time after signing the contract to prove that the purchased products do not involve conflict minerals. The legal department should review the certification documents to ensure their authenticity and validity.

4. Quality inspection: The quality department should conduct quality inspections on purchased products to ensure that they meet the company's quality requirements. For products involving conflict minerals, the quality department should focus on their quality and source compliance.

5. Handling of bad suppliers: For suppliers identified as involving conflict minerals, the company should immediately suspend cooperation and conduct an investigation. Based on the results of the investigation, appropriate measures should be taken, including but not limited to terminating the contract, filing a lawsuit, etc. At the same time, the supplier should be included in the blacklist and notified to other departments and subsidiaries.

VI. Training and publicity

The company should conduct regular conflict mineral compliance training for employees to improve their understanding of conflict minerals and compliance awareness. At the same time, the importance of conflict mineral compliance should be promoted to employees through internal communication channels to ensure that employees comply with relevant regulations in their actual work.

VII. Supervision and Assessment

The company shall establish a sound supervision mechanism to regularly inspect and assess the implementation of this policy and procedure by each department and subsidiary. Any violations discovered shall be handled in strict accordance with company regulations, and the relevant responsible persons shall be held accountable.

This policy procedure shall come into effect on the date of its issuance, and all departments and subsidiaries shall strictly comply with it. Any adjustments or modifications to this policy procedure in the event of special circumstances must be approved by the company's leadership before implementation.

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