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          Guangdong Hongteo Accurate Technology
          Responsible Mineral Sourcing Policy

          Background
          Hongteo is committed to responsible mineral sourcing and strives to conduct activities that respect and support human rights throughout its global supply chain. Although we do not procure minerals directly, our suppliers acquire and use minerals from multiple sources worldwide. In the U.S., the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires publicly traded companies to report annually on the presence of conflict minerals (tantalum, tin, tungsten, and gold, collectively referred to as “3TG”) originating in the Democratic Republic of Congo (“DRC”) or adjoining countries in the products they manufacture or contract to manufacture. Concerns about human rights abuses and other risks related to the extraction of minerals beyond 3TG, such as cobalt, and in geographies beyond the DRC, such as Conflict Affected and High-Risk Areas (“CAHRAs”) as defined by the European Union, are driving an increased demand for greater accountability and transparency in global mineral supply chains.

          Hongteo’s Commitment
          In support of this policy and our commitment to promote responsible sourcing practices that protect human rights and working conditions and are consistent with international law and the laws of the countries in which we conduct business, Hongteo commits to:

          ? Conduct due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas to identify and mitigate risks in our supply chain for 3TG and cobalt that are necessary to the functionality or production of our products that were sourced from CAHRAs, including the DRC;

          ? Require our suppliers to source 3TG, cobalt, and other minerals from smelters and refiners that are conformant to the Responsible Minerals Assurance Process (“RMAP”) or similar third-party assessment;

          ? Support our customers’ inquiries about the source of 3TG or cobalt that we use in manufacturing our products by providing upon request, our most recently updated Company-level Conflict Minerals Reporting Template (“CMRT”) or Cobalt Reporting Template (“CRT”) with declarations based upon our supplier statements and our assessment of our products; and

          ? Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.

          Hongteo’s Expectations of Suppliers
          To support our responsible sourcing practices, we expect our suppliers to:

          ? Conduct their business in accordance with Hongteo’s Supplier Code of Conduct;

          ? Source 3TG, cobalt, and other minerals from smelters and refiners that are conformant to RMAP or similar third-party assessment

          ? Maintain a policy to assure that the 3TG, cobalt, and other minerals in the products they manufacture do not directly or indirectly contribute to significant adverse human rights impacts in CAHRAs, including in the DRC, such as armed conflict, forced and child labor, and environmental degradation;

          ? Establish their own OECD-aligned due diligence program to achieve responsible mineral supply chains; and

          ? Respond to Hongteo inquiries for due diligence information, and promptly implement corrective actions identified and requested by Hongteo.

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