Conflict Minerals

Responsible Mineral Management

To achieve responsible and sustainable procurement practices, Wistron has established a Conflict Minerals Policy and a responsible mineral sourcing management process. Wistron is committed to conducting due diligence on suppliers in accordance with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent internationally recognized due diligence framework. Wistron is committed to cooperating exclusively with smelters and refiners that comply with global standards and strictly prohibits the procurement of tantalum, tin, tungsten, gold (3TG), and cobalt from conflict-affected or high-risk areas, thereby preventing any direct or indirect contribution to human rights violations or armed conflicts in these regions.

Key Practices:

1. Establish and implement a responsible minerals sourcing management process in accordance with the guidance and tools developed by the Responsible Minerals Initiative (RMI); and encourage suppliers to establish internal policies, implement mineral source traceability mechanisms, and monitor their supply chain.
2. Utilize RMI reporting templates (CMRT/EMRT) and Wistron’s internal SQP (supplier questionnaire platform) to systematically conduct due diligence, data collection, and audits. Suppliers are required to disclose the sources of minerals used in their products and sign the Conflict Minerals Statement. In 2025, all 407 Tier-1 suppliers completed the declaration process, achieving a 100% declaration rate(Note 3).
3. Conduct annual reviews of smelter and refiner lists based on the latest RMI conformant smelters list to ensure continued compliance with international standards, regulatory requirements, and customer expectations.
4. Apply the Reasonable Country of Origin Inquiry (RCOI) process and reference the RMI’s list of conformant smelters or refiners (SORs) to trace mineral origins, identify countries of origin, and support risk assessment activities.
5. Management of conflict mineral use uncovered from supply chain: If not mandatory, Wistron will require suppliers to halt procurement of the conflict mineral in question and switch to RBA-compliant sources (non-conflict or recycled) and provide related evidence. If mandatory, Wistron will ask suppliers to propose a phase-out plan or improvement plans to gradually reduce risks.
6. Wistron has begun incorporating recycled minerals with equivalent material properties, including recycled copper, into certain products to gradually reduce reliance on virgin minerals that may pose conflict mineral risks. 

• Note : Since 2023, Wistron has labeled its product packaging with “CMRT-Free” to clearly demonstrate its commitment to not using conflict minerals; Signing rate of the “Declaration of Conflict Mineral-Free” excludes logistics providers.