Responsible Mineral Management
To promote responsible and sustainable sourcing, Wistron has established a Conflict Minerals Policy and a Responsible Minerals Management Program. We conduct supply chain due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and other internationally recognized frameworks. Through supplier assessments and third-party verification mechanisms, Wistron encourages suppliers to source from smelters and refiners that meet responsible sourcing requirements, thereby helping to prevent the procurement of minerals that may directly or indirectly contribute to armed conflict, human rights abuses, or other significant risks.
Wistron requires suppliers to provide Conflict Minerals Reporting Templates (CMRTs) and other relevant declarations to disclose the sources and chain-of-custody information for gold (Au), tantalum (Ta), tungsten (W), tin (Sn), cobalt (Co), and mica. Supply chain due diligence and risk management activities are conducted in accordance with the OECD Guidance and relevant tools developed by the Responsible Minerals Initiative (RMI).
Conflict Minerals Management Organization
Wistron's Green Product Verification (GPV) team is responsible for conflict minerals due diligence, supplier guidance, and improvement activities. Compliance-related matters are handled by the Procurement function. Overall decision-making responsibility resides with the Vice President of Global Supply Chain Management and Procurement.
Complaint Mechanism
Conflict Minerals Complaint Mechanism: Stakeholders can express their concerns or report incidents related to conflict minerals through GSCM_Office@wistron.com.
Supplier Conflict Minerals Contract
Wistron Vendor Survey Procedure defines signing a "Conflict Minerals Declaration" as a necessary condition for new suppliers to become Wistron's qualified suppliers.
Conflict Minerals Management Process
Responsible Minerals Management
- Investigation (Identification of Smelters and Refiners)
Wistron collects supplier-submitted Conflict Minerals Reporting Templates (CMRTs) and Extended Minerals Reporting Templates (EMRTs) through its Supplier Questionnaire Platform (SQP) system. Relevant Responsible Minerals Initiative (RMI) resources, including CMRT/EMRT templates, Reasonable Country of Origin Inquiry (RCOI) information, and the RMI Conformant/Active Smelter & Refiner Lists, are used to identify smelters and refiners within the supply chain. - Audit (Due Diligence and Verification)
Wistron compares supplier-reported smelter and refiner information against third-party verification sources, including the RMI Conformant/Active Lists and RCOI data, to evaluate due diligence performance.
For smelters and refiners that are not included on the RMI Conformant/Active Lists, suppliers are required to provide further explanations and implement corrective actions. Such actions may include developing phased removal plans, transitioning to RMI Conformant/Active smelters and refiners, or evaluating alternative sources. Follow-up reviews are conducted through subsequent CMRT investigations to track progress and updated information.
Based on the annual assessment results, Wistron identified a total of 217 Conformant/Active smelters and refiners and 20 non-conformant smelters and refiners. Through ongoing follow-up and supplier engagement, all 20 non-conformant smelters and refiners were subsequently replaced by qualified sources.
- Tracking (Country of Origin Traceability System)
In accordance with the Wistron Responsible Minerals Sourcing Management Procedure, Wistron has established a mineral source traceability mechanism. Suppliers are required to submit CMRTs semi-annually, disclosing smelter/refiner names, Smelter IDs, and other relevant mineral information associated with the products supplied.
Based on supplier submissions, Wistron maintains a smelter and refiner database and cross-checks the information against the RMI Conformant Smelter & Refiner List and RCOI Data. Direct Sourcing information from the RCOI is used to identify the countries of origin of minerals processed by the reported smelters and refiners.
For smelters and refiners associated with Conflict-Affected and High-Risk Areas (CAHRAs), Wistron continuously monitors their RMI verification status and reviews and updates relevant RCOI information every six months to ensure the accuracy and traceability of mineral sourcing information.
According to the RCOI and SOR analysis conducted in November 2025, 34 of the 217 Conformant/Active smelters and refiners identified by Wistron were found to source minerals from CAHRAs. However, all of these smelters and refiners had successfully completed the RMI Responsible Minerals Assurance Process (RMAP) and were classified as Conformant. Their mineral sources covered 22 countries of origin.
- Mitigation (Risk Management Plan)
Wistron manages identified conflict minerals risks according to risk level and business requirements.
Where the use of a high-risk source is deemed non-essential, suppliers are required to discontinue procurement from such sources and transition to conflict-free or recycled sources that meet Responsible Business Alliance (RBA) requirements. Updated conflict minerals information must then be resubmitted for review.
Where the use of a source is considered necessary, suppliers are guided to develop removal plans, including phased timelines, alternative smelter/refiner options, and validation methods. Wistron monitors supplier progress on a semi-annual basis.
If no reasonable progress is demonstrated within one year, a Second Source mechanism will be initiated to reduce supply chain risk.
In 2025, Wistron identified 220 related suppliers (excluding distributors) associated with 20 non-conformant smelters and refiners. Following corrective guidance and continuous follow-up, all 220 suppliers successfully completed the removal of the identified non-conformant smelters and refiners.
- Alternative Sources (Investigation of Alternative Conflict-Free Sources)
In accordance with the Wistron Responsible Minerals Sourcing Management Procedure, Wistron conducts alternative source evaluations during supplier onboarding, material management, and supply chain risk assessment processes. These evaluations help enhance supply chain resilience, reduce mineral sourcing risks, and ensure the availability of appropriate alternative supply options for critical materials. The evaluation process includes regular reviews of mineral sources and smelter/refiner information, assessment of sourcing risks in both high-risk and lower-risk regions, supplier requests for alternative sourcing proposals, and verification that alternative sources meet relevant RMI requirements.
Alternative source investigations cover the following three areas:
- Smelter and Refiner Level
Suppliers are required to evaluate and propose alternative smelters and refiners that meet RMI requirements, as well as alternative mineral sources from lower-risk countries or regions. The compliance status and sourcing risks of such alternatives are assessed accordingly.
- Component Supply Level
Wistron evaluates whether qualified Second Source suppliers are capable of providing equivalent components and verifies that their mineral sources and associated smelter/refiner information meet company requirements. This approach strengthens supply chain flexibility and continuity.
- Raw Material Level
Wistron continuously collaborates with suppliers to evaluate alternative raw material solutions that can reduce dependence on minerals sourced from high-risk regions.
One example is the introduction of Recycled Copper. Through supplier evaluations and product reliability validation procedures, recycled copper has been successfully adopted in mass-produced notebook computer products as an alternative raw material solution.
This initiative not only helps reduce dependence on virgin mineral resources but also strengthens responsible minerals sourcing practices and mitigates risks associated with minerals originating from Conflict-Affected and High-Risk Areas .
Methodology and Results for Assessing Revenue from Products Containing Minerals from Conflict-Affected and High-Risk Areas
As components subject to conflict minerals management, such as active and passive electronic components, printed circuit boards (PCBs), and cables, are widely used across the Company's various electronic products, all product revenue is considered within the scope of conflict minerals risk management.
Wistron conducts supply chain due diligence and risk management through supplier Conflict Minerals Reporting Templates (CMRTs) and the RMI Conformant Smelter & Refiner List, and evaluates the relevant indicators based on the results of its supplier surveys and assessments.
- As components subject to conflict minerals management are widely used across the Company's various electronic products, revenue from products containing minerals originating from Conflict-Affected and High-Risk Areas (CAHRAs) covers the Company's entire product portfolio (100%)
- Wistron collects relevant information through supplier Conflict Minerals Reporting Templates (CMRTs) and reviews supplier-reported smelter and refiner information against the RMI Conformant Smelter & Refiner List. Based on the assessment results, 87% of suppliers complied with Wistron's conflict minerals management requirements.
