September 15, 2023
USI Supply Chain Policy for Responsible Sourcing of Minerals from Conflict-Affected and HighRisk Areas
Universal Scientific Industrial (Shanghai) Co., Ltd. and all its affiliates (hereafter collectively referredto as “USI”) provide a board range of electronic manufacturing services for brand customers globallyby offering diversified products in the sectors of wireless communication, computer, and storage,
consumer, industrial, medical, and automotive electronics. Through these services, USI acquires
numerous electronic and non-electronic components through levels of upstream suppliers andassemble them into sub-assemblies and finished good products. USI recognizes that the mining anddistribution of certain minerals originating from regions around the globe can inadvertently fundviolent organizations and contribute to various forms of human rights violations. These violations
can include forms of torture, cruel, inhuman and degrading treatment, forced or compulsory labor,
the worst forms of child labor, gross human rights violations such as widespread sexual violence,
war crimes or other serious violations of international humanitarian law, crimes against humanityor genocide. The minerals concerned include, but are not limited to, gold, tin, tantalum, tungsten,cobalt, and mica.
Our commitment is to ensure ethical sourcing of these minerals, irrespective of the geographic
region, with the aim of mitigating these negative impacts. We expect our suppliers to source theseminerals from smelters or refineries that have been certified by an independent third-party audit
program, thus aligning with our objective. We endeavor to support responsible mining practices
globally, promoting the human rights, health, and environment for workers in material production
areas.
USI commits a policy on responsible sourcing of minerals based on the five-step framework for riskbased due diligence in the minerals supply chains, published by the OECD Due Diligence Guidancefor Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, asrepresenting a common reference for conflict-sensitive sourcing practices and suppliers’ risk
awareness from the point of extraction until end user. We commit to refrain from any action which
contributes to the financing of conflict and we commit to complying with the relevant UnitedNations Sanction Resolutions or, where applicable, domestic laws implementing such resolutions.
Regarding Serious Abuses Associated with the Extraction, Transport, or Trade of Minerals:
While sourcing from, or operating in, conflict-affected and high-risk areas, USI will neither tolerate
nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:i) any forms of torture, cruel, inhuman and degrading treatment;ii) any forms of forced or compulsory labor, 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;iii) the worst forms of child labor;iv) other gross human rights violations and abuses such as widespread sexual violence;v) war crimes or other serious violations of international humanitarian law, crimes against
humanity or genocide.
Commitment Against Serious Abuses:
USI strictly prohibits and condemns any involvement in the above abuses. Should we identify a riskof involvement in any of these abuses, we will suspend or discontinue business engagement withthe concerned supplier.
Commitment Against Support to Non-State Armed Groups:
USI will not tolerate any direct or indirect support to non-state armed groups through the extraction,transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed
groups through the extraction, transport, trade, handling or export of minerals includes, but is not
limited to, procuring minerals from, making payments to or otherwise providing logistical assistanceor equipment to, non-state armed groups or their affiliates who:i) illegally control mine sites or otherwise control transportation routes, points where minerals
are traded and upstream actors in the supply chain; and/orii) illegally tax or extort money or minerals at points of access to mine sites, along transportationroutes or at points where minerals are traded; and/oriii) illegally tax or extort intermediaries, export companies or international traders.
Commitment Regarding Public or Private Security Forces:
USI emphasizes that the role of public or private security forces should solely be to maintain the ruleof law, human rights, and genuine security requirements. Any involvement of these forces in illegal
activities associated with the mineral supply chain is unacceptable.
We commit to engaging with security forces in alignment with the Voluntary Principles on Security
and Human Rights, ensuring no hiring of units or individuals known for gross human rights abuses.
Additionally, USI will engage with local authorities and relevant bodies to improve transparency andaccountability in payments to public security forces. We commit to minimizing the exposure ofvulnerable groups, such as artisanal miners, to adverse impacts due to the presence of securityforces.
Regarding bribery and fraudulent misrepresentation of the origin of minerals:
USI will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes toconceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid togovernments for the purposes of mineral extraction, trade, handling, transport and export.

Regarding money laundering:
USI will support efforts, or take steps, to contribute to the effective elimination of money laundering
where we identify a reasonable risk of money-laundering resulting from, or connected to, theextraction, trade, handling, transport or export of minerals derived from the illegal taxation orextortion of minerals at points of access to mine sites, along transportation routes or at points
where minerals are traded by upstream suppliers.
Regarding the payment of taxes, fees and royalties due to governments:
USI will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export fromconflict-affected and high-risk areas are paid to governments and, in accordance with the company’s
position in the supply chain, we commit to disclose such payments in accordance with the principles
set forth under the Extractive Industry Transparency Initiative (EITI).
Mitigation Plan for Risks and Violations in the Supply Chain
1. Identification of Risks: USI commits to a rigorous monitoring system that periodically reviews
the supply chain for potential risks and breaches of our policy.
2. Supplier Engagement and Training: Engage with suppliers when a risk is identified, providingthem with training and resources to address the issues.
3. Implementation of Immediate Corrective Actions: Propose and implement immediate corrective
actions based on the gravity of the identified risk.
4. Timeline for Corrective Measures: Establish a timeline for suppliers to address identified risks.
5. Re-evaluation and Assessment: Conduct a re-assessment after the corrective measures areimplemented.
6. Disengagement Protocol: If a supplier fails to address the risks in the specified timeline, USI willsuspend or discontinue business engagement with them.
7. Stakeholder Engagement and Collaboration: Collaborate with relevant stakeholders to refineand strengthen the mitigation process.
8. Periodic Review and Improvement: Periodically review and refine the mitigation plan based onreal-world experiences.
9. Reporting: Transparently disclose findings, actions taken, and progress to all relevant
stakeholders, adhering to the principles of the Extractive Industry Transparency Initiative (EITI).
By implementing this policy, we aim to uphold human rights, deter financial support to conflict,and establish a responsible and ethical minerals supply chain.