ZTE Corporation Conflict Minerals Report 2020/21
ZTE Corporation Conflict Minerals Report 2019/20
Policy on Conflict Minerals Management
ZTE abides by the United Nations Global Compact and other universally accepted international conventions and
practices, including the United Nations Global Compact, Due Diligence Guidance for Responsible Supply Chains
of Minerals from Conflict-Affected and High-Risk Areas of the Organization for Economic Cooperation and
Development (OECD), and the Responsible Mineral Initiative (RMI), respects human rights and the environment,
and strives to ensure that all product materials are properly sourced. Moreover, ZTE has released the Policy
on Conflict Minerals Management and Regulations on Conflict Minerals Management Regulations, specifying the
requirements for suppliers in terms of mineral exploitation, transportation, processing, trading,
processing, smelting, and export. We tolerate no activities which may aggregate conflicts, result in severe
environmental deterioration or violate human rights, and never profit from these activities or provide
assistance in any way. We prohibit the violations of human rights in relation to mineral mining,
transportation, or trading, and prohibit direct or indirect support to non-government armed groups or
security forces illegally controlling mining sites, transport routes, and/or trading sites.
In 2011, ZTE joined the Global e-Sustainability Initiative (GeSI), rejecting materials that directly or
indirectly caused conflicts. ZTE requires that all relevant suppliers (including component suppliers,
parts suppliers, or logistics suppliers of items containing tin, tantalum, tungsten, and/or gold must
guarantee that all materials come from environmentally and socially responsible sources. Each newly
accepted qualified supplier needs to submit a Conflict Minerals Reporting Template (CMRT) and a Extended
Minerals Reporting Template (EMRT) during their initial application, and each qualified supplier must sign
the Declaration of Compliance Management on Conflict Minerals. We conduct conflict minerals investigations
on our material suppliers each year.
ZTE is entitled to request suppliers to provide evidence for their material sourcing. To this end,
suppliers need to formulate and implement conflict mineral policies within their internal management
systems. Such policies shall contain a statement of compliance with applicable laws and regulations and a
commitment to the responsible purchasing of relevant materials. Suppliers also need to communicate with
upstream suppliers and to work together to ensure that the relevant materials can at least be traced back
to their smelting plants, so as to confirm that the purchased metals are from non-conflict-minerals
smelting plants.
Management Objectives and Commitments
Short-term objectives:
1.Integrate minerals management into internal and external IT platforms to increase efficiency and management effectiveness;
2.Expand the scope of conflict minerals management and improve suppliers' response rate in surveys of newly-added minerals;
3.Enhance the on-site task forces to improve the accuracy and credibility of on-site audits and inspections;
4.Provide training for audits and inspectors in these on-site task forces to improve their efficiency and professional capabilities;
5.Design and provide more training programs for suppliers to raise their awareness and enhance their conflict minerals management capabilities;
6.Actively work with upstream and downstream suppliers to improve partnerships and mitigate potential risks related to conflict minerals; participate in international conferences on conflict minerals to expand industry influence and contribute to more international initiatives;
7.Continuously improve our conflict minerals management capabilities to meet customer requirements and exceed the industry average;
8.Continue requiring suppliers to submit CMRT/EMRT responses and maintain the current 100% response rate;
9.Verify suppliers' due diligence and make this process part of the supplier assessment workflow.
Medium and long-term objectives:
1.Actively partner with upstream suppliers and SORs, support suppliers in obtaining third-party certifications, and participate in industry initiatives related to conflict minerals;
2.Collaborate with suppliers, stakeholders, and industry peers to further improve awareness and due diligence capabilities related to conflict minerals;
3.Establish and strengthen the management structure based on international requirements and standards for ESG rating;
4.Ensure steady improvements in conflict minerals management internally and externally;
5.Expand the audit scope to include more types of critical minerals from downstream and upstream suppliers, draw a more comprehensive supply chain map, and increase the transparency of the supply chain risks for both cobalt and other minerals;
6.Continuously optimize the conflict minerals management module of the GPM system to achieve 100% digitalization of conflict minerals surveys by 2030;
7.Continue to track updates to the responsible minerals management scope, and maintain 100% coverage of RMI-covered minerals.
Supply Chain Due Diligence
ZTE supports and accepts smelters certified by the Responsible Mineral Guarantee Program (RMAP). That is,
they will be qualified smelters recognized by ZTE as long as they have been certified by RMAP. In 2019, ZTE
formulated its Due Diligence Guidelines in reference to OCED's principles, and established third-party audit
procedures and tools. We promote suppliers to improve their own mineral tracking system. We conduct spot
checks on high-risk suppliers to evaluate the rationality and effectiveness of their mineral procurement
practices. According to ZTE's policy, ZTE shall terminate its contract(s) with a supplier who fails to
accept necessary third-party audit, rejects rectifications, or refuses to cooperate in rectifications.
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