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.

Click to download: Policy on Conflict Minerals Management

1.Integrate minerals management in internal and external IT platforms to increase our efficiency and management effectiveness in this regard;
2.Expand the scope of conflict minerals management, strengthen the building of on-site task forces, and improve the accuracy and credibility of on-site audits and inspections;
3.Provide training for the auditors and inspectors of on-site task forces to enhance their efficiency and capabilities;
4.Design and provide more training programs for suppliers to raise their awareness and enhance their capabilities of conflict minerals management;
5.Actively cooperate with suppliers to improve partnerships and mitigate potential risks related to conflict minerals; attend more international conventions on conflict minerals to improve our influence in the industry and contribute to the conflict minerals management of more international organizations;
6.Continuously improve our capabilities of conflict minerals management to meet customer requirements and excel in the industry;
7.Collect the CMRT/EMRT from suppliers and maintain a 100% response rate;
8.Ensure that all qualified suppliers sign the Declaration of Metal Conflict-Free;
9.Verify suppliers' due diligence and make the verification a part of the overall supplier assessments.

1.Actively cooperate with the upstream suppliers and SORs, provide support for suppliers to obtain third-party certifications, and participate in industry initiatives related to conflict minerals;
2.By 2025, more than 95% of 3TG SORs shall pass the independent third-party certification such as the RMAP;
3.By 2025, at least 80% of cobalt SORs shall pass the independent third-party certification such as the RMAP;
4.Collaborate with suppliers, stakeholders, and industry peers to further improve awareness and due diligence capabilities related to conflict minerals;
5.Establish and strengthen the management structure based on the international requirements and standards for ESG rating;
6.Ensure steady improvements on conflict mineral management internally and externally;
7.Expand the audit scope to more types of critical minerals from downstream and upstream suppliers, draw a more comprehensive supply chain map, and improve the transparency of the supply chain risks of both cobalt and other minerals.

As a member of RBA, 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.

Effective management of conflict minerals requires deep participation and joint promotion of all value chain partners. ZTE regularly communicates with our suppliers to confirm the progresses of conflict minerals issues and ensure that all partners have deeper and more comprehensive understandings on conflict minerals related issues. In 2020, ZTE held numbers of supplier meetings through supplier camps, supplier special topic seminars and more; ZTE studied and discussed with more than 200 suppliers on conflict mineral issues. The 2021 Training camp for High-risk Suppliers of Conflict Minerals had been postponed to May 21 due to the impacts of COVID-19. A total of 87 suppliers participated in the special training session to discuss with ZTE on how to improve their management capacity and supply chain traceability. In order to accommodate suppliers that were unable to attend the meeting due to COVID-19, ZTE provided the suppliers an option to learn online, we also uploaded the training materials of conflict minerals for suppliers to ZTE Supply Chain website and informed the suppliers to download and learn. In 2021, we were invited by GeSI to become a member of RMI. We actively participated in RMI regular meetings and exchanged views with other RMI members on conflict mineral management issues. We also worked with RCS Global to conduct systematic due diligence in the middle and downstream of ZTE cobalt supply chain. At the same time, we also keep close contact with CCCMC and other national organizations, actively participate in seminars and seize the industry trends.