This policy is applicable to all organizations of Jinhua Jinzhong welding materials Co., Ltd. (hereinafter referred to as "Jinzhong company") in order to achieve the goal of establishing a responsible mineral procurement and supply chain of Jinzhong company.

In order to reflect the values in the ethical program of Admiralty, Admiralty affirms that it aims to curb support for disputes, serious human rights violations or environmental pollution, minerals originating in disputed areas and high-risk areas, and sustainable and responsible mineral procurement.

This policy is adopted by Admiralty to operate a responsible supply chain.

Admiralty recognizes that in order to establish a responsible supply chain, it is an ongoing process to investigate mineral procurement from disputed areas and high-risk areas. Therefore, Admiralty will make its best efforts to ensure sustainable and responsible minerals in the supply chain to the extent commercially reasonable.

In order to achieve this goal, Admiralty will formulate investigation procedures for mineral procurement. Admiralty expects its suppliers to responsibly identify the sources of all imported materials, including minerals.

Admiralty will convey to the supplier TDK group's requirements for the supplier to conduct reasonable investigation on its own mineral supply chain from disputed areas and high-risk areas. Admiralty will include its supply chain policies and investigation procedures in applicable and monitored business contracts, written agreements and supplier evaluation signed with suppliers, including sampling inspection of suppliers and obtaining their documents without prior notice when deemed necessary.

In order to ensure that the products or raw materials sold by suppliers to Admiralty do not contain disputes, serious human rights violations or environmental pollution, Admiralty will cooperate with its suppliers to implement reasonable management in the supply chain to track the sources of minerals from disputed areas and high-risk areas. In addition, if Admiralty finds that suppliers do not comply with their supply chain policies and investigation procedures, the first step will be to work with them to make them comply by correcting the action plan. Admiralty will not cooperate with suppliers who do not meet their standards.

Achieving full traceability of minerals requires time, the efforts of all in the industry and the cooperation of all stages of the supply chain. This is mainly because the manufacturing and marketing methods of metals are very complex and ores from many different origins can be mixed. Therefore, the efforts required for product tracking and investigation are increased. All this is further complicated by the activities of local geopolitical forces. These reasons make the cooperation of industry scale the most important factor to realize the responsible source identification of the whole society. Admiralty strongly encourages its suppliers to comply with the existing international framework for responsible mineral procurement.

Admiralty is committed to achieving a responsible mineral supply chain from disputed areas and high-risk areas. Therefore, Admiralty is trying to implement a set of systems and procedures to convince us that the suppliers cooperating with Admiralty are responsible suppliers.

Jinhua Jinzhong Welding Material Co., Ltd

Formulated on April 27, 2018

Revised on November 29, 2021 (2nd Edition)