Sinotruk (Hong Kong) Limited
Sustainable Raw Materials Policy
1.Purpose
The purpose of this Sustainable Raw Materials Policy established by Sinotruk (Hong Kong) Limited (now referred to as 'the Group,' 'Group,' 'Sinotruk,' or 'we') is to purchase raw materials in a sustainable and responsible manner, implementing sustainable raw materials management activities in the process of vehicle manufacturing, supply chain management and other business processes.
2.Applicability
This Policy applies to all employees and contractors of the Group, including SINOTRUK's subsidiaries, wholly-owned subsidiaries, branches and affiliates, as well as organizations and individuals, contractors and other external employees who are assigned to work or serve on behalf of SINOTRUK..
3. Philosophy, Guidelines, and Principles
Sinotruk attaches great importance to the environmental and human rights risks that may arise from high-risk key raw materials, including conflict minerals, and strictly complies with the relevant laws, regulations and regulatory requirements of raw material procurement at home and abroad. With reference to the United Nations Sustainable Development Goals (UNSDGs) and the Group's raw material management strategy, the Group has established and continuously improved a sustainable raw material management system in line with internationally accepted standards.
4. Management Activities Policy
The Group promotes the sustainability of the whole process of raw material procurement through institutionalized management.
4.1 Principles of sustainable raw material procurement
4.1.1 Systematically incorporate sustainability requirements into procurement standards, product design and technological innovation, and strive to reduce the negative environmental and social impacts of raw material use.
4.1.2 Give priority to the use of raw materials certified for sustainability by third parties or from recycling to ensure that the materials meet ethical standards and effectively reduce waste generation.
4.2 Vendor Management
4.2.1 Regularly assess and analyze the environmental and human rights risks of key raw material suppliers, implement prevention and mitigation measures, and improve the transparency and traceability of the supply chain through supplier cooperation to ensure the responsible exploitation and use of key raw materials.
4.3 Traceability and risk control
4.3.1 Establish a traceability mechanism for raw materials to avoid the use of raw materials originating from globally or nationally important biodiversity sensitive areas.
4.4 Conflict minerals
4.4.1 Conflict Minerals Management
The Group undertakes to exclude products, components or raw materials containing conflict minerals (3TG: tin, tantalum, tungsten, gold) and extension minerals (cobalt, lithium, nickel, mica, etc.) in the supply chain, ensure that there are no human rights violations, environmental damage or financing of armed conflicts in the process of raw material mining and trading, and prohibit the flow of procurement funds to areas of armed conflict. The Group is committed to establishing a traceability mechanism covering the whole chain from smelters to terminal products, requiring suppliers to provide raw ore mining coordinates, transaction records and labor rights and interests protection certificates verified by third parties, and eliminating forced labor, ecological damage and commercial bribery.
4.4.2 Risk identification
The Group has established a risk management mechanism at the smelter, refinery (SOR) and supplier levels to promote technological upgrading to gradually reduce, replace or eliminate high-risk raw materials, thereby mitigating or eliminating raw material risks originating in conflict-affected areas and high-risk areas.
Suppliers shall ensure that they and their upstream suppliers comply with the Company's Conflict Minerals Policy and shall establish a supply chain due diligence system based on the OECD Guidelines for Responsible Supply Chain Due Diligence of Minerals from Conflict-Affected and High Risk Areas (the 'OECD Guidelines') and submit a Responsible Minerals Report to the Group.
Suppliers are required to provide complete supply chain information of 3TG and extended minerals in the product, including: smelter/refinery (SOR) name, geographical location of mineral source area, logistics path and broker list. The Group will verify the authenticity, completeness and consistency of data submitted by suppliers to ensure that the information provided by suppliers is credible. Suppliers shall coordinate the implementation of the Group's processes related to responsible procurement and traceability of key materials, including questionnaire evaluation, audit verification and other traceability mechanisms.
4.4.3 Risk response
Suppliers are required to immediately report to the Company and suspend supply of minerals from conflict-affected or high-risk areas as defined by OECD.
Suppliers should develop a high-risk mineral substitution plan, and for smelting plants or mineral sources that fail to pass the audit, suppliers must complete the rectification or replacement within 6 months, otherwise the cooperation will be terminated.
4.5 Industry collaboration
4.5.1 Actively participate in industry exchanges and cooperation, promote the sharing of experience and best practices, and jointly improve the overall level of sustainable raw material management in the industry.
5. Conclusion
This policy is approved by the board/senior management of Sinotruk. Legal systems vary from country to country, and in the event of any inconsistency between this policy and local laws and regulations, the more stringent requirements and local laws and regulations shall prevail. The Company will review this policy on a regular basis and make corresponding amendments to adapt to changes in laws and regulations or the Company's development.
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