Conflict Minerals Management

To ensure that minerals used in Compal products—including tantalum (Ta), tin (Sn), tungsten (W), gold (Au), cobalt (Co), and mica—comply with conflict-free mineral standards, Compal continuously strengthens responsible minerals management practices. In response to updates from the Responsible Minerals Initiative (RMI) and evolving international regulations, including the EU Battery Regulation, Compal expanded the scope of due diligence in 2025 by incorporating additional minerals covered under the Extended Minerals Reporting Template (EMRT), including copper (Cu), natural graphite, lithium (Li), and nickel (Ni). To address specific customer requirements, Compal also conducted pilot surveys using the Additional Minerals Reporting Template (AMRT) for selected suppliers to further enhance transparency regarding additional minerals within the supply chain.

In accordance with the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,” Compal has established a due diligence management framework. Internally, the Company has implemented a Supplier Conflict Minerals Management Procedure to proactively investigate the sources of minerals and smelters, and has published its Conflict Minerals Policy. In addition, suppliers are required to sign “Non-use Of Conflict Minerals Commitment Letter”. Through the investigation process, Compal works closely with internal stakeholders and suppliers to assess the necessity of using conflict minerals. Where appropriate, suppliers are required to gradually reduce, replace, or eliminate the use of conflict minerals, seek alternative mineral sources, and prioritize minerals sourced from regions that are not classified as high-risk areas.

In 2025, Compal conducted conflict minerals surveys covering 749 suppliers using the Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) issued by the RMI, achieving a 100% response rate. The Company thoroughly reviewed information provided by suppliers, including mineral types, smelter names, and countries of origin, to monitor and manage mineral sourcing throughout the supply chain. Following completion of the survey process, Compal continues to monitor updates published by the Responsible Minerals Initiative (RMI), including information from the RMI Public List, smelter operating status, and international regulatory developments, while maintaining ongoing communication with suppliers. Updated RMI information is promptly communicated through the conflict minerals survey system. Compal ensures that suppliers source minerals in compliance with RMI requirements and meet customer and regulatory expectations by avoiding metals originating from areas affected by armed conflict or controlled by armed groups. The Company also encourages suppliers to source from conflict-free smelters validated through the Responsible Minerals Assurance Process (RMAP) or other equivalent independent third-party audit programs and to provide relevant verification documentation. Through these measures, Compal seeks to ensure that products are manufactured using responsibly sourced, conflict-free minerals and to further strengthen the security and sustainability of its mineral supply chain.

 Conflict Minerals Management Procedure

 

1. No sourcing of conflict minerals from conflict areas.
2. Formulation of Conflict Minerals Policy with suppliers strongly urged not to use the Conflict Minerals either directly or indirectly in the raw materials they supply.
3. Expect suppliers to fully use approved smelters or require existing smelters to verify that they will take necessary measures to stop using the conflict minerals if they are found to have conflict minerals in their products.

For more information, please refer to the Compal Conflict Minerals Policy: