Conflict Minerals Compliance
To prevent the unintentional use of any conflict mineral such as tantalum, tin, tungsten and gold (3TG) from the Democratic Republic of the Congo and its neighboring countries, we have established the ASEH Corporate Policy for Sourcing Conflict Minerals, joined the Responsible Minerals Initiative (RMI), and participated in the RMI Mineral Reporting Templates (MRT) Teams and Due Diligence (DD) Practices Team to resolve conflict minerals issues in the supply chain and support responsible sourcing.
ASE Technology Holding Co., Ltd. Corporate Policy for Sourcing Conflict Minerals
The mining and distribution of “conflict minerals”* originating from the Democratic Republic of the Congo (the “DRC”) are sometimes controlled by violent organizations in order to fund conflict in that country and adjacent regions. Our industry supply chains are inadvertently subject to metals derived from these conflict minerals which can be introduced through the metals we use such as gold, tin, tantalum and tungsten. ASE Technology Holding Co., Ltd. and its subsidiaries (collectively, “ASE Technology Holding”) is dedicated to the elimination of these conflict minerals in our supply chain and to using only responsibly sourced “conflict-free minerals”*. We expect our suppliers to source conflict-free minerals from smelters or refineries that have been certified by an independent third party audit program to fulfill our objective. It is also our objective to support the continued use of conflict-free minerals from the DRC and its adjacent regions such that responsible mining* is not diminished. We exercise due diligence with our suppliers on the origin and supply chain of minerals in accordance with the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” to establish conflict minerals management mechanism.
To protect the human rights, health and environment for workers in the material production areas, we commit to widening the scope of investigation and information disclosure; in addition to gold, tin, tantalum and tungsten, more minerals (such as cobalt and mica) will be included gradually from conflict-affected and high-risk areas (“CAHRAs”) in accordance with the Responsible Minerals Initiative (“RMI”) standards. ASE Technology Holding requires suppliers must support this policy by the following guidelines and widen their scope of investigations and disclosures to continuously strengthen our responsible sourcing programs.
- Being diligent in their assessment and validation of their supply chains to ensure ASE Technology Holding’s objectives of a transparent supply chain and conflict-free purchases are inputs to the services and products we produce.
- Be in compliance at all times with all regional and international regulations for conflict minerals.
- Be in compliance at all times with industry standards for the sourcing and reporting of conflict minerals.
- Being diligent and accurate in their formal assurances of conflict-free minerals provided to us.
Conflict Minerals Management Approach
Conflict Mineral Requirement
ASEH communicates conflict mineral policies to our suppliers through our website. The suppliers are required to comply with ASEH Corporate Policy for Sourcing Conflict Minerals and establish their own conflict minerals policies and to their own suppliers. We also require our suppliers to actively assess and validate their supply chain, and encourage them to source minerals from Smelters or Refiners (SoRs) that have received "conflict-free" designations by the Responsible Minerals Assurance Process (RMAP), or other independent third party audit program.
Reasonable Country of Origin Inquiry (RCOI)
Each year, ASEH performs RCOI to identify and validate the sources of 3TG in our packaging and material services and electronic manufacturing services and products, and whether they come from conflict-affected regions.
Our RCOI includes two steps:
- Identify sources of 3TG SoRs through CMRT by conducting supplier survey.
- Suppliers are asked to sign the Representation Letters of compliance with ASEH Corporate Policy for Sourcing Conflict Minerals and to fully reveal the source of the SoRs they sourced from.
In 2021, we have identified 269 SoRs from more than 600 suppliers. According to the supplier survey we conducted in 2021, 100% of our suppliers are compliant with ASEH's requirement for sourcing DRC conflict-free minerals. In addition to 3TG, we have expanded the scope of the investigation by conducting proactively the supply chain survey for Cobalt and Mica since 2018 and 2021 respectively, and disclosed the source of smelters to our customers. In 2021, 105 suppliers used cobalt from 77 smelters, and no suppliers used mica.
Due Diligence (DD)
ASEH designed its DD measures to conform to the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance") and we also adopted the OECD Guidance to not only identify/assess supplier risks and mitigate these identified risks, but also to design a conflict minerals audit form for ASEH's suppliers. We were therefore able to provide guidance through both on-site/off-site audits to help suppliers set up management mechanisms that complied with OECD Guidance.
Independent Private Sector Audit (IPSA) and Public Disclosure
We undertake an IPSA on our Conflict Minerals Report and DD procedure to ensure they are in compliance with the requirements set forth by the U.S. Securities and Exchange Commission (SEC). Each year, the Conflict Minerals Report is also disclosed publicly.
Conflict Mineral Contact:
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