2025 Hefei Boda Precision Technology Co., Ltd. Responsible Procurement Report

2025-06-23


2025 Hefei Boda Precision Technology Co., Ltd. Responsible Procurement Report

1. Company Information

Hefei Boda Precision Technology Co., Ltd. is a wholly-owned subsidiary of Suzhou Chunqiu Electronics Technology Co., Ltd. The project site is located at No. 186 Zhongtang Road, High-tech Zone, Lujiang County, Hefei City. The company started construction in August 2018, covering an area of more than 100 acres, with a total building area of 59,000 square meters, including 51,000 square meters of production buildings; dormitories, office buildings, and other auxiliary facilities cover 8,000 square meters. The total investment is 550 million RMB, with the construction scale as follows:

  1. Stamping workshop, annual output of 14 million sets of metal parts for notebook shells;
  2. Assembly workshop, annual assembly capacity of 9.8 to 10 million sets of shells.
  3. Supporting office areas and supporting equipment.

Main products: Metal products
Processing raw material: Aluminum sheet
The period covered by this report: May 1, 2025 to April 30, 2026.

2. Responsible Procurement Report Summary

In May 2023, the company conducted ISO9001:2015, ISO14001:2015, and ISO45001:2018 quality management system reviews. According to the management review team’s decision, Hefei Boda Precision Technology Co., Ltd. complies with the responsible procurement policy. This decision is valid for three years from the date of the decision. The company’s compliance status will be updated on the Suzhou Chunqiu official website.

3. Company Supply Chain Management Policy

The company has established a supply chain management policy that fully complies with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). It covers the OECD Guidance, has been reviewed by company management and approved by the general manager, and management is committed to supporting the implementation of this policy. This policy has been widely communicated to relevant stakeholders (suppliers, customers, employees, etc.).

4. Company Management System

The company has established the "Conflict Minerals Management Procedure" and "Sustainable Procurement Control Procedure," adhering to the commitments in the supply chain policy according to the company’s "Conflict-Free Minerals Declaration," and has developed the following

Internal due diligence processes:

— The company has established a Risk Assessment Committee under the system operation management leadership team. Procurement and quality personnel are responsible for regularly and irregularly evaluating identified suppliers and raw material-related information, determining the reasonableness of raw material sources (such as origin, capacity, type characteristics, etc.), evaluating the origin, transportation process, and suppliers according to warning signals, investigating any warning signals found, and issuing handling opinions.

— The company conducts annual due diligence management system training for key personnel in all relevant departments according to responsible mineral supply chain management requirements. If updates are planned, additional training will be conducted as needed. In 2024, the company communicated the latest supply chain policy and procurement requirements to all identified upstream suppliers. Due diligence requirements have been incorporated into legally binding agreements with suppliers. The company conducts annual factory audits of suppliers and includes due diligence requirements as part of the discussions.

5. Risk Identification (All Sources)

First, the company has a sound process to identify risks in the supply chain, including the resources used and criteria for determining "conflict-affected and high-risk" areas.

Second, in 2025, 190 supplier surveys were completed and returned. "Conflict Minerals Survey Form," "Extended Minerals Report" The company’s Raw Material Procurement Risk Assessment Committee conducted risk assessments on the supply chains involving tantalum, tin, gold, tungsten, cobalt, and mica raw materials, with a professional team managing risk control throughout the process. The risk assessment committee and procurement team reviewed the collected summary information and conducted risk assessments according to management requirements. The current supply chains procured by the company were carefully evaluated, and no warning signals were found during the reporting period.

Third, the company formed a professional team to conduct due diligence on the current supply chains and compiled due diligence reports for each supply chain.

Fourth, the company reviewed all collected information against the Dodd-Frank Act, sanction lists, local laws, and internal procurement requirements.

Fifth, according to "Supplier Management," the company completed the 2024 supplier management evaluation and assessment, established and improved the customer management list, required the provision of origin information for each contract, and ensured understanding of transaction sources, transportation routes, and the names and locations of direct suppliers.

Sixth, during the period covered by this report, the company did not receive any complaints from relevant parties (affected persons or whistleblowers).

6. Risk Mitigation (Only High-Risk Procurement )

Based on the high-risk supply chain assessment results, the company requires the raw material procurement department to promptly take the following risk mitigation measures for risk control:

1. Report the high-risk supply chain investigation and assessment results to senior management, explaining relevant information and actual and potential risks of the high-risk supply chain.

2. According to the company’s supply chain policy risk management strategy, develop and implement a risk management plan. Effective mitigation measures must be developed and implemented for existing risks, and agreements reached with suppliers and affected stakeholders. Risk reduction strategies include: continuing transactions throughout the measurable risk management process.

3. Continuously monitor risks and reassess when risk conditions change. No high-risk procurement has occurred since 2025. Cooperation with suppliers will be terminated if unacceptable.

7. Related Forms

"Conflict-Free Minerals Declaration," "Conflict Minerals Survey Form," "Extended Minerals Report."

 

Hefei Boda Precision Technology Co., Ltd. 2025 Responsible Procurement Report.pdf   

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