Conflict Minerals Policy of
SP semiconductor & Communication Co., Ltd

Conflict minerals refer to tantalum, tungsten, tin, and gold originated in the Democratic Republic of the Congo and its adjoining countries (“Covered Countries”). There are concerns that the conflict minerals fund armed forces of the Covered Countries Causing many deaths of their own people and infringement of human rights in the course of mineral excavation such as forced labor and abuse of women and children. In response to these concerns, the United States Congress enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).

Section 1502 of the Dodd-Frank Act (“Conflict Minerals Rule”) requires manufacturing companies listed in U.S. stock exchange to disclose whether the products they manufacture or contract to manufacture contain conflict minerals

As a responsible corporate citizen,

SP Semiconductor & Communication Co., Ltd.’s policy is to eliminate the use of conflict minerals contained in our products that directly or indirectly finance or benefit armed groups in the Covered Countries.

In support of our Conflict Minerals Policy, SP Semiconductor & Communication Co., Ltd.




Will:

• Implement procedures compliant with and in support of the activities of the EICC-GeSI Conflict Free Sourcing Initiative and the OECD Due Diligence Guidance.

• Endeavor to trace the conflict minerals back to the source, at least to the smelter or refiner level through use of the EICC-GeSI Conflict Minerals Reporting Form(“Form”).

• Require our suppliers to submit the Form or otherwise verify in writing that all products supplied to SP Semiconductor & Communication Co.,Ltd. Do not contain conflict minerals from the Covered Countries that directly or indirectly finance or benefit armed groups in those Covered Countries.

SP Semiconductor & Communication Co., Ltd also requires our suppliers to familiarize themselves with the Conflict Minerals Rule and expects our suppliers to adhere to the Conflict Minerals Rule and SP Semiconductor & Communication Co., Ltd’s Conflict Minerals Policy to ensure alignment throughout their own supply chain.

SP Semiconductor & Communication Co., Ltd expects and will obligate our Suppliers to:




• Have a documented conflict mineral policy and procedures to ensure that all products supplied to SP Semiconductor & Communication Co., Ltd do not contain conflict minerals from the Covered Countries that directly or indirectly finance or benefit armed groups in those Covered Countries.

• Identify through reasonable efforts all smelters that supply conflict minerals in their supply chain

• Correct promptly any risk identified in their supply chain.

Should SP Semiconductor & Communication co., Ltd come to know or have reason to suspect that a supplier is procuring conflicts minerals from a Covered Country that directly or indirectly.

Finance or benefit armed groups in those Covered Countries, SP Semiconductor & Communication Co., Ltd will notify such supplier in writing and give the supplier reasonable time to cure the non-compliance and submit documentation showing the non-se of such conflicts minerals. If the supplier does not cure or cannot provide proper documentation evidencing a change in the sourcing of conflicts minerals, or is found to have provided false records or information at any time,

SP Semiconductor & Communication Co., Ltd may terminate its business with that supplier.

As a part of a commitment to corporate responsibility, SP Semiconductor & Communication Co., Ltd will voluntarily contribute to prevent violation of human rights in the Covered Countries through collaboration with our customers and suppliers. We will continue our efforts to source conflict-free minerals to achieve a conflict-free supply chain.