Responsible Mineral Sourcing
Good Way Technology is committed to maintaining a responsible global supply chain and ensuring that our sourcing practices do not directly or indirectly finance or benefit armed conflict or human rights abuses in the Democratic Republic of Congo (DRC) or its covered countries (CC).
Our Responsible Mineral Sourcing Strategy is based on internationally recognized standards and primarily focuses on the four conflict minerals: Tin, Tantalum, Tungsten, and Gold (3TG). In addition to 3TG, we also include Cobalt, Mica, Copper, Nickel, Graphite (natural), and Lithium within the scope of our responsible mineral sourcing.
Policy and Compliance
● Our Commitments:
1. Our company will not procure or use conflict minerals originating from mines in the DRC and its covered countries (also known as the adjoining countries of the DRC).
2. Our company is committed to conducting due diligence to ensure that the source of the metals used in procured raw materials complies with international regulations and recognized standards.
3. Our company requires suppliers to refuse the use of conflict minerals from conflict-affected and high-risk areas (CAHRAs) and to provide a commitment letter.
4. Our company will fully disclose the compliance status of the smelters and mines (SORs) used by us and our collaborating supply chain. We also require suppliers to cascade this requirement to their upstream suppliers.
Governing Framework
Our due diligence (DD) process strictly follows the five-step framework of the OECD Due Diligence Guidance and complies with the relevant regulatory requirements of the SEC (Dodd-Frank Section 1502) and the European Union Conflict Minerals Regulation.
Management Structure
The program is jointly led by the Group General Manager and the heads of Sustainability, Quality, and Procurement, ensuring the effective execution of the Responsible Mineral Sourcing program, as well as the openness and transparency of the process and results.
Annual Due Diligence Implementation Highlights
● Supply Chain Traceability:
- We conduct an annual survey of our suppliers and use the latest versions of the Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) published by the RMI to trace the source of the metals used in procured products.
- The goal is to achieve 100% identification and compliance assessment of the Smelters or Refiners (SORs) for the metals used in the supply chain.
● Risk Assessment and Response:
- Based on the RCOI (Reasonable Country of Origin Inquiry) results, we initiate due diligence through established cross-departmental standard operating procedures if there is reason to believe that some of the procured metals may originate from the DRC or CC.
- We are committed to the annual identification and auditing of SORs. For mineral resources of concern, we require suppliers to cease procurement and select non-conflict minerals that meet RBA requirements. If their use is essential, suppliers are required to present a removal plan or improvement measures.
● Reliance on Industry Standards:
- We actively utilize the RMI (Responsible Minerals Initiative) and its RMAP (Responsible Minerals Assurance Process).
- We prioritize requiring suppliers to use metal minerals produced by RMAP-certified SORs.
Performance
From Good Way’s RCOI and DD efforts we have identified as best possible all of the SOR’s in our supply chain and determined how many are conflict-free conformant. The below table indicates our overall progress trend and 2025 performance.
| GOODWAY Status | 2022 | 2023 | 2024 | 2025 |
| % Conformant | 100% | 100% | 100% | 100% |
| Conflict Mineral | Total Country | Total SOR | Conformant | % Conformant |
| Tantalum | 10 | 31 | 31 | 100 |
| Tin | 16 | 46 | 46 | 100 |
| Tungsten | 9 | 33 | 33 | 100 |
| Gold | 29 | 97 | 97 | 100 |
| Cobalt | 14 | 47 | 47 | 100 |
| Mica | 3 | 5 | 5 | 100 |
| Copper | 5 | 8 | 8 | 100 |
| Nickel | 9 | 20 | 20 | 100 |
| Overall | 95 | 287 | 287 | 100 |