（This policy is published in Chinese and English; where inconsistencies arise between the two, the Chinese version shall govern.）
JCHX Mining Management Co., Ltd. (hereinafter referred to as "JCHX" or the "Company") has always valued long-term and stable cooperative relationships with its suppliers. Throughout the entire process of supplier qualification and collaboration, the Company has established and continuously improved a supplier code of conduct system. This system focuses on key dimensions such as legal compliance, safety management, environmental and occupational health systems, and anti-corruption compliance to conduct multi-dimensional evaluations of suppliers. Ultimately, JCHX selects high-quality suppliers that align with its values and meet its requirements to establish long-term strategic partnerships.
The Company strictly implements a supplier admission review mechanism: through multiple methods such as document reviews, queries in local authoritative business and industry information systems, and on-site inspections, it comprehensively verifies suppliers' compliance records in areas such as business ethics, safety production, and environmental protection. This prevents suppliers with illegal or non-compliant behaviors from entering the supplier database at the source. All approved suppliers must strictly comply with anti-corruption laws and regulations in their respective countries (regions). If any violations are discovered during the cooperation, the company will immediately terminate the partnership and add the supplier to a "blacklist," thereby effectively safeguarding the compliance and stability of the supply chain.
To fulfill the above commitments, we will implement the following policies:
1. The Company clearly stipulates the following integrity requirements in contracts, declaring its stance on ethical procurement to suppliers, as detailed below:
If the Seller engages in any corrupt or fraudulent practices during the competition for and execution of this Contract, the Purchaser may, by providing written notice to the Seller, terminate this Contract in whole or in part and shall have the right to claim compensation from the Seller for all losses suffered as a result. For this purpose, the following terms are defined: (1) "Corrupt Practice" means the offering, giving, receiving, or soliciting, directly or indirectly, of anything of value to influence the procurement process or the execution of the Contract. (2) "Fraudulent Practice" means a misrepresentation or omission of facts in order to influence the procurement process or the execution of the Contract to the detriment of the Purchaser.
Meanwhile, to prevent corruption at the source, we have established strict systems such as the "Anti-Fraud and Anti-Commercial Bribery Management Policy" and the "Disciplinary Inspection and Supervision Work Policy." These policies clearly stipulate measures for penalizing corruption and set forth requirements for both employees and cooperative suppliers regarding anti-corruption practices.
2. The Company stipulates in the "Supplier Management Measures" that suppliers capable of providing new products, energy-saving and environmentally friendly products, or products with independent intellectual property rights recognized by relevant state authorities or the company shall be granted priority access. Additionally, suppliers that can provide certifications, qualifications, or credentials issued by national, local, or relevant authorities in the location where the equipment and materials are to be used shall also be granted priority access.
Scope of Application
As a public programmatic document, this policy applies to all members (including board members and senior management personnel) of the Company and its subsidiaries (with operational control), and requires relevant suppliers, partners, and their long-term/temporary employees providing services to JCHX to strictly implement it. Additionally, the scope of the policy extends to all operating entities under the Company and its subsidiaries (with operational control), specifically covering mining service project departments/project companies, resource project companies, other business sector’s operating units, etc.
Regarding associated and joint venture enterprises, the Company will actively promote the alignment of their policies and practices with the requirements of these guidelines through the exercise of shareholder/board rights, ensuring that their policy orientation and practical operations comply with the core principles advocated by this policy.
JCHX Mining Management Co., Ltd.
October 29, 2025
