Conflict Minerals Policy

1. Conflict Minerals Policy Overview

This Conflict Minerals Policy outlines how Sucatec Pte Ltd approaches responsible sourcing and supply chain due diligence relating to conflict minerals.

Sucatec Pte Ltd recognises the importance of responsible procurement and is committed to supporting ethical sourcing practices across its supply chain.

2. Scope of Conflict Minerals Policy

Conflict minerals generally refer to minerals that may originate from conflict-affected or high-risk areas and may contribute to armed conflict, human rights abuses or unethical trading practices.

This policy applies to minerals commonly referred to as 3TG:

• Tin
• Tantalum
• Tungsten
• Gold

3. Responsible Sourcing Commitment

Sucatec Pte Ltd is committed to supporting responsible sourcing practices and avoiding the knowing supply of products containing conflict minerals that directly or indirectly finance conflict or serious human rights abuses.

We support this commitment through:

• Supplier engagement and supplier declarations
• Reasonable due diligence based on available supply chain information
• Review of material and product compliance documentation where required
• Escalation of concerns relating to mineral origin or supplier transparency

4. Supplier Due Diligence

Sucatec Pte Ltd does not normally manufacture raw materials directly and therefore relies on information provided by manufacturers, distributors and suppliers within the supply chain.

Where applicable, suppliers may be requested to provide:

• Conflict minerals declarations
• Material origin information
• Smelter or refiner information where available
• Completed conflict minerals reporting templates where required by customers
• Supporting documentation for customer or regulatory due diligence

5. Supply Chain Transparency

Sucatec Pte Ltd works to improve supply chain transparency where conflict minerals may be relevant to supplied products.

This includes:

• Maintaining supplier compliance records where available
• Requesting updated declarations from suppliers when required
• Reviewing supplier responses for completeness and consistency
• Supporting customer requests for product-level conflict minerals information where practical

6. Customer Responsibility

Customers are responsible for confirming whether conflict minerals reporting requirements apply to their specific products, applications, markets or regulatory obligations.

Sucatec Pte Ltd will support reasonable requests for supplier declarations and available compliance information, but final application and regulatory responsibility remains with the customer.

7. Risk Management and Escalation

Where a concern is identified relating to the sourcing of conflict minerals, Sucatec Pte Ltd may take appropriate action depending on the risk and available information.

This may include:

• Requesting clarification or updated declarations from suppliers
• Reviewing alternative sourcing options
• Escalating the issue within supplier qualification processes
• Restricting or discontinuing supply from suppliers who fail to support responsible sourcing expectations

8. Documentation and Record Keeping

Sucatec Pte Ltd maintains conflict minerals documentation where available and relevant to customer, product or supplier requirements.

Records may include:

• Supplier conflict minerals declarations
• Customer-specific compliance responses
• Material and product compliance documentation
• Supplier qualification and review records

9. Limitation of Liability

Sucatec Pte Ltd provides conflict minerals information based on supplier-provided data and reasonable due diligence. Information may be incomplete where suppliers or upstream sources do not provide full traceability.

To the fullest extent permitted by applicable law, Sucatec Pte Ltd shall not be liable for any loss, damage or consequence arising from reliance on supplier-provided conflict minerals information.

10. Contact Information

For any conflict minerals or compliance-related enquiries, please contact:
Sucatec Pte Ltd
Email: [email protected]

This Conflict Minerals Policy is reviewed periodically and updated to reflect current regulations, standards and company practices.

Last updated April 2026