Responsible Sourcing & Conflict-Free Minerals Statement

1. Policy Statement

BoronHub Solutions Limited commits to sourcing all raw materials in a responsible and ethical manner, and fully complies with international initiatives and standards governing conflict-free minerals.

We hereby solemnly undertake that we will never procure minerals originating from conflict-affected and high-risk areas that fund or sustain armed conflicts. We fully adhere to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as well as the Guidelines for Responsible Mineral Supply Chain Due Diligence in China issued by the China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters. We also strictly abide by the regulatory controls set forth in China’s Export Control Law and the Regulations on Export Control of Dual-Use Items.

2. Scope of Application

This policy applies to all boron-containing mineral raw materials and related compound products procured by BoronHub, including but not limited to basic boron compounds such as boron ore, boric acid and borax, as well as boron carbide, boron nitride, rare earth hexaborides, transition metal borides and boron isotope products.

 

3. Due Diligence Framework

BoronHub has established and continuously refined a supply chain due diligence system built on the OECD five-step framework:

Formulate and publicly disclose this policy, with a dedicated full-time role assigned to supply chain compliance management;

 

Require all key suppliers to sign a Supplier Responsibility Commitment, and collect information on mineral origin, smelting and processing via questionnaires

Develop and track implementation of risk mitigation plans for identified supply chain risks;

Entrust qualified third-party institutions to conduct regular assessments of supply chain compliance;

Publish an annual supply chain due diligence report to disclose key information to customers and stakeholders.

4. Conflict-Free Mineral Commitment

BoronHub formally commits to the following requirements: Mandate all suppliers to provide complete mineral origin information to achieve full traceability across the supply chain; Refuse all mineral supplies sourced from conflict-affected or high-risk regions; Immediately terminate business cooperation with any supplier found sourcing conflict minerals or failing to cooperate with due diligence procedures.

5. Regulatory Compliance

BoronHub strictly complies with domestic and international laws and standards, including China’s Export Control Law, Regulations on Export Control of Dual-Use Items, the OECD Due Diligence Guidance, and the Guidelines for Responsible Mineral Supply Chain Due Diligence in China, to guarantee all mineral sourcing activities are legal and ethical.

 

6. Raw Material Origin Disclosure

BoronHub’s boron raw materials are primarily sourced from salt-lake boron mines and boron compound manufacturing bases located within China. All suppliers are situated in low-risk jurisdictions and fall outside the scope of conflict-affected or high-risk areas.

7. Continuous Improvement & Reporting Mechanism

BoronHub reviews and updates this policy annually and delivers regular compliance training to suppliers, proactively responding to legitimate customer inquiries regarding supply chain compliance.

The company has set up a dedicated supply chain compliance reporting channel: 📧 manage@boronhub.com. All stakeholders are encouraged to report suspected violations of this policy. All reports will be treated in strict confidence, and whistleblowers will be protected against retaliation of any form.