Conflict Mineral

Set of Zero-tolerance Policies in Compliance with RBA Code of Conduct

GIGABYTE commits to complying with local laws under high moral standards and obeying regulations of industrial responsibility. Although we are not a formal member of the Responsible Business Alliance (RBA, originally known as EICC), we voluntarily support the RBA Code of Conduct, including aspects of labor, health and safety, environment, and ethics.

Diversity and Nondiscrimination
Harassment Prohibition
Workplace Safety
Prevention of Human Trafficking, Forced Labor and Child Labor
Working Hours and Minimum Wage Standards
Freedom of Association/Collective Bargaining
Privacy and Freedom of Expression
Product Responsibility and Environmental Stewardship

In order to effectively carry out supply chain management, GIGABYTE amended the documentation to re-establish criteria for supplier evaluation and requirements for signing contract/commitment in 2017. Four zero-tolerance policies were also established. GIGABYTE has zero tolerance for the use of child labor, forced labor, discharge of untreated toxic or harmful matters or materials, and any behavior that may cause direct injury to employees. If any violation is identified, the improvement shall be made within a specified time frame. If the supplier designated by a customer fails to improve as scheduled, GIGABYTE would notify the customer. If the supplier that is not designated by any customer fails to meet the improvement standards, we would reduce orders, cease the business, or cancel the qualification of the supplier in order to avoid risks of supply chain and losses to our customers. For more information about the RBA, please visit the RBA website at：http://www.responsiblebusiness.org/

In addition to ethical requirements, to fully understand the impact of products on the environment and society, GIGABYTE launched a product environmental responsibility disclosure project in 2016. For more details, please refer to Extended Product Responsibility.

Prohibition on Conflict Minerals

Tin, tungsten, tantalum, and gold (3TG) minerals are indispensable raw materials in electronic products. However, such minerals may come from the areas of forced labor, child labor, or armed conflict. Using the minerals from these conflict areas as raw materials means indirect support of oppression and harm to the local human rights and living conditions. Therefore, GIGABYTE introduces the Responsible Minerals Initiative (RMI) under the RBA to investigate the use of 3TG minerals by first-tier suppliers in 2023 and traces the source through the latest Conflict Minerals Report Template (CMRT 6.31).

In 2019, after the RMI included cobalt mines in the scope of conflict mineral investigation, GIGABYTE immediately added cobalt mines into investigating items. In 2022, the RMI phased out the Cobalt Reporting Template (CRT) and Mica Reporting Template (MRT), so GIGABYTE changed to use the latest merged template (EMRT 1.2) to investigate the use of cobalt and mica in our supply chain.

Investigation Process of Conflict Minerals

The number of suppliers included in conflict minerals investigation in the recent 4 years

	2020	2021	2022	2023
Number of Investigated Suppliers	463	503	326	508
Number of Suppliers Completing Follow-up Improvement	Not implemented	Not implemented	Not implemented	17

[Note 1] The number of surveyed companies is determined by the number of questionnaires sent out. Different business groups and subsidiaries may purchase materials and parts from the same suppliers, but those materials and parts are managed in different product lines. In these cases, shared suppliers will still be counted repeatedly.

[Note 2] The number of suppliers completing follow-up improvement counts the suppliers who have replied with improvement measures to GIGABYTE after their upstream smelters have been identified as needing improvement in the year and have completed the improvement.

3TG Minerals

We further conducted statistical analysis on the CMRT responses to understand the actual management of conflict minerals by each supplier, and through their regulations and requirements for upstream to outline the use and management of conflict minerals by second-tier suppliers.

After screening the completeness of conflict mineral management policies of all suppliers responding in 2023, we selected 111 companies that reported having 3TG minerals from the Covered Countries in their processes and reviewed their management approaches in order to plan timely control measures in time.

The screening results found that only 3 high-risk suppliers had not defined a clearer conflict minerals management policy. GIGABYTE has drawn up a list and is formulating a follow-up tracking mechanism.

Conflict Minerals Management Status of the Suppliers using 3TG Minerals from Covered Countries

Cobalt Mineral

According to the cobalt and mica investigation of 397 first-tier suppliers in 2023, 136 suppliers used cobalt in their production processes, while the number of suppliers using mica was 10. Among them, 122 suppliers (89%) have already established cobalt sourcing management policies. Although currently cobalt and mica are not as widely used as 3TG metals, GIGABYTE will continue to expand the scope of cobalt investigation to eliminate human rights oppression caused by conflict minerals.