Purpose
Kumyang Co., Ltd. (hereafter KUMYANG) is committed to ensuring that it does NOT source, trade or handle minerals that fund or benefit armed groups in African countries such as the Democratic Republic of Congo and its adjacent countries. This policy outlines KUMYANG's commitment to develop and implement a comprehensive conflict mineral policy in accordance with all requirements and procedures set forth in the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Due Diligence Guidance).
Code of Conduct
1.
KUMYANG understands the importance of preventing human rights violations such as child labor and forced labor in the mining process and minimizing envi-ronmental destruction.
2.
KUMYANG endeavors to keep informed on news, regulations and policy updates related to conflict minerals to avoid even inadvertent non-compliance.
3.
KUMYANG shall comply with regulations related to conflict minerals, including the Dodd-Frank Act of the United States, the Conflict Minerals Regulation of the EU and the UN Security Council Resolutions. It shall endeavor to ensure that due diligence is conducted in accordance with the OECD Due Diligence Guidance.
4.
KUMYANG shall require its partners to handle conflict-free minerals that meet ITSCI or any other similar standards.
5.
If any violation is detected, KUMYANG shall take appropriate actions to correct the problem in an honest manner.
Action Plans
Based on the five-step framework recommended by the OECD Due Diligence Guidelines, KUMYANG shall manage as follows so that minerals can be mined and traded in a way that respects human rights and protects the environment:
1.
Establish an internal management system to manage risks related to minerals mined in conflict-affected and high-risk areas, including DRC;
2.
Identify and evaluate risks that may arise from mining, trading, and exporting minerals in conflict-affected and high-risk areas;
3.
Establish and implement a risk management system and strategy to manage and respond to identified risks, monitor implementation performance and improve the management system and strategy on an ongoing basis;
4.
Conduct due diligence on the supply chains in conflict-affected and high-risk areas and plan and conduct independent audits, if necessary; and
5.
Publicly report the results of the due diligence every year.
Enactment Date: Monday, the first days of September 2025
Risk Management
Reporting illegal, misconduct,
or unfair practices related to conflict minerals
whistleblowing@kyc.co.kr