Hunan Shuikoushan Non-ferrous Metal Group Co. Ltd. Silver Supply Chain Due Diligence Policy

Hunan Shuikoushan Non-ferrous Metal Group Co. Ltd  recognizes the risk of significant negative impacts on mineral exploitation, trade, processing and  export  in  conflict-affected  and  high-risk  areas  and  identifies our obligation  to  respect  human  rights arid   not   to   conflict .  We undertake to adopt and widely promote the following policies on responsible procurement of minerals from conflict-affected and high-risk areas and apply them to the contract negotiation process with suppliers. This policy will serve as a basic reference for the  Company's procurement and sales activities. We renew our commitments not to engage in any activities that will finance the conflict and to abide by relevant UN sanctions resolutions, or domestic laws for implementing such resolutions (if applicable).

1. When carrying out procurement or business activities m conflict-affected and high-risk areas, we will neither tolerate any following phenomena nor adopt any way to profit from, help, assist or facilitate any party to take the following actions:

1) Any form of torture, cruel, inhuman or degrading treatment;

2) Any form of forced or compulsory labor (forced or compulsory labor means labor or services not volunt arily provided by any person who is extracted under threat of punishment);

3) The worst forms of child labor;

4) Other serious violations and abuses of human rights, such as widespread sexual violence;

5) War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

If we have reasonable grounds to believe that the above risks exist, we will immediately suspend the cooperation with the supplier.

2. We will not tolerate any direct or indirect support to non-state  armed groups through mineral exploitation, transportation,  trade, processing or export. When these armed groups or associated parties have:

1) Illegal control of mine sites or other control of transportation routes, mineral trading points and upstream actors in the supply chain;

2) Illegal taxation or extortion of money or minerals at the entrance to the mine site, along transportation routes or at mineral transaction points;

3) Illegal taxation or extortion of middlemen, export enterprises or international traders.

It is reasonable to assume that upstream suppliers purchase from  or have relations with any party that provides direct or indirect support to non-state armed groups, and we will immediately suspend our

cooperation with the supplier.

3.  We firmly agree to not to provide direct or indirect support to public or private security forces. When these armed groups or associated parties have:

1) Illegal control of mine sites, transportation routes and upstream actors in the supply chain;

2) Illegally taxations or extortion of money or minerals at the entrance to the mine site, along transportation routes or at mineral transaction points;

3) Illegal taxation or extortion from  middlemen , export  enterprises or international traders.

If we find that such ris ks exist to a certain extent, we will require

suppliers to provide proof documents that they have not provided  direct or indirect support to illegal public or private security forces according to the  risk mitigation regulations of silver supply chain of Hunan Shuikoushan Non-ferrous Metals Group Co.Ltd,thus containing or reducing the risks. If the risk  mitigation management measures of silver supply chain have not helped for six months, we will immediately suspend cooperation with upstream suppliers.

4. We will not offer, undertake, carry out or seek any bribes, and  will resist temptation. We will not bribe the Government in order to cover up or forge the origin of minerals and falsely report the taxes, fees and concession fees that should be paid to the Government for mineral mining , trade, processing, transportation, export and  other  activities.  We  will adopt or take measures to eliminate money laundering behavior s in cases where there is a risk of money laundering. We will pay all taxes and fees payable to the relevant governments on time as scheduled.

If we find that there are such risks in the Company's silver supply chain to some extent, according to the Company's risk mitigation management measures of silver supply chain, we will require suppliers to provide certificates of origin that do not mislead minerals for bribery or fraud reasons, as well as certificates for proving that they do not involve money laundering and have paid taxes and fees payable to the Goverrunent, thus containing or reducing risks. If the risk mitigation management measures of silver supply chain have not helped for six months, we will immediately suspend cooperation with upstream suppliers.