Sustainability

Responsible Procurement Report

1. Company Information 

Suzhou JIAN YI Tech Co., Ltd. located at No. 99 Jinji Lake Avenue, Suzhou Industrial Park, Jiangsu Province, was established in August 2012. The company covers an area of 200 mu, employs 1,500 people, and has a total investment of RMB 200 million. 

Scale of Construction: Optical Lens Workshop: Annual output of 8 million precision optical lenses Module Assembly 

Workshop: Annual output of 5 million optoelectronic sensor modules Supporting R&D center, laboratory, and office area 

Main Products: Optical lenses, optoelectronic sensor modules, LiDAR core components 

Raw Materials: Optical glass, rare earth materials (e.g., lanthanum, neodymium), special metals, electronic components 

Reporting Period: January 1, 2024 – December 31, 2024 

 

2. Summary of Responsible Procurement Report
In March 2024, the company conducted its annual management review in accordance with ISO 9001:2015, ISO 14001:2015, and ISO 45001:2018 standards. The management review concluded that the due diligence management system and practices of Suzhou JIAN YI Tech Co., Ltd.fully comply with the company’s Responsible Procurement Policy. The conclusion remains valid for three years from the date of the resolution. The company’s compliance status will be periodically updated on the Sustainability section of the official website (/about/sustainability/). 

 

3. Company Supply Chain Management Policy
The company has formulated a Responsible Procurement Policy and a Supply Chain Due Diligence Management Manual fully aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This policy covers all mineral raw materials and extends to comprehensive social responsibility areas including environmental protection, labor rights, and business ethics. The policy has been reviewed and approved by senior management, who are committed to fully supporting its effective implementation. It has been communicated to stakeholders — including suppliers, customers, and employees — through supplier conferences, website announcements, and employee training sessions. 

 

4. Company Management System
The company has established and implemented the Conflict Minerals Management Procedure, Sustainable Procurement Control Procedure, and Supplier Code of Conduct, and solemnly commits to upholding responsible supply chain principles.
We have developed the following internal due diligence procedures: A Supply Chain Due Diligence Management Committee has been established, comprising representatives from Procurement, Quality, R&D, and Legal departments. The committee regularly or irregularly conducts risk assessments on identified suppliers and raw materials. 

 

Assessment criteria include but are not limited to: rationality of raw material origin (e.g., geopolitical risks, mining certifications), supplier social responsibility performance (e.g., labor policy, environmental management), and compliance during transportation. The committee follows a predefined Risk Alert Checklist; once a warning signal is detected, an investigation process is initiated immediately and corrective actions are issued. 

 

The company conducts annual training on responsible mineral supply chains and due diligence management systems for key personnel in relevant departments (Procurement, Quality, R&D, etc.). Additional training is arranged as needed whenever policies or procedures are updated. In 2024, the company formally notified all upstream suppliers — both in writing and through the supplier conference — of updated supply chain policies and procurement requirements. Due diligence clauses have been incorporated into legally binding procurement contracts. Supplier due diligence performance has been included as a core criterion in the annual supplier audit process (including on-site factory inspections).

Sustainable Procurement Policy

1. Policy Statement 

As an important supplier of die-cut components in the notebook computer industry, Suzhou JIAN YI Tech Co., Ltd. recognizes the profound impact of the supply chain on Environmental, Social, and Governance (ESG) performance. We are committed to integrating sustainability into the core of our procurement decisions and to building a green supply chain that is environmentally responsible, respectful of human rights, guided by integrity, and resilient. This commitment is not only central to our corporate social responsibility but also the foundation of our long-term competitiveness. 

 

2. Scope of Application 

This policy applies to all procurement activities and employees of Suzhou JIAN YI Tech Co., Ltd., and extends to all suppliers, contractors, and subcontractors providing products or services to us. 

 

3. Core Principles and Specific Requirements 

We expect and encourage our suppliers to collaborate with us in the following areas: 

(1) Environmental Protection We are dedicated to minimizing the environmental impact of our supply chain and prioritizing eco-design solutions. 

• Green Materials: Give preference to materials that comply with international environmental standards such as RoHS and REACH, including adhesive tapes, foams, insulation, and conductive shielding materials. Encourage the use of renewable, recyclable, or bio-based raw materials. 
• Energy Efficiency and Carbon Reduction: Encourage suppliers to conduct energy audits, adopt high-efficiency equipment, and set carbon reduction goals. Preference will be given to partners that adopt energy-saving and emission-reduction measures in production and logistics. 
• Waste Management: Require suppliers to properly classify, recycle, and dispose of production waste—particularly hazardous waste such as solvents and adhesives—and to track its final destination. 
• Pollution Prevention: Require suppliers to strictly control the emission of volatile organic compounds (VOCs) and wastewater in production processes, ensuring compliance with regulations and continuous improvement. 

 

(2) Labor and Human Rights 

We uphold a people-oriented philosophy and ensure that the dignity and rights of every worker in our supply chain are respected. 

• Prohibition of Forced and Child Labor: Strictly prohibit any form of forced labor, bonded labor, or the employment of child labor. Suppliers must verify employee age. 
• Freedom of Employment: Do not withhold employees’ identification documents or passports, and do not demand unreasonable deposits. 
• Working Hours and Compensation: Ensure working hours comply with local laws, pay wages not lower than the statutory minimum, and provide legally required benefits. 
• Health and Safety: Require suppliers to provide safety training, protective equipment (such as gloves and goggles), and a safe working environment, particularly for employees operating stamping and die-cutting machinery. 
• Non-Discrimination and Inclusion: Prohibit discrimination based on race, gender, age, religion, or other factors in hiring, pay, and promotion. Encourage workplace diversity and inclusion. 

 

(3) Business Ethics and Governance 

Integrity is the cornerstone of our business. We require our supply chain partners to adhere to the highest ethical standards. 

• Anti-Corruption: Prohibit all forms of corruption, bribery, extortion, or improper benefit transfers. 
• Transparency: Suppliers must provide transparent information regarding material composition, environmental performance, and social responsibility when reasonably requested. 
• Responsible Mineral Sourcing: We support the “Conflict-Free Minerals” initiative. Suppliers must cooperate in tracing the origins of tantalum, tin, tungsten, and gold (3TG) to ensure they do not directly or indirectly fund armed conflict in the Democratic Republic of the Congo and neighboring regions.
• Fair Competition: Comply with all applicable competition laws and prohibit collusion, bid-rigging, or other anti-competitive behavior. 

 

 (4) Supply Chain Resilience and Diversity 

• Localization and Diversity: While ensuring quality, cost, and delivery, actively assess and include local suppliers, women-led enterprises, and small-to-medium-sized businesses to enhance supply chain flexibility and resilience. 
• Long-Term Partnerships: We are committed to establishing long-term, stable, and strategic partnerships with suppliers who share our sustainability values and continuously improve their practices. 

 

4. Goals and Performance Measurement 

We will set annual sustainable procurement goals and regularly review progress. Initial goals include (subject to adjustment as needed): 

• By 2024, 100% of new suppliers will sign the Supplier Code of Conduct during the onboarding process. 
• By 2024, conduct social responsibility and environmental compliance assessments for 80% of high-risk (e.g., raw material and chemical) or key suppliers. 
• By 2024, achieve 100% training participation of the procurement team on this sustainable procurement policy. 
• By 2025, initiate 3TG conflict minerals due diligence covering at least 90% of major suppliers. 

 

5. Responsibilities and Implementation 

• The Procurement Department is the primary driver and executor of this policy, responsible for integrating sustainability standards into supplier selection, evaluation, and management processes. 
• Management is responsible for providing necessary resources and support, and for monitoring the effectiveness of policy implementation. 
• All employees are responsible for understanding and complying with this policy. Suppliers are responsible for understanding, communicating, and ensuring that they and their subcontractors comply with this policy. 

 

6. Supplier Collaboration and Evaluation
We will assess supplier compliance through questionnaires, on-site audits (when necessary), and document reviews. Suppliers that fail to meet the basic requirements of this policy or refuse to improve may face adjustments to their qualification or business share. 

 

7. Communication and Feedback Mechanism
This policy is publicly available both internally and externally. We encourage employees, suppliers, and all stakeholders to provide feedback on its implementation or to report any suspected violations.

Conflict Minerals Procurement Policy Announcement

Date of Issue: October 27, 2023 

1. Policy Statement

Suzhou JIAN YI Tech Co., Ltd. (“JIAN YI”), as a responsible supplier of die-cut components in the notebook computer and electronic device supply chain, recognizes its corporate social responsibility. We acknowledge that the illegal mining and trade of tantalum (Ta), tin (Sn), tungsten (W), and gold (Au)—collectively known as 3TG—from the Democratic Republic of the Congo (DRC) and its neighboring countries* may finance armed groups and contribute to severe human rights violations and environmental degradation. These metals are commonly referred to as “conflict minerals.” 

Therefore JIAN YI  solemnly declares and commits that we do not support, accept, or use any “conflict minerals” that directly or indirectly finance or benefit armed conflicts. 

 

2. Supplier Requirements
To ensure compliance and ethical responsibility throughout our supply chain, we require all suppliers to share this responsibility and take the following actions: 

• Policy Awareness and Commitment: Understand and support the spirit and requirements of this policy. 
• Due Diligence: Conduct immediate traceability investigations on tantalum (Ta), tin (Sn), tungsten (W), and gold (Au) contained in products. 
• Transparency of Source: Use internationally recognized reporting tools, such as the Conflict Minerals Reporting Template (CMRT), to disclose information about the smelters and refiners (SORs) of 3TG metals used in products.
• Assurance of Non-Conflict Sources: Ensure that all 3TG metals used in products supplied to JIAN YI originate from internationally recognized compliant smelters and not from conflict-affected areas in the DRC or its neighboring countries.
• Supply Chain Communication: Communicate these requirements to upstream suppliers and establish corresponding traceability and management systems. 

 

3. Our Commitments and Actions 

JIAN YI commits to: 

• Integrate conflict minerals management into supplier selection and ongoing evaluation processes. 
• Collaborate actively with suppliers to enhance supply chain transparency. 
• Prioritize procurement of metals from smelters certified by reputable organizations such as the Responsible Minerals Initiative (RMI). 

 

 4. Follow-Up Actions 

Suppliers who fail to provide the required due diligence information, or whose materials cannot be proven to be from non-conflict sources, will be required to submit a corrective action plan, and such cases may affect future business cooperation. We firmly believe that through the joint efforts of both upstream and downstream partners, we can promote responsible mineral sourcing and contribute to global peace and sustainable development. 

---

 Suzhou JIAN YI Tech Co., Ltd.
*Neighboring countries include: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.