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Material Management
Quality persistence

Material Management

Management of Restricted Substances

To ensure the parts, raw materials, packing materials, and components we use on products do not contain environment-related substances to be controlled in products; to comply with current laws and codes; to meet customer requirements; to protect Earth and the environment, and to reduce impacts on ecosystems. As such, we ask all suppliers to supply only materials that comply with our environmental and quality policies at the beginning of the development of new parts and components for products while incorporating

customers' requirements related to restricted substances into E Ink's Restricted Substances after reviewing them. Meanwhile, specific principles shall be complied with, including EU's RoHS REACH, free from halogen non-use of conflict minerals. We also conform to the specific control standards and supplier management regulations requested by customers, and require our suppliers to submit their lists of restricted substances and an RBA/GeSI Conflict Minerals Report. Currently, our suppliers are required to make a declaration of nonuse of conflict minerals, and the response rate from our material and component suppliers is 100%. Should the materials or components from our supplier contain any environmental restricted substances or conflict minerals, the supplier in question shall assume full responsibility for relevant indemnification that may incur. Currently, materials supplied by suppliers conform with the restricted substance requirements. In addition, our products are shipped with packaging materials with the RoHS Label for identification purposes. We had zero cases of product-related nonconformity or violations reported in 2021.


Apart from relevant international standards, after having received the accreditation of Sony Green Product (GP) for several years running, Sony GP has chosen E Ink as an outstanding partner. With this distinction, the Company receives preferential treatment of being eligible for self-audit operation by completing a printed checklist instead of having Sony dispatching a representative to carry out an onsite audit at our premises.


To implement the restricted substance management into the system, we have established the Environment-Restricted Substances Management Committee". E Ink also bases on The "Environmental Restricted Substances Management Procedure" to control all the parts and components so that they are compliant with pertinent requirements, and have constantly ensured that the management procedure keep pace with the time through meetings and reviews. In the event of any change in customer requirements or amendment in international restricted substances regulations, the Company would conduct an evaluation to adjust relevant standards and SOPs before informing all relevant units regarding the adjustments. For example, the European Chemicals Agency (ECHA) has announced four new additions to the Candidate List as Substances of Very High Concern (SVHC) on June 25, 2021. At present, 209 chemical substances have been identified and placed on the Candidate List. By means of public announcement, E Ink has notified all suppliers and updated existing documentation with the newly added restricted substances. Not only that, E Ink also requires suppliers to conform the E Ink's "Commitment of Restricted Substance Management" to guarantee their compliance with pertinent laws and the rules enforced by E Ink. Further, we also review and update the material reports on a regular basis to make sure that the materials offered by the suppliers

comply with E Ink's GP regulations.

Conflict Minerals Policy and Declaration

Conflict Minerals (CM) refer specifically to tantalum, tungsten, tin and gold (collectively "3TG") that are from the conflict zones controlled by non-governmental military organizations in Democratic Republic of Congo and extracted through a way that violates human rights. The sources of such conflict minerals also include other neighboring areas such as Rwanda, Uganda, Burundi, Tanzania and Kenya.


The relevant metallic minerals have become the main source of income to the non-governmental military organizations of the zones and been used for arms trading and continuation of armed conflicts, which leads to human rights violations and thus gives rise to international disputes.


As a contributing global citizen and active proponent of Responsible Business Alliance (RBA) Code of Conduct, E Ink hereby declares and pledges to reject minerals extracted from all existing conflict zones. Not only that, we also ask that all E Ink suppliers must

  1. actively fulfill their obligations to the society and environment;
  2. ensure that no products contain conflict minerals extracted from the aforementioned conflict zones;
  3. trace all sources of tantalum, tungsten, tin and gold that may be present in all E Ink products;
  4. confirm and sign the Declaration of Non-use of Conflict Minerals.

Conflict Mineral Investigation

With regards to all customers' requests for conflict mineral due diligence, the Company requires relevant suppliers to carry out due diligence on their part and sign respective declarations. As of December 2021, all of our suppliers (100%) have responded to our request for an inquiry. Not only that, we also implemented risk assessment and collected survey forms from suppliers. By double checking against the list of smelters and refiners published by Responsible Minerals Initiative (RMI), we were able to verify the response from our suppliers and determine if they had been working with qualified and approved smelters and refiners.


All of E Ink's suppliers have signed their Declaration of Non-use of Conflict Minerals and the Company has done its due diligence to ensure that all of its products are free of conflict minerals. In addition, to express and adhere to the requirements of conflict mineral management, we have presented our Conflict Minerals Policy and requirements to the suppliers in writing. The suppliers must comply with E Ink's Conflict Minerals Policy, establish their own conflict minerals policy accordingly, and pass the requirements to the next tier of suppliers.