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Strengthen Restricted and Hazardous Substances Management

E Ink is committed to providing products that meet customer needs while being environmentally friendly, adhering to the management principles of "No Entry, No Use, No Output" for hazardous substances. Strict controls are implemented at every stage, from product design, raw material procurement, and manufacturing to production testing and final sales, ensuring compliance with current domestic and international regulations and commitments on hazardous substance management. E Ink currently manages restricted substances in accordance with the Restriction of Hazardous Substances Directive (RoHS), the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH), the prohibition of conflict minerals, and Halogen Free requirements. No noncompliance issues were identified in 2024Note. Additionally, E Ink incorporates specific customers' restricted substance regulations into its controlled substance list after thorough review to further strengthen management. In 2025, E Ink plans to incorporate Persistent Organic Pollutants (POPs) and Per- and Polyfluoroalkyl Substances (PFAS) into its management scope and will continue to monitor key restricted substance regulations in its product markets to ensure compliance with the latest environmental regulations and customer requirements.

In 2021, E Ink's "Environmental Restricted Substances Management Committee" established the "Green Product" management guidelines, implementing comprehensive control over all components through the restricted and hazardous substances management process. In addition to regularly holding meetings and reviewing operations to ensure that management standards remain up-to-date, the committee also evaluates customer requests or changes in international restricted and hazardous substance regulations, adjusting control standards and operational modes as needed, and notifying relevant departments through announcements. If restricted substances are found in products, a phased-out or substitution will be developed.

Note: All raw materials must comply with E Ink's restricted substances management regulations. E Ink may require material suppliers to provide and update third-party certified restricted substances test reports, and also conducts annual sampling tests of materials for restricted substances through a third-party certified body to ensure compliance with its restricted substances management regulations.

Conflict Minerals Management

E Ink Conflict Minerals Policy and Declaration

E Ink conducts responsible mineral sourcing due diligence for Conflict Minerals (CM) in accordance with the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals, the framework of the Responsible Minerals Initiative (RMI), and customer requirements. E Ink also closely monitors the Reasonable Country of Origin Inquiry (RCOI) reports released by the RMI to stay informed about the country of origin of 3TG (Tungsten, Tantalum, Tin, and Gold), as well as Cobalt (Co) and Mica (Mica), which are mined in ways that violate human rights. As a global citizen, E Ink actively promotes the Responsible Business Alliance (RBA) Code of Conduct and declares its commitment to not accepting minerals from conflict-affected areas.

E Ink Conflict Minerals Policy

As a member of the global electronics industry supply chain, E Ink Holdings Inc. is not only active in product development and improvement, but also continuously committed to responsible procurement, including social responsibility and environmental protection issues. E Ink Group supports the Responsible Minerals Initiative (RMI) jointly initiated by RBA with practical actions, and does not support or use minerals from armed conflicts, illegal mining and poor working conditions. It also requires all suppliers to use the Conflict Minerals Reporting Template (CMRT) and The Cobalt Reporting Template (CRT) provided by RMI to investigate their products containing tantalum (Ta), tin (Sn), tungsten ( W), gold (Au) and cobalt (Co) and due diligence should be used to confirm the source of these minerals. In order to meet the specifications and customer requirements, we will continue to update the survey results in the future.

According to this policy, E Ink will:

1. Conduct supply chain due diligence in accordance with the OECD Due Diligence Guidelines for Responsible Mineral Supply Chains in Conflict-Affected and High-Risk Areas.

2. If the material of product contains minerals such as tantalum (Ta), tin (Sn), tungsten (W), gold (Au) and cobalt (Co), due diligence on conflict minerals should be carried out and the tantalum (Ta) used in the product should be fully disclosed. , tin (Sn), tungsten (W), gold (Au) and cobalt (Co) and other mineral sources.

3. We require suppliers to cooperate in filling out the conflict minerals survey template (please go to the RMI website to download the latest version), and provide relevant proof of origin. Suppliers should communicate this policy to their upstream suppliers and supply chain, and require their upstream suppliers to comply with it.

4. Pursue conflict-free minerals and refuse products containing tantalum (Ta), tin (Sn), tungsten (W), gold (Au) and cobalt (Co) from illegally mined areas in the People's Republic of Congo or its neighboring countries.

Compliance with Conflict Minerals Regulations

E Ink formally announced the "Conflict Minerals Policy and Requirements" to suppliers in writing, mandating compliance from all suppliers and encouraging them to establish their own conflict minerals policies, which should be communicated to their respective downstream suppliers. In 2024, 100% of significant suppliers signed the declaration of metal conflict-free. E Ink will continue to promote the signing of this policy to progressively achieve the goal of 100% signing rate by significant and Bill of Material (BOM) material suppliers by 2025.

Mineral Source Country Investigation

E Ink requires the use of 3TG minerals in its products to ensure product functionality, it is crucial to ensure that all parts, raw materials, packaging materials, and components containing 3TG minerals do not originate from smelters or countries identified by the Responsible Minerals Initiative. Each year, at least 5% of significant suppliers undergo reasonable country-of-origin investigations for minerals. The results of these investigations are systematically compiled and periodically reviewed to generate monitoring reports and conduct internal audits. Improvement measures are then formulated to ensure product compliance. If E Ink discovers that the products provided by a supplier contain conflict minerals, E Ink will switch to using materials from a second source supplier but will also further explore better alternative sources as substitutes to guarantee that all its products remain free from conflict minerals.

Due Diligence

To achieve the goal of 100% compliant mineral usage rate among suppliers, E Ink referred to the latest list of valid and qualified smelters published by RMI. The Company conducted due diligence on all conflict mineral requirements from customers to track the sources of conflict minerals from suppliers. In 2024, a total of 57 suppliers underwent due diligence, confirming that these suppliers achieved a 100% compliant mineral usage rate, and all E Ink products were free of conflict minerals.