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Conflict Minerals Management
Supply Chain Management
WPG Holdings is a semiconductor component distributor with two primary categories of suppliers: " Principal (IDM/Fabless/IC Design) Suppliers" and " General Affairs Supplier."
1.IDM/Fabless/IC Design Suppliers
WPG Holdings serves as a distributor (agent/dealer) in the semiconductor component supply chain and is not involved in the product manufacturing process. However, as an integral part of the industry value chain, WPG Holdings proactively monitors the products it distributes/represents, verifying their compliance with environmental and social issue regulations. Through public information disclosure on
our corporate website, we disclose whether key suppliers comply with environmental regulations and other requirements. This initiative helps enhance transparency across the entire value chain and increase consumer awareness, allowing WPG Holdings to leverage its influence within the value chain to jointly build a sustainable global electronics supply chain.
As a semiconductor component distributor, WPG Holdings provides Business-to-Business (B2B) electronic component supply chain services to upstream semiconductor manufacturing OEMs and downstream electronic product manufacturers. To unleash our value as a central hub between upstream and downstream partners, we establish robust cooperative relationships through regular and ad-hoc meetings, visits, monthly/quarterly performance reviews, and unscheduled audits. This ensures alignment and collaborative synergy across both parties' short-, medium-, and long-term development goals and corporate social responsibility planning. To provide localized customer service, we have established offices across our Taiwan headquarters, Asia, the Americas, and other regions, with dedicated windows for both OEMs and customers to respond promptly to feedback regarding product quality, environmental management, and social responsibility. Regarding support for customer initiatives on hazardous substance control, WPG has established an Eco-Friendly Corner on its official website and assigned dedicated units to provide necessary and sufficient information in real time to satisfy the requirements of downstream clients, end customers, and public sectors. We also cooperate with clients' CSR programs to conduct necessary activities, surveys, verifications, audits, and relevant data collection.

As of the end of 2025, WPG Holdings represents various semiconductor OEMs and IC design suppliers, using the "revenue share percentage" as the basis for identifying key suppliers. The top 30 major suppliers accounted for over 82% of WPG Holdings' total revenue. These suppliers are primarily located in the United States, Taiwan, Europe, Mainland China, South Korea, and Japan. In terms of revenue ranking, the Driven by global sustainability initiatives, WPG Holdings supports the "Conflict-Free Smelter Program" developed by the Responsible Business Alliance (RBA) and the Responsible Minerals Initiative (RMI). Every year, we utilize the Conflict Minerals Reporting Template (CMRT) or Form SD to periodically review the mineral and smelter source information within the supply chains of our top 30 key Principal suppliers. Simultaneously, we monitor chemical safety management and publicly disclose the results of our due diligence reviews.
2.General Affairs Suppliers
For general affairs suppliers, WPG Holdings has formulated a complete supplier policy and identified supplier risks, devoted to assisting supplier partners to continuously improve management measures.
【Evaluation and Management Mechanisms】
Principal IDM/Fabless/IC Design Suppliers
Conflict Minerals Management
The U.S. Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010. Pursuant to Section 1502 of the Act, the U.S. Securities and Exchange Commission (SEC) promulgated Rule 13p-1 under the Securities Exchange Act of 1934 in August 2012. This rule aims to address human rights abuses associated with mining operations in the Democratic Republic of the Congo (DRC) and adjoining countries. Minerals extracted from this region are referred to as "3TG," representing Tin (Sn), Tungsten (W), Tantalum (Ta), and Gold (Au).
As a semiconductor component distributor, WPG Holdings is not directly involved in the product manufacturing process. To communicate our requirements regarding conflict minerals, WPG Holdings is committed to not knowingly purchasing, directly or indirectly, any conflict minerals or products containing conflict minerals sourced from conflictaffected areas. Moving forward, we will continue to conduct annual supply chain due diligence to fulfill and enhance our sustainable supply chain management goals.
To implement WPG Holdings' requirements for conflict minerals, we review suppliers' conflict mineral management policies, their countries-of-origin investigations, and other publicly disclosed data every two years to track information. By publicly disclosing these findings, WPG Holdings reinforces its commitment to support the use of legal, conflict-free minerals.
Conflict Minerals Management Process:
WPG Holdings conducts conflict minerals due diligence every two years. According to the latest investigation results, 67% (20 out of 30) of key suppliers have publicly disclosed their lists of compliant smelters. Furthermore, within their raw material sources, the average percentage sourced from compliant smelters is as high as 99.5%.
Among the 10 suppliers that have not yet publicly disclosed their lists, 7 are members of the Responsible Business Alliance (RBA) and have issued statements through official channels. Because the data provided by suppliers is the aggregated result collected across the entire supply chain, it is currently not possible to analyze individual product items. WPG Holdings executes due diligence on a two-year cycle and will continue to optimize the tracking mechanism in the future, aiming to more precisely grasp dynamic supply chain information.
Among the 30 key suppliers, the average percentage of raw materials sourced from compliant smelters is 99.5%.
Note: Average percentage of raw materials sourced from compliant smelters = (Compliant percentage disclosed by key suppliers x Number of key suppliers with that specific compliant percentage) / Number of key suppliers that have disclosed their compliant percentages.
Implementation and Promotion of the "WPG Value Partner EP Sharing Platform" to Enhance Supply Chain Transparency
To further improve the efficiency of supply chain compliance management, WPG Holdings initiated the construction of the "WPG Value Partner EP (short for Environmental Policy data, including most conflict minerals data) Sharing Platform" (hereinafter referred to as the "EP Sharing Platform") in 2025. This platform integrates environmental policy data resources across the supply chains of various subsidiaries within the Group. Through digital methods, a comprehensive environmental policy big database is established, significantly reducing data duplication while
reinforcing data verification and tracking capabilities.
In terms of conflict minerals management, the EP Sharing Platform delivers the following synergistic benefits:
Data Digitalization and Standardization:
The platform introduces OCR (Optical Character Recognition) technology to automatically parse environmental policy data provided by OEMs, such as conflict minerals test reports in PDF format. It filters relevant values based on customer and regulatory requirements, effectively replacing the previous workflow that heavily relied on manual comparison. This mitigates the risk of errors caused by manual input and ensures the accuracy of conflict mineral reporting data.
Cross-Group Resource Sharing:
Designed with the core spirit of "cross-group resource sharing," the platform allows the same environmental policy data test report to be shared under configured conditions when provided to the same customer. This avoids repetitive requests that place burdens on suppliers. Concurrently, it establishes a comprehensive mechanism for data inquiry, download, and permission control to ensure sensitive data is properly protected.
Continuous Optimization Timeline:
The EP Sharing Platform was planned in early 2025, and the development of the main platform was completed by the end of 2025, with employees already utilizing it. Optimization is expected to take place in 2026, alongside interface connection and integration with third-party and client-side databases, progressively realizing the end-to-end digital management of supply chain compliance data.
Through the continuous construction of the EP Sharing Platform, WPG Holdings will further enhance data collection efficiency and transparency based on its existing annual supply chain investigations, fulfilling its long-term commitment to conflict mineral issues and continuously strengthening its sustainable supply chain management capabilities.
WPG Conflict Minerals Policy
As a distributor of semiconductor components, WPG Holdings did not participate in the product manufacturing process. In order to express the requirements regarding conflict minerals, WPG Holdings is committed not to directly or indirectly purchasing any conflict minerals from any source containing conflict minerals from the Covered Countries. In the future, WPG Holdings will continue to conduct supply chain due diligence annually to meet supply chain management targets.
For more information:WPG Conflict Minerals Policy
- Conflict Minerals Policy / Statement of Upstream Semiconductor Components Suppliers
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Semiconductor Components Suppliers - Conflict Minerals Policy |
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Semiconductor Components Suppliers - CMRT/SD Form |
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