ZTE Corporation Conflict Minerals Report 2020/21
ZTE Corporation Conflict Minerals Report 2019/20
Policy on Conflict Minerals Management
ZTE abides by the United Nations Global Compact and other universally accepted international conventions and
practices, including the United Nations Global Compact, Due Diligence Guidance for Responsible Supply Chains
of Minerals from Conflict-Affected and High-Risk Areas of the Organization for Economic Cooperation and
Development (OECD), and the Responsible Mineral Initiative (RMI), respects human rights and the environment,
and strives to ensure that all product materials are properly sourced. Moreover, ZTE has released the Policy
on Conflict Minerals Management and Regulations on Conflict Minerals Management Regulations, specifying the
requirements for suppliers in terms of mineral exploitation, transportation, processing, trading,
processing, smelting, and export. We tolerate no activities which may aggregate conflicts, result in severe
environmental deterioration or violate human rights, and never profit from these activities or provide
assistance in any way. We prohibit the violations of human rights in relation to mineral mining,
transportation, or trading, and prohibit direct or indirect support to non-government armed groups or
security forces illegally controlling mining sites, transport routes, and/or trading sites.
In 2011, ZTE joined the Global e-Sustainability Initiative (GeSI), rejecting materials that directly or
indirectly caused conflicts. ZTE requires that all relevant suppliers (including component suppliers,
parts suppliers, or logistics suppliers of items containing tin, tantalum, tungsten, and/or gold must
guarantee that all materials come from environmentally and socially responsible sources. Each newly
accepted qualified supplier needs to submit a Conflict Minerals Reporting Template (CMRT) and a Extended
Minerals Reporting Template (EMRT) during their initial application, and each qualified supplier must sign
the Declaration of Compliance Management on Conflict Minerals. We conduct conflict minerals investigations
on our material suppliers each year.
ZTE is entitled to request suppliers to provide evidence for their material sourcing. To this end,
suppliers need to formulate and implement conflict mineral policies within their internal management
systems. Such policies shall contain a statement of compliance with applicable laws and regulations and a
commitment to the responsible purchasing of relevant materials. Suppliers also need to communicate with
upstream suppliers and to work together to ensure that the relevant materials can at least be traced back
to their smelting plants, so as to confirm that the purchased metals are from non-conflict-minerals
smelting plants.
Management Objectives and Commitments
Short-term objectives:
1.Integrate minerals management in internal and external IT platforms to increase our efficiency and
management effectiveness in this regard;
2.Expand the scope of conflict minerals management, strengthen the building of on-site task forces, and
improve the accuracy and credibility of on-site audits and inspections;
3.Provide training for the auditors and inspectors of on-site task forces to enhance their efficiency and
capabilities;
4.Design and provide more training programs for suppliers to raise their awareness and enhance their
capabilities of conflict minerals management;
5.Actively cooperate with suppliers to improve partnerships and mitigate potential risks related to conflict
minerals; attend more international conventions on conflict minerals to improve our influence in the
industry and contribute to the conflict minerals management of more international organizations;
6.Continuously improve our capabilities of conflict minerals management to meet customer requirements and
excel in the industry;
7.Collect the CMRT/EMRT from suppliers and maintain a 100% response rate;
8.Ensure that all qualified suppliers sign the Declaration of Metal Conflict-Free;
9.Verify suppliers' due diligence and make the verification a part of the overall supplier assessments.
Medium and long-term objectives:
1.Actively cooperate with the upstream suppliers and SORs, provide support for suppliers to obtain
third-party certifications, and participate in industry initiatives related to conflict minerals;
2.By 2025, more than 95% of 3TG SORs shall pass the independent third-party certification such as the
RMAP;
3.By 2025, at least 80% of cobalt SORs shall pass the independent third-party certification such as the
RMAP;
4.Collaborate with suppliers, stakeholders, and industry peers to further improve awareness and due
diligence capabilities related to conflict minerals;
5.Establish and strengthen the management structure based on the international requirements and standards
for ESG rating;
6.Ensure steady improvements on conflict mineral management internally and externally;
7.Expand the audit scope to more types of critical minerals from downstream and upstream suppliers, draw a
more comprehensive supply chain map, and improve the transparency of the supply chain risks of both cobalt
and other minerals.
Supply Chain Due Diligence
ZTE supports and accepts smelters certified by the Responsible Mineral Guarantee Program (RMAP). That is,
they will be qualified smelters recognized by ZTE as long as they have been certified by RMAP. In 2019, ZTE
formulated its Due Diligence Guidelines in reference to OCED's principles, and established third-party audit
procedures and tools. We promote suppliers to improve their own mineral tracking system. We conduct spot
checks on high-risk suppliers to evaluate the rationality and effectiveness of their mineral procurement
practices. According to ZTE's policy, ZTE shall terminate its contract(s) with a supplier who fails to
accept necessary third-party audit, rejects rectifications, or refuses to cooperate in rectifications.