DS Myanmar underwent an initial RMAP assessment from 24.06.2022 to 25.06.2022, covering the period 09.07.2020 to 10.05.2022.

After two rounds of corrective actions, the site was certified as RMI-RMAP Conformant. We were supported by Kumi Consulting Ltd during this period to strengthen our systems and reach conformance. At this stage, we have no non-conformances but have been advised by RMI-RMAP auditors to:

• Improve our engagement with upstream mechanisms.
• Where possible, set timelines for the delivery of on the ground assessments.
• Ensure we collect enough documents to assure ourselves that the risks in our supply chain are being properly managed by our counterparties.

The site will be re-assessed from 03rd to 04th July 2023 by Arche Advisors. During the audit period, DS Myanmar sourced raw materials in concentrate and ingot form from Asia, Africa, Europe, and Latin America, and exclusively via trader.

Since March 2023, we have switched to sourcing ingots only. These come from two sources:

1. An RMAP-conformant smelter based in Southeast Asia
2. A recycled tin trader based in South Korea

The company is committed to ensure best practice with respect to safety, health, environment, and ethics at all stages of its supply and production chain.

To avoid the use of conflict minerals, which directly or indirectly finance or benefit armed groups and/or involve other serious human right abuses in high-risk and conflict-affected regions, DS Myanmar has developed a supply chain policy.

The supply chain policy is fully aligned with the third edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). It covers all the risks identified in Annex II of the OECD Guidance and its geographic scope is global. DS Myanmar is committed to addressing any Annex II risks if identified.

The policy was reviewed and approved by the senior management, which committed to support its implementation. The policy has been widely disseminated to relevant stakeholders (suppliers, customers, employees etc.) and is available on our website at http://www.dshm.co.kr/Eng/about-CSP_DSM.html

Management Structure

The company follows through on its commitments in the supply chain policy and has developed an internal procedure for due diligence with the following aspects:

    • The company’s Managing Director is responsible to oversee the due diligence program and risk management design and implementation.
    • The company has assigned a procurement team leader as a due diligence program manager to coordinate the work of the relevant departments. The program manager
         ensures each department fulfils their roles and responsibilities, implements the due diligence program and reports any red flags and potential risks identified.
    • The company conducts due diligence management system training once a year for key staff from all relevant departments (Including logistics and production team).
         o This was delivered in November 2022 by Kumi Consulting to DS Myanmar’s procurement leader in English, who subsequently delivered the same training to relevant
            colleagues in Korean.
         o When there is an update of the program, the company will conduct additional training as necessary.

Internal Systems of Control

The company has established its due diligence management system to be aligned with the OECD Guidance and the RMAP Standard. The entire process is managed by the DS Myanmar Internal Material Control System the (“IMCS Procedure”).

    • Shipments of materials are checked prior to arriving on site through document reviews delivered on suppliers and per transaction.
         o We review documents on the supplier, alongside relevant documents per transaction. These include, but are not limited to, documents related to provenance of materials
            and due diligence systems of suppliers. There are enhanced checks on materials from high-risk locations or suppliers.
         o If we are not satisfied with documents provided by suppliers, we will disengage following a process of engagement.
    • Once materials arrive on site, further document checks are conducted, and materials are weighed and cross-checked.
         o Material balances are recorded and reported to senior management once per month.
    • If there are any discrepancies, this is investigated, and materials are segregated. To date, DS Myanmar has not encountered this situation.
    • Each material has a lot number and is stored until it is required for use.
    • Once materials are refined, they are stored under a lot number until they are shipped.
    • Any junk materials that are collected as a result of our refining processes are stored and recorded until they are re-used and pass through the refining system.

Record Keeping Systems

The company requires that all records relating to the due diligence program are maintained at least for five years and that they be properly used and safely stored in company database.

CAHRA identification

DS Myanmar determines if sourcing or transportation countries are CAHRAs on an annual basis or if there is a change in the supply chain. We use the following methodology:

CAHRA Identification Sources and Criteria
Resource	CAHRA criteria	The country is classified a CAHRA if it:
US Dodd-Frank Act	OECD Annex II risks: Direct or indirect support to non-state armed groups, or public or private security forces. • Presence of armed conflict and    widespread violence (Democratic    Republic of the Congo) • Transit risks (nine surrounding    countries)	• Listed as a Covered Country
European Union CAHRAs List	OECD Annex II risks: All risks	• Listed as a CAHRA
RMI Global Risk Map: Heidelberg Conflict Barometer	OECD Annex II risks: Direct or indirect support to non-state armed groups, or public or private security forces   Risks evaluated this resource: • Presence of armed conflict • Widespread violence	• RMI’s Global risk map captures this    indicator • Ranked high or extremely high on    RMI’s Global Risk Map
RMI Global Risk Map: Fragile State Index: Human Rights and Rule of Law indicator	OECD Annex II risks: Serious abuses (torture, cruel, inhumane, and degrading treatment; forced labor; worst forms of child labor; sexual violence; war crimes)	• RMI’s Global risk map captures this    indicator • Ranked high or extremely high on    RMI’s Global Risk Map
RMI Global Risk Map: Worldwide Governance Indicators, Control of Corruption indicator	OECD Annex II risks: Bribery, fraudulent misrepresentation of the origin of minerals, money laundering, Non-payment of taxes, fees, and royalties to governments Risks evaluated this resource: • Governance, with a focus on    corruption or to the extent that public    power is exercised for private gain	• RMI’s Global risk map captures this    indicator • Ranked high or extremely high on    RMI’s Global Risk Map
RMI Global Risk Map: Fragile State Index - Security Apparatus Index	OECD Annex II risks: Direct or indirect support to public or private security forces	• RMI’s Global risk map captures this    indicator • ranked high or extremely high on    RMI’s Global Risk Map

Supplier red flags

To identify supplier red flags, DS Myanmar has a Know Your Counterparty (KYC) form that includes questions related to:

• Legal status and ownership of the company.
• Due diligence activities undertaken by the company.
• Source of the company’s materials.
• If using, how they engage with upstream mechanisms.

The company’s due diligence program manager will review the provided information and the UN Sanction List. The KYC procedure is conducted prior to initial transactions with new suppliers.

Whenever inconsistencies, errors or incomplete information are identified in the KYC form, the company will communicate the improvement areas to suppliers and request an updated form. If red flags were identified, the company will further engage with its suppliers to clarify and improve the documents as needed.

Transaction red flags

Thirdly, the company requests origin information for each material transaction considered to be. We will ensure that we are able to assure ourselves of the transaction origin, transportation routes, as well as direct suppliers’ names and locations.

We do not accept any lack of knowledge on material origins.

Risk Assessment (HIGH RISK SOURCING ONLY)

We source via established traders and therefore estimate our risks to be primarily at point of origin (CAHRAs), particularly in Africa and Latin America.

For these sources, we conduct enhanced due diligence, which includes further checks on suppliers to ensure their approaches for due diligence meet our expectations.

• Assessing the context of CAHRAs.
• Clarifying the chain of custody.
• Requesting KYC on upstream suppliers from direct suppliers or checking status of upstream suppliers on a purchase-by-purchase basis.
• Assessing the activities and relationships of upstream suppliers.
• Identifying locations and qualitative conditions of the extraction, trade, handling, and export of minerals.
• Conducting on-the-ground assessments

We rely on our suppliers as we do not have leverage or resource to easily engage directly at the point of origin.

During the period which is captured by the scope of the 2023 audit, we have sourced ASM materials from CAHRA that have come via upstream mechanisms as well via legalised national approaches to ASM. In these cases, we have requested further insight from our suppliers about how they engage with these mechanisms and how they manage, mitigate and eliminate risks.

Since March 2023, our risk profile has significantly reduced as we are exclusively sourcing tin ingots from an RMAP-conformant site. However, even when sourcing via RMAP-conformant sites, we conduct enhanced due diligence activities if we identify that that the site may be sourcing from a CAHRA. This involves engaging with our direct counterparty to obtain answers to our questions.

Any high-risk suppliers or transactions are reported to senior management and a risk management plan is developed using a risk management strategy as defined in the OECD Guidance Annex II Model Supply Chain Policy, notably to:

1. Continue trade whilst actions are undertaken to address risks.
2. Suspend trade whilst actions are undertaken to address risks.
3. Disengage from the supplier, within a reasonable timeframe and following engagement activities, if there is no measurable improvement.

We will develop risk management plans in consultation with suppliers and affected stakeholders, containing measurable actions to mitigate risks identified. Suppliers must accept the plan and commit to implementing it.

Whist the responsibility for implementing the risk mitigation plan lies with the supplier, DS Myanmar will support suppliers. For instance, we will help suppliers build their capacity by providing training on responsible sourcing matters, as appropriate.

Six months from the implementation of the Risk Management plan, DS Myanmar will evaluate the success of the plan.

DS Myanmar will undertake additional fact and risk assessments when necessary. We will also consider supporting community-based networks to monitor risk mitigation when applicable.

During the audit period, although we identified risks related to sourcing countries, our enhanced due diligence activities determined these were being managed by all suppliers except one.

This supplier refused to engage meaningfully with requests for information and therefore we could not assure ourselves that they were sourcing according to our expectations, and so we disengaged from them.

This report has been reviewed and approved by the company’s Managing Director.