Primax Electronic Ltd. Group are dedicating on enhancing business ethics and supplier chain environmentally friendly, & we follow international conventions, global initatives, and legal regulations to assure Primax as well as whole supply chain is capable to seize the market opportunity.
Therefore, along with experiencing global pandemic, extreme climate, endanger human right violated war, we seek for a stronger, healthier supply chain solutions, & then we released a new Primax Supplier Code of Conduct on December 12, 2023. we will obligate to oversight the whole supply chain maturity. 【More detail please download the document：Primax Supplier Code of Conduct】

Supplier overview

Primax Group manufactures an extensive range of products from computer peripherals (mouse and keyboard), mobile device components, office machines, to Smart Home and acoustics. There are three categories of supplier that are directly relevant to our production, including: 1 , 505 raw material producers, 367 electronic parts distributors, and 6 subcontractors for a total of 1 , 878 . Regionally, 281 suppliers were located in Taiwan, 1 , 422 were from China (including Hong Kong), and 175 were from other countries. Total transactions with suppliers amounted to approximately NT$ 58 billion in 2022 .

Supplier Audit  

We take supplier reviews as a means to improve suppliers' capabilities. A comprehensive set of procedures has been developed to help suppliers improve and comply with the Company's supplier management policies. All new Primax suppliers are required to pass QCDS+SER (Quality, Cost, Delivery, and Service &SER, QCDS) assessment before business. The specific suppliers (e.g., world-renowned manufacturers, vendors specifically designated by customers etc.) are still subject to comply with QCDS+SER requirements, but they may adopt the supplier's declaration in document review (such as statement of environmental or other self-declared environmental statement). Then could be involved in the Approved Vendor List (AVL) after approval.

Primax’s requirements for suppliers are not limited to performance and quality. Before collaboration, we require all new suppliers to sign the Integrity Statement and the Supplier Statement. They must cooperate in signing and submitting the environmental statement document reviewed by our company, including the responsible minerals statement, the restricted substances statement, company and the RBA Code of Conduct, to indicate that raw materials and finished goods they purchased have been in compliance with relevant initiatives, environmental laws and regulations, company policies and RBA Code of Conduct . Apart from environmental protection, it is mandatory for suppliers to make commitments with regard to intellectual properties, confidentiality, order placement, source of materials and compliance with relevant standards; as such, they are aware of our requirements for social and environmental responsibility and abide by the code of business ethics. In 2022 , Primax Group had a total of 216 new suppliers, all of which underwent the supplier review process.

Conflict minerals management and due diligence

Since 2012 , Primax has strictly complied with the "Conflict Mineral Law" and refrained from using and purchasing conflict minerals (such as: tantalum, tin, gold, and tungsten) that originate from Democratic Republic of the Congo, while at the same time demanded all suppliers to make a commitment to using responsible minerals and ensure that all minerals (such as: tantalum, tin, gold, and tungsten) used in production will not finance armed conflicts. This policy forms an essential part of our supplier management and product design, and we require suppliers to disclose information of their smelters and make announcements over GPPortal® relating to any conflict metal discovered in their supply.

In addition, with the rapid growth of the electric vehicle industry, the scope of applications of rechargeable batteries is also expanding. Therefore, Primax Group has also required suppliers to disclose the use of cobalt ore since 2020 . Our current disclosures cover cobalt refineries (processing of cobalt concentrates and intermediate products) or recycling plants (processing of cobalt recycled materials). The intermediate products of cobalt include impure cobalt hydroxide, cobalt carbonate, and metallic cobalt. Recycled materials include industrial or post-consumer waste (such as cobalt based alloys from metallurgical recycling processes). Factories that only produce battery cathodes, alloys, and ceramics are downstream factories rather than refineries.

As per the disclosed information on smelters in the supply chain in 2022 , suppliers announced a total of 252 smelters, most of which smelted gold with 100 . Followed by tin with 56 , tantalum with 34 , tungsten with 34 , and cobalt with 28 . The places of origin and distribution of all smelters are listed below and can be traced.

During the survey process, we refer to the list of 3 TG qualified smelters formulated by the Responsible Minerals Initiative (RMI) and require suppliers to work with RMI-certificated smelters. Meanwhile, we regularly check the latest list of smelters to ensure that the materials uses can meet the latest requirements of the list. In 2022 , of the smelters we worked with, 18 of them failed to pass the RMI audit and were removed from the list of the qualified smelters. We immediately launched a supply chain investigation, requesting suppliers to investigate the smelters with which their upstream manufacturers worked to ensure that they would not work with unqualified smelters by accident.

Meanwhile, we identified risks in the supply chain and evaluated them as per the supply chain policy standards and due diligence recommendations under the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Area. 405 suppliers conducted risk assessment regarding conflict minerals management and due diligence in 2022 .

Supplier due diligence  

We regularly conduct on-site evaluations of our suppliers and provide education and training on the assessment of hazardous substances and greenhouse gases. This is to ensure the proper implementation of all requirements. Meanwhile , to enforce the terms of the statement, we make online and offline checks on suppliers' fulfillment of social/environmental responsibilities on a yearly basis, and in doing so evaluate their CSR performance while at the same time identify risks and improvement opportunities. For suppliers that do not meet the requirements, we help them improve within the specified time. Suppliers that fail to make satisfactory improvements will be replaced with other suppliers that meet our ethical and environmental standards. Furthermore, we maintain regular contact with suppliers and conduct annual reviews, unscheduled surveys etc., to make sure that they keep up the expected standards.

As part of our corporate social responsibilities, Primax Electronics has implemented policies to prohibit use of child labor and forced labor, whereas stringent recruitment processes and regular internal reviews are being carried out to eliminate even the slightest chance of occurrence. Meanwhile, all potential and existing supply partners are required to comply with regulations and rules of RBA concerning prohibition of child labor.

In terms of integrity commitment, Primax requires all its suppliers and their employees to maintain integrity in all trading and transaction activities, including but not limited to: procurement of materials, work contracting, outsourced production, transfer of equipment, treatment of obsolete/waste materials, customs reporting, workforce dispatch, and subcontracting. Suppliers are encouraged to report any intentional or unintentional violation of proper procurement conduct by a Primax employee. These incidents may be reported via physical mail or e-mail through the following channels with details such as the employee's name, supplier's contact method, the violation committed or relevant evidence.

• Grievance hotline:：+886-2-27989008 ext：1046
• Email：This email address is being protected from spambots. You need JavaScript enabled to view it.

Supplier Training

Primax devotes to the participation of stakeholders and strive to create more opportunities and resources for suppliers to learn and improve, so as to achieve continues progress, and we will continue to follow up suppliers to control the potential risks. This is why we have engaged a third-party institution since 2015 to organize annual social responsibility training for suppliers. In 2022 , training was conducted online, with a total of 204 suppliers (including 60 of Tymphany) participating in the social and environmental responsibility network seminar developed by a third-party, Elevate. All participants completed the post-training assessments with a 100 % pass rate. We will continue to promote social responsibilities in the future and devise suitable and effective courses that conform to suppliers' needs.

To sum up, as of 2022 , Primax has covered a total of 1 , 754 suppliers through social and environmental responsibility questionnaires, on-site audits, online training, and advocacy.

Working Hand in Hand with Suppliers for Sustainability

In 2023 , we will respond to higher standards of supplier management principles, improve our supplier management mechanisms, and continue to demand that suppliers strengthen their focus on social and environmental responsibilities and enhance their management capabilities, collaborating with them to make continuous progress. To achieve this, we have formulated the following plans and are gradually implementing them:

• In 2022, we conducted a preliminary survey on the climate response status of the supply chain to serve as a reference for formulating climate change action plans in the future. We completed initial questionnaires for 234 key suppliers in 2022.
• We conducted surveys on greenhouse gas emissions and carbon reduction status for key suppliers to plan for climate change management and develop appropriate strategies in 2023. The responses from suppliers were evaluated and categorized into positive, managed, and disclosed statuses (excluding low-impact and low-control vendors such as overseas and agents).
• In 2023, we will actively engage in communication and greenhouse gas inventory checks related to the supply chain's climate change actions, as well as conduct training activities for experience sharing on emission reduction, and establish an ESG system for suppliers to facilitate continuous and systematic communication and documentation of climate change activities in the supply chain.