Our Focuses｜Sustainable Supply Chain｜Conflict Minerals

Responsible Sourcing of Minerals

Winbond continued to implement the requirements of Responsible Business Alliances requirements in the supply chain and considers them to be a mandatory element of supply chain management. In accordance with the management recommendations of the OECD due diligence, Winbond first issued a conflict-free minerals statement. Secondly, the material analysis is carried out according to the composition of the company's products, and the key suppliers that need to be investigated are identified to facilitate the implementation of due diligence. Suppliers are strictly required to select qualified smelters and update the information within the validity period. Finally, based on the annual survey results, Winbond published the due diligence report on conflict minerals for public disclosure. In 2025, suppliers directly related to Winbond products involving 3TG metals, cobalt, mica and other minerals included 18 suppliers for Winbond (Taiwan), 21 suppliers for Nuvoton (Taiwan), and 49 suppliers for Nuvoton (Japan). Winbond (Taiwan) also conducted on-site audits for 9 suppliers, achieving a 100% qualified rate.

Responsible Sourcing Management Process

Winbond Conflict-free Minerals Statement

Winbond follows the RMI to conduct due diligence on the sources and regulation of gold (Au), tantalum (Ta), tungsten (W), tin (Sn), cobalt, mica, copper, nickel, natural graphite, and lithium contained in its products, to ensure that its sourcing practices are in alignment with the OECD Guidelines for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework. Winbond also requires all suppliers to comply with and sign the sustainability-related codes of conduct and ethical standards, employee ethics standards, the International Declaration of Human Rights and the International Labor Organization's Tripartite Declaration of Principles, the adoption of green products, environmental protection and hazardous substance free (HSF) policies, or comply with the requirements set by the Responsible Business Alliance (RBA). In 2025, all qualified suppliers signed the Winbond Code of Ethics and Integrity and the Winbond Supplier Code of Conduct Commitment (including the terms of the RBA and Conflict Minerals Statement) to avoid the use of minerals originated from non-compliant smelters. Suppliers shall ensure that such minerals do not directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC), its adjoining countries, or other conflict-affected and high-risk areas, and comply with all applicable regional and international laws and regulations on responsible mineral sourcing.

Identification and Results of 3TG Metal Sources

Winbond first reviewed the Safety Data Sheets provided by the supplier to determine product composition and identify whether specific metals were included. Winbond then adopted the Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) to survey suppliers whose product composition involves gold (Au), tantalum (Ta), tungsten (W), tin (Sn), cobalt (Co), mica, copper, nickel, and other responsible mineral sources as reported in the Responsible Minerals Initiative (RMI). In 2025, surveyed suppliers included 18 suppliers for Winbond (Taiwan), 21 suppliers for Nuvoton (Taiwan), and 49 suppliers for Nuvoton (Japan), with smelter sources come from various countries include spanning North America, South America, Europe, Asia, and Central Asia. Qualified smelters included 67 for Winbond (Taiwan), 191 for Nuvoton (Taiwan), and 226 for Nuvoton (Japan). In addition, Winbond has also formally implemented on-site conflict minerals audits to reinforce its conflict-free commitment and ensure suppliers’ management commitments. In 2025, all suppliers comply with the requirements and have not been prohibited from selling related products to Winbond.

Due to the ever-changing nature of global political relationships, intergovernmental conflicts or even wars between countries in recent years can arise with little warning. To ensure that Winbond abides by its commitment to not using conflict minerals, Winbond has implemented three measures to manage and control risks related to the use of 3TG metals. First, Winbond continued to issue regular due diligence surveys and annual due diligence reports on conflict minerals, and simultaneously expanded to suppliers who use 3TG metals, conducting on-site audits to ensure their practices are consistent with their stated policies. Second, we continued to trace the compliant 3TG sources domestically and internationally, and the suppliers implementing conflict minerals management policies to diversify supply risks to implement diversified supply risk control and conflict prevention of mineral sources. Third, for suppliers with potential conflict minerals risks, Winbond supported traceability toward other compliant minerals; if improvements were not achieved, Winbond would cease business with the supplier. Winbond's supply chain team was also actively monitoring stakeholders' requirements for conflict minerals management, dynamically adjusting internal supplier management measures based on a principle of proactive prevention, hoping to ensure the humane spirit of mineral extraction with the strictest standards. 
In 2025, in accordance with the regulations of the RBA and U.S. Securities and Exchange Commission, Winbond Taiwan also actively responded to the U.S. Dodd-Frank Act (DFA) and strengthened the implementation of corporate social responsibility. Winbond Taiwan will label all product outer packaging with a “Conflict-free” mark to clearly declare that the company's products were manufactured without the use of conflict minerals. 
 

• 2025 Winbond Responsible Minerals Due Diligence Report