Sustainable Supply Chain

GCL Technology focuses on collaborative supply chain management with a customer-oriented approach.At key processes spanning fromsupplier access, cooperation to review, we factor in ESG issues including environmental protection, labor protection,and complianceintegriy. Additionally, the Group has estabished the Supply Chain Management Commitee and the Supply Chain Management Department of the Silicon Industry Group. Each base has its supply chain management department which, following the authorization principle, handles specific tasks under the guidance of themanagement system and the leadership of the Group. This tiered approach ensures that policies and actions are cascaded throughout theorganization, moving our supply chain progressively toward a more transparent, responsible, and sustainable system.

Supplier Code of Conduct

GCL Technology formulated the GCL Technology Supply Chain Partner Code of Social Responsibility with its partners, further reinforcing ESG management and requirements for suppliers, stimulating positive changes among supply chain partners, andjointly promoting the sustainable development of the industry.

Environmental Protection

Properly dispose of and store hazardous materials and waste, such as harmful substances and wastewater management;

Avoid or minimize impacts on biodiversity in production and operational activities, with no involvement in deforestation, destruction of natural ecological reserves, or similar behaviors;

Implement conservation and substitution measures, such as using renewable energy to replace traditional energy sources;

Keep abreast of national and international environmental protection legislation to mitigate compliance risks.

Labor Protection

Health and Safety

Comply with legal and contractual safety standards;

Implement a "one-vote veto" system for major safety incidents;

Control hazards and take measures to prevent accidents and occupational diseases;

Provide training on health and safety issues to ensure the safety of oneself and colleagues.

Human Rights

Prohibit the employment of child labor and forced labor, and prohibit any form of discrimination or unfair treatment;

Protect employees' freedom of association and the right to collective bargaining;

Provide fair compensation;

Prohibit human trafficking.

Integrity and Compliance

Abide to GCL Technology’s Sunshine Procurement Principles;

Potential suppliers participating in procurement bidding must sign the Supplier Anti-Bribery and Anti-Fraud Commitment Letter;

Suppliers are required to sign the GCL Technology Supply Chain Partner Code of Social Responsibility with its partners;

Prohibit any form of corruption or bribery by employees, third parties, or intermediaries;

Suppliers shall establish complaint, reporting, and whistleblower protection mechanisms; comply with anti-monopoly and fair competition laws in the countries/regions where they operate, and refrain from any unfair competitive practices.

ESG integration in the supply chain

GCL Technology prioritizes ESG topics such as environmental protection, labor rights, ethical compliance, and workplace safety. The Group developed and signed the GCL Technology Supply Chain Partner Code of Social Responsibility with its partners. Preference is given to suppliers with relevant ESG certifications, and ongoing efforts are made to encourage continuous ESG performance improvement. In 2024, the Group introduced new governance documents including the Sustainable Procurement Policy and the Supply Chain Due Diligence Guidelines. Core suppliers were required to sign the Conflict Minerals Declaration to ensure responsible sourcing and enhanced ESG risk control. These measures are part of a broader effort to standardize ESG practices and elevate sustainability performance across the supply chain.

ESG due diligence and risk management

In accordance with the Supply Chain Due Diligence Guidelines, GCL Technology systematically conducts annual ESG risk assessments for suppliers and standardizes risk identification, assessment, management, and appeal mechanisms. Through a three-dimensional screening mechanism of "supplier self-assessment + Company review + third-party data comparison," the Group conducts a comprehensive review of suppliers' performance in environmental, social and governance (ESG), and material traceability. In 2025, we systematically identified 251 suppliers with significant business relevance to the Group (including 18 tier-one key suppliers and 233 nontier-one key suppliers), and conducted special ESG audits of 50 core and key suppliers, identifying a cumulative total of 593 improvement items. We implemented tiered risk controls and promoted targeted rectification and improvement. Among the 50 important suppliers that completed on-site or questionnaire-based assessments, we found no significant negative ESG impacts and no suppliers had theircooperation terminated during the year.