HuiTongDa Tech Co. Ltd – Human Rights Policy

Preamble

HuiTongDa Tech Co. Ltd (hereinafter referred to as “we” or “the Company”) is committed to upholding and protecting human rights across all aspects of our operations. Based in Shenzhen, China, and serving customers and partners worldwide, we believe that every individual deserves to be treated with dignity, fairness, and respect.

Respect for human rights is both a moral responsibility and a cornerstone of our long-term sustainable growth. This policy outlines our commitments, principles, and expectations regarding human rights within our own operations and throughout our supply chain.

We adhere to internationally recognised human rights standards, including the United Nations Guiding Principles on Business and Human Rights, the Ten Principles of the United Nations Global Compact, and other relevant conventions.

1. Our Commitment to Human Rights Protection

1.1 Identification of Significant Human Rights Risks

We recognise the importance of identifying and addressing human rights risks in our business and supply chain.

1.1.1 Human Trafficking & Forced Labour

We strictly prohibit any form of human trafficking or forced labour. All employment relationships within HuiTongDa Tech Co. Ltd and our supply chain are based on voluntariness and equality.

1.1.2 Child Labour

We do not employ anyone below the legal minimum working age in any country where we operate, and we take active measures to prevent child labour in our supply chain.

1.1.3 Freedom of Association & Collective Bargaining

We respect employees’ rights to organise, join associations, and engage in collective bargaining.

1.1.4 Equal Pay for Equal Work

We ensure fair pay for all employees, regardless of gender, race, religion, nationality, or other personal characteristics.

1.1.5 Non-Discrimination

We are committed to maintaining a workplace free from discrimination of any kind.

1.1.6 Other Rights

We respect privacy, freedom of expression, and the right to a safe and healthy working environment.

1.2 Human Rights Practices in Our Operations

1.2.1 Employees

• Transparent and fair recruitment processes
• Safe and hygienic working environments
• Fair remuneration systems
• Equal career development opportunities

1.2.2 Direct Business Activities

• Full compliance with all applicable laws
• Human rights impact assessments for major business decisions
• Environmentally responsible operations

1.2.3 Products & Services

• Strict quality and safety compliance for all iPhones and electronic products we distribute
• Accessibility considerations in customer services

1.3 Supplier Requirements

We require all suppliers, contractors, and partners to:

• Comply with human rights laws
• Avoid forced labour, human trafficking, and child labour
• Implement safe and fair working conditions
• Allow audits to verify compliance

Failure to meet these requirements may result in contract termination.

2. Human Rights Risk Assessment & Mitigation

We use a risk-based approach to identify, evaluate, and mitigate human rights risks within our operations and supply chain.

• Risk Assessment Methodology based on OECD guidelines and industry standards
• Stakeholder Engagement with employees, suppliers, and communities
• Mitigation Measures including internal policy enforcement, training, and supplier collaboration

3. Grievance Mechanism

We provide clear and confidential channels for reporting human rights concerns:

• Email: huitongdatech.cn@gmail.com
• Anonymous Reporting: Allowed and protected against retaliation
• Investigation Process: Prompt, impartial, and handled by designated personnel
• Corrective Actions: Implemented when violations occur

4. Oversight & Review

• Internal Monitoring: Regular audits and policy reviews by our HR and compliance teams
• External Review: Engagement with independent auditors and human rights experts

5. Continuous Improvement

• Periodic evaluations of our human rights practices
• Adjustments based on evolving best practices and legal requirements
• Training programs for staff and suppliers

HuiTongDa Tech Co. Ltd will continue to integrate respect for human rights into all aspects of our business operations, ensuring that our growth and success benefit our employees, partners, customers, and the communities we serve.

HuiTongDa Tech Co. Ltd

Shenzhen, China

March 2025