The purpose of this report is to demonstrate that Lanix supports government initiatives aimed at public disclosure regarding Conflict Minerals originating from the Democratic Republic of Congo, which include tin, tantalum, tungsten, and gold used in electronic components. In this regard, Lanix is committed to operating in a socially and environmentally responsible manner, rigorously complying with current legislation and, especially, with our customers’ expectations. We recognize that corporate transparency and adherence to standards are fundamental to consumer trust.

Lanix markets products under its own brand, whose components are manufactured by third parties. Therefore, this report also aims to assure customers that our products are free of materials derived from Conflict Minerals originating from the Democratic Republic of Congo

Since our electronic component suppliers are globally dispersed, Lanix is disconnected from the direct origin of the supply chain of the products we distribute. However, we are committed to ensuring that our suppliers provide conflict-free materials originating from the Democratic Republic of Congo. We also encourage our suppliers to investigate the origin of Conflict Minerals and follow the appropriate protocols to ensure the integrity of this process.

Lanix is committed to taking appropriate actions, including suspending purchases from suppliers who fail to cooperate or comply with our Conflict Minerals policies. We will resolve any potential violations of these policies and report our progress through public reports.

It is our expectation that our suppliers maintain detailed records of their activities and provide us with accurate information regarding the origin of the Conflict Minerals used in the products supplied to Lanix. This enables us to demonstrate their compliance with accepted standards and requirements.

Additionally, Lanix expects suppliers not to provide products containing Conflict Minerals from the Democratic Republic of Congo without proper certification of their

conflict-free status. Suppliers must notify us in advance of any situation related to these minerals and acquire them exclusively from sources that guarantee their conflict-free status.

We urge our suppliers to support both governmental and industrial efforts to ensure the responsible management of the Conflict Minerals supply chain.

Lanix supports the public disclosure initiative regarding the management of Conflict Minerals and understands its relevance to our customers. We are committed to leading responsible initiatives that promote a conflict-free supply chain in the Democratic Republic of Congo. This includes ensuring that our products do not contain materials derived from Conflict Minerals, which will be documented in publicly accessible online reports. Furthermore, we will publish an annual report explaining our supply chain so that customers can trust that our products are free of Conflict Minerals from the Democratic Republic of Congo. Likewise, we collaborate with suppliers who can certify the origin of their raw materials, thus strengthening customer confidence in our products.

Conflict Minerals Policy

Lanix is committed to responsible sourcing practices and ensuring that the materials used in our products are obtained in a way that respects human rights and prevents the financing of armed conflicts. This policy establishes our commitment to addressing the issue of Conflict Minerals in our supply chain.

This policy applies to all suppliers providing components, materials, or products used in the manufacturing of Lanix computers and related devices.

Conflict Minerals include tin, tantalum, tungsten, and gold (known as “3TG”) that may originate from conflict-affected and high-risk areas, such as the DRC and its neighboring countries.

Lanix de America is committed to:

Responsible Sourcing: Working to procure materials from suppliers who share our commitment to ethical and responsible practices.

Supplier Accountability: Requiring suppliers to provide documentation verifying the origin of 3TG minerals included in the products they supply to us.

• To ensure compliance with this policy, Lanix expects all its suppliers to:

• Adopt and comply with a Conflict Minerals policy consistent with this document.

• Identify and disclose the smelters and refineries in their supply chains to ensure traceability of 3TG minerals

• Provide evidence of their efforts to source conflict-free minerals, including audits and certifications.

• Immediately address any identified risks or issues related to Conflict Minerals in their supply chains.

Collaboration and Continuous Improvement

We understand that achieving a conflict-free supply chain is a shared responsibility. Lanix is committed to working with suppliers, industry groups, and other stakeholders to improve supply chain transparency and promote responsible sourcing practices.

Non-compliance with this policy or refusal to cooperate in our due diligence efforts may result in termination of the supplier relationship.

Suppliers or stakeholders with questions about this policy or concerns related to Conflict Minerals may contact us at green@lanix.com.

Lanix de América remains steadfast in its dedication to ethical sourcing and will continue refining and strengthening its efforts to ensure its supply chain is free of Conflict Minerals.

Reasonable Country of Origin Inquiry (RCOI)

We conduct a Reasonable Country of Origin Inquiry (RCOI) to determine whether any Conflict Minerals used in our 2024 products originate from the DRC or neighboring countries (referred to as “Covered Countries”), or if these Conflict Minerals were obtained from recycled or scrap sources.

For this purpose, we collect and evaluate sourcing information about the entities supplying essential Conflict Minerals used in the functionality or manufacturing of our products, specifically minerals such as gold and derivatives of tin, tantalum, and tungsten.

We request our direct suppliers to provide relevant information and identify the entities supplying them with these essential minerals. Additionally, Lanix’s social and environmental responsibility requirements, which include due diligence and reporting obligations on Conflict Minerals, are incorporated into our contracts with direct suppliers.

Description of Due Diligence Measures Undertaken

We conduct a due diligence process to trace the origin and supply chain of essential Conflict Minerals obtained from relevant 3TG facilities.

Although we do not directly manufacture components, our company takes proactive measures to ensure our supply chain operates in a responsible, transparent, and sustainable manner. Through rigorous supplier assessments, compliance documentation, and testing protocols, we uphold industry standards and contribute to responsible sourcing practices.

1. Supplier Verification and Assessment

   We conduct risk-based assessments of our suppliers to verify their adherence to environmental, social, and governance (ESG) standards.

   We prioritize working with vendors that are RoHS-compliant, and REACH-certified to ensure component materials meet sustainability and safety standards.

2. Responsible Sourcing Policies

   We request Material Declarations and Certificates of Compliance to confirm the absence of restricted substances like bromine and chlorine.

3. Documentation and Traceability

   We maintain detailed records of supplier agreements, test reports, and compliance certificates to support audit requirements.

   A traceability system is in place to track the origin of critical components and materials used in our assembly process.

   We periodically request updated declarations from suppliers regarding material composition and supply chain transparency.

4. Third-Party Audits and Testing

   When necessary, we engage third-party laboratories to verify compliance with material safety regulations, such as bromine and chlorine testing to meet EPEAT standards.

   We conduct supplier audits in collaboration with industry partners to assess compliance with ethical sourcing and sustainability criteria.

5. Continuous Improvement and Risk Mitigation

We regularly review and update our due diligence procedures to align with evolving regulatory requirements and best practices.

Our procurement team engages in supplier training programs to enhance awareness of sustainability and compliance expectations.

In cases of non-compliance, we implement corrective action plans and may seek alternative suppliers to mitigate risks.

Lanix de America Role in the Supply Chain and Conflict Minerals Due Diligence

Lanix is not a manufacturer, nor does it engage in “contract to manufacture” as defined by the Dodd-Frank Act for a significant portion of our procurement spend. We primarily operate as a final assembly and testing entity, while our suppliers function more as retailers. Many of our supplier relationships are better characterized as Lanix serving as a “sales channel” rather than outsourcing manufacturing. Nonetheless, Lanix conducts conflict minerals due diligence on its supply chain despite these considerations.

The OECD Guidance requirements acknowledge Lanix position within the broader supply chain, where we sell technology products and services to end-users and act as a “downstream” retailer. For a significant number of the components we procure, Lanix has no direct influence over their composition, materials, or manufacturing. Many of these are standardized products for which we only specify or negotiate contractual terms unrelated to production (e.g., price and legal conditions). We do not dictate the composition of CPUs, storage devices, memory, circuit boards, batteries, or other electronic components beyond compliance with hazardous substance regulations.

We are positioned multiple tiers away from the mining operations and the actual extraction process.

As a result, there are challenges in data accuracy, coverage, confidentiality, scope, language, communication, and transparency within the supply chain. Once raw ores are smelted, refined, and processed into ingots, bullion, or other conflict mineral derivatives, it becomes difficult to determine their origin with certainty from Lanix position in the supply chain.

Lanix de America 3TG List

This document provides a detailed list of the 3TG (Tantalum, Tin, Tungsten, and Gold) materials present in our supply chain. It includes information on the sources, suppliers, and usage of these minerals in our products. Our goal is to ensure transparency and compliance with conflict minerals regulations by identifying and tracking the origin of these materials in accordance with industry standards and due diligence guidelines.