Acer Incorporated 2024 Responsible Minerals Report

Introduction

Acer has a long-standing commitment to ensuring the responsible sourcing of minerals in its supply chain, beginning in 2009 with supplier engagement on conflict minerals. Acer joined the Responsible Minerals Initiative (RMI) and participated in the development of the Conflict Minerals Reporting Template (CMRT) and the Responsible Minerals Assurance Process (RMAP). In 2014, Acer released its first conflict minerals report and joined the Public-Private Alliance for Responsible Minerals Trade (PPA). For the past two years, Acer has achieved its goal of having 100% of its 3TG SORs conformant or participating in an OECD-aligned 3rd party assessment program.

This report covers the period from January 1 to December 31, 2024, detailing Acer's due diligence efforts on the source and chain of custody of gold, columbite-tantalite (coltan), cassiterite, wolframite, tantalum, tin, and tungsten (collectively "3TG") that may have originated from the Democratic Republic of the Congo ("DRC") or adjoining countries, and may not have come from recycled or scrap sources. The report also includes due diligence efforts for cobalt in lithium-ion battery supply chains and mica in coatings, identified as priority minerals originating from Conflict-Affected and High-Risk Areas (CAHRAs) or other high-risk areas.

Terms used include "responsible minerals" for Acer's due diligence programs, "priority minerals" for minerals identified in the supply chain with a risk of originating from CAHRAs, and "conflict minerals" specifically relating to 3TG sourced from the DRC.

Founded in 1976, Acer is a global ICT company with a presence in over 160 countries, focused on integrating hardware, software, and services. Acer employs 7,700 individuals dedicated to research, design, marketing, sales, and support of technology solutions.

Reasonable Country of Origin Inquiry (RCOI)

Acer conducted an RCOI using supply-chain surveys with direct suppliers via the CMRT and Extended Minerals Reporting Template (EMRT) to determine the origin of necessary 3TG and cobalt. Smelters or refiners (SORs) identified were compared against RMI's known SOR lists and those validated by OECD-aligned 3rd party assessment programs like RMAP, LBMA, or RJC.

When country of origin could not be determined through validation programs, Acer engaged in direct contact with SORs, reviewed industry-led program outreach, or utilized shared outreach results from suppliers. In 2024, Acer identified 219 3TG and 67 cobalt SORs. The RCOI results are visualized in Figures 1 and 2.

Figure 1: Reasonable Country of Origin Inquiry - 3TG

The pie chart shows the following distribution for 3TG SORs: 101 "Unknown", 45 "Excludes Covered or Other High Risk Countries", 41 "Includes Covered Countries", 18 "Recycled/Scrap only", and 14 "Includes Other High Risk Countries".

Figure 2: Reasonable Country of Origin Inquiry – Cobalt

The pie chart shows the following distribution for Cobalt SORs: 24 "Unknown", 29 "Includes Covered Countries", 10 "Excludes Covered or Other High Risk Countries", 3 "Includes Other High Risk Countries", and 1 "Recycled/Scrap only".

Based on RCOI results, Acer believes some necessary 3TG and cobalt may have originated in the DRC, Covered Countries, or other high-risk countries and may not be from recycled or scrap sources. Acer has exercised due diligence conforming to a recognized framework, as described in this RMR.

Design of Acer's Due Diligence Measures

Acer has implemented a responsible minerals due diligence program aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. As a brand company, Acer does not purchase raw ore and has no direct purchases in CAHRAs. Acer relies on its first-tier suppliers to identify and assess risks and provide information on SORs. Requirements are passed down to indirect suppliers.

Acer's due diligence follows the 5-Step OECD Framework:

1. Establish strong company management systems: Maintain a cross-functional Responsible Minerals Program Management Team, update the internal data management system (ARSM), maintain a public responsible minerals policy, revise procedures and risk management plans, operate a grievance mechanism (whistleblower.acer@acer.com), and provide capacity building to internal personnel and suppliers.
2. Identify and assess risks in the supply chain: Conduct annual surveys (CMRT for 3TG, EMRT for cobalt and mica) with a 100% direct supplier response rate. Consolidate survey responses, compare with RMI lists and RMAP to verify SORs and status. Conduct audits to verify due diligence program implementation. Utilize the Responsible Business Alliance's (RBA) Standards Comparison and Risk Readiness Assessment (RRA) tool.
3. Design and implement a strategy to respond to identified risks: Engage suppliers through the ARSM system, participate in RMI's Smelter Engagement Team, conduct direct outreach to SORs to encourage RMAP participation. Issue "Smelter Action Required Lists" to suppliers and escalate non-responsive suppliers. Distribute a high-risk prohibited SOR list, removing identified high-risk SORs from the supply chain. Measure conflict minerals KPIs in Acer's supplier ESG scorecard. Monitor RMI Grievance and Complaints Mechanism cases.
4. Carry out independent third-party audit of smelter/refiner's due diligence practices: Continued support of the RMAP.
5. Report annually on supply chain due diligence: Published an updated list of known SORs and reported via this RMR.

Description of Due Diligence Measures Performed

During the reporting period, Acer performed the following due diligence measures:

• Established strong company management systems: Maintained a cross-functional Responsible Minerals Program Management Team, updated the Acer Responsible Supply Chain Management System (ARSM), updated the public responsible minerals policy to include new minerals for 2025 (aluminum, copper, graphite, lithium, nickel), revised procedures and risk management plans, maintained a grievance mechanism, and provided capacity building through supplier ESG communication meetings and ARSM system functionality.
• Identify and assess risks in the supply chain: Conducted annual surveys for 3TG (CMRT) and cobalt/mica (EMRT) with 100% direct supplier response rates. Consolidated and compared survey responses with RMI lists and RMAP for verification. Conducted audits with no findings in 2024. Utilized the RBA's RRA tool, receiving results from 188 SOR facilities.
• Design and implement a strategy to respond to identified risks: Continued supplier engagement via ARSM, participated in RMI's Smelter Engagement Team, and engaged 10 SORs directly to encourage RMAP participation. Issued "Smelter Action Required Lists" and escalated non-responsive suppliers. Distributed a high-risk prohibited SOR list, resulting in the removal of 12 identified SORs from Acer's supply chain. Measured conflict minerals KPIs in Acer's supplier ESG scorecard, with 94.5% of suppliers rated "Good" and 5.5% "Needs Improvement".
• Carry out independent third-party audit of smelter/refiner's due diligence practices: Continued support of the RMAP.
• Report annually on supply chain due diligence: Published an updated list of known SORs and reported via this RMR.

In-Region Clean Minerals Trade

Acer supports projects and organizations that promote economic development and stability in the Great Lakes Region and contribute to RMAP tools and processes. Acer monitors the activities of the ICGLR-OECD-UN Joint Forum on Responsible Mineral Supply Chains and continued its involvement in the PPA, attending the thirteenth annual multi-stakeholder membership meeting in November 2024.

Results of Due Diligence Measures

In 2024, Acer identified 219 unique 3TG, 67 cobalt, and 6 mica SORs in its supply chain, based on supplier survey responses and RMI information. The report provides year-over-year progress updates for 3TG, cobalt, and mica (Figures 3, 4, & 5), and a 2024 status breakdown by metal (Figure 6).

Figure 3: 3TG Progress

This bar chart shows the number of 3TG SORs from 2020 to 2024, categorized as "Conformant", "Participating", and "Outreach". In 2024, there were 214 "Conformant", 5 "Participating", and 0 "Outreach" SORs.

Figure 4: Cobalt Progress

This bar chart shows the number of Cobalt SORs from 2020 to 2024, categorized as "Conformant", "Participating", and "Outreach". In 2024, there were 48 "Conformant", 13 "Participating", and 6 "Outreach" SORs.

Figure 5: Mica Progress

This bar chart shows the number of Mica SORs from 2020 to 2024, categorized as "Conformant", "Participating", and "Outreach". In 2024, there were 3 "Conformant", 2 "Participating", and 1 "Outreach" SORs.

Figure 6: 2024 Status, by metal

This bar chart displays the status of SORs for Gold, Tantalum, Tin, Tungsten, Cobalt, and Mica in 2024. For Gold, there are 95 "Conformant" and 2 "Participating". For Tantalum, 34 "Conformant". For Tin, 51 "Conformant" and 1 "Participating". For Tungsten, 34 "Conformant" and 2 "Participating". For Cobalt, 48 "Conformant", 13 "Participating", and 6 "Outreach". For Mica, 3 "Conformant", 2 "Participating", and 1 "Outreach".

Acer achieved 100% of its 3TG SORs conformant or participating in an OECD-aligned 3rd party assessment program, and 81% for cobalt. Acer aims to maintain 100% for 3TG and increase cobalt SORs to 75% conformant or participating in 2025.

Future Due Diligence and Risk Mitigation Measures

Acer will continue to improve due diligence and mitigate supply chain risks by:

• Reviewing and updating policies, procedures, risk-management plans, and program metrics.
• Supporting due diligence processes for other priority minerals through multi-stakeholder initiatives like RMI.
• Working with suppliers to increase SOR identification accuracy, support SOR engagement, and drive sourcing from RMAP-conformant SORs.
• Encouraging SORs to participate in and achieve RMAP conformant status.
• Continuing participation in the RMI Smelter Engagement Team.
• Conducting supplier audits to evaluate responsible minerals policies and practices.
• Measuring and grading supplier due diligence performance via the corporate social responsibility scorecard.
• Supporting in-region projects and organizations that boost economic development and mitigate risks.
• Setting targets for 2024: 100% of 3TG and 75% of cobalt SORs conformant or participating.
• Improving mica processor identification and adding aluminum, copper, graphite, lithium, and nickel to the responsible minerals due diligence program.

Appendix A - 3TG Supply Chain Indicators

Appendix B - Other Minerals Supply Chain Indicators

Appendix C - Smelter or Refiner List

Acer publishes a list of tantalum, tin, tungsten, gold, cobalt, and mica SORs confirmed in its supply chain, updated annually. For the most current information, visit the Responsible Minerals Initiative website at www.responsiblemineralsinitiative.org.

*Status is defined as follows: Conformant: Smelters or refiners compliant with RMAP or similar programs. Participating: Committed to RMAP audit, Active or In-Progress. Outreach: Not agreed to participate, but Acer is assisting. **SORs conformant or participating in 2024 but became non-conformant in 2025; Acer is working to remove them. ***The smelter was not identified by RMI or Acer on or before 12/31/2023 and gained status in 2024.