亞 洲 鎢 品 有 限 公 司

Asia Tungsten Products Co Ltd (Hong Kong) Annual Due Diligence Report 2015

Asia Tungsten Products Co Ltd (HK) owns 100% of the Vietnamese charter capital company Asia Tungsten Products Vietnam Ltd which operates a ferrotungsten refinery located in the Vinh Bao District, Haiphong, Vietnam. Asia Tungsten Products Co Ltd (ATC) itself operates under an Incorporated Joint Venture and Shareholder Agreement between Hazelwood Resources, an Australian Stock Exchange listed company and Chen Guangyu, a private investor.

Both ATC and Hazelwood Resources Limited condemn all activities in the raw material sector connected to illegal or unlawful exploitation of ores that directly or indirectly finances or benefits armed groups in conflict areas. Both ATC and Hazelwood support the goals and objectives of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  This commitment can be viewed on the Hazelwood Website at http://hazelwood.com.au and on the ATC Website at http://vonframachau.com.vn/index.php/news/atc-policy--13.htm.

ATC has a strong commitment to the principles behind the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. Both Hazelwood and ATC adopted the OECD Guidance as a policy item for procurement of tungsten raw materials on 19^th December 2012.

ATC was granted full membership to iTSCi on the 25th September 2014.

Tungsten Mineral Purchasing

Decision making in regards to the procurement of tungsten for the ferrotungsten refining operation in Vietnam occurs through the Hong Kong company. All members of the Material Procurement committee take responsibility for the informing of potential mineral suppliers of the Company's Conflict Minerals Policy Statement with mineral suppliers being asked to sign a Supplier Declaration of Agreement with ATC Conflict Minerals Policy.

A comprehensive due diligence checklist is used to ensure that all purchases of tungsten minerals conform to the company policies, with the purchasing of concentrate from Level 3 countries coming only from iTSCI full member suppliers that use the iTSCI tag system. Documents from each supply of tungsten raw materials are kept on site for supply chain audits. The Company is using the iTSCI due diligence programme to review the origin of the material and assess through the provision of iTSCI incident reports, assessment summaries and district and mine visit reports if the material meets the guidelines and conforms to the Company's Conflict Minerals Policy.

All senior ATC-VN operations personnel involved in the chain of custody of tungsten minerals have also signed and committed to the policy. Operations Personnel have received training in regards to the Conflict Minerals Policy through routine Safety and Policy training sessions.

2015 Activities

Operations Personnel have received training in regards to the Conflict Minerals Policy through routine Safety and Policy training sessions.

During October 2015 ATC has successfully completed its second annual EICC - GeSI Conflict Free Smelter (CFS) Audit and was found to be compliant with the CFSP tungsten protocol.

Additional procedures have been developed to capture non-conformances within the purchasing and documentation systems to enable the continual development of due diligence procedures.

Future Commitment

Asia Tungsten Products Co Ltd (Hong Kong) and its wholly owned subsidiary Asia Tungsten Products Vietnam Ltd. continues to support iTSCI initiatives and actions and will continue to assess and develop due diligence procedures to ensure that all tungsten minerals purchased support the aims of a conflict free supply chain.