Raw Material Policy for the TANIOBIS Group

Pol-Grp-004, 3, 2023-30-06

This policy is valid for the TANIOBIS GmbH, Germany and its affiliates TANIOBIS Smelting GmbH &Co.KG; TANIOBIS Japan Co. Ltd.; TANIOBIS Co., Ltd., Thailand and TANIOBIS USA LLC.
TANIOBIS Group is one of the leading global manufacturers of technology metals tantalum andniobium. We are committed to ensuring safety, health and protection of the environment and of thepeople in contact with our products. As responsible corporate citizens, we pursue excellence infulfilling governmental, industrial and environmental standards worldwide. We are committed tocomply to all relevant sanctions, in particular UN resolutions, as well as all national and international
legislations, especially the REGULATION (EU) 2017/821 Supply chain due diligence obligations forUnion importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affectedand high-risk areas.
With this policy, we fully commit the whole TANIOBIS Group to the OECD Due Diligence Guidanceon Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. As
elaborated in Annex 2 of the guidance:-We condemn all activities in connection to unlawful exploitation of mineral resources, nomatter where such activities take place. Furthermore, we do not accept any forms of torture,cruel, inhuman and degrading treatment.
We commit ourselves to avoid any measures that may help to finance conflicts.
We don’t accept any forms of forced or compulsory labor, which means work or service
which is exacted from any person under the menace of penalty and for which said person
has not offered himself voluntarily
We will not tolerate any direct or indirect support to non-state armed groups nor tolerate thesupport of public and private security forces exercising unlawful control over mining sites,
transport routes, etc.
We will not tolerate other gross human rights violations and abuses such as widespreadsexual violence
We commit ourselves to avoid the worst forms of child labour in the supply chain according
ILO Convention No.182
We will not tolerate war crimes or other serious violations of international humanitarianlaw, crimes against humanity or genocide
According to our Code of Conduct, we do not accept bribes in any form and do not accept
any form of money laundering in our supply chain.
We urge all our suppliers and subcontractors to ensure all taxes, duties and royalties payable
relating to the raw materials supplied to us.

In case we identify the aforementioned risks in our supply chain, we will immediately suspend or
discontinue activities which such partners.
Moreover, we apply the Due Diligence systems:--

have a due diligence system for transparent commodity supply from Conflict Affected andHigh Risk Areas (CAHRAs) that meets the requirements of the OECD Guidance on
Responsible Supply Chains of Minerals from Conflict - Affected and High - Risk Areas these
are currently the International Tin Supply Initiative (ITSCI) and the Better Sourcing
Program (BSP) andof our own Responsible Supply Chain Management (RSCM), an internal supplierqualification system to formalise supervision and selection of mining, as well as trading
activities.

We undergo a yearly third-party audit according the assessment protocol designed by theResponsible Minerals Initiative (RMI) to maintain our Conformant Smelter Status.
The latest version of this guideline is exclusively available in the document control system SYCAT.

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Raw Material Policy for the TANIOBIS Group

Pol-Grp-004, 3, 2023-30-06

We are committed to actively support our customers with their diligence and disclosure requirements
defined in section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
pertaining to “Conflict Minerals” and the regulations promulgated thereunder by the U.S. Securities
and Exchange Commission.
With strong recycling activities and certified procurement, we ensure a conflict-free andsustainable raw material supply for our customers, following strong ethical, social andenvironmental principles.
Where appropriate, we support our suppliers and the countries from which we source raw materials
in implementing and enforcing the EITI criteria.
The commitment of this policy by our raw material suppliers is mandatory for the supplierqualification which take place before approval of raw material contracts.

Goslar, June 30’Th 2023

Dr. Kazuyuki Marukawa
Vice Chairman
TANIOBIS GmbHThe latest version of this guideline is exclusively available in the document control system SYCAT.

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