Umicore Global
Sustainable Sourcing
PolicyV1.23-03-2022

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About
Umicore strives to have a positive impact. We enhance quality of life throughour products and services, reducing harmful vehicle emissions, giving new life
to used metals and powering the cars of the future.

The Umicore Way, is the cornerstone of everything
we do at Umicore. It outlines our values of openness,innovation, respect, teamwork and commitment that are
crucial to our success. It defines our mission: Materials
for a Better Life.
The Umicore Global Sustainable Sourcing Policy is fullyaligned with the Umicore Way, the Umicore Code of
Conduct and the Global Framework Agreement on
Sustainable Development between Umicore and theIndustriALL Global Union.
Umicore is committed to creating sustainable value
with our global network of suppliers through a mutually
beneficial relationship based on strong ethical businessstandards, trust and shared commitments to meet or
exceed our customers’ requirements. We therefore seek to
do business with partners also committed to the principles
of sustainable development and whose partnershipsupports and is aligned with our strategic ambitions.

Sustainable sourcing is one component in the Zero Harm
pillar of Umicore’s sustainability strategy. Umicore’s Let’sgo for Zero strategy, which was announced in June 2021,
is built using the following key pillars:••••

Net Zero GHG by 2035
Zero Harm
Zero Inequality
Best in class Governance

For more on our sustainability strategy, visit:umicore.com/sustainability
Umicore pursues responsible sourcing certification
wherever appropriate to highlight our best practices andto provide the necessary documentation to the increasing
number of customers seeking assurance on our products.
To view our certifications, please visit:
annualreport.umicore.com

This Global Sustainable Sourcing Policy defines the Umicore approachto direct and indirect procurement in line with our commitments to promote
fair dealing, to ensure health and safety, and to manage impact
on climate and environment in our supply.

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THESE PRINCIPLES ARE APPLICABLE TO ALL OUR SUPPLIERS, AS A MINIMUM:
We expect our suppliers to be committed to businessintegrity, to promote the principles of sustainableprocurement in their supply chain, to be compliant
with international and local laws, to strive to minimize
impact on climate and the environment and to respect
international human rights legislation, to abolish childand forced labor and eliminate discrimination on theirown sites and from their own suppliers.

Umicore utilizes a risk-based approach to determine
where documentation, management systems andperformance/compliance monitoring are necessary
from suppliers to remain aligned with our continued
commitment to sustainable and ethical sourcing. Thisapproach includes considerations on size, business andsupplier type, complexity and risk environment.

Additional considerations resulting from this risk-based approach that may apply for specific suppliers are highlighted
throughout this Policy. In complement to this Policy, additional guidance exists for specific sourcing approaches,covering various aspects of sustainability including, but not limited to, environmental, health, safety, ethical or
regulatory aspects.
These specific approaches include:•
The Umicore Responsible Global Supply Chain of Minerals from Conflict Affected & High-Risk Areas•
Umicore Sustainable Procurement Framework for Cobalt

Umicore’s engagement to you as a supplier
FAIR DEALING WITH SUPPLIERS
We treat you with honesty, fairness and respect. Ourpurchasing activities are conducted in accordance withthe highest ethical and professional standards, as set out
in our Code of Conduct.
TRANSPARENCY & COMMUNICATION
We take the engagement to report on a regularand consistent basis, both internally and externally, on
our sustainable development supply chain project. In
addition, we will provide feedback to suppliers regarding
improvements in their sustainable development
performance.

IMPARTIAL SELECTION
We select suppliers based on objective criteria suchas technical specifications, quality, price, service andtechnology, environmental and social impact.
RELATIONS WITH LOCAL COMMUNITIESWe seek to include smaller-sized and local suppliersin our procurement processes, wherever possible, tosupport the local economy.
HEALTH & SAFETY
We will apply the same health & safety standards to allcontractors working on our sites as the ones we apply to
our own employees.

Our relationships with suppliers and customers are essential elements
in building financial and economic value and play a key rolein the promotion of social and environmental best practice.

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Your engagement to Umicore

1

Business Integrity

CORE PRINCIPLES, FOR ALL SUPPLIERSLAWS & REGULATIONS
You apply the highest standards of business and personal
ethics and comply with all applicable laws and regulationsin the countries where you operate. These include, but
are not limited to export control regulations, economic
sanctions, anti-money laundering and competition laws
and regulations.
CONFLICT OF INTEREST, CORRUPTION, FRAUD &ANTI-COMPETITIVE PRACTICESYou are committed to work against all forms of corruption,
extortion, fraud and bribery.
You do not offer any benefit to Umicore employees tofacilitate your business with Umicore.

We strongly advocate for our suppliers to foresee a
process for their stakeholders to report grievancesand ensure an anti-retaliation mechanism.

If you execute works at the request of or for an Umicore
employee involved in any procurement decision-making
process, you will inform and disclose this information to
the site general management prior to execution.
TRANSPARENCY & ACCOUNTABILITY
You are committed to transparency and accountability
in your business dealings and strive to detect andprevent illegal and unethical activities conducted
through commercial transactions via the screening ofyour business partners, transactions and materials.
You commit to collaborate in screenings conducted by
Umicore of which you are the subject.

Umicore invites all stakeholders to report concerns
or complaints about Umicore’s business approach,or that of its suppliers, using our Grievance contact
form. Such complaints can be made anonymously.

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Labor & Human Rights

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CORE PRINCIPLES, FOR ALL SUPPLIERS
You respect the ILO’s Declaration on Fundamental Principles and Rights at Workand the international law on Human Rights. You are not complicit in Human Rights
abuses. You do not compromise on a safe and healthy working environment.
In this context, you define and implement a policy, a management system and/or
practices to ensure respect for the following principles on your sites:•

Abolition of child labor.

•

Elimination of any form of forced or compulsory labor.

•

Freedom from torture and inhumane or degrading treatment.

•

Freedom of association and the right to collective bargaining.

•

Promotion of diversity and inclusion, of equal opportunity, andelimination of discrimination and harassment, ensuring fair treatmentin the workplace. Diversity includes gender, religion, race, nationalor ethnic origin, cultural background, social group, disability, sexual
orientation, marital status, age or political opinion.

•

Compliance with all applicable laws regarding wages, benefits andworking hours (including overtime).

•

Employee and contractor health and safety, with a management
system that defines clear guidelines for risk analysis and risk
management measures, including the provision of personal protective
equipment, and an emergency response.

If you are operating on one of Umicore’s industrial sites, the minimum age of anyof your employees will be 18 years, except in the framework of internships or
vocational training programs, organized in cooperation with schools and training
institutes or approved by the competent authority.

FOR SPECIFIC RAW MATERIALS SUPPLIERS
Based on our risk assessment, we may also require from specific suppliers to besignatories to, or be committed to alignment with, the Voluntary Principles on
Security and Human Rights.

We strongly advocate for our suppliers to foster a working environment
with attention to overall employee wellbeing and where employees findtraining and development opportunities, where rewards are in relation to
the contribution made by the employee, and where employees can engage
in constructive dialogue with their employer.

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3

Environment & Climate

CORE PRINCIPLES, FOR ALL SUPPLIERS
You comply with the applicable environmental laws and regulations in the
territories in which you operate, and you possess all the necessary environmental
permits and registrations, as a minimum standard.
You strive to minimize environmental impact, including on climate, whilesafeguarding the health and safety of your employees and of the public.
You maintain an environmental management system which enables you tocontinuously improve environmental performance. Documentation about thismanagement system is updated and available.
You have procedures in place to prevent incidents. Your procedures are designed tomitigate consequences on the environment, should an incident occur. You identify
and assess potential emergency situations and you implement an emergency
response procedure to minimize their impact.

FOR SPECIFIC RAW MATERIALS SUPPLIERS
Based on our risk assessment, we may also require some of the following from specific suppliers:•

You characterize and monitor the emissions
to water and air of substances with apotential adverse effect on humans or theenvironment.

•

You reduce solid waste generation throughprevention, reduction, recycling and reuse.

•

You characterize and monitor the emissionsof greenhouse gases. You define targets
and roadmaps for GHG emissions reduction,
striving to be in line with the latest IPCC
recommendation/Paris agreement.

•

You monitor the water consumption, identify
the areas affected by water stress anddevelop plans to reduce water consumption
with a specific focus on these areas.

•

You manage natural resources efficiently. You
improve energy efficiency and increase theuse of renewable energy.

•

Any hazardous products or materials that you
produce are always accompanied with up-todate environmental information by way of an
appropriate material safety data sheet.

•

You identify and assess the potential impact ofyour operations on the neighborhood and takethe appropriate measures to minimize if not
avoid any adverse impact be it on the healthof local residents or the environment.

•

You understand the connection between yourbusiness activity and biodiversity and, as
relevant, act to safeguard biodiversity.

We strongly advocate for our suppliers to offer products with the lowest
possible climate and environmental impacts from production, use and at
end-of-life.

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Supply Chain

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CORE PRINCIPLES, FOR ALL SUPPLIERS
Due diligence begins with knowing your supplier. You understand your supply
chain. You identify and you register your direct suppliers. You promote andcommunicate the principles of sustainable sourcing and procurement as stated inthis Policy in your own supply chain.
Umicore pursues responsible sourcing certification wherever appropriate tohighlight our best practices and to provide the necessary documentation to theincreasing number of customers seeking assurance on our products. To view ourcertifications, please visit: annualreport.umicore.com.
See also:•

The Umicore Responsible Global Supply Chain of Minerals from
Conflict Affected & High-Risk Areas•

The Umicore Sustainable Procurement Framework for Cobalt

FOR SPECIFIC RAW MATERIALS SUPPLIERS
Based on our risk assessment, we may also require some of the following from specific suppliers:•

You comply or undertake to comply with
Umicore guidelines/policies where Umicore
has created dedicated guidelines, guidance,
policies for suppliers of specific raw materials.

•

When extracting, sourcing, transporting,trading, handling or exporting minerals fromconflict-affected and high-risk areas, youcomply with the specific Umicore guidance for
Responsible global supply chain of minerals
from conflict-affected and high-risk areas.

•

You communicate to your suppliers about
the need for them to comply with the ILO’s
Declaration on Fundamental Principles andRights at Work and the international law onhuman rights.

•

You provide additional information andcommitments to comply with our own
responsible sourcing certifications and due
diligence schemes.

We strongly advocate for our suppliers to adopt a supplier policy and to
conduct due diligence that is aligned with this Policy and best practices,
including: risk identification, management systems, mitigation actions, third
party verification of due diligence practices, robust systems of logistical
documentation and annual reporting on due diligence.

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Monitoring
ADHERENCE TO THE POLICY
To adhere to this Policy, we ask that you provide a signed letter of commitment to your Umicore business contact.
IMPLEMENTATIONThe Policy is the foundation of our relationship with our suppliers, and we follow-up on the implementation and on
compliance.
You therefore undertake to maintain the documentation necessary to demonstrate compliance with this Policy andaccept:•To respond promptly to reasonable inquiries
from our procurement representatives regarding
implementation of the principles of this Policy, and,if applicable and necessary:––•

To complete a self-assessment question-naire,based on this Policy and to provide proof of any
statements made therein.
To answer requests – either from Umicore or
through a third party – to conduct site visits
and/or audits to verify compliance with thisPolicy or elements thereof, as a result of theself-assessment process or of the inquiries.

That, should elements of this Policy not be met,
you are required to provide satisfactory explanation
and/or evidence that corrective action is planned
to amend the situation and prevent any recurrence.
Your Umicore contact may support you in defining acorrective action.

Lack of cooperation from your side may result in thereconsideration of the business relationship.
POLICY REVIEW
To continuously improve our contribution to a moresustainable world, Umicore commits to ensure that
this Policy reflects customer and supplier feedback andreflects consideration of material societal challenges,
with a review at least every 5 years. Any change shallbe communicated to our suppliers.
CONTACTFor any question or remark concerning this policy andits implementation please contact your Umicore businesscontact.
GRIEVANCE MECHANISM
Umicore invites all stakeholders to report concerns orcomplaints about Umicore’s business approach, or thatof its suppliers, using our Grievance contact form. Suchcomplaints can be made anonymously.

REFERENCES•The Umicore Way https://www.umicore.com/en/about/the-umicore-way•

The Umicore Code of Conduct http://www.umicore.com/en/governance/code-of-conduct•

Universal Declaration of Human Rights https://www.un.org/en/universal-declaration-human-rights•

ILO Declaration on Fundamental Principles and Rights at Work http://www.ilo.org/declaration/lang--en/index.htm•

Guidelines on occupational safety and health management systems ILO-OSH 2001 http://www.ilo.org/public/english/
protection/safework/managmnt/guide.htm•

Eco-Management and Audit Scheme (EMAS) http://ec.europa.eu/environment/emas/index_en.htm•

ISO 14000 series environmental management systems https://www.iso.org/iso-14001-environmental-management.
html•

OHSAS 18001 Health and Safety Systems https://www.bsigroup.com/en-GB/ohsas-18001-occupational-health-andsafety•

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
https://www.oecd-ilibrary.org•

Grievance mechanism https://www.umicore.com/en/contact or grievances@umicore.com

For inquiries and additional information
please contact
UmicoreNaamloze vennootschap – Société anonyme

Broekstraat 31 Rue du Marais
1000 Brussels
Belgium
BE92 2100 0538 0623
RPR/RPM Brussels BE0401 574 852
Tel.: +32 (0)2 227 71 11
Fax: +32 (0)2 227 79 00
www.umicore.com/contact

www.umicore.com