Modern Slavery Statement 2022

Together wecreate opportunity.

Introduction

This statement has been prepared by Allkem Limited (Allkem) to meet the requirementsof the Australian Modern Slavery Act 2018 for the financial year ended 30 June 2022 (FY22).
The statement outlines the activities of Allkem (Orocobre Ltd prior to November 30, 2021),
our subsidiaries and the joint ventures of which we had management control during FY22.
During the reporting period, we actively engaged andconsulted with each operation and development project
where we have management control, to contribute to thedevelopment of this statement.

Signed,This Statement was approved by the Allkem Board on
10 December 2022.
Martín Pérez de Solay
Managing Director and CEO

About Allkem

Allkem Limited (Allkem) (ACN 112 589 910
ABN: 31 112 589 910) is a global supplier oflithium chemical products and is listed on theAustralian Securities Exchange (ASX:AKE) andToronto Stock Exchange (TSX:AKE).
Our vision is to be a sustainable, world class supplier of lithiumchemicals. We create long term value by investing in our people,
our operations, and the communities where we operate and weare committed to respecting, protecting, and promoting humanrights across our operations and supply chains. We produce
lithium concentrate and chemical products for our global
customer base. We are focused on expanding and diversifying
our lithium operations and partnerships to contribute to the
responsible development of this chemical product which is
critical for the transition to a net-zero carbon future.
On 25 August 2021 we completed a merger of equals with
Galaxy Resources. This merger provides the combined groupwith a portfolio of world class assets that allow us to partnerwith the largest and most influential customers to supply highquality lithium chemicals. On 30 November 2021, the combined
company was renamed ALLKEM Limited, recognising our focus
on battery chemicals and that, together, we can achieve more.
Additional information about our assets, controlled
entities, and investments is available in this statement aswell as on our website and in our FY22 Annual Report andSustainability Report. The scope of this Modern Slavery
Statement references our progress during FY22 focused onstandardising approaches and policies across each subsidiarycompany of the merged entity.

Allkem Modern Slavery Report 2022

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Structure, Operationsand Growth Projects
Allkem’s operations and development projects during FY22 are identified in the map
in Figure 1.
Figure 1—Map of Allkem operations and growth projects during FY22

James Bay (100%)Stage

Permitting and Engineering

Type

Hard rock

Product

Spodumene concentrate

Production Capacity

321 ktpa @ 5.6% Li20

Resources1

40.3 Mt @ 1.4% Li20

Olaroz (66.5%)
Stage

Operating/development

Type

Brine

Product

Carbonate

Production Capacity
Resources142.5 ktpa
16.2 MT LCE (100%)

Borax (100%)
Stage

OperatingType

Borates minerals and refined chemical products

Subsequent to the end of the period Allkem entered into a binding andconditional Heads of Agreement to sell Borax. Subject to satisfaction of theconditions, it is currently anticipated that this sale will complete in Q4 CY22.

Sal de Vida (100%)
Stage
Type
Product
Production Capacity
Resources1

Construction
Brine
Carbonate
45 ktpa
6.85 MT LCECauchari (100%)
Stage
Type
Resources1

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Allkem Modern Slavery Report 2022

Early studies
Brine
6.3 MT LCENahara (75%) Non-Operated Joint Venture
Stage

Commissioning

Type

LiOH conversion facility

Product

Hydroxide

Production Capacity

10 ktpa LiOH

Mt Cattlin (100%)
Stage

OperatingType

Hard rock

Product
Resources1

Spodumene concentrate
13.3 Mt @ 1.2% Li20

Brisbane office
Perth office
Buenos Aires (Head Office)Key
Operating Asset
Development Asset
1

Refer to FY22 Annual Report for Resource and Reserve information.

OfficeAllkem Modern Slavery Report 2022

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Mt Cattlin

Olaroz is operated by Sales de Jujuy S.A. (SDJ) with
Allkem managing the operations pursuant to a
Management Agreement. The structure of this joint
venture between Allkem, Toyota Tsusho (TTC) and JEMSE(a mining investment company owned by the provincial
government of Jujuy, Argentina), is outlined in Figure 2.
Allkem also has 100% ownership of the Cauchari resource
adjacent to the Olaroz facility that is in the early study
stage of development.

Operation
Mt Cattlin, a 100% owned subsidiary of Allkem, is a hardrock spodumene mine located 2km from Ravensthorpe
in Western Australia.
The Mt Cattlin mine produced 193,563 dmt2 spodumene
concentrate (average grade of 5.6% Li2O) in FY22.
Spodumene concentrate is shipped to customers in Asia
who convert our product to lithium hydroxide for use in
the battery storage value chain.

The Olaroz Lithium Facility produces primary gradelithium carbonate and both micronised and nonmicronised purified lithium carbonate. Products are soldto a diverse customer base in Asia, Europe, and North
America with over 85% of the 12,863 tonnes lithium
carbonate produced during FY22 estimated to havecontributed to the global battery supply chain. Targeted
Production Capacity (Including Stage 1 and 2) is 42.5 ktpa
of lithium carbonate.

As at 30 June 2022, Mt Cattlin had 95 permanent, direct
employees and a contractor workforce contributing afurther 419,755 hours during the year.

The Olaroz Lithium Facility
Stage 1 Operation and Stage 2
Expansion Project

As at 30 June 2022, Olaroz had 628 direct employees,
an increase of approximately 28% from FY21. 521 ofthese are permanent employees and 107 employees
on fixed term contracts. These figures include people
employed in Stage 1 operations as well as the Stage 2
Expansion Project.

The Olaroz Lithium Facility (Olaroz) is a large-scalebrine-based operation located in the Jujuy provinceof northern Argentina at an altitude of approximately
3,900 metres above sea level. The facility commenced
operations in 2015.

Figure 2—Olaroz Lithium Facility (operated by SDJ) JV Structure
Allkem(Australia)

6.2%

72.68%(SDJ S.A. 66.5%)

Toyota Tsusho (TTC)(Japan)27.32%(SDJ S.A. 25%)

JEMSE
(Jujuy, Argentina)

Sales de Jujuy Pte Ltd(Singapore)
91.5% (Common Share)

8.5% (Class B Share)

Project Company—Sales de Jujuy S.A. (SDJ)(Jujuy, Argentina)

Debt

Guarantee

Lender(Mizuho)

Guarantor(JOGMEC)

2	Dry Metric Tonne—This production volume is based on the full financial year ending 30 June 2022. The FY22 financial statements are based on Mt Cattlin’s results from the
10-month period post-merger completion date i.e. 25 August 2021 to 30 June 2022.

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Allkem Modern Slavery Report 2022

Borax Argentina
During FY22 Allkem owned 100% of Borax Argentina(Borax), a producer of borates minerals and refinedchemical products, located in northwest Argentina. Borax
operates two open pit mines and concentration plants at
Tincalayu and Sijes at approximately 4,000 metres above
sea level, as well as refinery, logistics and dispatch facilities
at Campo Quijano, at 1,350 metres above sea level.
As at 30 June 2022, Borax had a workforce of 287 people,
269 permanent employees and 18 employees on fixed
term contracts. Subsequent to the end of the reporting
period, Allkem entered into a binding and conditional
Heads of Agreement to sell Borax. It is currently
anticipated that this sale will be completed in Q4 CY22.

Non-Operated Joint Venture
The Naraha Lithium Hydroxide Plant, the first of its kind
to be built in Japan, is designed to convert primary
grade lithium carbonate feedstock into approximately
10,000 tonnes of battery grade lithium hydroxide perannum. The joint venture structure of the plant is shownin Figure 3.
First production at the Naraha plant occurred following
the end of the reporting period, in October 2022. Although
Allkem has a 75% economic interest in the Toyotsu
Lithium Corporation (TLC), and influence via joint venturecommittee, the operational control is exercised by Toyota
Tsusho Corporation (TTC).

As Allkem does not have operational control of thisasset, the Naraha Project is not included in the scopeof our Modern Slavery Statement. Further information
about TTC’s approach to Human Rights and Supply Chain
Responsibility is available on the Toyota Tsusho
Corporation Website.

Other Growth Projects
Sal de Vida
Sal de Vida is a lithium carbonate from brine project
located at the Salar del Hombre Muerto in the Catamarca
Province of Argentina and construction of Stage 1(15 ktpa) has commenced. First production is targeted in
H2 CY23 with brine evaporation occurring during plant
construction, allowing concentrated brine to feed the plant
once commissioned. Development of Stage 2 (30 ktpa)
will occur sequentially. During FY22 the project employed
211 permanent, full-time employees, and contractors
contributed a further 653,000 hours.

James BayThe James Bay project, located in Quebec, Canada,
was in the permitting and detailed engineering phaseduring FY22. When in operation, the mine will have atargeted production capacity of 321 ktpa spodumene
concentrate @ 5.6% Li2O. During FY22 the project had
20 direct employees.

Figure 3—Naraha Lithium Facility JV Structure
Allkem(Australia)

Toyota Tsusho (TTC)(Japan)Economic interest 75%

Economic interest 25%

Toyotsu Lithium Corporation (TLC)

Awarded an engineering, procurement, and construction(EPC) contract to build the Naraha Lithium Hydroxide Plant

Veolia Water
Technologies

Allkem Modern Slavery Report 2022

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Supply Chains

During FY22, our key supply chain activities were associated with our operations in Australia
at Mt Cattlin and in Argentina at the Olaroz Lithium Facility and Borax, as well as theconstruction activities at our Stage 2 Expansion Project at the Olaroz Lithium Facility andat the Sal de Vida Project.
Key goods and services procured included:• Process input materials for operations (e.g. soda ash,lime, sulfuric acid, hydrochloric acid)• Construction materials (e.g. steel, geomembrane)• Fuel (natural gas, diesel and intermediate fuel oil)
• Construction labour• Logistics and transport (trucking, maritime freightand storage)

SDJ operations at the Olaroz Lithium Facility, operations at
Borax Argentina and the Sal de Vida Project are in remoteareas of Argentina. Due to this, and in accordance with
our principles of shared value, we make efforts to procure
as many goods and services as possible from the local
communities and regions around our operations. Figure 4
shows the geographic distribution of supplier numbers for
our Argentina based operations and projects in FY22.

• Cleaning, catering and maintenance.

We make efforts to procure as many goods andservices as possible from the local communities
and regions around our operations.

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Allkem Modern Slavery Report 2022

Figure 4—Distribution of Suppliers for Argentine assets in FY22 (‘National’ refers to Argentina)

Sales de Jujuy(Olaroz Lithium
Facility)

Borax Argentina

Sal de Vida

Local 4%/28

Local 5%/19

Local 3%/16

Provincial 20%/157

Provincial 38%/160

Provincial 39%/187

National 70%/529

National 56%/240

National 53%/256

International 6%/45

International 1%/6International 5%/24

Most of our tier 1 suppliers for these operations (approximately 94% for Olaroz, 99% for Borax and 95% for Sal de Vida),
are based in Argentina. Our largest recurring supplier by spend outside of Argentina is our soda ash supplier in the USA.

Figure 5—Distribution of suppliers for Mt Cattlin
in FY22 (‘National’ refers to Australia)Mt Cattlin

Mt Cattlin

Local 11%/45

Local 11%/45

Local 4%/3

Local 4%/3

Provincial 66%/262

Provincial 66%/262

Provincial 67%/47

Provincial 67%/47

Mt Cattlin

National 19%/75

International 4%/14

Local 11%/45

Local 11%/45

Figure 6—Distribution of suppliers for James Bay

MtProject
Cattlin in FY22 (‘National’
James refers
Bay
James Bayto Canada)

James Bay

National 19%/75

James BayInternational 4%/14

Local 4%/3

Approximately
96% ofProvincial
suppliers
for our Australian
Provincial 66%/262
66%/262
Provincial 67%/47
miningoperationat
Mt
Cattlinare
National 19%/75
National 19%/75based in Australia,
National 17%/12
representing
97% of procurement
spend.
International 4%/14International 4%/14International 12%/8

National 17%/12

National 17%/12International 12%/8International 12%/8

Local 4%/3

Approximately 88% of suppliers for the James Bay
Provincial 67%/47
project are based in Canada, representing 93% of
National 17%/12
procurement spend.
International 12%/8

Allkem Modern Slavery Report 20229

Modern Slavery Risk andDue Diligence
Modern Slavery, as defined the Australian Government Modern Slavery Act 2018 (the Act)refers to eight types of serious exploitation: trafficking in persons; slavery; servitude; forced
marriage; forced labour; debt bondage; deceptive recruiting for labour or services; and theworst forms of child labour. The worst forms of child labour refer to situations where children
are subjected to slavery or similar practices or engaged in hazardous work.

Risk factors Identified
We need to understand potential risk factors that could
indicate that we are at risk of causing, contributing to, or
being linked to (through the activities of other entities that
we have business relationships with) modern slavery. To
do this, we draw on internal and external data sources tocontinually refine our modern slavery risk profile. Below,
we have summarised the key risk factors relevant to ouroperations and supply chain.

Product and Services Risks
Although modern slavery can occur in all industries
and sectors, some products or services are associatedwith higher incidences of modern slavery3. This can be
due to working conditions, or the processes used to create
the products.
Higher risk products in our supply chains include materials,
chemicals, textiles, and technology.
Higher risk services that we procure are associated withconstruction, cleaning and laundry services, logistics
and transportation (including trucking, maritime freight,
and storage).

Geographic Risks
Some countries may have higher vulnerability to modern
slavery due to poor governance, weak rule of law, conflict,and other socio-economic factors like poverty. Most of
our tier 1 suppliers are based in Argentina, Australia or
Canada which have a relatively low prevalence of andvulnerability to modern slavery based on the classificationby the Global Slavery Index4. Very few of our tier 1
suppliers5 are based in countries identified as being
highly vulnerable to modern slavery.

Some countries may havehigher vulnerability to modern
slavery due to poor governance,
weak rule of law, conflict, andother socio-economic factors
like poverty.

3 ACSI (2019) Modern Slavery Risks, Rights and Responsibilities
4 https://www.globalslaveryindex.org/2018/data/maps/#prevalence
5	Further investigation with our tier 1 suppliers is required to quantify potential
geographic risks present in tier 2 suppliers.

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Allkem Modern Slavery Report 2022

Entity Risks—Local Suppliers
Through our shared value team, we work closely with our
local communities in Argentina to identify opportunities
for local businesses in our supply chain. We recognisethat there may be some small to medium enterprisesthat are still developing management capabilities andunderstanding of labour standards.

How we Manage Risk andAssess EffectivenessGovernance and Policies
Our Board Sustainability Committee Charter specificallyassigns responsibility for Human Rights in relation
to community and supply chain and including AustralianGovernment Modern Slavery Act 2018 Reporting to
the Committee.
We also have policies in place which outline ourcommitment to human rights, responsible labour
practices, and associated capacity building. These
are available on our website and include:• Corporate Code of Conduct Policy• Supplier Code of Conduct• Human Rights Policy• Community Policy• Sustainable Development Policy.

Contractual Requirements for
our Suppliers
During FY22, our Spanish language Supplier Code of
Conduct was updated and approved by the Executive
for use at our operations and projects in Argentina. This
Code of Conduct defines our expectations of our suppliers
including adherence to policies regarding Human Rights,
Environment, Labour and Anti-Corruption. The Codesupports our commitment to the UN Guiding Principles
for Business and Human Rights, and our obligations under
Australian Government Modern Slavery Legislation. At of
30 June 2022, 265 of 759 Olaroz suppliers had signed thisupdated version of the Code of Conduct.

During the year we also worked towards standardising
our English language supplier documentation. Standard
form contracts for suppliers of operations and projects
in Australia and Canada have been updated to include
clauses requiring adherence to Allkem’s policies. Goods
and Services Agreements and Purchase Order Terms andConditions used in Australia also include specific clauses
relating to ethics and modern slavery. For Canadian
suppliers, these documents are also being translated into
French. Information regarding a new supplier’s acceptanceof our policies is recorded in the supplier management
system for each operation or project along with general
legal, fiscal and tax information.
During FY21, we initiated environmental and social
assessments of key suppliers of Olaroz and Borax.
23 Olaroz suppliers and 12 Borax suppliers were screened
through this process. No additional suppliers wereassessed using environmental and social screening
during FY22 as we focused on internal standardisationof these processes across each of the operations of themerged entity.

Additional Requirements for
On-Site Suppliers
For any contractors working on our sites, appropriate
health and safety performance is considered critical.
The Health, Safety and Environment teams and Risk
Management teams support the Procurement teams
with site-based inspections and evaluation of suppliers.
For contractors and service providers who work on oursites, we have incorporated an additional level of control
with our supplier management systems. The suppliermanagement systems assist us with documenting all
supplier relationships and managing vendor service
delivery at our sites. This system helps to monitor
compliance with statutory and contractual requirements.
Through the system, we document supplier adherence toour policies concerning health, safety, environment, andsocial requirements (including human rights), as well asother contractual requirements. At our sites in Argentina,
checks are completed to ensure companies are complying
with the legal requirements of Argentine authorities
regarding issues such as payment of salaries, health andsafety, and fair workload.
Instances where suppliers or contractors fail to meetrequirements are investigated with outcomes also
documented in the supplier management system.

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Engagement and Collaboration with
Local Community Suppliers
Our Shared Value Team work to identify opportunities topromote human rights with our local communities andmanage programs aimed at empowering local indigenous
populations. We are focused on building the capacity of
our local and provincial suppliers so that revenue fromour supply chain activities can further contribute to thesocio-economic development of communities in theregions where we operate. We have built strong networks
with our local communities and draw on these to better
understand how we can manage any potential risks withthese suppliers. Our Procurement and Shared Value
teams provide support and training for these suppliers
regarding labour regulation and the implications of thecorresponding labour union agreements. During FY22 we
conducted training sessions with 43 suppliers.

A comprehensive set of Crisis Management Plans werealso developed in FY22 to standardise incident response
procedures across Allkem’s global operations and projects.
These plans may provide guidance for responding toincidents such as modern slavery, if detected in our
supply chain.

Consultation with Controlled Entities

Training and External Partnerships

During FY22, the management teams of each controlled
entity, worked to understand the different approaches
used for managing supply chain risk, and work has begun
to standardise these approaches across the operations
and development projects of the merged entity.

Through our membership with BSR during FY22, we
conducted training workshops about the UN Guiding
Principles on Business and Human Rights for our staff andleadership teams. During the year we have also begun
developing specific Modern Slavery e-learning training
modules to be rolled out across each country where we
operate during FY23.

Grievance Mechanisms andResponse Plans
Allkem has grievance mechanisms in place, includinga Whistleblower Policy that applies not only to ouremployees but also our suppliers and employees of our
suppliers. This policy encourages disclosers to reportissues if they reasonably believe someone has engaged inserious wrongdoing.

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This system is managed by external companies for each of
the regions where we operate to guarantee transparency,
objectivity and if required, anonymity. When complaints
are registered, details are communicated to Allkem’s
Corporate Internal Audit Manager, and an investigation
is opened. A response team is then formed with theappropriate skillsets based on the nature of the incident.
The team may include internal and external subject matter
experts. All whistle blower investigations are reported to
the Board Sustainability Committee and investigations arefollowed through until a resolution is reached.

Allkem Modern Slavery Report 2022

Reporting on Progress
Our performance against material social andenvironmental topics is reported annually, in our
Sustainability Report, and performance data. We willcontinue to adapt our key performance indicators
to include progress against our Modern Slavery Action
Plan, summarised below.

Modern Slavery Action Plan

Actions

FY23 future focus on implementing approach across all operations

1. Map our structure, operations, and supply chains• Mapping of Allkem structure, operations, and high-level supply chains• Continue mapping and categorising Tier 1 supply chains (for Allkem Corporate, Olaroz, Mt Cattlin,
Sal de Vida and James Bay)2. Set policy commitments in relation to modern slavery• Gap Analysis: Collating current policies, identifying gaps
• Adapting existing policies and formulating new policies as required

3. Carry out a risk assessment• Identify high level risk factors for modern slavery across operations and supply chain• Carry our further, more detailed modern slavery risk assessment focusing on suppliers or categories
where high-level risk factors are identified

4. Assess and manage identified risks• Evaluate current controls for modern slavery risk across operations and supply chains• Review and adapt contract terms and codes of conduct with suppliers• Continue integrating modern slavery risk evaluation into supplier selection and review process• Clarify and communicate Allkem Modern Slavery Response Plan

5. Monitor the effectiveness of steps taken• Develop supplier performance KPIs to monitor the effectiveness of steps taken• Implement and report on supplier performance KPI’s

6. Awareness raising actions• Conduct training for employees on the UN Guiding Principles on Business and Human Rights• Developing training for staff on modern slavery risks and impacts• Developing training for contractors on modern slavery risks and impacts• Developing training for local community contractors in payroll and tax obligation topics
Complete

Ongoing

Allkem Modern Slavery Report 202213

allkem.co