Modern Slavery Statement2023

Introduction
This statement has been prepared by Allkem Limited (Allkem) to meet the requirements of
the Australian Modern Slavery Act 2018 for the financial year ended 30 June 2023 (FY23).
The statement outlines the activities of Allkem, our subsidiaries, and the joint ventures overwhich we had management control during FY23.
During the reporting period, we actively engaged andconsulted with each operation and development project
to contribute to the development of this statement.

Signed,This Statement was approved by the Allkem Board on
4 December 2023.

Allkem Modern Slavery Report 2023

Martín Pérez de Solay
Managing Director and CEO

2

About Allkem
Allkem Limited (Allkem) (ACN 112 589 910
ABN: 31 112 589 910) is a global supplierof lithium chemical products and is listedon the Australian Securities Exchange(ASX:AKE) and Toronto Stock Exchange(TSX:AKE).
Our vision is to be a sustainable, world class supplier oflithium chemicals. We create long term value by investingin our people, our operations, and the communities
where we operate and we are committed to respecting,protecting, and promoting human rights across ouroperations and supply chains. We are focused on
expanding and diversifying our lithium operations andpartnerships to contribute to the responsible developmentof this chemical product which is critical for the transition
to a net-zero carbon future.
On the 10th of May 2023, Allkem announced a proposed
merger of equals with Livent. At the time this statement
was published, the effective date of this merger was
expected to be around the end of the 2023 calendar year.

Allkem Modern Slavery Report 2023

Additional information about our assets, controlled
entities, and investments is available in this statement
as well as on our website and in our FY23 Annual Report
and Sustainability Report. The scope of this Modern
Slavery Statement references our progress during FY23.
This was focused on expanding Allkem’s Modern Slavery
Working Group and developing a standardised approachto assessing and mitigating modern slavery risk factors
across each of Allkem’s subsidiary companies. During theyear we also completed the first combined, group wide
modern slavery risk assessment of our tier 1 suppliers.

3

Structure, Operationsand Growth Projects
Allkem’s offices, operations and development projects
at 30th June FY23 are identified in the map below.
Figure 1—Map of Allkem operations andgrowth projects during FY23

James Bay (100%)
Stage

Engineering

Type

Hard rock

Product

Spodumene concentrate

TorontoMontreal

Allkem Modern Slavery Report 2023

Olaroz (66.5%)

4

Stage

Operating/development

Type

Brine

Product

Carbonate

Cauchari (100%)

Buenos Aires
Sal de Vida (100%)Stage

Early studies

Stage

Construction

Type

Brine

Type

Brine

Product

Carbonate

For information on Reserves and Resource estimates, see Allkem ASX Release Allkem
confirms material growth profile underpinned by 40 Mt Resource, 25th September 2023

Our company has a diverse
global portfolio of high-quality
lithium assets that produce
critical battery materials used indecarbonising our economies.

Naraha (75%)
Commissioning

Type

LiOH
conversion facility

Product

Hydroxide

BrisbaneSydneyMt Cattlin (100%)
Stage

OperatingType

Hard rock

Product

Spodumene concentrate

Key
Operating Asset
Development Asset
OfficeAllkem Modern Slavery Report 2023

Perth

Stage

5

Mt Cattlin

The Olaroz Lithium Facility

Operation

Stage 1 Operation andStage 2 Expansion Project

Mt Cattlin, a 100% owned subsidiary of Allkem, is a hardrock spodumene mine located 2km from Ravensthorpe inWestern Australia.

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 2014. Olaroz is operated by Sales deJujuy S.A. (‘SDJ”) with Allkem managing the operations
pursuant to a Management Agreement. The structure ofthis joint venture between Allkem, Toyota Tsusho (“TTC”)
and JEMSE (a mining investment company owned by theprovincial government of Jujuy, Argentina), is outlined in
Figure 2. Allkem also has 100% ownership of the Cauchariresource adjacent to the Olaroz facility that is in the early
study stage of development.

The Mt Cattlin mine produced approximately 131K dry
metric tonnes (“dmt”) of spodumene concentrate(average grade of 5.3% Li2O) in FY23. Spodumene
concentrate is shipped to customers in Asia who convert
our product to lithium hydroxide for use in the battery
storage value chain.
As at 30 June 2023, Mt Cattlin had 115 permanent, direct
employees and a contractor workforce contributing afurther 718,892 hours during the year.

Operations at Olaroz were highly stable and consistentthrough the year with annual production reaching a newrecord of 16,703 tonnes of lithium carbonate for FY23, a~30% increase from FY22.

Further information on our
workforce diversity, locationand training is available in our
FY23 Sustainability Report andPerformance Data.

As at 30 June 2023, Olaroz had 777 direct employees, anincrease of approximately 24% from FY22. 212 of these
employees were new hires during the year. These figures
include people employed in Stage 1 operations as wellas the Stage 2 Expansion Project. A contractor workforce
contributed a further 2.4 million hours during the year.

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

Allkem(Australia)

Toyota Tsusho (TTC)(Japan)6.2%

72.68%(SDJ S.A. 66.6%)

27.32%(SDJ S.A. 25%)

Sales de Jujuy Pte Ltd(Singapore)

JEMSE(Jujuy, Argentina)
91.5% (Common Share)

8.5% (Class B Share)

Allkem Modern Slavery Report 2023

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

6

Debt
Lender(Mizuho)

Guarantee
Guarantor(JOGMEC)Non-operated Joint Venture

Growth Projects

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.

Sal de Vida

First production at the Naraha plant occurred in October
2022. Although Allkem has a 75% economic interest in
the Toyotsu Lithium Corporation (“TLC”), and influence
via joint venture committee, the operational control is
exercised by Toyota Tsusho Corporation (“TTC”). As Allkem
does not have operational control of this asset, the Naraha
Project is not included in the scope of 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.

Sal de Vida is a lithium carbonate from brine project
located at the Salar del Hombre Muerto in the Catamarca
Province of Argentina. Construction of the first two
strings of Stage 1 ponds neared completion by the endof FY23 with the first 9 ponds completed and filled withbrine and all ponds lined. Camp expansion activities andprocurement of long lead items progressed with the arrival
on site of a number of items of proprietary equipment.
Detailed engineering of the Process Plant achieved
significant milestones during the year and steady progress
was made on procurement activities for this package.
Capital expenditure for the year ended 30 June 2023
was US$135.5 million, excluding VAT and working capital.
During FY23 the project employed 294 permanent,
full-time employees, and contractors contributed afurther 1.5 million hours.

James BayThe James Bay project, located in Québec, Canada, wasin the permitting and detailed engineering phase during
FY23. Capital expenditure for the year ended 30 June
2023 was US$80.0 million, excluding VAT and working
capital. During FY23 the project had 28 direct employees.
Contractors in Canada contributed a further 142,148 hours.

Figure 3—Naraha Lithium Facility JV Structure

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 2023

Allkem(Australia)7Supply Chains
During FY23, our key supply chain activities
were associated with our operations inAustralia at Mt Cattlin and in Argentina
at the Olaroz Lithium Facility, as well as
the construction activities at our Stage 2
Expansion Project at Olaroz and at the Sal
de Vida Project.
Key goods and services procured included:•

Mining contractors•

Process reagents for operations (e.g. soda ash, lime,
sulfuric acid, hydrochloric acid)•

Fuel (natural gas and diesel)•

Construction labour•

Logistics and transport (trucking, maritime freightand storage)•

Cleaning, catering and maintenanceAllkem Modern Slavery Report 2023

The Olaroz Lithium Facility and the Sal de Vida Project
are in remote areas of Argentina. Due to this, and inaccordance with our principles of shared value, we makeefforts to procure as many goods and services as possible
from the local communities and regions around ouroperations. Figure 4 shows the geographic distributionof supplier numbers for our Argentina based
operations and projects in FY23.

8

76

2%/10

/214

224

%/9

Mt Cattlin

S(O

National 18%/76

Figure 4—Distribution of suppliers for Argentine assets in FY23 (‘National’ refers to Argentina,
International 2%/10‘Provincial’ for Olaroz refers to Jujuy and for Sal de Vida refers to Catamarca)
Most of our tier 1 suppliers for these operations (approximately 95% for Olaroz and 98% for Sal de Vida), arebased in Argentina. Our largest recurring supplier by spend outside of Argentina is our soda ash supplier in the USA.

Sales de Jujuy(Olaroz Lithium
Facility)

Local 6%/53
Provincial 17%/148
National 72%/637
International 5%/45

Sal de Vida
(Contruction
Phase Project)

Local 2%/12
Provincial 47%/214
National 49%/224
International 2%/9

Figure 5—Distribution of suppliers for Mt Cattlin
in FY23 (‘National’ refers to Australia, ‘Provincial’refers to Western Australia)

Figure 6—Distribution of suppliers for James
Bay Project in FY23 (‘National’ refers to Canada,‘Provincial’ refers to Quebec)

Approximately 98% of suppliers for our Australian mining
operation at Mt Cattlin are based in Australia, representing
99.5% of procurement spend. Other countries represented
in our tier 1 suppliers include Singapore, South Africa,
Germany and the USA.

Approximately 81% of suppliers for the James Bay project
are based in Canada, representing 91% of procurement
spend. Other countries represented in our tier 1 suppliers
include Australia, USA and South Africa.

Local 13%/54

Mt Cattlin

Provincial 67%/289
National 18%/76
International 2%/10

Sal de Vida
(Contruction
Phase Project)

Local 2%/12
Provincial 47%/214
National 49%/224
International 2%/9

Sales de Jujuy
James
Bay
(Olaroz
Lithium
Facility)

Local
Local 2%/2
6%/53
Provincial
Provincial 67%/60
17%/148
National
National 20%/18
72%/637

International
International 11%/10
5%/45

Allkem Modern Slavery Report 2023

/289

Local 13%/54
Provincial 67%/289

9Modern Slavery Risk and Due Diligence
Modern Slavery, as defined by the Australian Government Modern Slavery Act 2018 (“theAct”) 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 the worst forms of child labour. The worst forms of child labour refer to situations wherechildren 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 modern slavery. To do this, we draw oninternal and external data sources to continually refine
our modern slavery risk profile. During the year,
we completed an assessment of our tier 1 suppliers
across the business, applying a preliminary risk ratingbased on the following criteria:

Sector (Product and Services) Risks
Although modern slavery can occur in all industries andsectors, some products or services are associated with ahigher incidence1. This can be due to working conditions,or the processes used to create the products.

Higher Risk Products•

construction materials (such as bricks and rubber)•electronics and technology (in particular, solar panels)•

textiles and garments (including Personal Protective
Equipment (PPE) and uniforms

Some services, regardless of where they are sourced,
have also been associated with higher incidents ofmodern slavery. These include:

Higher Risk Services•

construction•

cleaning and laundry services•

logistics and transportation (including trucking,maritime freight, and storage)•

sectors using labour hire or outsourcing tothird party contractor

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. In our
preliminary risk assessment, we used a vulnerability scoreabove 50 to define geographic risk level based on theclassification by the Global Slavery Index (“GSI”)2.

Allkem Modern Slavery Report 2023

1 Global Slavery Index (2023) https://cdn.walkfree.org/content/uploads/2023/05/17114737/Global-Slavery-Index-2023.pdf
2 www.walkfree.org/global-slavery-index/map

10Figure7—GSI (2023) Estimate of Vulnerability to Modern Slavery and Location of Tier 1 Suppliers
In FY23, our tier 1 suppliers included two countries with higher vulnerability to modern slavery (as indicated by GSI scores
above 50). These countries were Mexico and South Africa.

Modern Slavery Vulnerability
Tier 1 Suppliers
High

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 recognise that
there may be some small to medium enterprises (“SME”)
that are still developing management capabilities and anunderstanding of labour standards. During the year, we
worked with 65 local companies based in the communities
surrounding our remote project and operation innorthwest Argentina. These companies provide a rangeof goods and services to Olaroz and the Sal de Vida
project including catering, cleaning, construction andtransport logistics.

FY23 Risk Assessment Outcomes
Using the assessment of sector, geography and entity risk
outlined above, we classified our tier 1 suppliers as either:
Low Risk = low geographic risk + low sector risk + low
entity risk
Medium Risk = geographic risk or sector risk
(but not both)High Risk = geographic risk + sector risk
High Risk (Local SME) = entity risk

Our preliminary risk assessment for FY23 found thatless than 1% of our supply chain spend is with tier 1
suppliers identified as ‘high risk’ for modern slavery.
These are suppliers that are providing higher risk products
or services and are based in regions with a higher
vulnerability to modern slavery. This also includes local
suppliers where we have identified that higher entity risk
factors for modern slavery may be present.

47% of our supply chain wasassessed as ‘medium risk’.
Our Modern Slavery Working Group provides a network
for sharing information and incorporating feedback from
implementation of the Modern Slavery Standard at eachof our operations and projects. We will continue to refine
our assessment of ‘high risk’ in our supply chain throughthis Working Group. We have identified that for certain
higher risk sectors such as shipping logistics and solar
panels, assigning a higher risk rating and implementing
further mitigation actions is considered reasonable even iftier 1 suppliers are in countries with a lower vulnerability tomodern slavery risk.

Allkem Modern Slavery Report 2023

Low

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Tier 1 Supplier - Preliminary Risk Level
Figure 8—Tier 1 Supplier Preliminary Risk Level

Tier 1 Supplier
Spend (Preliminary
Risk Level)

High (including local SMEs) 1%
Medium 47%
Low 53%

How we Manage Risk andAssess Effectiveness

The Standard outlines the actions required acrossour business to identify risks of modern slavery in ouroperations and supply chains and also sets out actions
to be implemented to address any risk factors identified.
These actions are being implemented through a phased
approach. The first stage was conducting a preliminary
risk assessment for our FY23 tier 1 suppliers. We are
now implementing the mitigation actions defined in theStandard across the business. The Modern Slavery Working
Group will continue to refine these by incorporating
shared experience across the Group and by monitoring
international research on modern slavery risk including
available tools and databases. The initial mitigation actions
identified in the Standard are summarised below:

Process for Managing Low-risk Suppliers•

Contracts with our suppliers use Allkem’s standard
form contracts or purchase order terms, whichcontain Allkem’s anti-modern slavery obligations
and warranties.

•

If a supplier insists on amendments to Allkem’s standard
documents or on using their own form of agreement,
Allkem’s Legal Department must assess the risk andgive approval.

•

Allkem’s Code of Conduct also applies to our suppliersand contractors. A record of each acceptance of ourpolicies must be stored within the supplier management
system for each operation.

Governance and Policies
Our Board Sustainability Committee Charter specificallyassigns responsibility for Human Rights in relation
to community and supply chain and including
Australian Government 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 areavailable on our website and include:•

Corporate Code of Conduct Policy—reviewed andapproved by the Board in December 2022
(applies to employees, contractors and suppliers)•

Human Rights Policy—reviewed and approved by the
Board in May 2022•

Community and Social Performance Policy—reviewed
and approved by the Board in September 2023•

Sustainable Development Policy—reviewed andapproved by the Board in May 2022

Process for Managing Medium-risk
Suppliers
In addition to requirements for low-risk suppliers,•

Conduct additional due diligence. We are currently
testing a web-based screening tool to assess if the
supplier has been associated with any reported
instances of modern slavery or other human rights
abuses. If the pilot project (being carried out for our
Argentine operations) is successful, this tool will berolled out across all sites and projects. For our othersites, this process is being implemented as a desktop
search in the interim.

•

Medium risk suppliers where annual contract
spend is expected to be greater than a set amountare also required to respond to a modern slavery
due diligence questionnaire before entering intoor renewing a contract.

•

Where any specific modern slavery risk factors are
identified, the process for managing high-risk suppliers
will apply. If no further risk factors are identified,
this will be documented.

Allkem Modern Slavery Report 2023

Consultation Across Controlled Entities

12

During the year, we finalised Allkem’s Group level Modern
Slavery Standard. This Standard was developed with input
from Allkem’s Modern Slavery Working Group comprising
representatives from sustainability, procurement, legal andcompliance teams from across the business and subsidiarycompanies. Working group sessions were held with teams
from Australia, Canada, and Argentina to develop andfinalise the Standard. Bringing this group together fromall across the business, has been a valuable exercise in
identifying risks, sharing knowledge and expanding thescope of existing mitigation efforts.

Process for Managing High-risk Suppliers
In addition to requirements for low and medium risk
suppliers, the following mitigation actions are to be
implemented for suppliers identified as high risk.
•

Regardless of contract spend, all high-risk suppliers
will be required to respond to a modern slavery due
diligence questionnaire before Allkem enters into or
renews its contract with that supplier.

•

The outcomes from additional research and the
supplier’s response to the questionnaire (including
supporting documentation) are to be used to conduct a
more detailed risk assessment.

•

Where any specific modern slavery risk factors are
identified through this process, the compliance andsustainability teams will assess appropriate mitigation
actions on a case-by-case basis.

•

In cases where no additional risk factors are identified,
this must also be documented.

Process for Managing High Risk Local
SME Suppliers
Our Shared Value Teams 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 from our
supply chain activities can further contribute to the socioeconomic development of communities in the regions
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 with these
suppliers. Specific training is an ongoing part of Allkem’s
local capacity building programs.

Additional Requirements
for On-site Suppliers
For any contractors working on our sites, appropriate
health and safety performance and care for theiremployees is considered critical. The Health, Safety andEnvironment teams and Risk Management teams support
the Procurement teams with site-based inspections andevaluation 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. Through the system, we document
supplier adherence to our policies concerning health,safety, environment, and social requirements (including
human rights), as well as other contractual requirements.
At our sites in Argentina, checks are completed to ensurecompanies are complying with the legal requirements ofArgentine authorities regarding issues such as payment ofsalaries, health and safety, and fair workload.
Instances where suppliers or contractors fail to meetrequirements are investigated with outcomes documented
in the supplier management system.

Case Study—Local Supplier Withholding Payments
From Their Employees

Mitigation Response

Prevention and Monitoring

Sales de Jujuy Legal and Human Resources teams
engaged directly with the contractor company toinvestigate the claims that the employee payments
were not being made. We then undertook further
engagement with the contractor, representatives of
the Jujuy Ministry of Labour and the local union toresolve the dispute.

Sales de Jujuy’s Value Chain and Complianceteams have put monthly follow-up audits in placewith the contractor to monitor for any further
deviations in relation to employee documentation
and/or payments.

Resolution: the contractor committed to making theoverdue payments, which were subsequently made ininstalments to the impacted workers.

As this company is a local supplier, the Sales deJujuy Shared Value team continue to engage withlocal community members to better understand any
further outcomes associated with the incident.

Allkem Modern Slavery Report 2023

During the year, workers for one of our local suppliers in Argentina reported to our operating company (Sales deJujuy) that they were not receiving payments from their employer. These direct reports were also backed up by aformal claim from the trade union representing the workers.

13

Grievance Mechanisms
and Response 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 is publicly available in the local
languages of the areas where we operate. This policy
encourages disclosers to report issues if they reasonably
believe someone has engaged in serious wrongdoing. Thissystem is managed by external companies for each region
to guarantee transparency, objectivity and if required,anonymity. When complaints are registered, details arecommunicated to Allkem’s Corporate Internal Audit
Manager, and an investigation is opened. A response teamis then formed with the appropriate skillsets based on
the nature of the incident. The team may include internaland external subject matter experts. All whistle blower
investigations are reported to the Board Sustainability
Committee and investigations are followed throughuntil a resolution is reached.
A comprehensive set of Crisis Management Plans havealso been developed 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.

Training and External Partnerships
During the year we have started rolling out specificModern Slavery e-learning training modules. We have also
incorporated modern slavery training within the Codeof Conduct e-learning module that all employees are
required to complete.

Allkem Modern Slavery Report 2023

Completion rates of Code of Conduct training acrosseach of our operations and projects during FY23 areshown below:

14

88%

79%

Sales de Jujuy (Olaroz)

Mt Cattlin

97%

79%

Sal de Vida

James BayAs demonstrated in the case study on p.13, we work withexternal stakeholders in the regions where we operate
to improve outcomes for workers in our supply chain. We
work with government departments and labour unions toraise awareness and improve working conditions.
We also engage with the Argentine National Institute ofIndustrial Technology (INTI) to better understand theneeds of our local suppliers and provide the training
required to improve business acumen and outcomesfor our suppliers, their employees and our business.
The continuing education program that we have
implemented for local employees of our Olaroz Lithium
Facility is also available to employees of our local suppliers.
Further information on this initiative is available in our
FY23 Sustainability Report. By increasing education levels,
employees in the local communities are also increasing theemployment options available to them. During FY23, 22of the 66 students enrolled in the program were employedby local contracting companies with the remainder being
direct employees at Olaroz.

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

Modern Slavery Action Plan
Actions

FY23 Progress

1. Map our structure, operations, and supply chains.
•

Mapping of Allkem structure, operations, and high-level supply chains across each operationand project•Continue mapping and categorising Tier 1 supply chains for new suppliers

2. Set policy commitments in relation to modern slavery•

Gap Analysis: Collating current policies and identifying gaps•

Adapting existing policies and formulating new policies as required including developmentof the Group Level Modern Slavery Standard

3. Carry out a risk assessment•

Complete standardised initial risk assessment for modern slavery risk factors across each operationand project•

Carry out further detailed modern slavery risk assessment for medium-high risk level suppliers.
Focus for FY24—Product Shipping and Solar Panel Procurement

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

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
Ongoing
Allkem Modern Slavery Report 2023

Complete15

allkem.co