SUPPLY CHAIN POLICY

Doc.-No.:
Version:Published:

4.03.01-POL
09
12.4.2021

SUPPLY CHAIN DUE DILIGENCE POLICY OF HERAEUS DEUTSCHLAND GMBH AND ITSWORLDWIDE SITES
As a family owned company with over 165 years tradition, Heraeus commits itself to the principle of sustainability by introducing
the Heraeus Code of Conduct and publishing a sustainability report. Due to this we are aware that the choice and control of its
suppliers, especially in the precious metal trading and in sourcing critical raw materials, is of key importance for a businessactivity focusing on sustainability.
Our Sourcing Guideline… is lying down and reshaping the already existing principles for the choice and control of suppliers for our precious metal
trading and recycling businesses. Our worldwide efforts ensure that we source precious metals only from legitimate and ethicalsources, and that they have not been associated with crime, armed conflict or human rights abuse.
We aim to establish long-term relationships with our immediate suppliers and counterparties.
We exercise due diligence with our precious metals suppliers consistent with the OECD Guidance, the respective responsible
guidance of LBMA and LPPM, the Responsible Business Alliance’s responsible Minerals Assurance Process (RMAP) andcomply with the European Union regulation 2017/817.
Precious metals… for us includes Gold, Silver, Platinum, Palladium, Rhodium, Iridium, Ruthenium and Osmium.
Handling of risk products
Products are considered “risk products” if their exploitation and purchase involve a particularly high risk of violation of humanrights, violation of international trade rules and realization of criminal offenses. When accepting risk products in our supply chainspecial duties of due diligence apply. We do not tolerate nor profit from, contribute to, assist in or want to be linked to:- Violation of Occupational safety- Torture, cruel, inhuman and degrading treatment- Worst forms of child labor or any form of forced labor- Other gross human rights violations and abuses such as widespread sexual violence- Corruption or any other illegal activities like bribery or money-laundering- Violations of granting the freedom of association or the right to organize- Violations of international humanitarian law- War crimes, genocide, or any other crimes against humanity- Direct or indirect support to non-state armed groups as well as public or private security forces- fraudulent misrepresentation of origin of minerals- Non-payment of taxes, fees and royalties to respective governments- Non-compliance with Environment and Sustainability legal requirements
We will not engage respectively immediately disengage with any business opportunity or business partner where we identify arisk as described above. Business relationships with partners acting against those principles is not tolerated throughout ourorganization.
Our compliance system for Precious metals and 3T (Tin, Tungsten and Tantalum)
Heraeus has established an effective and comprehensive compliance management systems based on strong local andinternational KYC due diligence practices to target anti-money laundering, bribing in commercial transactions and to comply withthe regulations set forth in the OECD due diligence guidance on Minerals from Conflict-Affected and High-Risk Areas.
This sets our responsibility for conducting risk based due diligence, screening and monitoring of transactions and governancestructures in place for all Heraeus entities involved in purchasing, refining or other transactions with Minerals from ConflictAffected and High-Risk Areas (including but not limited to Gold, Tin, Tungsten and Tantalum).
Our definition of high risk is in accordance with Annex II of the OECD due diligence guidance on Minerals from Conflict-Affectedand High-Risk Areas and includes Gold, Tin, Tungsten and Tantalum and their Minerals. The Compliance officer has theauthority to deny any new suppliers classified as high risk. Senior management retains the ultimate control and responsibility forthe supply chain.
We expect our suppliers of precious metal and precious metal containing material to take appropriate steps to ensure that theyadopt a similar policy and the provisions of this policy are communicated to their employees and down their own supply chain.
We perform annual training sessions with relevant employees and encourage them to raise any suspicious transactions tomanagement immediately.

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Identifying and assessing risks in the supply chain
For every supplier we have established a client database and allocated a risk profile according to our internal compliancecriteria. This process is a formal requirement before entering any business relationship with our precious metals supplying
counterparty.
If we are offered any minerals originating from or transiting through Conflict-Affected and High-Risk Areas we conduct anextensive due diligence check. Only if we can exclude any risk mentioned above for these products a business relationship canbe established.
In addition, we conduct appropriate scrutiny and monitoring of all transactions undertaken through the course of the relationshipwith our counterparts by using sophisticated IT systems.
An internal management system has been set up to define the governance, roles and responsibilities, internal audit, training
schedules and communication. The compliance officer has been assigned to manage this process and has a direct line ofreporting to the executive senior management.
We review our system for any deficiencies at least annually and improve our compliance systems as necessary to meet any
new requirements.
Grievance mechanism:
We encourage our employees or any external stakeholders to use our grievance mechanism, allowing to anonymously voice
concerns over our supply chain or any newly identified risk. Such concerns are treated discreetly, strictly confidential and any
attempt to identify a whistle-blower who has chosen to raise his concerns anonymously is strictly forbidden.
Please use any of the following options so we can receive, review and respond accordingly to any supply chain grievanceOur internal compliance hotline:+49 (0) 6181 / 35 - 5500 or write to heraeuscomplianceofficer@heraeus.com
External ombudsman:+49 (0) 6105 / 921355
or write to dr-buchert@dr-buchert.deConcerns can also be reported to the Responsible Minerals Initiative’s grievance mechanism at:
http://www.responsiblemineralsinitiative.org/minerals-due-diligence/risk-management/grievance-mechanism/
Similarly, anyone else involved in the gold or silver supply chains is encouraged to contact LBMA with all legitimate concerns
they may have.
LBMA and LPPM
Heraeus is an accredited Gold and Silver producer to the LBMA standards and Platinum and Palladium producer to the LPPM
standards and it is our commitment to abide to LBMA’s Responsible Gold and Silver Guidance as well as LPPM’s corresponding
guidance on Platinum and Palladium.
Due diligence of our supply chain counterparts comprises of all the measures required by the latest LBMA Responsible Gold &Silver Guidance and respective LPPM Guidance and is performed before entering into a new business relationship with any ofour precious metals supplying counterparts.
We have a robust lot-receipts process and specific documents must be received and transactional details entered before weprocess precious metal bearing material.
We distinguish our precious metals supplying counterparts into the following categories:
Mining counterparts
We request a third-party due diligence audit report to comply with OECD guidelines or – if not available - we conduct on-site
audits ourselves. Such audits are based on LBMA’s or LPPM’s questionnaire on mined material including assessment of theenvironmental impact of the mining site.
Recycling material – secondary precious metals
All our counterparties must undergo a due diligence process, before we accept material. For recycling material from high riskcountries, we engage very strict due diligence processes and material checks to prevent any commingling of secondary
precious metals with precious metals of unknown or conflict-affected origin.
For investment precious metals
Our supplier agreements do refer to the OECD due diligence guidance on Minerals from Conflict-Affected and High-RiskAreas.
Third party audit
An independent third-party audit of our supply chain due diligence is performed annually based on the LBMA, LPPM and RMI
requirements and the regulations set forth in the OECD due diligence guidance on Minerals from Conflict-Affected and HighRisk Areas.
Further information of how our systems, procedures, processes and controls have been implemented to align to the specificrequirements in the LBMA, LPPM and RMI Guidance are detailed in our annual compliance report and can be found in ourdownload section here: http://www.herae.us/conflictminerals
If you have additional questions, please contact Juergen Mueller-Schaefer, Head of PMCE, at juergen.mueller@heraeus.com
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