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Statement of Commitment on Responsible Minerals Sourcing

dormakaba Statement of Commitment on Responsible Minerals
Sourcing
This Statement of Commitment on Responsible Minerals Sourcing formalizes andspecifies the commitment of dormakaba to not contribute to conflict or human rights
infringements when sourcing minerals.
Subject matter and objective
The objective of this Statement of Commitment is to provide a common framework forthe company’s due diligence process specifically related to the mineral supply chain
which may potentially originate from conflict-affected or high- risk areas.
Conflict-affected and high-risk areas are identified by the presence of armed conflict,generalized violence or other risks of harm to people. Armed conflict can take variousforms, such as a conflict of international or non-international character, which may
involve two or more states, or may consist of wars of liberation, or insurgencies, civilwars, etc. High-risk zones may include areas of political instability or repression,
institutional weakness, insecurity, collapse of civil infrastructure and widespread
violence. These areas are often characterized by widespread human rights abuses andviolations of national or international law.
dormakaba is committed to proactively establishing a responsible supply chain
management of minerals which may originate from conflict-affected and high-riskareas.
PurposeAs a company procuring electronic components, dormakaba acknowledges its
responsibility to take action to increase transparency in its mineral supply chains, inparticular regarding the potential human rights violations during the mining process ofcertain minerals.
However, dormakaba is far removed from the extraction of minerals in the value chain,and does not directly purchase or import raw ore or unrefined minerals. These minerals
may be contained in small quantities in components of dormakaba products. Hence,the company relies on collaboration with its supplier base to identify and manage therisks associated with potential links to conflict-affected or high-risk areas by thedormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakaba.com

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Statement of Commitment on Responsible Minerals Sourcing

actors present in the upstream supply chain involved in mineral extraction, processing
or transport.
The purpose of this Statement of Commitment is to provide dormakaba entities withthe framework necessary to source responsibly from conflict-affected and high-riskareas, while creating the enabling conditions for constructive engagement withsuppliers.
dormakaba is committed to:••••

Exercise due diligence with relevant suppliers
Collaborate with customers, suppliers, and industry associations to help
develop long term solutions to enable responsible mineral sourcing
Participate in responsible sourcing initiatives to improve the upstream
communities in our supply chain
Encourage the smelters and refiners in the upstream supply chain to pass the
Responsible Minerals Assurance Process (RMAP)

Framework of reference
dormakaba is committed to following the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
dormakaba encourages its suppliers and business partners to follow the same
standards and principles.
Supplier Obligations
dormakaba aims at establishing and maintaining long-term relationships withimmediate suppliers as a means to foster mutual trust and increase its leverage in thearea of responsible sourcing of minerals.
dormakaba requires its business partners to comply with their own due diligenceobligation to establish responsible mineral supply chains and to submit written
reports, documentation or assurances upon request.
At minimum, dormakaba expects its business partners and suppliers to:••Comply with the OECD Due Diligence Guidance 5 step framework.
Annually report to dormakaba the mineral country of origin and utilized smelters
and refiners in their products’ supply chains via the standard Conflict Minerals
Reporting Template (CMRT) and/or the Extended Minerals Reporting Template(EMRT).

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakaba.com

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Statement of Commitment on Responsible Minerals Sourcing••

Utilize smelters and refiners that conform to an independent third-party
responsible materials sourcing program (RMAP) to increase our level ofconfidence that the components and materials in our products contain conflict
free minerals.
Extend these requirements and expectations to all of its’ sub-tier suppliers.

Due diligence
A. Company management systems

In addition to tin, tantalum, tungsten and gold – which are commonly referred asconflict minerals - dormakaba has expanded its responsible minerals
management system to include cobalt, which is mainly used in the production oflithium-ion batteries and is known to be associated with child labor risks. In
pursuing its commitment, dormakaba has set a public target to ensure supply
chain traceability for minerals having high risk of child labor.
dormakaba has established a company management system aimed at:• Identifying those suppliers that provide the company with products that
may contain conflict minerals and/or cobalt.
• Tackling the risks associated with the sourcing of these raw materials.
dormakaba communicates the requirements of this management system to thepublic and to all its immediate suppliers.
The responsibility for engaging and collecting supplier information lies with theProcurement function, whereas risk identification and categorization lies with
Corporate Sustainability. The supplier information collected is reviewed andstored for a period of at least 5 years.
B. Identification and assessment of risks in the upstream supply chaindormakaba has established a centralized system to identify those suppliers ofproducts or materials that contain minerals potentially linked to conflict orhuman rights abuses in their process of extraction, trade and/or handling.
After the identification process, dormakaba categorizes the risk linked to eachsupplier and deploys the tools provided by the Responsible Minerals Initiative(RMI) – such as the CMRT and EMRT – to those suppliers that pose the highest
risk. Once completed, the CMRT and EMRT provide the company with valuable
information about the actors present upstream in its supply chain and allows
management to decide on further due diligence measures.

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakaba.com

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Statement of Commitment on Responsible Minerals Sourcing

In addition, due to the particular risks linked to the extraction, trading andhandling of cobalt, dormakaba is engaged in Cobalt Traceability Dialogues withkey suppliers since the financial year 2021/22. The goal of the discussions is tounderstand the joint upstream value chains and to collaborate to tackle thehuman rights and environmental risks present in them.
dormakaba has also established a grievance mechanism that allows any internalor external interested party, including affected stakeholders and whistle-blowers,
to voice concerns regarding the circumstances of extraction, trade and handlingof the minerals present in dormakaba’s products. Substantiated reports aretaken into consideration in the risk assessment.
Lastly, as a member of the RMI, dormakaba leverages the organization’s risk
assessment resources to enrich its own risk identification in relation to thedifferent minerals present in its supply chain.
C. Strategy to respond to identified risks

dormakaba supports suppliers to build capacity during the process of disclosureand the establishment of corrective action plans. dormakaba monitors thesustainability performance of targeted suppliers, including their responsible
sourcing management, on a regular basis.
For those suppliers that refuse to fill in the CMRT and EMRT forms or that do not
implement the agreed corrective actions, dormakaba has defined an escalation
process in its Sustainable Procurement Directive. Ultimately, non-participation ornon-conformance will lead to a suspension of trade and/or ending the supplier
relationship.
D. Independent third-party audit of supply chain due diligence at identified points inthe supply chain

In assisting corporations to meet the requirements of the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected andHigh-Risk Areas (Step 4) and of the EU Regulation on Conflict Minerals (article 3),
the RMI conducts regular audits of smelters and refiners around the globe andyields a list of conformant actors through the RMAP process.
The audits conducted by the RMI follow the design and prescriptions of theOECD. dormakaba leverages the list of RMAP-conformant smelters and refiners
to identify those present in its supply chain and is developing due diligencemeasures for suppliers working with other smelters/refiners.

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakaba.com

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E. Reporting

Through its Sustainability Report, dormakaba reports annually on the due
diligence measures it implements to ensure that the conflict minerals and cobalt
present in its products are sourced in a responsible manner.
Scope of application
The Statement covers fully consolidated operations of dormakaba Holding AG
worldwide, including those of direct and indirect subsidiaries and applies to all
dormakaba employees and managers, including part-time and temporary workers aswell as casual workers (e.g. day labor workers).
Validity
The Statement comes into force from 7 August 2023 onwards and remains valid until
further notice.
Responsibility
This Statement is written by Corporate Sustainability. All questions related to thecontent may be addressed to the e-mail address sustainability@dormakaba.com
Corporate Sustainability bears the responsibility for keeping this Statement updated.
This Statement will be reviewed periodically and updated as required to amend it tochanged business processes, regulatory requirements as well as political and societalexpectations.
Communication and Implementation
This Statement is made publicly available on the dormakaba corporate website for thecompany’s external stakeholders, suppliers and business partners. It is also madeavailable on the company’s internal communications channels. Furthermore, every
procurement manager must ensure that dormakaba procurement employees becomeaware of this Statement, understand it and adhere to it. The authors’ department is
responsible for implementing the Statement into workflows and to provide trainings
for employees as appropriate.
Approval

dormakaba Holding AG | Hofwisenstrasse 24 | 8153 Rümlang | Switzerland | T +41 44 818 90 11 | F +41 44 818 90 18 | www.dormakaba.com