Policy Statementon Human Rights
Sandvik Holding GmbH- Confidential -ContentCommitment towards international human rights standards

1

Procedure to fulfill SCDDA due diligence obligations

2

Risk analysis (direct suppliers and own business area)

2

Preventive measures and remedial actions

3

Indirect suppliers

3

Prioritized human rights and environmental risk clusters

4

Discrimination against employees

4

Disregard of occupational health and safety

4

Environmental damage with human rights implications

5Expectations towards employees and suppliers

5

Continuous improvement

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Commitment towards international
human rights standards
The Sandvik Holding GmbH is a global engineering company and an integral part of
the Sandvik Group, specialized in the field of mining, rock excavation, metal-cutting
and materials technology. In Germany, the Sandvik Holding GmbH is present throughvarious divisions and subsidiaries, focusing on offering cutting-edge solutions inmanufacturing, mining and materials technology.
The Sandvik Holding GmbH is committed to utilize high-end engineering andinnovation to enable the fast shift towards a sustainable business model. By
integrating sustainability into the business model and ways of working, Sandvik
Holding GmbH creates value for all stakeholders: customers, employees,
shareholders as well as the entire society. With its global footprint Sandvik Holding
GmbH bears a major responsibility to everyone within and outside the company.
Therefore, social and employee-related responsibilities and the commitment tocontinuous compliance with human rights and environmental-related due diligenceobligations are taken with the utmost seriousness.
As Sandvik Holding GmbH we strive to ensure the effectiveness of our sustainablebusiness practices. To achieve this, it is essential that sustainable practices areintegrated across our entire supply chain. This involves not only establishing rigorous
standards for our own operations but also mandating our suppliers and other business
partners to adhere to mandatory environmental and social criteria. We follow anintegrated approach, including our entire value chain into our sustainability agenda.
Our efforts to respect human rights and environmental protection are primarily guided
by internationally recognized standards and frameworks. As anchored within ourCode of Conduct, we are committed to comply with applicable laws and regulationsin the countries where we operate as well as to (1) the 10 principles of the UN GlobalCompact, (2) the OECD (Organization for Economic Cooperation and Development)

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Guidelines for Multinational Enterprises, (3) the UN Guiding Principles on Businessand Human Rights and (4) the Science Based Targets Initiative (SBTi).

Procedure to fulfill SCDDA due diligenceobligations
As Sandvik Holding GmbH, we take a holistic approach by considering our entire
supply chain and own business area for SCDDA due diligence obligations. To
implement our human rights and environmental obligations, we use a standardizedrisk management process with clear organizational responsibilities and measurable
KPIs to monitor our performance.

Risk analysis (direct suppliers and own business area)
We conduct a risk analysis for our entire own business area and the direct supplierbase on a continuous basis, at a minimum, once per year. The risk analysis isconducted by Sandvik Holding GmbH for all its subsidiaries regardless of whether
they are in Germany or abroad.
For the direct supplier base, a systematic assessment approach is implemented
company-wide utilizing an external sustainability risk rating platform to screen
suppliers for inherent risks based on country and industry related risk factors.
Identified medium to high-risk suppliers are subject to a further qualitative assessment
to verify the results on a case-by-case basis. This is ensured by requesting selectedsuppliers to perform a detailed sustainability assessment.
In our own business area, after creating transparency about the nature and scope ofour business activities, a qualitative assessment is carried out regarding human rights
and environmental risks. These risks are individually identified, weighted, andprioritized. Criteria such as the influence on the originator of the risk, the severity ofthe duty violation and the probability occurrence are considered.

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Preventive measures and remedial actions
Based on the results of the risk analysis selected preventive measures and remedialactions are defined and implemented within the direct supplier base and the own
business area, to mitigate identified human rights and environmental-related risks.
The effectiveness of these implemented measures is reviewed on a regular basis andadjustments are made if necessary. First preventive measures, as for example theSupplier Code of Conduct are already implemented as a mandatory document to besigned by all direct suppliers. In our own business area, we initiated preventive
measures through our Code of Conduct, our Sustainability Policy and various further
CSR-related guidelines.

Indirect suppliers
All components described in the procedure to achieve compliance with human rights
and environmental due diligence obligations apply to our own business area as wellas to our direct suppliers. If we become aware of violations by indirect suppliers, wetake appropriate measures to mitigate their impact.

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Prioritized human rights andenvironmental risk clusters
Based on the initial risk analysis performed for the Sandvik Holding GmbH, agenerally low to moderate risk profile for human rights and environmental-related risks
was identified within the direct supplier base. The initial risk analysis within the own
business area revealed a low risk profile for all assessed subsidiaries.
Nevertheless, within our detailed due diligence approach we place particularemphasis on the following prioritized human rights and environmental aspects thatare of great importance to our industry, in addition to the standards alreadyestablished:

Discrimination against employees
We reject any form of discrimination or harassment based on ethnic or social origin,gender, religion, age, health status, sexual orientation, gender identity, skin color,
political conviction, nationality or other protected characteristics. We are committed
to promoting diversity and to ensuring a working environment in which mutual respect
and acceptance are essential values. We champion people, our goal and targets ofZero Harm are governed by our environment, health & safety policies, and our people
policy. Our people-centered targets with focus on safety, health, diversity, equity andinclusion, are monitored on group level.

Disregard of occupational health and safety
The health and safety of our employees is of the utmost importance to us. For thisreason, we are committed to creating a safe working environment and to complying
with applicable health and safety standards. With these provisions, we ensure a safeand health-promoting working environment in which the health of employees ismaintained, accidents and injuries are avoided, and absenteeism is reduced. In case
we become aware that the given requirements are not being complied with,particularly at direct suppliers, we take appropriate countermeasures.

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Environmental damage with human rights implications
We are committed to environmental protection and place the highest value on
compliance with environmental protection standards to minimize and prevent thenegative impact of our daily business on the environment. We are aware of the factthat all our business activities have an impact on the environment and the climate.
Therefore, we are committed to strictly adhere to all environmental standards in all
our activities and are preventively addressing all environmental impacts with potential
consequences for human rights. Furthermore, annual targets are set on climate
mitigation to reach Net Zero and be in line with our Global sustainability objectives for
the Sandvik Group. Purchasing such as energy and internal transports is done in away that supports our long-term Net Zero target, focusing on three primary areas,
reducing consumption, increasing efficiency, and reducing GHG emissions. We
encourage all our suppliers to commit to science-based targets through our Supplier
Code of Conduct. Accepting and complying with the Supplier Code of Conduct is aprerequisite for doing business with us, and a basis for ensuring a sustainable supply
chain.

Expectations towards employees andsuppliers
We expect all our employees to behave appropriately towards colleagues, business
partners and communities in accordance with our defined principles. We also expect
all our business partners to establish appropriate structures for respecting humanrights and environmental standards and to pass these on to their respective business
partners to ensure the integrity of our entire supply chain. In case a violation of humanrights or environmental obligations occurs in our value chain, appropriate remedialaction will be taken. Depending on the severity of the violation or in the event of provenviolations of the law, we reserve the right to refer the violation to the authorities.

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Continuous improvement
The goal of Sandvik Holding GmbH is to create long-term added value throughsustainability and to raise awareness of this issue through continuous communication.
Therefore, this policy statement is regularly reassessed and updated in relation tohuman rights and environmental protection along our continuous improvement
process.

January 24, 2024

Børge Anegaard*

Damian Göppert**The original policy statement has been signed

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