POLICIES OF MMC HARTMETALL GMBH

Preamble

As a subsidiary of Mitsubishi Materials Corporation, we (MMC Hartmetall GmbH) adhere to the common Corporate Philosophy “For People, Society and the Earth” and share a common vision with our parent company: We strive to become the leading business group committed to creating a sustainable world through materials innovation, with use of our unique and distinctive technologies. We are committed to earning the trust of our stakeholders by sincerely fulfilling the social responsibilities expected of us through our business activities.

Based on the shared vision and values, and as part of the group of companies, we commit ourselves to complying with the following guidelines defined by our parent company:

The Sustainability Policy

Introduction

The Mitsubishi Materials Group upholds its Corporate Philosophy “For People, Society and the Earth”. The Group strives to become the leading business group committed to creating a sustainable world through materials innovation, with use of our unique and distinctive technologies. We are committed to earning the trust of our stakeholders by sincerely fulfilling the social responsibilities expected of us through our business activities. We accelerate our proactive engagement with sustainability. The Mitsubishi Materials Group pursues its journey to sustainability and growth as we work to achieve our mission of contributing to a “prosperous society,” “recycling-oriented society” and “decarbonized society”.

1. Build a work environment that puts safety and health first

We place utmost priority on safety and health. We will build a work environment that eliminates work-related accidents, ensures occupational health, maintains employee wellness and reinforces risk management that mitigates adverse impacts from emergency situations including natural disasters and global infectious diseases.

2. Respect human rights

Respect for human rights is considered to be the foundation of the business activities of the Mitsubishi Materials Group. We respect the principles enshrined in the international human rights instruments.

3. Promote diversity and inclusion

We embrace diversity and acknowledge its importance in creating new value. We will promote diversity and inclusion as a source of sustainable growth within the Group.

4. Cultivate mutual prosperity with stakeholders

We will communicate proactively with our stakeholders – including shareholders, investors, employees, customers, suppliers, business partners, global and local communities – to foster mutual understanding toward mutual prosperity.

5. Strengthen corporate governance and risk management

We will strengthen corporate governance and reinforce risk management systems to ensure legal compliance. Fulfilling regulatory requirements is a prerequisite for enhancing our business operations and preventing corporate scandals from arising.

6. Engage in fair business transactions and responsible sourcing

We will engage in fair and responsible business transactions with all our suppliers and business partners. We will strive to ensure responsible procurement of minerals and other raw materials in collaboration with our suppliers and business partners.

7. Ensure stable provision of safe, secure and high value added products

We practice quality control and pursue innovative solutions to develop safe and secure products, services and solutions with high added value to society.

8. Proactive engagement for the global environment

We recognize the critical importance of environmental conservation. We will engage proactively in resource recycling, decarbonization and biodiversity conservation across all areas of our operations, from procurement of raw materials to the development, manufacturing, distribution, consumption, disposal, and recycling of materials and products.

(Stipulated on December 01, 2021)

Human Rights Policy

This "Human Rights Policy of the Mitsubishi Materials Group" (the "Policy") was established based on the Sustainability Policy and is considered to be the foundation of the business activities of the Mitsubishi Materials Group.
The Mitsubishi Materials Group understands that its business may directly or indirectly have an impact on human rights across all areas of its operations, from procurement of raw materials to the development, manufacturing, distribution, consumption, disposal, and recycling of materials and products. This Policy applies to all executives and employees*1 of the Mitsubishi Materials Group companies*2.

*1: Employees include short-term, contract, part-time, and temporary employees of the Mitsubishi Materials Group.

*2: “Mitsubishi Materials Group companies” (or “Group companies”) refers to our consolidated subsidiaries.

We expect our business partners to support and practice this Policy and aim to work together towards the promotion of respect for human rights.

1. Respect for International Human Rights Norms

The Mitsubishi Materials Group respects the human rights stipulated in the International Bill of Human Rights*1 and the Declaration on Fundamental Principles and Rights at Work*2 of the International Labour Organization (ILO) and understands them to be the minimum standard to be observed. We also support international human rights norms such as the Guiding Principles on Business and Human Rights and the 10 principles of the UN Global Compact*3 and conduct our business activities in line with these principles.

*1: The International Bill of Human Rights is the term applied to the set of three documents: the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights.

*2: The ILO's Declaration on Fundamental Principles and Rights at Work sets forth four areas as the minimum standard to be observed in relation to labor: “freedom of association and the effective recognition of the right to collective bargaining,” “the elimination of forced or compulsory labour,” “the abolition of child labour,” and “the elimination of discrimination in respect of employment and occupation.”

*3: Approved by the UN Human Rights Council in 2011, the Guiding Principles on Business and Human Rights set forth the responsibilities and actions required of business enterprises to respect human rights and provide access to remedy in the context of Business and Human Rights.

The Mitsubishi Materials Group complies with the laws and regulations applicable in the countries and regions where we conduct our business activities. In cases where there is a conflict between internationally recognized human rights and the laws and regulations of the country or region in which we operate, we will seek ways to honor the international principles while complying with the laws and regulations.

2. Governance and Promotion Structure

The Sustainable Management Office regularly reports on the status of compliance with this Policy and the Group‘s human rights efforts to the Executive Officers’ Meeting and the Board of Directors of the Mitsubishi Materials Corporation, and promotes the efforts under the supervision of the Board of Directors.

3. Human Rights Due Diligence

The Mitsubishi Materials Group conducts due diligence to identify, assess, prevent, and mitigate negative human rights impacts related to its business activities.
Where we identify that our business activities are causing or contributing to negative human rights impacts, we will take appropriate measures to correct and remedy the situation.

4. Stakeholder Engagement

The Mitsubishi Materials Group recognizes the importance of understanding human rights issues from the perspectives of stakeholders whose human rights have been or may be impacted. We further recognize that there are vulnerable or marginalized groups which require special consideration. Therefore, we will continue to engage in constructive dialogue with relevant stakeholders to understand, improve and address human rights issues.

5. Grievance Mechanisms

The Mitsubishi Materials Group promotes a culture of free and open communication. Employees may consult with their superiors regarding human rights concerns and/or report such concerns to our internal whistleblowing system.
We have also established a "Responsible Minerals Sourcing Hotline" which is available to internal and external stakeholders for any concerns or violations of the Responsible Minerals Control Policy.
To identify and respond to the human rights concerns of our stakeholders in a timely manner, we work to establish an effective reporting and grievance handling system.

6. Training and Awareness-Raising

The Mitsubishi Materials Group provides all executives and employees of each Group company with the training and capacity building necessary to put this Policy into practice.

7. Reporting and Disclosure

The Mitsubishi Materials Group periodically discloses the progress of efforts based on this Policy.

8. Commitment to Human Rights Issues

• Prohibition of Forced Labor and Human Trafficking
  We do not permit forced labor. We also do not tolerate modern slavery in any form, including bonded labor and human trafficking.
• Prohibition of Child Labor
  We prohibit child labor and observe the statutory minimum working age. In addition, we do not allow young workers to engage in hazardous labor.
• Prohibition of Discrimination
  We do not tolerate any form of discrimination based on race, religion, gender, sexual orientation and gender identity, age, disability, nationality, national origin, social origin, or personal history.
• Prohibition of Harassment
  We do not tolerate behaviour, whether physical or psychological, which threaten the dignity of individuals. These include power harassment, sexual harassment, harassment related to pregnancy, and other forms of harassment such as those related to childcare and nursing care leave.
• Promotion of Diversity and Inclusion
  We aim to build workplaces where team members with diverse attributes, values, and experiences can coexist and mutually respect one another, and where individuals can work confidently with a sense of growth and fulfilment as they elevate each other and demonstrate their capabilities to the full.
• Respect for Freedom of Association and the Right to Collective Bargaining
  We engage in constructive dialogue between labor and management and respect the freedom of association and the right to collective bargaining.
• Working Hours and Wages
  In accordance with the laws and regulations applicable in the countries and regions in which we operate, we duly manage employees' working hours, holidays, vacations, and wages.
• Occupational Safety and Health
  In accordance with the laws and regulations applicable in the countries and regions in which we operate, we protect the safety and health of employees and aim to create workplaces that are conducive to maintaining mental and physical wellbeing.
• Respect for Privacy
  We respect and protect the privacy of individuals. When handling personal information, we comply with relevant laws, regulations, and internal rules.
• Impact on Local Communities
  We recognize that the Group’s business activities may have an impact on local communities such as the health of local residents, land rights, access to water, and indigenous peoples’ rights. We respect local cultures and customs, engage in dialogue and consultation with local communities, and take necessary actions in accordance with relevant international norms to prevent and mitigate any negative impact on the rights of local residents.
• Responsible Procurement of Raw Materials and Minerals
  We work together with our suppliers to procure raw materials and minerals in a responsible manner. Specifically, we ensure that our suppliers are fully aware of our procurement guidelines and conduct supplier evaluations. We also work together with our suppliers to promote cooperation with industry associations and international initiatives.
• High Risk Circumstances
  In the event that we are confronted with a specific situation or environment where there is a high risk of human rights abuses, we, based on the basic principle of respect for human rights, will strive to prevent such abuses with the utmost care.

This Policy has been approved by the Executive Officers’ Meeting after deliberation at the Board of Directors of Mitsubishi Materials Corporation.

Established on 01 December, 2021
Revised on 13 December, 2021

The Environmental Policy

This “Environmental Policy of the Mitsubishi Materials Group” was established based on the Sustainability Policy and is considered to be the foundation for the business activities of the Mitsubishi Materials Group.

1. Promote recycling and provide environmentally friendly products

We leverage our advanced recycling technologies to promote recycling of waste. At the same time, we provide environmentally friendly materials and products across all areas of our operations, from procurement of raw materials to the development, manufacturing, distribution, consumption, disposal, and recycling of materials and products.

2. Advance decarbonization

We work towards the decarbonization of our business activities by reducing energy consumption. We will also tap into geothermal and other renewable energy sources to decarbonize our entire value chain.

3. Respect biodiversity

We engage in business activities that take ecosystems into account throughout our value chain, including the development of natural resources.

4. Effectively use and conserve water resources

We work to reduce water consumption through circular water management and reuse of cooling water, cleaning water and all other water used across our business activities.

5. Sustainably manage company-owned forests

We make effective use of timber and other forest resources as well as ensure appropriate management of company-owned forests that contribute to decarbonization, biodiversity and water conservation and recreational activities of the local communities.

6. Encourage environmental education and harmonious coexistence with society

We strive to reduce the environmental impact from our business activities and prevent pollution by educating all our employees on relevant laws, regulations, and agreements on an on-going basis. We will communicate proactively with our stakeholders and engage in environmental conservation initiatives.

Revised on 01 December, 2021

The Procurement Policy

Open Door/Fair Trade

When selecting suppliers, we provide a wide range of opportunities for all suppliers to engage in transactions.
We select suppliers based on fair and appropriate assessments of quality, price, delivery time, management base and so on, predicated on mutual trust for the sake of mutual prosperity.

Legal Compliance

In conducting procurement operations, we comply with local laws and regulations.

Observance of Ethical Procurement

In conducting procurement operations, we do not engage in any inappropriate transfer of profits with suppliers.

Working Environment and Occupational Health and Safety

In conducting procurement operations, we strive to improve working environments and ensure occupational health and safety.

Environmental Protection and Decarbonization

In conducting procurement operations, we endeavor to protect the environment, apply every measure for the effective use and recycling of natural resources, and work toward decarbonization.

Respect for Human Rights

In conducting procurement operations, we respect the fundamental principles of human rights as declared internationally.

Information Security

In conducting procurement operations, we maintain strict confidentiality of information obtained from suppliers.

In conducting procurement operations, we promote CSR initiatives in all business activities, including the procurement of raw materials, development, production, distribution, consumption, disposal, and recycling of materials and products.

Stipulated on 01 December, 2021