STL Responsible Supply Chain Due Diligence Policy

1. Purpose

The purpose of this policy is to establish STL’s commitment to responsible sourcing and supply chain due diligence in accordance with international standards, including the OECD Due Diligence Guidance, the RMI Joint Due Diligence Standard (JDD), and the ISO framework for policy compliance. It defines STL’s approach to managing environmental, social, governance (ESG), and human rights risks within its supply chain, even though STL sources exclusively from its own concession in the Democratic Republic of Congo.

2. Scope

This policy applies to all STL operations, employees, and stakeholders involved in the management, transformation, and export of mineral products derived from the legacy slag heap located within STL’s facilities in Lubumbashi, DRC. It also applies to any service providers or partners involved in STL’s supply chain and value chain processes.

3. Policy Statement

STL is committed to maintaining a responsible and transparent mineral supply chain. As an actor operating in a Conflict-Affected and High-Risk Area (CAHRA), STL recognizes the risks associated with sourcing, handling, and transforming mineral materials. While STL does not source externally, it maintains a robust due diligence system aligned with the OECD and RMI JDD frameworks.

4. Commitments

• Respect for human rights, including the prohibition of child labor, forced labor, torture, or other degrading treatment.
• Zero tolerance for corruption, bribery, and money laundering.
• No engagement with or support to non-state armed groups.
• Support for transparent payments and disclosure in line with the Extractive Industries Transparency Initiative (EITI).
• Engagement of public and private security providers is only under strict adherence to international human rights standards.
• Compliance with all applicable national laws, international norms, and industry expectations.

5. Roles and Responsibilities

The RMI appointed person is accountable for the implementation of STL’s Responsible Supply Chain Due Diligence Policy. This includes staff training, provision of resources, coordination of risk assessments, and engagement with external auditors. All STL personnel and business partners are expected to comply with this policy.

6. Risk Assessment and Mitigation

STL conducts an annual risk assessment aligned with OECD Annex II risks and Fragile States Index (FSI) P3 Human Rights indicators. Risks include human rights abuse, illegal artisanal mining, corruption, tax irregularities, and environmental degradation. Mitigation measures include incident monitoring, grievance resolution, and third-party verification under the RMI RMAP framework.

7. Documentation and Record Keeping

All documentation related to responsible sourcing, risk assessment, audits, and grievance mechanisms are retained for a minimum of five (5) years. Records are stored securely and made available for stakeholder review and external audits.

The relevant documents to be stored are in Annex I of this policy. 

STL CAHRAs P3 Assessment Questionnaire will be filled out every year.

8. Communication and Awareness

This policy is communicated to all STL employees, stakeholders, and partners. It is available publicly on STL’s website. Annual updates on due diligence performance will be published in STL’s annual due diligence report.

9. Grievance Mechanism

Any individual or stakeholder may raise concerns about STL’s supply chain practices through the company’s grievance mechanism. All grievances are handled confidentially and reviewed in accordance with STL’s Grievance Policy.

10. Review and Continuous Improvement

This policy will be reviewed annually or in response to significant changes in legal requirements, operational context, or stakeholder feedback. STL is committed to continual improvement of its Responsible Supply Chain Due Diligence System.

Annex I: List of relevant archived documents

 

This document outlines the categories of physical and digital records that STL, as a mining company, should maintain. These archives support compliance with the five OECD-aligned due diligence steps and demonstrate responsible sourcing, risk management, stakeholder engagement, and legal compliance.

1. Supply Chain Mapping and Traceability Records

• Mine production records (volume, type, and location)
• Transportation logs and weighbridge records
• Supplier and buyer contracts and declarations (KYC)
• Chain of custody documentation (shipment tracking, batch numbers)
• Export permits and customs documentation

2. Risk Assessment and Management Records

• Risk assessment reports (e.g., ESG, human rights, security risks)
• Incident reports (accidents, security incidents, grievances)
• Risk register or matrix
• Internal audit reports
• Third-party assessments or baseline studies
• Risk mitigation plans and follow-up reports

3. Policies, Procedures, and Governance Documents

• SHEC policy and supply chain policy
• Code of Conduct or Responsible Sourcing Policy
• Grievance mechanism procedures and logs
• Internal control procedures (due diligence SOPs)
• Training records

4. Stakeholder Engagement and Communication Records

• Community consultation meeting minutes
• Correspondence with authorities, NGOs, and leaders
• Complaint and grievance logs
• Employee and contractor training attendance
• Records of industry initiatives or associations

5. Monitoring, Reporting, and Improvement Records

• Internal and external monitoring reports
• Annual due diligence reports
• Corrective action plans and updates
• KPI monitoring data (HSE, environment, etc.)
• Reports submitted to regulators or RMI

6. Legal and Regulatory Compliance Records

• Environmental permits and monitoring data
• Health & safety inspection reports
• Labor and tax compliance records
• Security provider contracts
• Sanctions and embargo screening documentation

 

Suppliers Standard

All supplier information is stored in a database which includes:

SUPPLIER FORM CONTAINING RELEVANT INFORMATION

In addition to providing STL with details of its identity and all legal documents, the supplier agrees to:

• Fight against child labor
• Fight against corruption
• Fight against all forms of torture or inhuman and degrading treatment
• Fight against all forms of forced labor
• Avoid any violation of human rights or sexual violence
• Avoid war crimes or other violations of international humanitarian law
• Contribute to the community’s social development with 0.3% of the amount of each invoice
• Respect the environment

In the event of false information transmitted on the form to STL or if we have reason to believe that a supplier does not respect this policy, we will suspend or this supply.

PROCEDURE FOR VALIDATING INFORMATION PROVIDED BY SUPPLIERS AGAINST NATIONAL OR INTERNATIONAL SANCTIONS.

• STL verifies the authenticity of the information and documents provided by suppliers by exploiting all possible sources of information: investigations with the commercial court, research on the net, publications and requests for information from the general public.
• Regarding crimes, other human rights violations and national and international sanctions, STL uses information from various sources: press: local and international, Lubumbashi commercial court , Lubumbashi prosecutors, etc.
• Rejection of validation of suppliers who do not comply with the relevant provisions.
• Forms meeting criteria for responsible procurement practices are validated by STL’s General Manager.
• Validation is renewed each year after evaluation of the supplier.

PROCEDURE FOR COMMUNICATING STL’S POLICY AND RESPONSIBLE PROCUREMENT PRACTICES TO SUPPLIERS

In order to encourage the supplier to adhere to and take ownership of its policy and good responsible procurement practices, STL:

• Organizes documented and archived exchange meetings with its suppliers;
• As a reminder, STL Attaches to each purchase order a document summarizing the points of its policy and good practices.
• STL also undertakes to publish its procurement policy on its WEB site
• It will be the same for all updates.
• STL undertakes to revise its supply policy to incorporate relevant observations from suppliers.

SUPPLIER CONTRACT

Integration of procurement policies content in the contracts.

• Criteria of the supply policy are integrated as articles and terms of any contract signed between STL and its partners.
• Any contract must clearly provide for the sanctions foreseen in the event of violation of these criteria.
• STL also undertakes to publish its procurement policy on its WEB site
• STL undertakes to publish goods and services supply contracts on its WEB site.

EVALUATION OF SUPPLIERS

According to the annual periodicity, STL undertakes to produce the supplier evaluation grid in relation to compliance with the criteria set out in the STL’s supply policy, which are:

• No employment of children
• Does not practice torture or forced labor
• No support for armed groups
• No corrupt practice
• Not be involved in money laundering
• Commitment to environment preservation
• Transmission of correct information on the application forms provided to STL
• Comply with all STL procedures, regulations and policies.

Code of ethics

1. Introduction

Purpose and application of the Code

The code describes the fundamental principles which must govern day to day conduct of STL’s business (“the company”) in its relations with various stakeholders. This Code of Ethics has been approved by the Board of Directors and senior management of the company and applies to all employees, officers and directors of STL, regardless of their seniority, and to any entity owned or controlled by the company.

This code does not define detailed rules and procedures. These are documented in specific policy and procedure manuals.

Compliance with Laws and Other Standards

Directors, officers and employees should be familiar with the laws, regulations, professional or industry codes, and company policies and procedures to which their position and related activities are subject. They must ensure that they comply with these laws and standards at all times.

Policy

The company is committed to applying a policy of loyalty and integrity in the conduct of its business. This policy, which is actively supported by the Board of Directors, requires that employees act at all times with the utmost honesty, integrity and good faith, and comply with the letter and spirit of all laws, regulations, occupational or industry standards as well as company policies and procedures that apply to their occupation.

2. The company and its employees

Safety and Health

The company recognizes that all of its employees have the right to work in a safe and healthy environment. This commitment is supported by research programs, ongoing training in occupational health and safety, and the provision of adequate and comprehensive medical care to its employees.

The company expects from all of its employees to be aware of health and safety hazards in the workplace and to comply with all applicable health and safety standards.

Employees should report to their supervisors all potential hazards and any quality or nonconformity issues they identify so that the necessary corrective action can be taken.

Employment Practices

All employees are entitled to fair and equitable employment practices. These include fair remuneration and opportunities for advancement or promotion, based solely on knowledge, skills, experience and performance. The company is committed to equal opportunity and equity in employment, with merit and ability being the only criteria, for all current and future employees.

Discrimination and Harassment

The company respects and upholds the rights of all employees to a work environment free from discrimination based on race, gender, religious belief, political affiliation, age or disability.

Freedom of association with trade unions or other bodies representing workers is also guaranteed.

All employees have the right to freedom of association and the exercise of this freedom within the limits of the law, collective agreements and the rights of others.

Employees and their elected representatives must assume the duties and responsibilities attached to this right.

Disciplinary measures

Company policies and procedures provide for disciplinary actions in various circumstances. The primary objective of these measures is not to punish the employees concerned, but rather to bring them into conformity with the standards of behavior and performance at work.

It is the company’s duty to ensure that all employees know and practice these required standards.

Any disciplinary action must be fair and legal, both substantively and procedurally. The company undertakes to protect employees against any arbitrary action that could lead to abusive disciplinary measures (layoff, dismissal, etc.)

Grievances

Employees are encouraged to use established procedures to alert management to any dissatisfaction or feelings of unfairness arising from their employment. The company undertakes to give the necessary attention to these grievances and, if necessary, to take all reasonable measures consistent with the instructions of the company to rectify the situation.

3. The company and the environment

The company recognizes that the environment represents a strategic resource for current and future generations, and is committed to minimizing the impact of its activities on the environment by applying appropriate and cost-effective measures to promote sustainable development.

The company expects all its employees to participate actively in the actions initiated in this regard, both by minimizing the impact they have on the environment and by reporting to management all incidents of degradation of environment, actual or potential.

4. Company and community

The company and all of its agents recognize that they share a very real responsibility to contribute to the development of the local community. The company therefore encourages its employees to participate in religious, charitable, educational and civic activities.

Employees should, however, avoid engaging in any activity that would create or appear to create:

An excessive demand on their time, attention and energy which would deprive the company of their best efforts at work

A conflict of interest that would interfere with the independent exercise of judgment in the best interests of the company

5. Commercial transactions and public contracts

The company recognizes that relations with suppliers or customers may give rise to situations of real or perceived conflicts of interest. Directors and employees must take care to be independent, and to be perceived as such by any commercial organization having a contractual relationship with the company for the supply of goods or services.

Purchasing contracts and tenders must be concluded on the basis of quality of service, price and availability, within the parameters of the purchasing policy of the group, the company and any applicable law.

All approved vendors must be in good standing and eligible to compete for STL business.

Company purchasing power cannot be used for personal or related benefits. It is unethical to seek concessions or benefits from suppliers, customers, or vendors for your personal benefit.

Financial Interest in a Supplier or Customer

Directors or employees must not invest in a supplier or a customer, nor acquire a financial interest, directly or indirectly, when they have knowledge that this interest could influence, or give the impression of influencing, their decisions in the exercise of their functions on behalf of the company.

However, Directors and employees are permitted to make investments in good faith.
In all cases, if the nature of their work requires them to negotiate with a supplier or customer in which they have a financial interest, they must disclose the nature and extent of their interest to management and, if necessary, withdraw from any decision-making processes.

Expression of Interest

A declaration of interest procedure is in place, whereby employees are required to disclose their respective interests to senior management. General managers in turn present these declarations at the various meetings of the management committee. Members of the Board of Directors file a declaration of interest at each meeting of the Board of Directors.

Employees, managers and directors of the company confirm that they have familiarized themselves with the group’s procurement policy as well as with the declaration of interest procedure.

6. Gifts, hospitality and entertainment

Directors and employees shall not accept any gifts, hospitality or favors from suppliers or purchasers of goods or services. This rule extends to the immediate family of the director or employee, including spouses.

However, acceptance of the following items would not be considered contrary to this policy:

Novelty or advertising items of nominal commercial value, for example calendars, pens, diaries, ties, etc.;

All gifts, hospitality, entertainment or favors must be disclosed in the book provided for this purpose at the Secretariat of the senior Management, which will keep an appropriate record.

7. External jobs and mandates

Outside Employment

Employees cannot take outside employment without prior approval from management.

Mandates of external directors

Employees will not hold outside directorships without prior approval of the Company and should avoid any outside directorship that would create or appear to create:

a) Undue demands on their time, attention and energy that would deprive the company of their best efforts at work; or

b) A conflict of interest that would interfere with the independent exercise of judgment in the best interests of the company.

Employees who hold, or have been invited to hold, outside directorships must take particular care to comply with all provisions of this Code.

Directors who hold an outside director position must disclose this in their declaration of interest at board meetings and, if necessary, must recuse themselves from any discussion and decision-making processes.

8. Use of company services and properties

Directors and employees are expected to take good care of all company property in their possession or assigned to them for their personal use. Specifically

Company motor vehicles or accommodation

Directors or employees who are entitled to the use of a motor vehicle under the company’s motor vehicle scheme or to the use of accommodation owned or rented by the company, must take due care of the assets concerned and will not use them for purposes other than those stipulated or provided for this purpose.

Company Workshops

Directors or employees may not perform private work in a company-owned workshop nor use company equipment without prior approval.

Use of Company-owned or Controlled Land

Directors or employees may not engage in agricultural or commercial activities for personal gain on company-owned or company-controlled land without prior approval.

Use of Company-owned or Licensed Computer Software

Directors and employees may not use, copy or distribute licensed computer software without prior permission.

Intellectual Property

Managers or employees may, during the course of their employment, be involved in the development of new processes or new designs. Such processes or designs, whether or not patented by the Company, shall at all times remain the property of the Company, and such directors or employees may not use such processes or designs for personal purposes without prior permission.

9. Confidential information and external communication

Directors and employees are required to treat all information relating to the company, and which is not in the public domain, in the strictest confidence and may not disclose such information to any third party without permission. This obligation of confidentiality continues to bind directors and employees even after the cessation of their functions within the company.

In the event of uncertainty as to the confidentiality of information, the manager or the employee must request a written decision from the general manager.

Directors or employees are not permitted to speak, lecture or make presentations on Company business or on Company matters or matters without the prior written consent of the general manager.

Communication with business partners and other stakeholders

Managers and employees need to communicate quickly and effectively with business partners and stakeholders. In doing so, however, directors and employees remain subject to the confidentiality requirements of this Code, the Company’s disclosure requirements and the Company’s announcements framework.

Public presentations

When making public presentations on behalf of the company, directors and employees must at all times take steps to protect and enhance the reputation of the company and its employees. The content of any public presentation made by employees must be approved by the General Manager or the Chairman of the Board of Directors before the employee agrees to make such presentation.

Communication with the press and/or the investment community

No communication can be made to the press or to the investment community. Such communication must be approved in advance by the General Manager or the Chairman of the Board of Directors.

10. Violation of the code and whistleblowing of unethical behavior

Any violation of this Code, or any policy or procedure based upon it, will be considered serious, and persons who commit such a violation will be subject to disciplinary action and may be subject to further civil or criminal prosecution.

Employees who become aware of any violation of this Code are required to immediately bring such violation to the attention of senior management and/or General Manager, who must address it promptly and fairly, while respecting confidentiality. If an employee becomes aware of a behavior of a director or a member of the board of directors that would be incompatible with this code of ethics, he is required to report it to the Senior Management.

The company will not tolerate any form of retribution or victimization against those who report violations of this Code and employees are urged to report any instances of victimization to a senior manager, General Manager or Board of Directors.

Grievance mechanism

The Grievance Mechanism allows community members or other stakeholders to voice their concerns, real or perceived, with the aim of resolving difficulties before they escalate.
The Grievance Mechanism is also for our employees and workers who feel unable to directly raise a problem or complaint with their supervisor or local personnel department.

Key Objectives

The key objectives of the grievance mechanism are:

• Become aware of and respond to concerns and complaints promptly (including by carrying out an assessment of the legitimacy of such grievances in relation to this procedure).
• Communicate and apply an understandable and transparent process.
• Ensure that this process is easily accessible to the public, by any affected person or community.
• Ensure that the complaint resolution procedure is applied free of charge.Ensure that grievances are managed without fear of punishment.
• Apply a process that does not hinder or prevent recourse to justice or other administrative remedy.
• Ensure the protection of personal information and the identity of the persons concerned at each step of the process.

Definition of a Grievance

The term grievance is defined as a concern or complaint resulting from the activities of the Society and affecting local communities or other stakeholders.

Stakeholders impacted may include local or national residents and businesses, leaders and representatives of formal or informal communities, and other interested parties.

Types of grievances

Anyone who believes that the Company’s activity has a negative impact on them, their community or the local environment can file a complaint. Examples of grievances

May include:

• OECD Annex II risks such as human rights abuses, bribery and corruption, worst form of child labor, etc.
• Negative social or environmental impacts suffered by local residents and communities (such as excessive noise, dust, odor, traffic, etc.), resulting from the Company’s activities.
• HSE risks related to the company’s activities (cobalt production) and endangering the health and safety of employees or local communities.
• Damage to community property.
• Failure to respect the rights of workers directly employed by the Company.
• Unacceptable behavior by a staff member or company representative.
• To avoid any confusion, this policy will not apply in the following cases:
• Commercial disputes for which the appropriate resolution procedure for a dispute or disagreement is already stipulated in the contract.
• Complaints not related to the Company or its activities.
• Complaints of a criminal or violent nature; these must be reported to the competent authorities.
• Complaints related to government policy or government institutions.
• Unfounded or malicious complaints.
• Complaints motivated by the desire to obtain a financial, personal or political advantage, or any other advantage not directly related to the grievance.
• Any problem that has already been brought to the attention of the Company and for which the Company has already made a recommendation or issued a decision unless the contribution of new elements justifies it.

How to send us your complaint

To facilitate the submission of grievances by our stakeholders, STL uses the following methods
1) By email to the following address: info@stlgcm.com
2) By post to the following address STL, 04 Route Kipushi, Lubumbashi city, Haut-Katanga province.
3) Through the “suggestion boxes” available on the STL site, near the main entrance of the STL plant and on the website of the STL Société pour le traitement du Terril de Lubumbashi (stlgcm.com)

• Internally, methods 1), 2) and 3) are used.
• Externally:
  • For suppliers, mainly method 1).
  • For the community: method 3), suggestion box located at the main entrance of the STL site.

Process in the event of a complaint (grievance management form)

Step 1: Confirmation of receipt

The Company acknowledges receipt of the complaint to its sender. Confirmation of receipt will include contact information for the Company representative handling the grievance and, if possible, the time frame for investigating and responding to the grievance.

Step 2: Investigation

The Company will investigate the facts contained in the complaint as quickly as possible. In some cases, the Company may need to contact the complainant for more information during the investigation. Among other things, the investigation will have to determine whether the complaint meets the criteria listed above (Types of grievances).

* Incident

An incident is an unwanted event which could potentially lead to a deterioration of health.
If the grievance is an incident, the department handling it should classify it according to the following colors:

• Red incident: incident related to OECD Annex II risks and other laws. The incident is confirmed to have happened and could be repeated in the near future: abuse of human rights, corruption & bribery, fatalities due to HSE risks, legality conflict and use of excessive force, modern slavery etc….
  This is an incident that is serious. Since the incident is not an isolated case and could happen again in the future, it has to be treated as a risk and as per the risk management plan (STL/GR/001/2021_revision1). The risk behind the incident will be analyze and recorded in the risk register.
• Yellow incident: incident of medium severity. After investigation, if the incident has a probability of recurrence, it will be analyzed and the related risk and recorded in the risk register. Otherwise, if the incident is not likely to reoccur, it will be reclassified as a green incident.
• Green Incident: Isolated incident, thanks to existing measures the probability of its recurrence is unlikely and the resolution is immediate. There is no risk related to the incident.

After analysis of the incident and its related risk, it will be included in the risk register and the risk management plan will apply to it. If there is a similar risk that exist already in the risk register, it will be re-evaluated and see if there is need to improve the mitigation measures

Step 3: Resolution

Once the investigation is completed, the Company communicates its findings and response to the complainant.
If, during the investigation, it turns out that the grievance does not relate to the activities of the Company or that the subject of the grievance falls within international and national standards, the griever will be informed of this in writing.
In other cases, the Company offers a written response to resolve the grievance brought to its attention.
If the complainant is satisfied with the Company’s response and its application, the Company requests verbal and written confirmation and the file is closed.

* Additional measures

If the complainant is not satisfied, the Company will initiate a further discussion to determine if further action can be taken to remedy the situation.
If the complainant is not satisfied with the outcome, they may appeal the decision. The STL will then involve external stakeholders in the further review of the case (appeal panel). External stakeholders include, as appropriate: representatives of the community and civil society organizations for community-related issues and local authorities and civil society for other issues.
If the complainant is still not satisfied, he or she will be notified in writing that the process has been exhausted and that other avenues, including judicial or non-judicial, may be considered. This notification will be recorded and archived.

* Timelines

As far as possible, complaints are handled within the following deadlines:

• Acknowledgment of receipt must be sent within 7 working days of receipt of the complaint.
• After receiving the complaint, the Company has 30 working days to investigate and communicate its response to the complainant.

In the event of delays, the Company undertakes to provide the complainant regularly with an inventory of the advance of the processing of the complaint and the date on which the response can be expected.

* Followed

The Company will subsequently contact the complainant to ensure that the situation is resolved and that there are no further problems with the Company’s operations.

* Confidentiality/ Anonymous complaints

The grievance procedure gives equal consideration to complaints filed anonymously.
Except as required by local law in a judicial proceeding, STL is committed to protecting the identity of a whistleblower. In all cases, the STL will take steps to protect the whistleblower from any form of retaliation. In this context, it will ensure that the identity of the whistleblower is not included in all the documents analyzed and that a unique reference number is used instead of this identity.
If the complaint received by the Company is anonymous (no contact information on the form), the Company will make every effort to investigate the complaint. The response or comment to the complaint will be recorded on the Grievance Management Form.

* Policy implementation

A proactive communication strategy is put in place by the Company to ensure that members of management, employees, contractors, suppliers and external stakeholders are all informed of the existence of this procedure and that they are empowered to apply through the provision of information and support and easy access.

* Monitoring and Reports

Complaints made to the STL (email, post, etc.) will be recorded on the “Grievance Report Form” and processed by the Management Committee, will be retained for 5 years.
It is also the responsibility of the Management Committee to review annually the effectiveness of the company’s complaints procedure and its application.