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Policies in relation to modern slavery

At the heart of our approach to human rights are a number of important internationally recognised
declarations, standards and codes. These are the foundations for how and where we work, and
include:

- The UN Universal Declaration of Human Rights
- The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
- The UN Guiding Principles on Business and Human Rights
- The UN Global Compact

Our approach to addressing modern slavery sits within this wider human rights agenda. Metalor
strategy is supported by our

- Code of Business Conduct
- Child and Forced Labour Policy
- Supply Chain Due Diligence Policy

which applies to our Group and sets out our obligations to customers, employees, suppliers,
stakeholders and communities in our own operations and supply chain. We take any breach of
our policies or allegations extremely seriously.
Performance against our policies, including on modern slavery, are reviewed by the Group
Compliance Committee chaired by the Group CEO.

Modern slavery statement

Metalor Technologies group do acknowledge and recognize its responsibility for the impact of its
business activities on the people who work for or with us and the people within the communities
where we operate. We act on this responsibility by using our influence to promote and protect
the human rights of all those we work with and alongside.
Metalor supports, and expects all its suppliers to support the principles defined within
conventions, rules and policies that are part of Metalor Policies on Modern Slavery. Metalor
continues to work to improve its approach to tackling modern slavery and increasing supply chain
accountability.

Modern Slavery report for the year 2018

The UK Modern Slavery Act 2015 (the ‘Act’) requires business to state the actions they have taken
during the financial year to ensure modern slavery is not taking place in their operations and
supply chains. We are fully committed to playing our part in eradicating modern slavery. We firmly
advocate for transparency and collaboration to eliminate the risks of modern slavery. This
statement refers to the financial year ending 31 December 2018. It sets out the steps taken by
Metalor to prevent modern slavery in its own operations and supply chains.

Due diligence processes

Within our 3 divisions and our corporate functions, the company is well advanced in respect of
supplier due diligence. In terms of risk, and due to nature of Metalor business because of the
intensive use of precious metals, the Refining division is the most exposed to potential slavery
concerns, since it deploys its activity in developing countries where the respect of the legal system
has still a significant room for improvement. This includes as well the additional risk of corruption
and non-respect of human rights, including child labour. Compliance process are fully deployed
in that division. Regarding advanced coatings, and even though the potential risk of the activity
from that perspective is substantially lower, a due diligence and compliance system has been also
implemented. We believe that this is a proportionate and fit-for-purpose supplier process.
The due diligence include specifically being in compliance with the standards of the London Bullion
Market Association (LBMA) and Responsible Jewelry Council (RJC) that include, but are not limited
to, the respect of human rights along the supply chain.
Metalor has successfully passed LBMA and RJC audits (run externally by independent audits firms)
for all its refining locations in 2018.

Whistleblowing Policy

Metalor has implemented a “Whistleblowing Policy” that includes a direct and confidential line of
communication with the General Counsel of the company, available to employees and third parties
to raise concerns regarding unsafe, unethical or unlawful conduct. This is one of the ways
employees, suppliers and contractors can notify Metalor if they have concerns regarding any
slavery or human trafficking in our business or supply chains. The General Counsel has full
autonomy to launch investigations and take appropriate actions within the company to prevent
this kind of conducts.

Supplier terms & conditions

Current suppliers considered to be exposed to the greatest risk, dependent on industry, sector
and country, are currently having their terms and conditions enhanced to include a modern
slavery provision on a case by case basis. A modern slavery clause will form part of the terms
and conditions on which we do business with new suppliers going forward. Our standard terms
and conditions of purchase across our UK businesses are being reviewed and will be enhanced to
include a modern slavery clause as appropriate.

Training and Awareness

Members of Metalor Legal & Compliance teams have provided workshops and training to the
members of the marketing, sales, front office, logistics and treasury teams across the company
to provide a yearly update on compliance processes and trends, making special emphasis on
human rights, including modern slavery. This is becoming part of the regular annual training
organized every year. The intent is to raise awareness of the issue of modern slavery amongst
our employees.

Our commitment

Metalor is committed to ensuring that there is no modern slavery in our business or any of our
supply chains. Our ambition is to demonstrate that this is the case by undertaking the steps
outlined in this statement, working with our supply chain partners and by building increasing
rigour in our supply chain due diligence processes.

This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It has been
approved by the board of Metalor Technologies (UK) Limited on March 8, 2019.

Birmingham March 8 2019

Mark Parkhurst

AC Manager Northern Europe