Responsible minerals

In line with the OECD Due Diligence Guidance, LT Metal will not provide direct or indirect funding or benefits to armed groups in high-risk and conflict-affected areas, and will prevent gold from being used in other serious human rights abuses, thereby fulfilling its role and responsibility in the global gold supply chain.

To support the above, we will comply with the third edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Our due diligence addresses all of the risks set out in Annex II of the OECD Guidance, and its scope is global.

This policy is reviewed, approved, and implemented by the company’s management. It is also shared with relevant stakeholders such as suppliers, customers, and employees, and is published on the company website.

Where the Annex II risks listed below are identified, we will work to address them.

Annex II risks

• Serious abuses associated with the extraction, transport, or trade of minerals

• Any form of torture, or cruel, inhuman, and degrading treatment
• Any form of forced or compulsory labor
• The worst forms of child labor
• Other gross human rights violations and abuses, such as widespread sexual violence
• War crimes or other serious violations of international humanitarian law, crimes against humanity, and genocide
• Direct or indirect support to non-state armed groups
• Direct or indirect support to public or private security forces
• Bribery and fraudulent misrepresentation of the origin of minerals
• Money laundering
• Non-payment of taxes, fees, and royalties due to governments
• Terrorist financing

LT Metal respects the dignity and importance of human rights and regards any mineral that carries a risk of causing the harms listed in Annex II of the OECD Guidance as a “conflict mineral”.

LT Metal purchases only gold-bearing materials from sources confirmed not to be connected with, or to contribute to, illegal armed groups, human rights abuses, or financial misconduct as defined in Annex II of the OECD Guidance.

Policy implementation

To support this policy, we do the following.

• We have established a corporate management system, an internal control system, and a record-keeping system for the supply chain policy.
• We operate a robust process for identifying risks in the supply chain.
• We conduct due diligence on suppliers in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, and we encourage upstream suppliers to do the same.
• We provide due diligence information to demonstrate that we do not support conflict or human rights abuses, and we expect suppliers to cooperate in the collection of the information required.
• Suppliers that do not meet the expectations above, or that present a reasonable risk, are managed under our risk management strategy.

Supplier risk management strategy

• Where a supplier implements risk management measures, we continue to trade with that supplier.
• Where a supplier does not implement risk mitigation measures, we temporarily suspend trading.
• Where a supplier’s risk mitigation efforts are not feasible or not acceptable, we terminate the trading relationship with that gold supplier.

Anti-money laundering and countering terrorist financing

All employees comply with anti-money laundering legislation under Korean law and with our anti-money laundering and counter-terrorist-financing policy, which is based on the standards of the Financial Action Task Force (FATF).

We meet our responsibilities under the applicable laws and regulations.

Supply chain traceability and risk management

LT Metal uses the Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT) provided by the Responsible Minerals Initiative (RMI) to collect supply chain information.

This allows us to trace the supply chains for tin, tungsten, tantalum, gold, cobalt, and mica, and to work to identify and mitigate potential supply chain risks in advance.

Policy implementation and disclosure

To improve transparency in the implementation of this policy, we prepare a public report following the five steps of the OECD Due Diligence Guidance and post it on the company website, where customers and other stakeholders can review it.