Conflict mineral policy statement

LUMEL ALUCAST Sp. z o.o. attaches great importance to corporate social responsibility and sustainable development across our global supply chain. Recognizing the global challenges associated with the illegal extraction and trade of raw materials, we fully support international efforts aimed at severing the link between mineral sourcing, armed conflict financing, human rights abuses, and environmental degradation in high-risk zones.
Our company is fully committed to complying with all applicable national and international regulations regarding conflict minerals (3TG: tin, tantalum, tungsten, and gold). Our compliance framework aligns directly with:

• Regulation (EU) 2017/821 of the European Parliament and of the Council, laying down supply chain due diligence obligations for importers of minerals originating from conflict-affected and high-risk areas.
  
• Section 1502 of the US Dodd-Frank Wall Street Reform and Consumer Protection Act.
  
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs).

To ensure that our products do not contain minerals that finance or benefit armed groups, LUMEL ALUCAST implements the following strict measures within its management systems:

• Due Diligence Framework: We actively conduct supply chain inquiries and risk assessments. We utilize the industry-standard Conflict Minerals Reporting Template (CMRT) established by the Responsible Minerals Initiative (RMI) to gather transparency data from our suppliers.
  
• Supplier Requirements: We require our direct suppliers to exercise appropriate due diligence within their own supply chains and to source materials exclusively from smelters and refiners validated as conformant with the Responsible Minerals Assurance Process (RMAP) or equivalent third-party audit programs.
  
• Continuous Monitoring: We continuously review the origin of raw materials used in our products. Should any non-compliance or sourcing risk be identified, we will take immediate corrective actions, up to and including the disqualification of the supplier.

Through these robust compliance measures, we assure our customers that we make every effort to deliver products that are ethically sourced, legally compliant, and fully aligned with modern global ESG expectations.