Due Diligence Process [Due Diligence Policy] at SULIQ sp. z o.o.

SULIQ sp. z o.o. carries out its due diligence process based on the Company's core values and principles, taking care not only of its own economic interest, but also of ensuring that its actions bring broadly understood benefits to all parties involved in a transaction as well as to the natural environment.

SULIQ sp. z o.o. focuses on two business profiles: distribution of steel products and supply of materials for protective coatings in industry. In the global supply chain of 3TG minerals (Tin, Tantalum, Tungsten, Gold), the Company acts as an EU importer of tin wire and a responsible participant in the domestic surface engineering market.

Aware that due diligence in the supply chain is a continuous process of monitoring and managing purchases and sales so as not to contribute to financing conflict or human rights abuses, and taking into account the risk of significant adverse impacts that may be associated with the extraction, trade, processing and export of minerals from conflict-affected and high-risk areas, the Company commits to adopting and disseminating a procedure for a responsible global supply chain of 3TG minerals (Tin, Tantalum, Tungsten, Gold) from conflict-affected and high-risk areas ("Conflict Minerals Regulation").

The Company's due diligence process is carried out in accordance with the model set out in the OECD Due Diligence Guidance for Responsible Business Conduct (2018) and with Regulation (EU) 2017/821 of the European Parliament and of the Council. This model provides for regularly and comprehensively addressing the following areas:

• Embedding due diligence into the company's policies and management systems
• Identifying and assessing adverse impacts and risks related to the Company's operations
• Eliminating, preventing or mitigating identified adverse impacts
• Monitoring the effectiveness of measures taken
• Communicating on due diligence
• Remediating harm or cooperating in remediation

Key elements of the process:

• Compliance Programme — the programme builds procedures and control measures, including an internal control system, to support appropriate, lawful conduct within the company.
• Due diligence policy for the supply chain of materials containing 3TG minerals — the policy helps to more effectively avoid adverse impacts and to take appropriate action should adverse impacts occur as a result of operations within the supply chains.
• Irregularity reporting procedure — the procedure governs the process of receiving and handling irregularity reports and the way any resulting investigation is managed.
• Supplier qualification instructions — a detailed specification of the requirements placed on material suppliers to ensure the quality, timeliness and price level expected by the customer.

The Company's Management Board makes every effort to ensure that the due diligence policy is known to its commercial and financial partners, as well as to all collaborators and suppliers. We would be grateful for any reports of violations of the laws, guidelines and principles set out in the due diligence policy, in particular within the supply chain of materials containing 3TG minerals, and for any comments in this regard.

Reports can be submitted, among other ways, by filling in the "Application form for reporting irregularities" made available on the suliq.pl website, and sending it:

• by e-mail, to the following address: biuro@suliq.pl
• by traditional mail, to the following address: SULIQ sp. z o.o., 43-600 Jaworzno, ul. Drzymały 19, Poland

Although the Company accepts anonymous reports, the Management Board suggests that Reporting Persons choose to report non-anonymously, as this allows for a faster and more effective investigation.

The subsequent stages of preliminary verification and investigation are easier if reports contain accurate and detailed content, such as:

• a description of the reported facts, indicating known circumstances (how, when and where they occurred);
• the identity of the person(s) being reported, if known;
• an indication of any other persons who may be able to provide an account relating to the reported facts;
• any documents — including in physical form — supporting the report, as well as the identity of the Reporting Person (e.g. personal and contact details), if the anonymous route was not chosen.

The Company ensures that all reports will be analysed and archived, classified as "Justified" or "Unjustified" and marked as to whether "Action was taken" or "No action was taken".

Please contact us if you are also interested in the detailed procedures of the Due Diligence Policy adopted at our Company.