RESPONSIBLE POLICY

Scope

This policy applies to selection and retention of Eti Bakır A.Ş. suppliers that provide materials that contain copper, zinc, cobalt etc.

Introduction

Eti Bakır A.Ş. is leading about bringing natural resources into economy and providing sustainability in its sector. Eti Bakır Mazıdağı Plant request consistently from their suppliers to conduct their business with the highest-level ethics, to respect labour and human rights and also expect primarily sensitivity of environment. Eti Bakır Mazıdağı Plant has adopted the following policy which compliant with Model of Supply Chain Policy in Annex II of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas.

Products and Operating Processes

Cobalt is especially used in the production of high-capacity batteries, magnets and electromagnets. Zinc is mainly used in galvanizing area for production of construction materials and overhead line poles. Copper is used in the electrical industry and in many other fields.

In the production process of Eti Bakır Mazıdağı plant, pyrite raw material which is concentrated copper production waste of Eti Bakır Küre mine is used. The pyrite raw material is roasted in the sulfuric acid plant, and the resulting calcine ash is transferred to the leaching plant. After the calcine is slurried and leached in an autoclave process, products are obtained by separating cobalt, zinc and copper with selective organics.

Supply Chain Commitment

As Eti Bakır Mazıdağı Plant;
• We will carefully evaluate our suppliers regarding compliance of the OECD Due Diligence Guidance, National and International Governmental Policies and Eti Bakır A.Ş. Ethical Policy,
• We commit to follow OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“CAHRAs”) when identifying, mitigating, and reporting risks within our value chain
• We commit to implement the five-step due diligence process defined in the OECD Guidance Annex I
• We commit to identify and regularly revisit risk for adverse social and environmental impacts within our value chain.
• We will confirm our suppliers whether they supply minerals from Conflict-Affected and High-Risk Areas or not,
• We will not make a profit or benefit from the suppliers which are in violation of the OECD Due Diligence Guidance,
• We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals,

And we will support our suppliers and business partners to comply with the decisions in the same way.

Eti Bakır A.Ş. applies a "Zero Tolerance Policy" concerning unethical business behaviour, bribery, corruption and forced or compulsory labour.

Requirements for Our Suppliers

As part of our efforts to identify and manage our risks and exposures associated with conflict minerals, our expectations from our suppliers and business partners are as follows;

• Any forms of torture, cruel, inhuman and degrading treatment should not occur
• Business partners should not participate to any form of forced or compulsory labour
• Absence of worst forms of child labours
• Other gross human rights violations and abuses such as widespread sexual violence should not be occurred
• War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide should not be existed
• There must be no non-state armed group which illegally tax or extort money or minerals in mining sites or transport routes, or in mineral trade areas
• There must be no non-state armed group which illegally tax or extort intermediaries, export companies or international traders
• Any company in our supply chain makes a contract with public or private security forces, these security forces do not act against Security and Human Rights
• Transparency, proportionality and accountability in payments made to public security forces should be provided
• Exposure of vulnerable groups (artisanal or small-scale mining) to adverse impacts associated with the presence of security forces, public or private should be minimised
• Any bribes must not be offered, promised, given and demanded to disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export
• Money laundering must be effectively eliminated where reasonable risk of moneylaundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.
Regarding these risks we will not tolerate when we determine that our suppliers are in violation of the OECD Due Diligence Guidance, and we will immediately suspend and terminate our relations with the supplier.

Occupational Health and Safety & Environment

Eti Bakır Mazıdağı Plant’s commitment to sustainability includes its commitment to protect the environment and provide healthy and safe workplaces, as well as the efficient use of resources. Eti Bakır Mazıdağı Plant expects its suppliers to make similar commitments to continuously improve their environmental, health and safety performance.

Ensuring Occupational Health and Safety: Suppliers will provide a safe and healthy workplace for their direct and indirect employees, including appropriate controls, training, work procedures and personal protective equipment. Suppliers will comply with all health and safety laws applicable to the workplace.

Respect for the Environment: Suppliers shall comply with applicable environmental laws and have systems in place to ensure the safe management of waste, air emissions and wastewater discharges. By using recycled materials, suppliers must continually strive to minimize environmental impact and make continuous improvements in resource efficiency.

Expectations Regarding the Code of Business Ethics for Suppliers

Eti Bakır Mazıdağı Plant expects its suppliers to implement systems and controls that will encourage compliance with applicable national and international laws and principles set forth in this Code, including policies, training, monitoring and inspection mechanisms. Suppliers should apply these or similar principles to the subcontractors and suppliers which they work with while providing goods and services to Eti Bakır Mazıdağı Plant.

Eti Bakır Mazıdağı Plant, reserves the right to evaluate and monitor suppliers' compliance with these Code. Eti Bakır Mazıdağı Plant may request corrective actions from suppliers which do not comply with this Code or these suppliers may not be considered as approved suppliers in future works.

Supply Chain Department