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National Initiatives

SWITZERLAND : Ordinance on Due Diligence and Transparency in relation to Minerals and Metals from Conflict-Affected Areas and Child Labour (DDTrO)

Metalor Technologies SA ensures that all its supply chains are fair, sustainable and transparent. Its adherence to responsible sourcing is grounded in the policies, procedures and due diligence that it has instated at Group level, irrespective of where the Company operates. Through these commitments, it aims to ensure that precious metals come from legal and ethical sources, and that they have not been associated with illegal activities, crime, armed conflict, or human rights abuse. As a consequence, Metalor Technologies SA and its Group companies adhere to the relevant applicable standards, as defined in the Regulation (EU) 2017/821 and in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, dated April 2016, including all annexes and supplements.

PROFESSIONAL EQUALITY INDEX
between WOMEN and MEN

References : Law “Avenir” 2018 du 5 septembre 2018
Code du travail : Titre IV ” Egalité professionnelle entre les femmes et les hommes”

METALOR Technologies Electrotechnics France SAS calculates each year the 5 indicators for measuring professional equality:

• Pay differentials between women and men
• Differences individual rates of increase between women and men
• Promotion rates differences between women and men
• Increases for employees on their return from maternity leave
• Number of employees of the under-represented sex among the 10 highest paid.

The total of each indicator determines the company’s Professional Equality INDEX (X/100)

For the year 2023, the PROFESSIONAL EQUALITY INDEX between WOMEN and MEN for METALOR Technologies Electrotechnics France is: 92/100.

UK TAX RISK

MUK is an UK registered company, primarily selling and distributing from the Warstone Lane, Birmingham, premises, and also serving the Netherlands and other local markets from a warehouse in Eindhoven. The company is registered for VAT in the UK and the Netherlands.

MUK is a directly owned subsidiary of Metalor Technologies International SA (MTSA) a company incorporated in Switzerland. MTSA is 100% owned by Tanaka Holdings Co. Ltd (Tanaka) a company registered in Japan.

It is the intention of Tanaka and MTSA to comply with all applicable tax laws, rules, regulations and disclosure requirements: and to pay the right amount of tax in a prompt and timely manner in all territories where they operate.

Tanaka, MTSA and MUK have a zero tolerance attitude to tax risk.

THE MANAGEMENT OF TAX AFFAIRS

MUK, whilst qualifying as a large business from the sale of precious metal products only has 26 employees, and pays varying amounts of tax to local and national fiscal authorities namely:

VAT
Corporation Tax / Employers National Insurance / Local property taxes / Customs and excise duties / Environmental taxes

ON BEHALF OF EMPLOYEES
Income tax / Employees National Insurance

In addition to the accounting for, and reporting of, the tax categories above, MUK as the seller of standard rated gold uses the procedures as set out in the special accounting scheme for VAT.

TAX PLANNING AND COMPLIANCE
Corporation tax planning is undertaken by MUK, but the reporting and compliance service is provided by external professional advisors. In all the other tax categories MUK seeks and uses guidance from external professional advisors as and when appropriate.

Working with HMRC

MUK has a frank and open working relationship, and is completely transparent in all its dealings and disclosures, with HMRC.

FINANCE ACT 2016 REQUIREMENTS
This document is deemed to comply with Paragraph 22(2) Schedule 19, Finance Act 2016 and with all other obligations within Schedule 19 Finance Act 2016

MODERN SLAVERY ACT

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 2023

China: compliance with the USA legislation “Uyghur Forced Labor Prevention Act” (UFLPA)

Consistent with the full respect of human rights as stated in the Supply Chain Policy of Metalor -applicable to all territories where Metalor does business- , the Company confirms its compliance with the UFLPA in the sense that Metalor is not sourcing material from areas in the PRC where forced labour may still exist. Through Metalor compliance and due diligence program, the company does monitor the provenance of material that come to its facilities across the world to make sure that human rights are not compromised.

We are the world’s first refiner to meet LPPM’s Responsible Platinum and Palladium standards
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