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Conflict minerals and responsible sourcing policy statement

As a global commodities trading firm, Traxys is firmly committed to conducting its business with integrity and transparency and in compliance with best practices and all applicable laws, regulations and guidelines. For minerals and ores known as “Conflict Minerals”, these include: (1) the conflict mineral provisions (Section 1502) of the United States Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and (2) the due diligence guidance for responsible mineral supply chain activities related to conflict-affected and high-risk areas formulated by the Organization for Economic Cooperation and Development (the “OECD Guidance”). The Conflict Minerals covered by the Dodd-Frank Act and the OECD Guidance are known as the “3TGs”, being cassiterite (for tin), wolframite (for tungsten), coltan (for tantalum), and gold ore, minerals and their derivatives that are extracted from and that have been determined to be financing conflict in the Democratic Republic of the Congo or adjoining countries (“Great Lakes”).

It is Traxys’ policy to source minerals and metals in a transparent, ethical and responsible manner and, with minerals originating from the Great Lakes, to engage in responsible trade with mineral producers who participate in conflict-free and transparent supply chain initiatives. It is likewise Traxys’ policy to source minerals and metals that are free of unlawful child or forced labor or other human rights abuses. Consequently, it is also Traxys’ policy not to engage in the purchase of material that may contain minerals that directly or indirectly finance or benefit armed groups in the Great Lakes or that lend themselves to labor or other human rights abuses. Traxys’ policy not only extends to the 3TGs within the scope of the Dodd-Frank Act and the OECD Guidance, but also cobalt and other minerals originating from these regions.

Traxys recognizes the risk that mineral mining and sourcing practices may lend themselves to labor and other human rights abuses and that revenue from mineral trading may be misused to fund armed conflict or corruption. These risks are higher in vulnerable parts of the world with weak or corrupt governments and poor enforcement of the rule of law such as the Great Lakes. Traxys aims to remain engaged in, and source responsibly from, conflict-affected and high-risk areas while enabling communities to benefit from their mineral resources and contributing to sustainable development in such areas, acknowledging that losing access to markets for artisanal miners can directly translate into lost livelihoods for vulnerable individuals and families.

To identify, manage and mitigate these risks, Traxys conducts due diligence on its supply chain and works to establish and participate in transparent and responsible mineral supply chain initiatives such as, for this area, the iTSCI supply chain initiative of the International Tin Research Institute for traceability and responsible sourcing, which involves tagging and tracing of responsibly sourced material and includes local governments, mineral producers, exporters, traders and smelters as participants. Given Traxys’ position in the supply chain, this due diligence includes know-your-counterparty (KYC) procedures to know proposed suppliers, including determining their good standing with conflict-free supply chain initiatives and, when warranted, on-the-ground visits and meetings. Traxys companies also reserve audit rights in their contracts with suppliers and the right to disengage with suppliers whose commitment to conflict-free sourcing and legal and ethical labor practices is questionable or appears to be compromised.

Traxys’ due diligence for Conflict Minerals follows the OECD Guidance’s five-step framework and seeks to further the Guidance’s objectives, including taking steps to identify and assess risk in the supply chain and make continued efforts to source only traceably conflict-free minerals from the Great Lakes and to refrain from sourcing minerals extracted or produced with unlawful child or forced labor or other human rights abuses. While no member of the Traxys Group is an SEC-reporting company, we are nevertheless committed to cooperating with our customers and business partners in their compliance with the Dodd-Frank Act.

June 2019

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