LAST UPDATED 4 APRIL2025

RESPONSIBLE SUPPLY CHAIN OF PRECIOUS AND HIGH-VALUE METALS FROM CONFLICT-AFFECTED AND HIGH-RISK AREAS POLICY

Introduction

Bale Capital Pty Ltd (hereinafter “the Company”) is committed to establishing and maintaining a responsible supply chain for precious and high-value metals sourced from conflict-affected and high-risk areas (CAHRAs).

This policy is designed in accordance with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

The Company acknowledges its responsibility to respect human rights and avoid contributing to conflict through its sourcing practices.

Policy Statement

The Company commits to sourcing precious metals responsibly, ensuring that its supply chains do not fund conflict or contribute to human rights abuses in CAHRAs.

The Company will implement the OECD’s five-step framework for risk-based due diligence in the mineral supply chain.

Scope

This policy applies to all employees of the Company and extends to all suppliers and subcontractors involved in the supply chain of precious metals, from extraction through to final delivery.

1. Establish Strong Company Management Systems

1. Adopt, and clearly communicate internally and externally, the Company’s commitment to responsible sourcing from CAHRAs.
2. Incorporate this policy into contracts and agreements with suppliers.
3. Establish a system for grievance and whistleblower protection to allow employees and external parties to report concerns or violations of this policy.
4. Maintain detailed records of due diligence processes, findings, and actions taken for at least five years.

2. Identify and Assess Risk in the Supply Chain

1. Conduct thorough due diligence on the supply chain to map the flow of materials and identify CAHRAs.
2. Assess risks of adverse impacts in the supply chain, including support to unlawful armed conflict, human rights abuses, and bribery and corruption.
3. Engage directly with suppliers to gather information and improve transparency.

3. Design and Implement a Strategy to Respond to Identified Risks

1. Develop a strategy for risk management that includes measures to prevent or mitigate identified risks.
2. Consult with affected stakeholders, including local communities and NGOs, when planning and implementing risk management actions.
3. Suspend or discontinue engagement with suppliers where risks cannot be managed effectively.

4. Carry Out Independent Third-party Audit of Supply Chain Due Diligence

1. Engage independent, third-party auditors to review the Company’s due diligence practices and the compliance of suppliers with this policy.
2. Ensure that audit results are communicated to relevant stakeholders and used to improve due diligence practices.

5. Report on Supply Chain Due Diligence

1. Prepare an annual report detailing the Company’s due diligence processes, findings, and actions taken in response to risks.
2. Make this report publicly available to demonstrate transparency and accountability in the Company’s sourcing practices.

6. Training and Awareness

1. Conduct regular training for all relevant employees on responsible sourcing practices and the importance of due diligence in the supply chain.
2. Raise awareness among suppliers and subcontractors about the standards expected for compliance with this policy.

7. Continuous Improvement

1. Regularly review and update due diligence practices to reflect changes in the supply chain or emerging risks.
2. Engage in industry and multi-stakeholder initiatives to support responsible sourcing from CAHRAs.
   
   

Bale Capital Pty Ltd is dedicated to upholding the principles of responsible sourcing and due diligence within its supply chains. Through the implementation of this policy, the Company aims to contribute positively to the economic and social development of conflict-affected and high-risk areas while respecting human rights and avoiding complicity in conflict.

This policy serves as a guiding document for Bale Capital Pty Ltd and its commitment to responsible sourcing of precious metals from CAHRAs. The Company recognises the importance of continuous improvement and stakeholder engagement in achieving and maintaining compliance with OECD Due Diligence Guidance and commits to reviewing and updating this policy regularly.