JX Metals Group understands that human rights of individuals must be respected in all countries and regions in which it conducts business activities, and as the guidelines for fulfilling its responsibility and obligation for ensuring the above, hereby stipulates this “JX Metals Group Human Rights Policy” (hereinafter referred to as this “Policy”) based on the “Guiding Principles on Business and Human Rights” set forth by the United Nations. JX Metals Group positions this Policy as the primary policy on human rights in conducting its business activities and continues to promote its efforts in upholding human rights.

1.Commitment to Respect for Human Rights

While understanding that its business activities may have a direct or indirect impact on an individual’s human rights, JX Metals Group fulfills its responsibility for respecting human rights by avoiding any possible violation of human rights, and pledges to take appropriate actions to correct any negative impact on human rights that may be caused in the course of its business activities.

JX Metals Group supports and respects the following international codes on human rights:

• The United Nations’ (UN) “International Bill of Human Rights”, which stipulates the basic human rights of all individuals (including the “Universal Declaration of Human Rights”, the “International Covenant on Civil and Political Rights”, and the “International Covenant on Economic, Social and Cultural Rights”);
• The International Labour Organization’s (ILO) “ILO Declaration on Fundamental Principles and Rights at Work”, which stipulates the fundamental rights of workers such as their wages and working hours;
• The “United Nations Declaration on the Rights of Indigenous Peoples”;
• The UN’s “Children’s Rights and Business Principles”;
• The Organization for Economic Co-operation and Development’s (OECD) “OECD Guidelines for Multinational Enterprises on Responsible Business Conduct”;
• The “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas”;
• and other international codes on human rights

JX Metals Group complies with laws and regulations applicable in each country and region in which it conducts business activities, and in the event of a conflict between internationally-recognized human rights codes and the laws of each respective country and region, JX Metals Group will seek a way to respect international human rights principles above all else.

2.Human Rights Due Diligence

To fulfill its responsibility for respecting human rights, JX Metals Group establishes and continues to implement a structure for “human rights due diligence”. “Human rights due diligence” refers to a continuous process to prevent and reduce any possible negative impact on human rights that it could cause to society, by conducting preventive investigations and developing early identification systems, taking corrective actions where applicable, and externally disclosing the progress and results of those activities.

3.Remedy

In the event that JX Metals Group discovers that it has caused or contributed to any negative impact on human rights, it will endeavor to correct such a situation as seen fit. All parties involved, including, but not limited to, employees, employees in its supply chain, local residents, and other stakeholders, will be referred to an ever-improving complaint hotline where they can file formal complaints.

4.Education

JX Metals Group will provide appropriate education to its officers and employees to ensure that this Policy is incorporated into the business activities of all JX Metals Group companies.

5.Information Disclosure

JX Metals Group will disclose the progress and results of its efforts in respecting human rights under this Policy on its website, in a report or other forms.

6.Dialogue/Consultation

JX Metals Group will hold a sincere dialogue with any relevant stakeholders as to any violations on human rights that could be caused in the course of business activities so that it (JX Metals Group) can understand and address the issue from the view of the potentially affected individuals.

7.Scope of Application

This Policy shall apply to all officers and employees of JX Metals Group. JX Metals Group also requires that all business partners related to its business activities understand and cooperate with this Policy.