Basic Policy on Procurement

1. 1.Comply with laws, regulations, and rules and engage in fair transactions.
   • Respect the letter and spirit of relevant laws and social norms in executing business operations.
   • Conduct purchasing activities based on fair evaluations.
   • Maintain appropriate relationships with business partners based on the highest ethical values.
2. 2.Protect intellectual property rights.
   • Strictly control personal information obtained in the course of procurement activities.
   • Do not illegally obtain or illegally use intellectual property, including the patents, utility models, designs, and trademarks of third parties, and do not infringe such rights.
3. 3.Build relationships with business partners based on mutual understanding and trust.
   • Provide business partners with high reliability and satisfaction through accurate, fast, and highly transparent activities.
   • Endeavor to achieve robust communication with business partners and consistently promote creativity and innovation through advanced ideas.
   • Contribute to the development of a sustainable society by promoting the purchase of environmentally friendly materials and machinery.
4. 4.Follow the below principles regarding conflict minerals.
   • Do not engage in raw materials procurement that contributes to illegal activities in conflict-affected regions or to human rights infringements through such illegal activities.
   • Respect the guidance of the Organisation for Economic Co-operation and Development related to raw materials procurement from conflict-affected areas, and control supply chains in an appropriate manner.

In the conduct of the JX Metals Group's business operations, it is necessary for not only the Group but also our business partners' supply chains to fulfill their responsibility to society. Therefore, we also require our business partners to operate in accordance with the items below. Going forward, we will confirm the process of improvement with respect to business partners who violate the items below and receive an adverse disposition from the government, and business partners revealed not to be complying with the items below. Furthermore, in the case that a business partner is not complying with the items below, we will consider whether it is necessary to review (or cancel) the contract with the business partner.

1. 1.Comply with laws, regulations, and social norms, such as those below, and place priority on human rights and environmental impact. In the case that there is an inconsistency between internationally-recognized human rights principles and the laws, regulations, social norms, etc., respect the international human rights principles.
   • Obey laws and regulations related to manufacturing and sales, etc.
   • Comply with labor-related laws and regulations.
   • Abide by laws and regulations related to safety and health and develop a proper labor environment.
   • Prohibit child labor and forced labor.
   • Prohibit discrimination based on race, gender, etc. and respect the human rights, personality, and individuality of employees.
   • Comply with environmental laws and regulations.
   • Prohibit bribery and other unfair conduct.
   • Do not engage in conflict minerals procurement or use that contributes to inhumane acts.
2. 2.Engage in sound and fair business management.
3. 3.Based on the JX Metals Group's Green Purchase Guideline, build environmental management systems and properly manage specified chemical substances.
4. 4.Offer stable supply capacity and satisfy the quality, price, delivery, and service requirements of the JX Metals Group.
5. 5.Possess technological capabilities that meet the requirements of the JX Metals Group.