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Procurement Guidelines

JFE Mineral & Alloy Procurement Guidelines

JFE Mineral & Alloy has established these JFE Mineral & Alloy procurement Guidelines in accordance with
the JFE Group Standards of Conduct and the JFE Group Basic policy on Human Rights, aiming to enhance
sustainability across its entire supply chain.

We share these guidelines with our business partners and promote sustainability initiatives throughout our
supply chain. In addition to asking all business partners to implement the guidelines, we also ask that
partners' own suppliers be encouraged to do the same.

JFE Mineral & Alloy is committed to maintaining and improving mutual understanding and trust with its
business partners as part of pursuing mutual development as a true business partner.

1. Compliance

Compliance with Applicable Laws and Regulations

  • We comply with all relevant laws, regulations, and social norms in countries and regions where we operate our business. We also respect treaties, agreements and other international rules in our international transactions.
  • We develop and implement policies, systems, codes of conduct, education, and other frameworks to ensure thorough compliance.

Management of personal and confidential information

We properly manage and protect all personal information of all parties involved in our business,
including suppliers, customers and employees, as well as confidential information obtained through
transactions and other business.

Cyber security

We implement cyber security measures and manage our systems to prevent damage to our company and
other parties.

Anti-Corruption

We do not participate in bribery of government officials, other public servants, or business partners,
and we strive to prevent corruption and maintain fair business practices.

Avoidance of Organized crime

We refuse to have any relationship with criminals or groups that threaten civil order and safety,
and we do not respond to illegal or unreasonable demands.

Fair competition

  • We comply with all laws and regulations of countries and regions where we operate our business, and
    we do not engage in practices such as private monopoly, unfair restrictions on trade (cartels, bid
    rigging, etc.), unfair trade practices, or abuse of superior bargaining positions.
  • When selecting suppliers, we base our decisions on economic rationality as well as suppliers' thorough
    implementation of appropriate quality-control and quality assurance covering not only quality but
    also technology, price, delivery time, supply stability, reliability, business stability and
    commitment to CSR(corporate social responsibility).
  • Intellectual property (IP) policy

    We take all necessary steps to protect our own IP rights. In addition, we respect the IP rights owned
    by other parties and do not unlawfully obtain, use nor infringe such rights.

    Quality assurance

    • We comply with all applicable laws and regulations regarding the quality of our products and services
      as well as observe our own quality standards and the requirements of customers.
    • We establish and operate quality-management systems that ensure high and stable quality.

    2. Respect for Human Rights

    JFE Steel is committed to implementing JFE Group's Human Rights Basic policy, as outlined hereafter.

    Prohibition of Child labor

    To avoid hindering children's development and educational opportunities, we do not employ children
    under the minimum working age stipulated by the laws and regulations of counties and regions where
    we operate our business.

    Prohibition of Forced labor

    • We do not use labor obtained through inhumane means, such as forced labor, human trafficking, or
      "modern slavery." Also, we do not engage in any dealings that promote such inhumane acts.
    • We do not force anyone to perform labor against their will. We do not retain employees' passports,
      official identification, or work permits as a condition of employment. We also do not require
      employees to pay recruitment fees or any other costs considered unreasonable under international
      norms.

    Prohibition of Discrimination and harassment

    We respect each person as an individual in all aspects of corporate activity and do not Discriminate
    on the basis of race, nationality, ethnicity, creed, religion, social status, family origin, age,
    gender, sexual orientation, gender identity, disability or for any other reason. We also do not engage
    in any other form of harassment, including language or behavior that offends a person's dignity or
    causes them discomfort.

    Rights of indigenous and local peoples

    We respect and give due consideration to local people's land rights, water access, safety, and health
    as well as the rights of indigenous peoples in areas where we operate. Occupational health and safety
    based on our policy of prioritizing safety above all else, we strive to prevent work-related accidents
    and illnesses as well as consistently maintain safe and healthy working environments.

    Working hours and leave

    We manage working hours appropriately, including by providing work breaks and time off in accordance
    with the labor laws and regulations of countries where we operate.

    Wages

    We pay at least the minimum wage, overtime pay and other allowances, including legally mandated
    benefits, as stipulated by the labor laws and regulations of countries and regions where we operate,
    and we do not reduce wages in violation of such legal mandates.

    Freedom of Association and Collective Bargaining

    We respect the rights of employees, including freedom of association and the right to Collective
    bargaining, in accordance with international norms and the laws and regulations of countries and
    regions where we operate.

    Remedy and Grievance Mechanism

    We establish contact points for receiving complaints and reports from employees or business partners
    regarding any misconduct or concerns about human rights, the environment, and other issues, and we
    maintain systems that ensure whistleblowers are not subjected to disadvantageous treatment.

    3. Environment

    Harmony with the environment

    • We continuously promote our business activity with due consideration for resource conservation,
      environmental protection, and biodiversity, aiming to remain consistently in harmony with the
      environment.
    • We comply with the environmental laws and regulations of countries and regions where we operate our
      business.

    Environmental management system

    We maintain environmental management systems for continuous improvements in order to reduce our
    environmental impact.

    Response to climate change

    We strive to reduce our own company's CO2 emissions as well as contribute to the reduction of CO2
    emissions across society to support the pursuit of carbon neutrality.

    Preventing environmental pollution

    We give due consideration to environmental protection by complying with laws and regulations regarding
    air, water, soil, and marine pollution as well as waste disposal, noise, and vibrations in countries
    and regions where we operate our business.

    Resource recycling and Waste management

    We comply with all applicable laws and regulations of the countries and regions where we operate
    regarding the proper disposal and recycling of waste, and we also promote resource recycling.

    Chemical substance management

    • We manage chemical substances in accordance with all relevant regulations and laws.
    • We comply with all applicable laws, regulations, and customer requirements relating to prohibitions
      or restrictions regarding the use of certain substances in our products.
    • 4. Responsible Procurement

      Approach to Conflict minerals

      We buy tin, tantalum, tungsten, gold, and cobalt only after confirming that these minerals were not
      extracted in conflict-affected or high-risk areas.

      5. Formulation of flexible response system to demand fluctuations

      Strengthening the ability to respond to demand fluctuations

      We will try to build out a flexible response system during our whole supply chain within the rapidly
      occurring demand fluctuations of the industry that is related to our products.

      6. Business Continuity Plans

      Formulation of BCPs

      To ensure that we can stably supply products and services even during a crisis, such as a natural
      disaster or pandemic, we maintain business continuity plans (BCPs) for thorough organization-wide
      crisis management.

      7. Relationships with Stakeholders

      Information disclosure

      We disclose corporate information in a timely and appropriate manner to maintain and Develop mutual
      understanding and trust with our diverse stakeholders through open and fair communication.



JFE Mineral & Alloy may conduct questionnaires, on-site surveys, etc. to confirm the status of
partners' efforts to comply with these JFE Mineral & Alloy Procurement Guidelines. If significant
deviation from these guidelines is identified, JFE Mineral & Alloy will follow up in an effort to encourage improvements. If no
improvement is made and significant deviations continue, JFE Mineral & Alloy may review its business
dealings with that partner. If any misconduct occurs with respect to these guidelines in the course of business dealings with JFE
Mineral & Alloy, the partner is sincerely requested to report such matters to JFE Mineral & Alloy.

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