This is Tabuk Trading’s Conflict Minerals Policy.

Tabuk Trading (PTY) Ltd is dedicated to upholding the highest standards of ethical conduct in all aspects of its operations. We are committed to complying with all relevant laws and regulations while conducting business in a responsible, sustainable, and honest manner.

We firmly believe that honesty, sustainability, and ethical behavior are fundamental in establishing enduring and trustworthy relationships with our customers, business partners, shareholders, and the communities in which we operate.

In response to the U.S. Securities and Exchange Commission’s (SEC) final rule on conflict minerals, based on section 1502 of the Dodd-Frank Act, we acknowledge the obligation for transparency in mineral sourcing. We recognize the importance of responsible mineral supply chain activities in conflict-affected and high-risk areas, as highlighted by the Organization for Economic Cooperation and Development (OECD) due diligence guidance.

In alignment with these principles, Tabuk Trading (PTY) Ltd has adopted a specific policy concerning conflict minerals originating from conflict-affected and high-risk areas. Although we are not directly subject to the reporting requirements of Dodd-Frank, we have integrated its guidelines and the OECD due diligence guidance into our policy framework.

When procuring minerals from conflict-affected and high-risk areas, we are committed to identifying and addressing any potential risks associated with human rights violations, including forced labor, child labor, and other gross human rights abuses. We will not engage with any party involved in activities such as torture, forced labor, or other violations of international humanitarian law.

Furthermore, we will not provide support to non-state armed groups or any illegal activities within the mineral supply chain. We will actively monitor our upstream suppliers and discontinue engagement if there is a reasonable risk of their involvement with entities supporting non-state armed groups.

Tabuk Trading (PTY) Ltd also prohibits any form of bribery in relation to mineral extraction, trade, handling, transport, and export.We are committed to ensuring that our suppliers adhere to this policy and are willing to collaborate with relevant stakeholders to enhance performance and mitigate risks associated with mineral sourcing from conflict-affected and high-risk areas.

In the event that we have credible concerns regarding a supplier’s non-compliance with this policy, we will take immediate action to suspend or discontinue the questionable supply.

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