REMELT SOURCES, INC. POLICY PROHIBITING HUMAN TRAFFICKING

Remelt Sources, Inc. and its affiliated entities (i.e. companies under common control or controlled by or controlling Remelt Sources, Inc.) (collectively referred to herein as “Remelt”), are committed to conducting business in a lawful and ethical manner and expect our employees and suppliers to conduct themselves in the same manner. We have implemented various procedures in our efforts to prevent slavery and human trafficking ourselves and in our supply chains. This Policy will describe those procedures.

Remelt strictly prohibits employees, subcontractors, suppliers, and agents from engaging in human trafficking-related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud, or coercion to subject a person to involuntary servitude, or obtaining labor from a person by threats of serious harm to that person or another person, among others.

Remelt also prohibits employees, subcontractors, suppliers, and agents from engaging in practices relating to trafficking in persons, including:

• Destroying or otherwise denying access to an employee’s identity or immigration documents
• Using misleading or fraudulent practices to recruit employees, such as failing to disclose key terms and conditions of employment
• Using recruiters that do not comply with local labor laws
• Charging employees recruitment fees
• Providing housing that fails to meet host country standards
• Failing to provide return transportation to certain employees who are brought to a country for the purpose of working for Remelt
• Failing to provide an employment contract or work document where required by law
• Failure to communicate terms of employment in a language the employee can understand
• Failure to pay applicable wages required by the country in which the worker is employed

Remelt will take appropriate disciplinary action for violations of any of the rules and/or policies discussed herein, up to and including discharge of employees, subcontractors, and suppliers. Remelt will cooperate fully with the U.S. Government or other appropriate governmental authorities in audits or investigations relating to such violations. Employees of Remelt are required to cooperate in any internal or external investigation of suspected wrongdoing under this policy.

Remelt will from time to time survey its supply chains in order to evaluate and to address risks of slavery and human trafficking inherent in those activities. Depending on the results of such surveys, any such surveys can form the basis of additional anti-slavery, anti-human trafficking efforts on Remelt’s part, including targeted supplier requirements and third-party audits.

Remelt advocates the use of contractual provisions prohibiting the use of involuntary labor and child labor, and requiring compliance with applicable labor and employment laws, in the production of materials that we sell. In our efforts to confirm compliance with such contractual provisions, we will from time to time require our suppliers to certify that the materials incorporated into the materials they supply comply with applicable laws regarding slavery and human trafficking. Suppliers may also be required to ensure that any subcontractor used in the manufacturing or distribution of any merchandise to us complies with the same standards.

Any supplier that is not able to provide any of the foregoing upon our request, will be required, as a condition to continuing to supply materials to us, to submit to us an action plan to achieve such certification within a reasonable period of time. Those suppliers that fail to comply will be subject to increasing levels of discipline, up to and including termination of their relationships.

Employees having knowledge of credible information concerning actual or potential violations of the rules and policies contained herein must report them immediately to Remelt management. Failure to report actual or potential illegal behavior or actual or potential violations of this policy may subject employees to disciplinary action, up to and including termination of employment.

Remelt companies do not tolerate retaliation or threats of retaliation against anyone who raises a concern under this policy or who assists with an internal or governmental audit or investigation. Any employee who engages in retaliation or threats of retaliation will face disciplinary action, up to and including termination of employment.

Last Updated 2019-08-08 TAM