In view of being a “sustainable company”, Metaltech sets the following goals for the next year:

• Prevention of situations breaching human rights.
• Improvement the efficiency of its organizational structure and supply chain.
• Diffusion of a culture of social responsibility through a process of continuous training, involvement and empowerment of the staff.
• Rationalization of the corporate structure and procedures with a clear and well-balanced definition of duties and responsibilities.
• Establishment of an encouraging and gratifying working environment for the staff’s professional development.
• Participation and contribution to social and solidarity initiative.
• Commitment to publicize ethical principles to all of our stakeholders.

Metaltech is a company producing advanced master alloys for the production of gold and silver jewelry. Based in Vicenza, heart of the Italian jewelry production, Metaltech is present with its products and services in the world most important jewelry production districts. This policy confirms Metaltech’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

Metaltech is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

1. 1. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
   2. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
   3. support transparency of government payments and rights-compatible security forces in the extractives industry;
   4. do not provide direct or indirect support to illegal armed groups;
   5. enable stakeholders to voice concerns about the jewelry supply chain; and
   6. are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We also commit to using our influence to prevent abuses by others, adopting OECD due diligence guidance and making an annual evaluation of our supplier.

Regarding serious abuses associated with the extraction, transport or trade of gold: we will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

1. 1. torture, cruel, inhuman and degrading treatment;
   2. forced or compulsory labour;
   3. the worst forms of child labour;
   4. human rights violations and abuses; or
   5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

Regarding direct or indirect support to non-state armed groups: we will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups.

Regarding public or private security forces: we affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 5.

Regarding bribery and fraudulent misrepresentation of the origin of gold: we will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold.

Regarding money laundering: we will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of gold.

Metaltech srl has carried out a due diligence towards its relevant business partners in order to verify any deviation from the OECD guidelines and, up until now, no human rights risks have been detected.
The transactions considered are low risk and the checks carried out comply with the RJC principles.