Table of Contents:

1. Equality, Diversity and Inclusion Policy
2. Health, Safety and Environment Policy
3. Political Engagement Policy
4. Anti-Corruption and Bribery Policy
5. Anti-money laundering Policy
6. Competition Law Policy
7. Recycling And Circular Economy Policy
8. Energy And Climate Policy
9. Sustainable Development Policy
10. Social Responsibility Policy
11. Responsible Sourcing Policy
12. Code Of Business Conduct For Suppliers

EQUITY, DIVERSITY AND INCLUSION POLICY

SCOPE AND APPLICATION

Aluminij Industries (hereinafter “Aluminij” or “we”) has the responsibility of approving the Equity, Diversity and Inclusion Policy for all employees and companies under M.T. Abraham Group, that are engaged with the mutual goal of creating a work environment that fosters Equity, Diversity, and Inclusion.

People are the most important asset of Aluminij, for this reason the difference and plurality of people, equality of opportunities, non-discrimination and inclusion in the workplace are priority and strategic factors in the organization.

Aluminij maintains a strong will to promote equity, diversity, and inclusion, through inclusive leadership as a lever change and business sustainability.

A truly diverse and inclusive culture is crucial to helping us grow our business and attract, develop, and retain talent.

This policy focuses on creating a climate which allows diversity in all of the following areas: gender, age, sexual orientation, culture, race, religion, thought, education, talent, social condition, individual quality, work style, disability, special needs or any other circumstance of employees; and, at the same time, rejecting any type of discrimination for said reasons which may prevent the growth of Aluminij or that affects selection, retention, development and well-being of its employees.

Equity, diversity, and inclusion is a business and commercial imperative in Aluminij, and a diverse workforce strengthens our culture and our ability to deliver our business objectives. We expect and need our workforce to perform at their best and we strive to create a culture that embraces different perspectives to drive the business forward. This policy sets out our approach to equity, diversity, and inclusion.

Aluminij is committed to Equity, Diversity and Inclusion through the socially responsible, integrating, inclusive and transversal management of its human team, based on the variety of different cultures, backgrounds, knowledge, skills and experiences to develop the full potential of the organization, providing equal opportunities to promote equity in the workplace, non-discrimination, direct or indirect, on the basis of sex, age, race, religion, sexual orientation, thought, education, social condition, culture, work style, talent, individual quality or special needs such as illness, disability, accident or family situation, and inclusion to provide fair opportunities of work for people with disabilities, older people or people from vulnerable situations.

POLICY BREACHES

All of our employees, and companies under M.T. Abraham Group are responsible for ensuring that we meet our commitments.

All Aluminij’s employees have a responsibility to treat others with dignity and respect at all times.

We expect our employees and contractors to speak openly and raise concerns about possible breaches of the Code of Conduct and this policy.

Aluminij has zero tolerance for retaliation against anyone who speaks openly about conduct they believe is unethical, illegal, or not in line with our Code of Conduct and policies, even if the concern isn’t substantiated, as long as they have not knowingly made a false report.

Any employee found to have exhibited any inappropriate conduct or behavior against others may be subject to disciplinary action.

Any questions regarding this Equity, Diversity and Inclusion Policy may be directed to the Human Resources team at Aluminij.

POLICY REVIEW

This Policy shall be reviewed from time.

HEALTH, SAFETY AND ENVIRONMENT POLICY

APPLICABILITY AND PURPOSE

Aluminij Industries (hereinafter „Aluminij“ or „we“) top priority is the health and safety of our employees, contractors and others who may be impacted by our operations. We are committed to providing a healthy and safe workplace for all employees as well as safe products and services for customers.

Our concept focuses on prevention, with health and safety being integrated into all of our activities in order to create a safe working environment.

This policy applies to all employees, directors, and also to all other contractors that are under Aluminij direct supervision and they are all required to follow all safety instructions.

They are also responsible for taking reasonable care for their own health and safety and that of others who may be affected by what they do or do not do.

Health, Safety and Environment policy is the fundamental elements of Aluminij approach to health and safety and environment.

Business unit managers are responsible for the health and safety of their employees, and for compliance with policies and relevant regulation/legislation. They are also responsible for providing safe work equipment, methods of work, and the necessary training to all employees, addressing specific training needs as required.

All individuals that enter into premises of Aluminij have an obligation to work in a safe and healthy manner and to look out for one another. Our workforce must report any unsafe acts or conditions to management who will follow up and rectify.

If an employee experiences a work-related injury or illness, they should seek medical assistance as quickly as possible from a competent person and then report the matter to human resources or a senior member of staff immediately.

Aluminij puts a significant focus on environmental protection and recognition in the local communities and business partners through its business operations.

Environmental policy is grounded on the law legislation, and we care about environmental protection thus regularly monitor air, water, soil, vegetation and conduct adequately a waste management system which is in direct correlation with health and protection of the community and its flora and fauna. We educate every new employer in our company about environment policy through our internal education.

Aluminij is committed to:

1. Providing and maintaining a safe place of work, with safe means of entry and exit,
2. Providing and maintaining safe plant, safe equipment and safe systems of work,
3. Providing and maintaining a safe and healthy working environment, by identifying and mitigating or eliminating workplace hazards and reducing occupational health & safety risks,
4. The control of the health and safety risks arising from work activities,
5. Providing and maintaining the necessary information, instruction, training and supervision to protect safety and health at work.

POLICY BREACHES

Non-compliance with this Policy may result in disciplinary action.

Any questions about possible health and safety hazards, laws, or policies governing the workplace at any facility, should be brought to the timely attention of facilities management, human resources, or a senior member of staff.

POLICY REVIEW

This policy will be reviewed from time.

Together we can achieve a safe and pleasant work environment.

POLITICAL ENGAGEMENT POLICY

APPLICATION

This Policy applies to Aluminij Industries (hereinafter “Aluminij” or “we”) and all employees, and officers.

ENGAGING IN THE POLITICAL PROCESS

Aluminij has a policy in place which prohibits donations being made that would:

• improperly influence legislation or regulation,
• promote political views or ideologies, and
• fund political causes.

Aluminij does not favour or supports any political party, group or individual.

We do not get involved in political activities or have any political links.

Aluminij may engage in public policy discussions where relevant to our business, employees, customers, suppliers, end users and the communities in which we operate. Any such engagement must be approved in advance by the Chief Executive Officer.

PROHIBITED ACTIVITIES

Aluminij employees shall not:

• use or associate their position with any political activity or in any manner through which any such association could be reasonably inferred, or
• engage in campaigning for or promoting any political party or candidate in the workplace or seek to pressure or influence co-workers to vote for any particular political party or candidate.

POLICY BREACHES

This Policy support our values and reflect what is important to Aluminij. Non-compliance with this Policy may result in disciplinary action.

Depending on the severity of the breach, consequences may range from a warning to termination of employment

We expect our employees and contractors to speak openly and raise concerns about possible breaches
of this Policy.

POLICY REVIEW

This Policy shall be reviewed periodically.

ANTI CORRUPTION AND BRIBERY POLICY

SCOPE

This Policy applies to Aluminij Industries (hereinafter “Aluminij” or “we”) and all employees, and officers.

In addition, the Aluminij expects its agents, consultants, representatives, suppliers, vendors, contractors, advisors, business partners and any other person that performs services for or on behalf of the Company to comply with the principles contained in this Policy.

It is intended to minimize Aluminij’s risks related to bribery and corruption and to emphasize responsibilities under both the relevant anti-corruption laws and our policies. It also provides guidance on identifying potential risks, dealing with challenging situations and reporting when those situations violate or may lead to a violation of this Policy and Anti-Corruption Laws.

Corruption and bribery are illegal and unethical, and any violation of relevant anti-corruption laws can lead to severe civil and criminal penalties and reputational harm to Aluminij.

Aluminij has zero tolerance for corrupt activities of any kind. Bribes or other improper or unauthorized payments, or acts that create the appearance of promising, offering, giving, or authorizing such payments, are prohibited by this Policy.

Offering, promising, and authorizing the giving of money, or anything else of value, to a government official in order to secure an improper advantage is strictly prohibited.

The Company’s prohibition on bribery applies to all improper monetary or non-monetary, tangible or intangible bribes; payments of money; gifts or entertainment, discounts, loans and/or financing given on non-commercial terms, rebates or kickbacks in relation to services provided, including “facilitating” (or expediting) payments. Facilitating payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power, or water service, or loading or unloading of cargo.

INDICATORS FOR SUSPICION OF CORRUPT ACTIVITIES

The following is a list of activities that may indicate the possible existence of corrupt practices and should be kept in mind by all those subject to this Policy:

1. Unusually large commission payments,
2. Cash payments, or payments made without a paper trail or without compliance with normal internal controls,
3. Unusual bonuses for which there is little supporting documentation,
4. Payments to be made through third party countries or to offshore accounts,
5. Unexplained preferences for certain sub-contractors,
6. Invoices rendered or paid in excess of contractual amounts.

This list is not exhaustive.

GIFTS AND ENTERTAINMENT
This Policy does not prohibit normal and appropriate hospitality (given or received) to or from third parties.

Gifts and entertainment are commonly offered as gestures of gratitude or tokens of appreciation. We allow these tokens and gestures when they are reasonable, proportional, made in good faith and in compliance with our Code of Business Conduct and Ethics and this Policy.

All employees should consult with their superior for further guidance on giving or accepting gifts or forms of entertainment or hospitality.

It is not acceptable for any employee to:

1. give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or Aluminij will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
2. accept payment from a third party where it is known or suspected that it is offered or given with the expectation that the third party will improperly obtain a business advantage;
3. threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under this Policy; or
4. engage in any activity that might lead to a breach of this Policy.

POLICY BREACHES

It is the responsibility of all employees to ensure compliance with this Policy. Any employee who witnesses a breach of this policy is obliged to promptly contact Aluminij’s Compliance Officer.

Aluminij’s employees that violate these laws can face severe disciplinary, civil and criminal penalties.

POLICY REVIEW

This Policy shall be updated from time.

ANTI-MONEY LAUNDERING POLICY

APPLICATION

Anti-money laundering (hereinafter „AML“) refers to the laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

This Policy has been developed by Aluminij Industries (hereinafter “Aluminij” or “we”) to reduce the risk of money laundering and terrorist financing associated with its business and the sale of its products. We do not assist, support, participate in or permit money laundering or terrorist financing.

Aluminij strongly upholds all laws relevant to preventing money laundering in all of the jurisdictions in which Aluminij operates.

This Policy applies to Aluminij and all employees, and officers. It provides information and guidance on how to recognize and deal with money laundering issues.

All Aluminij’s business partners are requested to follow the same principles and commitments regarding anti-money laundering and to adhere to the provisions of this Policy at all times while conducting business with Aluminij.

PROHIBITED ACTIVITIES

The following types of activities are prohibited under this Policy:

1. the conversion or transfer of property (including money), knowing or suspecting that such property is derived from criminal or certain specified unlawful activity (“criminal property”), for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
2. conducting a financial transaction which involves criminal property;
3. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, ownership or control of criminal property;
4. the acquisition, possession or use of criminal property;
5. promoting the carrying on of unlawful activity; and
6. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.

INDICATORS FOR SUSPICION OF MONEY LAUNDERING ACTIVITIES

The examples of possible indicators of suspicion for money laundering activity:

1. transactions which have no apparent purpose, and which make no obvious economic sense;
2. where the client/business partner refuses to provide the information requested without reasonable explanation;
3. A client/business partner refuses to proceed with a transaction when asked for identification;
4. where cash payment been offered by the business partners/clients;
5. business activities that contradict core values;
6. suspiciously close ties to government officials, previous allegations of corruption or unethical behavior or a lack of proportionality between the proposed work and fees;
7. engage in any activity that might lead to a breach of this Policy.

The above is not intended to be an exhaustive list.

POLICY BREACHES

Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.
Any uncertainties as to whether a particular act constitutes money laundering, or any other queries, should be raised with Aluminij’s Compliance Officer.

Aluminij is committed to ensuring that no one suffers any detrimental treatment as a result of their good faith reporting of their suspicion under this Policy.

POLICY REVIEW

This Policy shall be updated from time.

COMPETITION LAW POLICY

INTRODUCTION
The maintenance of high ethical standards in adhering to national and international laws is one of the fundamental Aluminij Industries (hereandafter „ Aluminij“ or „we“) Principles.

Competition laws – also referred to as antitrust laws – are designed to protect competition. They prohibit business behaviour which has the objective or the effect of preventing, restricting or distorting competition. It is the belief of the management that even in the absence of such laws, the interest of the Aluminij, its employees and other are best served by the principles of free market economy and fair competition. For these reasons, it is the policy of the Aluminij to comply strictly, in all respects, with competition laws.

PURPOSE

As a company with worldwide business activities, Aluminij is subject to the competition and antitrust legislation in many jurisdictions. Although country-specific legislation is different in application, the underlying principles of anticompetitive behaviour are similar and the guidelines provided below highlight these behaviours.

This Policy is designed to make both management and employees aware of the basic rules, and how these rules affect their business behaviour in making commercial decisions.

This Directive cannot cover all facts and circumstances that may encounter in business activities. Accordingly, it is strongly recommended and expected that in every case of doubt or in any instance where an employee has a question as to whether a particular course of action is appropriate or not, should contact the legal department for advice.

This Policy sets out Aluminij approach to ensuring that we fully comply with competition laws applicable to our business activities and that we appropriately manage associated risks.

We are committed to competing fairly across our global operations and do not engage in practices that restrict fair market competition.

We are aware that the greatest risks occur when dealing with competitors, in particular through commercial agreements, coordinating strategy or exchanging sensitive information.

Competition laws aim to protect consumers by promoting free, undistorted competition between companies, protecting independent decision making of market participants, and preventing the misuse of market power.

In certain circumstances, agreements with competitors may be considered permissible when their restrictions to competition are outweighed by efficiencies, e.g. improvements in technology or production. Examples of such arrangements are Joint technical or quality control standards or Joint research and development ventures.

When employees are proposing, or invited to participate in, any arrangement with competitors, they must inform and consult with their Legal Department immediately and before the event.

We do not discuss or share commercially sensitive information with our competitors unless there is a legitimate reason, as this can of itself be a hardcore breach of competition law. We do not share detailed current and future pricing, cost and volume information and future strategy and investment plans, as this type of information is particularly high risk.

We do not share high risk information with our competitors.

We must inform Legal if we receive, or are asked to share, this type of information with a competitor.

Particular risks arise when the supplier, customer or agent is also a competing producer. We must not enter into agency or marketing agreements with competing producers without consulting Legal.

The obligation is on each employee to bring to the attention of the Legal Department as soon as an employee suspects that a transaction or activity may be viewed as anticompetitive promptly and before any action is taken on behalf of the Company, circumstances which may have anticompetitive implications.

POLICY BREACHES

We look out for certain clauses which are considered hardcore breaches invertical agreements and which attract significant penalties.

Failure to address the risk of anti-competitive practices may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/or individuals.

POLICY REVIEW

This Policy shall be updated from time.

RECYCLING AND CIRCULAR ECONOMY POLICY

INTRODUCTION

Aluminij Industries d.o.o. (hereinafter “Aluminij Industries” or “we”) is responsible for approving the recycling and circular economy policy for all employees and companies under M.T. Abraham Group, who were engaged with the common goal of creating a work environment that supports the aforementioned policy.

This policy applies to our entire organization and those with whom we do business or are our partners, including suppliers, sellers and contractors.

PURPOSE

Recycling is essential for modern business with materials such as aluminum and provides raw material for the same supply chain. Recycled or secondary aluminum is about 95% less energy intensive to produce than new or primary aluminum. Aluminum, as a material, can be endlessly recycled. This is why, according to estimates, 75% of all aluminum ever produced is still in use today.

Aluminum cans can serve as a striking example, since they are the most sustainable type of beverage packaging in almost every respect. With better recycling rates and a far greater proportion of recycled material than glass or plastic, aluminum cans are a tailor-made product that enables a highly circular economy in the industry in which they are used.

It is very important to emphasize that aluminum does not lose its original properties through recycling and that it has a high internal material value. These are the reasons from which it follows that it is also profitable from an economic point of view to return aluminum to the circular cycle consisting of decomposition, separation and reuse. One of the great advantages of aluminum is that it can be recycled extremely easily and efficiently, and in a way that does not impair its quality. In addition to favorable mechanical properties with excellent reshaping, light weight and resistance to corrosion, aluminum is a material that, compared to other metals, has a significantly lower impact on the environment.

Environmental protection and preservation of natural resources are the focus of Aluminij Industries d.o.o. which, considering the increased production on a global level with the simultaneous reduction of raw material stocks, is considered a commendable commitment.

In order to establish a line of sustainability, the best way is to form a circular business model that ensures the reuse of resources. Aluminum as a material fits perfectly into this – it retains its qualitative properties even after an unlimited number of recyclings. Namely, the entire production of logs, blocks and small ingots, which are products of Aluminij Industries, is based on the principle of recycling, i.e. aluminum products that have already been used as raw materials.

We want to initiate and support the recycling of aluminum packaging, but achieving this goal requires a comprehensive, responsible and reasonable consumer culture of recycling. The entire recycling agenda fully fits into our Company’s clear commitment to environmental protection and the preservation of natural resources.

VIOLATION OF POLICY

Violation of the law, this Code of Conduct or Aluminij Industries policy has appropriate consequences, including potential termination of employment. Failure to report knowledge of a breach, attempting to prevent a colleague from reporting a breach and falsely reporting a breach may also have consequences. All criminal offenses are reported to superiors.

POLICY OVERVIEW

This Policy is periodically reviewed and may be updated.

ENERGY AND CLIMATE POLICY

INTRODUCTION

Aluminij Industries d.o.o. (hereinafter “Aluminij Industries” or “we”) is responsible for approving the energy and climate policy for all employees and companies under M.T. Abraham Group, who were engaged with the common goal of creating a work environment that supports the aforementioned policy.

This policy applies to our entire organization and those with whom we do business or are our partners, including suppliers, sellers and contractors.

PURPOSE

It is our responsibility, and at the same time our focus, that resources are used as carefully and conscientiously as possible. This philosophy shapes everything we do. Aluminij Industries produces aluminum logs, small ingots and aluminum blocks which, apart from their shape, also differ in terms of production and energy requirements. Light, durable and infinitely recyclable, aluminum as a material can help solve many global energy and climate challenges.

The aluminum industry on a global level continuously introduces innovations in technological processes in order to reduce energy consumption and therefore carbon production, which has a direct impact on reducing environmental pollution in terms of impact on air quality and flora and fauna. It can be safely concluded that aluminum, as an industrially usable potential, has its important place in creating a greener future, in which Aluminij Industries also found its important place. Mostar.

The overall importance in contributing to environmental protection, and thus to the prevention of negative climate change, is the use of green energy. Namely, our company uses CNG – compressed natural gas as an energy potential and electricity that is entirely produced from green sources, regularly monitoring emissions of harmful gases into the air in accordance with legal obligations. In addition to all that, Aluminij Industries continuously works on the rationalization of energy consumption, which is the focus of the activities of all our employees, and therefore the entire team.

VIOLATION OF POLICY

Violation of the law, this Code of Conduct or Aluminij Industries policy has appropriate consequences, including potential termination of employment. Failure to report knowledge of a breach, attempting to prevent a colleague from reporting a breach and falsely reporting a breach may also have consequences. All criminal offenses are reported to superiors.

POLICY OVERVIEW

This Policy is periodically reviewed and may be updated.

SUSTAINABLE DEVELOPMENT POLICY

INTRODUCTION

Aluminij Industries d.o.o. (hereinafter “Aluminij Industries” or “we”) is responsible for approving the sustainable development policy for all employees and companies under M.T. Abraham Group, who were engaged with the common goal of creating a work environment that supports the aforementioned policy.

This policy applies to our entire organization and those with whom we do business, including suppliers, associates, and contractors.

PURPOSE

In order to protect our planet as best we can, our task is to follow an ambitious sustainability strategy with a strong focus on CO2 emissions and on the transparency of our operations and rational management of resources. We work closely with our partners to analyze each phase of aluminum production and to identify new opportunities and share data together with our experts, which ultimately results in more acceptable solutions for the entire community in which we operate. In this way, we continuously strive to be efficient and productive, bearing in mind the environment in every step of the process, and we actively implement our process management in accordance with legal norms and international conventions, which is verified by globally recognized certificates.

We do all this with the aim of creating a circular society that not only benefits our customers, but also provides the necessary resources for future generations.

Aluminij Industries aims to achieve the best possible achievements in the field of environmental protection and quality in all segments as well as in the field of health and safety at work in order to achieve the best possible safety of employees, associates and our visitors.

Taking responsibility for the implementation of the principles of sustainable development in regular business is manifested by supporting generally applicable principles in the areas of employment and work, ethics, biodiversity and environmental protection, health and safety at work, and quality and related leadership and management systems.

VIOLATION OF POLICY

Violation of the law, this Code of Conduct or Aluminij Industries policy has appropriate consequences, including potential termination of employment. Failure to report knowledge of a breach, attempting to prevent a colleague from reporting a breach and falsely reporting a breach may also have consequences. All criminal offenses are reported to superiors.

POLICY OVERVIEW

This Policy is periodically reviewed and may be updated.

SOCIAL RESPONSIBILITY POLICY

Aluminij Industries d.o.o. is dedicated to the development of the community in which we work. We consider it our duty to be drivers of development and initiators of the modernization of society, while at the same time respecting the environment and the society in which we live.

We stand for open communication, development and compliance with the requirements of the SA 8000 standard. The fundamental approach to social responsibility is respect for the rule of law and legal obligations. We respect national and international instruments and their interpretation.

We strive to provide a pleasant working environment for our employees by understanding their wishes and needs. We encourage suppliers and other legal entities (companies) and individuals with whom we cooperate to support social responsibility guidelines.

We believe that the success and sustainable development of Aluminij Industries comes as a result of the organization’s ability to achieve its goals in the long term, while paying attention to the needs and expectations of all interested parties alike: customers and consumers, workers, owners, suppliers, partners and the wider community.

We have identified eight areas of special interest:

• Child labor
• Forced labor
• Health and safety
• Freedom of association and the right to collective bargaining
• Discrimination
• Disciplinary measures
• Working hours
• Fees/compensation for work

We have decided to fulfill the applicable requirements from the SA 8000 standard and the requirements of national labor laws.

Copies of this Policy are displayed in visible locations within the company’s workplaces and are communicated to all employees, as well as the public and other interested parties upon request. The adequacy of the policy is reviewed periodically, and changes must be approved by the company’s director before publication.

The company director is responsible for reviewing the adequacy, appropriateness and effectiveness of the SA 8000 social responsibility policy, procedures and results at least once a year.

To maintain the policy and fulfill the applicable instructions of this standard, we have selected a management representative for management systems.

RESPONSIBLE SOURCING POLICY

1. GOALS

Aluminij Industries d.o.o. has no legal responsibility for the business standards of its suppliers. However, according to UN and OECD standards, we are expected to act with due diligence towards our suppliers to avoid contributing to human and labor rights violations, environmental degradation, or anti-corruption violations within the supply chain.

Aluminij Industries defines responsible sourcing as conducting purchases in a way that enables the company to identify the risk that violations of human and labor rights, environmental protection legislation or anti-corruption legislation may occur in the company’s supply chain and – if such violations are detected – initiate actions against the supplier to end the mismatch.

This document describes the key principles of responsible procurement in Aluminij Industries.

We believe that by adhering to these principles, we will not only contribute to more sustainable supply chains but also reduce commercial risk and strengthen our long-term competitiveness.

     2. SCOPE

This procedure covers all procurement activities within Aluminij Industries.

      3. LIABILITY

The senior management of the Company is responsible for updating this policy.

The Sales Department, the Procurement Department and the Legal Department are responsible for being guided by the principles of this policy.

4. DESCRIPTION

4.1 PRINCIPLES FOR RESPONSIBLE SOURCING IN ALUMINIJ INDUSTRIES

Responsible sourcing in Aluminij Industries involves risk-based engagement with suppliers, meaning that efforts should be directed toward the product categories and suppliers that pose the greatest risk. Aluminij Industries is dedicated to continuous improvement, both in terms of setting internal goals and in terms of expectations for suppliers to achieve progress.

4.2 SUPPLIER REQUEST

Aluminij Industries Code of Business Conduct for Suppliers describes requirements for suppliers in relation to management and ethics, labor and human rights, occupational health and safety, and the environment. This Code should be communicated to all suppliers with a special focus on risky suppliers. Suppliers should be encouraged to present the same type of requirements to their suppliers.

4.3 RISK EVALUATION

Aluminij Industries will carry out a risk assessment of its suppliers to identify suppliers that may pose a risk of non-compliance with the requirements presented in Code of Business Conduct for Suppliers.

Supplier evaluation will be conducted according to our supplier evaluation procedure which includes the “Supplier Evaluation Form”. The supplier’s risk assessment will be carried out based on the specified form. It will be categorized as low risk, medium risk or high risk. Suppliers that are assessed as medium or high risk suppliers should be subject to a more detailed risk assessment.

4.4 REACTIONS TO VIOLATIONS OF THE CODE OF BUSINESS CONDUCT FOR SUPPLIERS

The purpose of responsible sourcing is to use our purchasing power to better influence supplier business standards. Therefore, when violations of the Code of Business Conduct for Suppliers are discovered, the contract with the supplier should not be automatically terminated, even when the contract gives us the right to do so. Instead, the company will assess the severity of the breach. The usual response to non-compliance should be to follow up with suppliers through requirements, dialogue, and guidance.

Suppliers who do not meet our requirements will demonstrate a willingness to comply by documenting improvements within a specified timeframe. In case of a serious breach of requirements or lack of progress over time, the contract should be terminated. Risk issues associated with complex supply chains, such as for commodities, should be addressed on a case-by-case basis. Potential actions may include product certification, collaborative projects with other industry players, or government dialogue.

CODE OF BUSINESS CONDUCT FOR SUPPLIERS ALUMINIJ INDUSTRIES D.O.O.

COMMITMENT

Aluminij Industries d.o.o. recognises that our supply chain activities can have wide ranging social and environmental impacts and that our responsibility extends beyond our own operations, into our supply chain.

We are committed to socially and environmentally responsible procurement and have set high standards for the way we do business so our customers and other partners know we can be trusted.

Our business mindset requires that we work only with Suppliers who have the ability to consistently meet our standards and specifications and are committed to values of conduct that are compatible with our own.

This commitment is reflected in our Code of Business Conduct for Suppliers Aluminij Industries that sets out the minimum standards of behaviour we require of our Suppliers.

We ask our Suppliers to not just comply with the Code, but to use reasonable endeavours to exceed it and promote continual improvement throughout their business operations.

The United Nations Sustainable Development Goals (SDGs) invite action from the private sector to address some of the world’s most pressing development issues. Situated in a broader ethical sourcing framework, our Code is one way Aluminij Industries aligns with the SDGs.

APPLICATION AND ACCEPTANCE

The Code is applicable to all contract Suppliers and business partners, who are expected to cascade these requirements to their own supply chain.

Sustainability and compliance with this Code are part of the criteria Aluminij Industries uses during Supplier selection, and this Code is applicable to all of our Suppliers and their affiliates.

Suppliers must diligently provide official answers, documents, certificates related to sustainability as soon as it is requested by Aluminij Industries.

Adhering and signing this Code is therefore a requisite to do business with Aluminij Industries.

ASSESSMENT

By adhering to this Code, each Supplier accepts to be assessed or audited by Aluminij Industries or by a third party mandated by Aluminij Industries.

In case of violation of this Code, Aluminij Industries will determine corrective actions with the violating Supplier which can include termination of our business relationship.

QUESTIONS

Suppliers may raise any concern or questions by sending an email at the following email address:

info@aluminij.ba .

We will provide guidance when requested.