SUPPLY CHAIN DUE DILIGENCE REPORT

INTRODUCTION

Purpose of the Report

At P. Kay Metal, CID005189, we are committed to upholding our responsibility to respect human rights and to refrain from any action which contributes to the financing of conflict.

As part of such commitment, this report is intended to share, with relevant stakeholders and the public, an overview of our due diligence management system, and the results it yields during the past year, with a view to continuous improvement.

This document alligns with the reporting expectations of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (hereafter, “OECD Due Diligence Guidance”) and RMI RMAP Tin and Tantalum Standard.

Scope of the Report

This Supply Chain Due Diligence Report covers our tin supply chain for the following reporting period: 1 January 2024 - 31 December 2024. Where updated information is already available for the year 2025 at the time of writing, such information has been integrated into the report to provide a better understanding of our progress made and continuous improvement efforts.

COMPANY INFORMATION

P. Kay Metal, CID005189, supplies a wide assortment of metals, including Tin and Lead alloys, wire and metal cores for all industries, including contractors and ammunition manufacturers. In addition, P. Kay Metal, Inc. is a global supplier of soldering materials used in the electronic assembly process. P. Kay bar solder, solid wire, cored wire and soldering fluxes have been specified in an array of electronic assemblies, ranging from military to consumer product applications.

Our commitment to consistently producing quality soldering material and providing reliable technical and recycling services was the foundation upon which P. Kay was established over 30 years ago. Our growth continues as we respond to the demands of an ever changing marketplace. Our new facilities and state issued recycling permits provide solutions for the challenges of today and tomorrow, one connection at a time.

DUE DILIGENCE MANAGEMENT SYSTEM

P. Kay Metal implements a risk-based due diligence management system aligned with the 5-step framework of the OECD Due Diligence Guidance which includes:

1. Establishing a strong management system for due diligence;

2. Identifying and assessing risks in mineral supply chains;

3. Designing and implementing a strategy to respond to identified risks;

4. Carrying out independent third-party audits;

5. Reporting annually on supply chain due diligence.

Each step is described in the sections below.

Step 1. Establishing a strong management system for due diligence

1.1 Policy

P. Kay Metal has adopted a Responsible Supply Chain Policy (https://www.pkaymetal.com/responsible-supply-chain-policy), which was approved by senior management and made effective in June 2025. The Policy formalizes the company’s approach to responsible supply chain management of mineral and metal supply chains from Conflict-Affected and High-Risk Areas (CAHRAs), and it covers the following risks:

• Serious abuses associated with the extraction, transport, or trade of minerals:

  • any forms of torture, cruel, inhuman and degrading treatment;

  • any forms of forced or compulsory labour;

  • the worst forms of child labour;

  • other gross human rights violations and abuses such as widespread sexual violence;

  • war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

• Direct or indirect support to non-state armed groups.

• Risk associated with the contracting of public or private security forces.

• Bribery and fraudulent misrepresentation of the origin of minerals.

• Money laundering.

• Non payment of taxes, fees and royalties due to governments.

The policy and consequences of non-compliance have been communicated to all suppliers, and embedded into Purchase Orders.

1.2 Management Structure

In early 2025, P. Kay Metal formalized a dedicated Due Diligence Standard Operating Procedure (SOP), with the purpose to establish an effective internal management system for due diligence.

Senior Management is responsible for overseeing the effective implementation of the SOP, in collaboration with all relevant departments. The ultimate accountability for P. Kay Metal’s due diligence management system is held by Senior Management.

Due diligence training has been provided for all relevant personnel by an external specialized consultant, TDi Sustainability, in early 2025.

1.3 Internal Systems of Control and Transparency

In early 2025, P. Kay Metal strengthened and formalised its system of control and transparency through the development of a Know Your Counterparty (KYC) & Due Diligence Questionnaire, with the purpose to ensure that the Company collects all information relevant for due diligence, specifically:

• KYC data including information on suppliers’ identity, nature and legality of suppliers’ business operations; their owners and beneficial owners.

• Information needed to identify potential red flags, such as information on material origin and transit.

At the time of writing, the Questionnaire has been sent to all tin Suppliers.

1.4 Grievance Mechanism

In early 2025, P. Kay Metal adopted a grievance mechanism to receive, log, investigate, and address concerns related to our mineral sourcing, in line with the effectiveness criteria of the UN Guiding Principles on Business and Human Rights.

The following channels are available to stakeholders wishing to submit a grievance:

• Email grievances@pkaymetal.com

• Online form https://www.pkaymetal.com accessible anonymously

The process includes pre-determined timelines for acknowledgement, investigation, response, and appeal.

At the time of writing, no grievance has been received.

1.5 Record Keeping System

All information and documentation collected for due diligence purposes is documented, recorded, and kept physically/digitally on the Company’s internal intranet, with controlled access, for at least 5 years.

Step 2. Identifying and assessing risks in mineral supply chains

2.1 Red Flags Identification

P. Kay Metal has adopted a formal system to identify potential red flags in its tin supply chains. A red flag is triggered if one of the following red flag is identified:

• Red flag locations of mineral origin and/ or transit:

  • The minerals originate from or have been transported via a Conflict-Affected or High-Risk Area (CAHRA);

  • The minerals are claimed to originate from a country that has limited known reserves, likely resources or expected production levels of the mineral in question (i.e. the declared volumes of mineral from that country are out of keeping with its known reserves or expected production levels);

  • The minerals are claimed to originate from a country in which minerals from CAHRAs are known to transit.

• Supplier red flags:

  • Direct suppliers or other known upstream companies have shareholder or other interests in companies that supply minerals from or operate in one of the above-mentioned red flag locations of mineral origin and transit.

  • Direct suppliers or other known upstream companies are known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months.

  • Site Visits are often completed by Senior Management.

• Beneficial Owner & Ultimate Owner red flags:

  • Verification of individuals and entities that hold indirect or direct ownership stakes of 25% or more against relevant Government sanction lists.

The CAHRA determination process of P. Kay Metal is based on credible sources of data covering 3 criteria: conflict, human rights, and governance.

A country is determined to be a CAHRA if:

1. The Country is identified as high risk (i.e., colour red) in TDi CAHRA Index (https://platform.tdi-digital.com/risk/explore);

2. The Country is the Democratic Republic of the Congo (DRC) or one of its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act (DFA 1502), namely Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia;

3. The Country is identified as high risk in the EU indicative and non-exhaustive list of CAHRAs, provided by the European Commission pursuant to Article 14.2 of the European Union Regulation 2017/821 available here: https://www.cahraslist.net/cahras.

During the reporting period, P. Kay Metal has sourced recycled input material from the United States and Mexico, and no red flag has been identified.

2.2 Risk Assessment

At P. Kay Metal, enhanced due diligence is conducted to assess the presence of risks covered in our Responsible Supply Chain Policy, for all red-flagged supply chains.

During the reporting period, no red flag was identified, requiring further enhanced due diligence or risk assessments.

Step 3. Designing and implementing a strategy to respond to identified risks

P. Kay Metal’s Responsible Supply Chain Policy describes the company’s management approach to potential risks covered by the policy, as follows:

Where potential risks are identified, P. Kay Metal favors adopting the principle of engagement. To this end, where necessary, P. Kay Metal engages with suppliers, as well as relevant stakeholders, as appropriate, to design and adopt appropriate risk management plans, to improve and track performance with a view to preventing or mitigating risks through measurable steps taken in reasonable timescales (6 months).

However, P. Kay Metal reserves the right to immediately suspend or discontinue engagement with suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses and/or direct or indirect support to non-state armed groups, as defined in our Policy.

During the reporting period, P. Kay Metal did not identify supply chain risks requiring mitigation.

Step 4. Carrying out independent third-party audits

In 2024/5, P. Kay Metal committed to SCS Global Services, a third-party audit of its supply chain due diligence management system by the Responsible Minerals Initiative (RMI) Responsible Minerals Assurance Process (RMAP) against the Tin and Tantalum Standard. The audit was completed July 29-31, 2025.

Step 5. Reporting annually on supply chain due diligence

This Supply Chain Due Diligence Report fulfils the reporting expectations of the OECD Due Diligence Guidance and is made publicly available on the company website www.pkaymetal.com, sustainability, scroll to bottom for supply chain link.