Responsible Minerals Sourcing Policy

Novamet Specialty Products is committed to a socially responsible supply chain, especially as it
pertains to conflict minerals and compliance with Section 1502 of the U.S. Dodd-Frank Wall
Street Reform and Consumer Protection Act (Dodd-Frank Act) and the Regulation (EU)
2017/821 of the European Parliament. Furthermore, Novamet supports the goal of ending
violence and human rights violations in the Democratic Republic of Congo, surrounding
countries, and all conflict-affected and high-risk areas, which have been partially financed by
the exploitation and trade of conflict minerals, including tungsten, tantalum, tin, gold, and
cobalt.

In support of this objective, Novamet does not purchase any materials containing tungsten,
tantalum, tin, gold, or cobalt sourced from any of the “covered countries” including the
Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of
Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

To support this commitment, Novamet continuously works with our supply chain to strengthen
compliance and ensure that no conflict minerals are sourced from the “covered countries” for
use in our products. We also work with suppliers to prevent the sourcing of any materials
involved with armed rebels, terrorist groups, or serious human rights violations