Policy & Strategy

Supply Chain Our main raw material, Copper Concentrate, is entirely being imported from overseas. Just as of 2022, 1.64 million tons were imported. Main importing countries include Chile(28%), Indonesia(18%), Australia(16%), Peru(12%), Canada(11%), and Panama(7%). Our secondary raw material, Copper Scrap, is procured both domestically(25%) and internationally(75%). The import volumes by continent are as follows: South America(40%), Africa(30%), Middle East(17%), North America(6%), Asia(4%), and Europe(3%).

Responsible Sourcing Management Policies LS MnM seeks to cooperate with suppliers and business partners to build a sustainable society. To this end, we have been implementing responsible sourcing management policies based on OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, which is essential for the requirements of the LME, LMBA, and Copper Mark* on responsible sourcing management.

Compliance with the Code of Conduct LS MnM has implemented a comprehensive Business Partner Code of Conduct that defines responsible behaviors and encourages our suppliers to comply with them. The Code of Conduct covers GRI standards as well as global regulations, such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals. It includes guidelines on environmental, human rights, labor rights, safety, supply chain management, social responsibility, and ethical management. We advise our suppliers to voluntarily comply with the Code of Conduct and actively participate in our ESG management by including it in our contracts.

Sustainable Growth Strategy with Partner Companies LS MnM considers all suppliers, including the company itself, subsidiaries, direct suppliers, and subcontractors, as partners with whom we aim to establish meaningful and sustainable business relationships. We strive for a win-win management approach based on mutual trust. To this end, we intend to establish a sustainable supply chain by conducting assessments on environmental and social impacts and operating response systems. In order for the partnership to be beneficial for both parties involved, profitability and continuity must be met. Therefore, LS MnM advises our responsible sourcing policy and operates a fair and transparent management process for our partners. We utilize a procurement system to carry out tasks related to partner companies. We conduct registration evaluation, comprehensive evaluation, on-site due diligence, and risk monitoring to identify and improve any negative factors. When positive factors are discovered, we encourage them to increase competitiveness. Through this, we manage various potential risks that may occur from all of our partners and support them to achieve sustainable management. We will continue to strive for the sustainable growth with our partners.

Organization

Our Procurement team carries out ESG activities for sustainable growth such as establishing company-wide procurement strategies, promoting win-win cooperation, setting up procurement data, and evaluating our partners. Procurement team oversees the entire procurement strategy establishment and business partner management and operation. They not only plan and execute tasks in-depth but also collaborate with relevant teams such as Safety & Health team, Environment team, and Quality Management team. Furthermore, we prioritizes win-win cooperation by maintaining effective communication with our business partners.

Performance

Supply Chain Management System LS MnM strives to ensure responsible sourcing and supply chain management by complying with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, LME, LBMA, and Copper Mark’s guidelines. To manage these processes effectively, we have established a dedicated organization responsible for observing responsible sourcing policies and managing processes essential for social responsibility. The Raw Materials team and Procurement and Logistics team executives are responsible for responsible sourcing and have the authority to make decisions on related tasks. Our Sustainability Management team regularly reviews and updates relevant policies, which are then managed by the Raw Materials team and Procurement and Logistics team. We also continuously monitor and manage supply chain risks through supplier surveys and history management.

Supply Chain Risk Identification and Assessment

Standards for Risk Identification LS MnM currently manages a list of 42 conflict-affected areas, and it includes 24 countries in Africa, 12 in Asia, 4 in South America, and 2 in Europe. This list is based on UN Security Council’s sanctioned countries, OECD's Conflict-Affected and High-Risk Areas, and LBMA's sanctioned countries.

Risk Assessment Method After first determining whether raw materials were produced or made a stop at conflict-affected areas, we evaluate each supplier for risk factors such as violation of human rights using the survey we have created. The survey is divided into two parts, one for copper concentrate suppliers and the other for gold/silver concentrate suppliers. The survey for copper concentrate suppliers includes questions on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, proof of origin, and social and environmental aspects. The survey for gold/silver concentrate suppliers includes questions on OECD’s Annex II* provided by LBMA. With these questions, we evaluate supply chain policies, management systems, and practices.

Supply Chain Risk Follow-up So far, there has been no history of red flags in the LS MnM supply chain. If red flags are found in the evaluation process of supply lines in conflict-affected areas, we will immediately conduct due diligence as per our policy. When measures such as business trips are difficult due to disasters like COVID-19, we have established a process in which we can determine the existence of actual risks through comprehensive explanations. To minimize negative impacts in case of a red flag, we review the risks meticulously and request our suppliers to explain that there are no conflict-affected areas issues. The explanatory items are based on our survey questions. If necessary, our company will verify if those responses are actually being applied in practice and document all explanations to prove that the items are irrelevant to conflict-affected areas. If the problems persist and the improvements seem insufficient despite our request to prevent, improve, and solve them, we conduct due diligence through an independent organization. In case the due diligence results come out inadequate and it is clear there is no room for improvement, we have strengthened our regulations so that we can suspend the contract and halt the procurement. These follow-ups will be made under the management’s prompt decisionmaking.

Responsible Sourcing

Acquisition of Copper Mark To adapt to the changing industrial landscape, LS MnM has committed to obtaining the Copper Mark, the primary ESG certification in the copper industry. We established a TFT to address the 32 standards required by the Copper Mark, and reviewed and improved them based on the four components: Rule & Policy, Organization, Process, and System. As a result of these efforts, we became the first company in Asia to receive the Copper Mark in December 2021. This is a year ahead of target and the valuable achievement was resulted from all employees active participation and cooperation.

Response to LME’s Responsible Sourcing Our electrolytic copper cathode are maintaining Grade A status at the London Metal Exchange(LME). In order to maintain our Grade A status, we have proactively established responsible sourcing practices required by LME and obtained the Copper Mark certification in 2021. We will maintain long-term partnerships with suppliers that faithfully comply with these responsible supply chain management policies.

Response to LBMA’s Responsible Gold Guidance LS MnM's supply chain policies and practices are in accordance with the Responsible Gold Guidance and Responsible Silver Guidance of the London Bullion Market Association(LBMA). At the end of 2021, LBMA revised the Responsible Gold Guidance to strengthen due diligence items related to ESG factors and specify requirements. In response, we have monitored and applied the revised elements to our responsible sourcing. Additionally, we disclose the compliance report and audit report mandated by LBMA every year after having them reviewed by a third party.

System

Logistics Visibility System Advanced Planning & Scheduling(APS) is a system that establishes a combination plan to reliably process raw materials through algorithms. Through the establishment of a step-by-step system, we are establishing an annual plan and completing the systemization of the overall raw material processing and production plan. We are striving to manage supply chain risks in advance by utilizing longterm detailed introduction information on raw materials by supplier and information on conflict areas within the raw material system.

Supply Chain Management System At LS MnM, we conduct an annual survey for all of our suppliers to assess whether they have met the standards outlined in the Responsible Sourcing Policy. In addition, we utilize Transportation Management System to manage shipments to ensure they do not pass through conflict-affected areas.