OUTOKUMPU STAINLESS UK RESEARCH FOUNDATION LTD

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Civil society organisations Professional auditors Workers within your organisation Workers within your supply chain

Social audits

Audit conducted by your staff Third party audit arranged by your organisation

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

via own managers or NGOs indication

Demonstrated progress

We ammended our Supplier requirements: Suppliers and Subcontractors agree to answer self-assessment questionnaires, issued by Outokumpu or a duly representative chosen by Outokumpu to assess their compliance with Outokumpu’s Supplier Requirements, Code of Conduct and the Suppliers and Subcontractors performance in terms of Environment, Labor & Human Rights, Ethics and Sustainable Procurement.

Reported risks and mitigations

• Risk: Protection of indigenious people of a ferroalloy producer in Brazil
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Group: Other vulnerable groups
• Location: Brazil
• Mitigation: We met with the company, the indigenous people and several institutions in Brazil in December 2021, together with an independent expert. We discussed with the indigenous people to hear their opinions on the process and learn about their lives and their problems. We also got very positive feedback and were invited back.
• Risk: Environmental damage, negative impacts on local people and lack of transparency raised toward a ferronickel sub-supplier in Guatemala
• Tier: Tier 2 suppliers
• Mitigation: The purpose of an assessment was to investigate, identify and assess the human rights impacts of company’s operations on the affected communities, focusing on indigenous rights-holders. This included a review of the company’s human rights risk management practices and their status of implementation. We are committed to engaging and working with the company on improving the situation for the local population and their welfare and safety.