Code of Conduct

Integrity: CMM Metals & Alloys and its employees commit to honesty and openness in all business dealings, both internal and external.

Compliance with the Law, Regulations, and Sanctions: CMM Metals & Alloys follows a strict policy of compliance with all applicable laws, regulations, and sanctions in all its business operations.

Ethics: We strive to ensure that our employees conduct themselves ethically, promoting honesty, fairness, and courtesy in all interactions, both within the organization and with external contacts.

Confidentiality: CMM Metals & Alloys employees are prohibited from disclosing confidential information to third parties, obtained during their duties.

Conflicts of Interest: Employees must avoid outside activities that may conflict with their loyalty to CMM Metals & Alloys or compromise their judgment. Any potential conflicts must be reported to the Company Chief Executive Officer.

Business Gifts and Corporate Hospitality: CMM Metals & Alloys discourages the acceptance of business gifts or excessive hospitality that may be perceived as influencing decisions. Any doubts should be discussed with the Company Chief Executive.

Expenses: Recoverable expenses must comply with the Company’s policy, be reasonably and necessarily incurred on behalf of CMM Metals & Alloys, and claimed within three months with accompanying receipts.

Price Fixing: Employees must not collude with third parties to fix prices for metals, minerals, or materials traded by CMM Metals & Alloys.

Bullying: CMM Metals & Alloys strictly prohibits any form of bullying, defined as intimidating, malicious, insulting, or humiliating behavior that undermines individuals or Companys.

Discrimination: Employees must act fairly and without discrimination based on race, color, ethnicity, sex, marital status, sexual orientation, disability, age, political persuasion, or religion.

Sexual Harassment: CMM Metals & Alloys employees must not engage in any form of sexual harassment, including unwanted conduct, offensive materials, or making decisions based on sexual advances.

This list is not exhaustive, so if there are additional matters you believe the company should know about, please follow the outlined procedure in this policy. Detecting malpractice early enables us to take necessary steps to safeguard everyone’s interests. It’s important to note that this procedure does not replace the standard Grievance Procedure or other relevant policies, and it is not intended for addressing issues related to your employment terms and conditions.

Our Pledge: The Company is dedicated to upholding this policy. If you utilize this policy to raise concerns, the Company assures you that there will be no retribution or victimization. We take your concerns seriously and will adhere to this policy without requiring you to provide proof. If you request confidentiality, the Company will respect your wishes and only disclose information with your consent. We commit to providing feedback on any investigation, and the Company will be considerate of any concerns you may have arising from actions taken under this procedure.

How to Express Your Concern? Anyone with concerns about malpractice should bring them to the attention of one of the Partners.

Company’s Response Upon receiving your concern, the Company will determine a responsible and appropriate response under this policy. Typically, this involves initial internal inquiries, but it may necessitate a formal or informal investigation later, depending on the nature of the raised concern. The Company may involve auditors or professional advisers in the process.

To the extent possible, the Company will keep you informed about decisions and outcomes of inquiries and investigations. However, there may be instances where confidentiality obligations prevent disclosure of certain matters.