Eramet

Board of Directors

The Board of Directors determines the business strategy, examines and approves all decisions on the Group's major strategic lines of action and monitors their implementation. Eramet's strategy aims to promote the Company's long-term value creation by considering the social and environmental challenges of its activities.

Composition

18 members

• Christel BORIES, Chair and Chief Executive Officer
• Émeric BURIN DES ROZIERS, independent director
• Christine COIGNARD, independent director
• François CORBIN, lead director, independent director
• Nathalie DE LA FOURNIÈRE (CEIR), director
• Héloïse DUVAL, director
• Jérôme DUVAL (SORAME), director
• Tanguy GAHOUMA BEKALE, director
• Jean-Yves GILET, director
• Solenne LEPAGE, independent director
• Manoelle LEPOUTRE, director
• Ghislain LESCUYER, independent director
• Miriam MAES, independent director
• Nicolas NOEL, director representing employees
• Franck PECQUEUX, director representing employees
• Arnaud SOIRAT, independent director
• Romain VALENTY, director appointed by the state
• Jean-Philippe VOLLMER, director

Key statistics

• 12 meetings in 2024
• 44% proportion of independent directors (7/16, excluding employee representatives)
• 44% gender balance (7/16, excluding employee representatives)
• 90% average attendance rate of directors at meetings

The work of the Committees and the Board in 2024

The Board relies on the work of four Committees to carry out its duties. During the 2024 financial year, the work more specifically involved:

Board of Directors

In 2024, the Board of Directors continued to pay particular attention to the implementation of the Group's strategic changes and the monitoring of its strategic growth projects (in particular the start of production of the Centenario lithium plant in Argentina).

CSR and Strategy Committee

10 members, including 3 independent members 4 meetings Chair: Miriam Maes

The Committee assists the Board in determining the Group's strategic lines of action in terms of CSR, in particular by monitoring of the CSR Roadmap and the achievement of its objectives. It reviews developments taking place in the Group's markets and the resulting strategic options. In 2024, together with the Audit, Risks and Ethics Committee, it monitored the preparation of the first report on the Group's sustainability information.

In 2024, the committee, with the support of the CSR and Strategy Committee, paid particular attention to monitoring the preparation of the first report on the Group's sustainability information.

Audit, Risks and Ethics Committee

6 members, including 4 independent members 4 meetings

In addition to monitoring the financial reporting process, the Committee also monitors the main risks and implements the appropriate risk management plans.

Appointments Committee

4 members, including 2 independent members 3 meetings Chair: Ghislain Lescuyer

The Appointments Committee leads the process of proposing new directors for appointment by the Board. The Committee conducts an annual review of the independence criteria for independent directors and of the succession planning for key Group management personnel.

Compensation and Governance Committee

6 members, including 3 independent members 3 meetings Chair: Ghislain Lescuyer

The Committee conducts an annual review of the collective criteria for variable remuneration of management executives and the executive corporate officer. It also proposes the terms and conditions of the performance share award plans for the Group's main management executives.

Integration of sustainability-related performance in incentive schemes

Overview

The remuneration of the management bodies and of all Group executives is based on demanding and measurable objectives that are consistent with the corporate strategy. These objectives are mainly based on performance criteria for the CSR roadmap, safety, decarbonisation, financial performance and business development.

The objectives of the annual and long-term variable compensation are set each year during the first quarter by the Board of Directors on the recommendation of the Compensation and Governance Committee. At the same time, the Board of Directors annually assesses the level of achievement of the performance criteria to which the annual and long-term variable compensation is subject.

Chair and CEO remuneration structure

The remuneration of Eramet's Chair and Chief Executive Officer for the 2024 financial year breaks down into three main components:

Decarbonisation targets relate to reducing the Group's carbon intensity, such as reducing the carbon intensity of mining activities. These objectives are a reflection of the targets in the Act for Positive Mining roadmap. They also relate to the commitment of the Group's customers and suppliers and the deployment of decarbonisation projects for the pyrometallurgy activities.

Overall, climate-related considerations account for 4.6% of the total target compensation of the Chair and CEO of Eramet and represent 6.7% of her target variable remuneration, reflecting Eramet's commitment to social and environmental responsibility.

Executive Committee members

The members of the Executive Committee also have climate-related targets, namely:

• Target annual variable remuneration: 75% of this target is based on collective objectives, including:

  • 5% corresponding to the decarbonisation target
  • 15% are targets for achieving the roadmap (4/28 being associated with decarbonisation)

• Long-term variable remuneration: the indicators for the targets related to this part are identical to those of the CEO, namely:

  • 5% correspond to the decarbonisation target
  • 20% are targets for achieving the roadmap (4/28 associated with decarbonisation)

Given the weight of variable remuneration in their total compensation, climate-related indicators account for:

• Nearly 4% (between 3.7% and 3.9%) of their total target compensation
• Between 6.5% and 6.6% of their target variable compensation

Other senior executives

The climate targets for the Group's senior executives are:

• Target annual variable remuneration: 65% of the target is based on collective targets, of which:

  • 20% are targets for achieving the roadmap (4/28 being associated with decarbonisation)

• Long-term variable remuneration: the indicators for the collective objectives related to this part are identical to those for the CEO and all beneficiaries, namely:

  • 5% are decarbonisation targets
  • 20% are targets for achieving the roadmap (4/28 associated with decarbonisation)

Sustainability KPIs

Sustainability KPIs tied to remuneration include:

• Decarbonisation targets (reduction of carbon intensity)
• CSR roadmap achievement (28 targets, of which 4 are associated with decarbonisation)
• Safety performance
• Reduction of Scope 1 & 2 emissions per saleable ton to 0.221 t/t by 2026
• 10% reduction in the carbon intensity of mining activities by 2026 compared to 2022
• Commitment of the Group's customers and suppliers
• Deployment of decarbonisation projects for pyrometallurgy activities

Performance structure

Variable remuneration is divided between:

• Short-term incentive (STI): Annual variable remuneration based on collective targets (75% for Executive Committee, 65% for other senior executives)
• Long-term incentive (LTI): Long-term variable remuneration with decarbonisation and roadmap targets

Both STI and LTI incorporate sustainability metrics, with specific weightings for decarbonisation (5% in annual variable, 5% in long-term variable) and overall roadmap achievement (15% in annual variable, 20% in long-term variable).

Our strategic focuses

The Group's strategy has two main focuses: to sustainably support global economic development and to contribute to the energy transition.

With a diversified portfolio of assets and world-class mining deposits, Eramet is well-equipped to deliver premium solutions tailored to the demands of this new era of metals. To uphold its corporate purpose, the Group has established and implemented a strategy aligned with the main macroeconomic trends.

Strategic pillars

Growth in metals supporting global economic development

MANGANESE ORE AND ALLOYS | NICKEL | MINERAL SANDS

Continued global economic development should support growth in the demand for metals related to infrastructure (carbon steel), construction (pigments, ceramics) and consumer goods (stainless steels). The initial focus of the strategy is to expand the Group's activities in these robust markets, for which Eramet boasts world-class assets. The Group supplies high-grade ores, enabling its customers to mitigate their carbon impact, along with manganese alloys, boasting one of the best CO2 footprints in the industry.

Given the calibre of these assets, the growth in these metals will primarily occur through organic growth, by improving the use of current assets and their productivity.

Sustainably develop critical metals for the energy transition

LITHIUM | NICKEL FOR BATTERIES | BATTERY RECYCLING

At the same time, the demand for metals used in electrification (primarily for electric mobility and energy storage), which participate in decarbonising global economies, is seeing exponential growth. The second strategic focus relates to the expansion of the portfolio into metals essential for the energy transition. Leveraging the substantial mineral resources of the Centenario salt flat (Argentina) for lithium and the Weda Bay mine (Indonesia) for nickel, the Group aims to establish itself as a leading player in metals for the energy transition.

Deploy an exemplary responsible approach

In 2024, Eramet's corporate social responsibility was enhanced by a new CSR roadmap called "Act for Positive Mining". At the heart of this initiative lies a vision: to go beyond environmental and social management and foster, wherever possible, a positive impact for the Group's stakeholders and ecosystem, promoting a proactive and responsible approach centred on the continuous improvement of our practices. The roadmap is organised around three ambitions, encompassing all of Eramet's responsibilities and interactions, and is broken down into ten objectives for 2024-2026 and three objectives for 2035.

Creating value via operational excellence

Eramet is deploying the Eramet Production System (EPS) in its subsidiaries to improve the productivity of operations and sustain positive results in terms of safety. The EPS is based on proven techniques for improving operational performance that aim to establish the best operational standards and the adoption of these standards by all employees. The objective is to maximise value creation by making the best use of resources and production tools, and to take full advantage of the Group's leading geological potential.

Business model

Our purpose

Become a reference for the responsible transformation of the Earth's mineral resources for "living well" together.

Our value creation

Employees

• 100% employees covered by the Eramet Global Care social protection agreement
• 71%: employee commitment rate measured in the 2024 survey

Customers

• Major industrial customers in 47 countries
• Deployment of EraTrace (traceability platform) on the mineral sands activity and on the European production of manganese alloys

Suppliers

• Over 150 EcoVadis assessments completed
• More than 55% domestic purchases

Shareholders and investors

• €1.6 billion market capitalisation at 31/12/2024
• Proposed dividend of €1.50 per share for 2024
• €814 million adjusted EBITDA (excluding SLN) in 2024

Local communities and regions

• €16 million: community investment and sponsorship expenses including €11 million for the Group and €5 million for PT Weda Bay Nickel
• €440 million: taxes paid to states and local governments

Environment

• 68% of the electricity consumed in 2024 came from a low-carbon source (renewable and nuclear energy)
• Our biodiversity commitments validated by Act4nature and Business for nature
• 10% reduction in our scopes 1 and 2 CO2 emissions between 2023 and 2024 (2024 carbon footprint: 2.6 MtCO2eq)

Stakeholders

Dialogue with each stakeholder is ensured by the departments responsible for the topics of interest, such as finance, social impact and human rights, sales, public affairs, communication, human resources and ESG performance. These departments are in direct contact with the correspondents and liaise with the various governance bodies through their regular reporting.

Major risks

The risk factors mentioned below were identified in the 2024 risk mapping. A description of these risks and the associated management measures is provided in Chapter 4.5.

Risk management model

The risk management model is founded on dedicated and integrated governance based on the three lines of defence model, and is applied at every level of the business.

Governance Bodies

• Board of Directors
• Audit, Risks and Ethics Committee, Appointments Committee, CSR and Strategy Committee, Compensation Committee, Executive Committee

Three Lines of Defence

1st line of defence

• Operational managers
• Functional managers excluding control functions

Responsible for assessing and reducing risks, in particular by implementing a control system, allowing better control of activities.

2nd line of defence

• Departments responsible for areas of expertise dedicated to organising the risk control system (risk management, internal control, insurance, ethics and compliance, legal etc.)

Responsible for the risk control systems of the various business lines.

3rd line of defence

AUDIT INTERNE

Provide independent, objective assurance for any issue connected with the control of the Group's main processes.

External Assurance Providers

(STATUTORY AUDITORS, OTHERS)

Transition plan for climate change mitigation

Governance and accountability

The transition plan was approved by Eramet's Executive Committee. Performance on decarbonisation challenges is one of the objectives of the Decarbonisation Steering Committee led by the Decarbonisation Director and chaired by the Group's Chair and CEO. This Committee meets once every quarter and comprises all the members of Eramet's Executive Committee.

The Board of Directors relies on the recommendations of its Strategy Committee and CSR Committee. The CSR Committee specifically analyses the Group's progress in carbon emission reduction.

A decarbonisation department was created in 2023 as part of Eramet's drive to actively manage climate risks.

Scope of the plan

Eramet's transition plan covers all assets over which Eramet has operational control, including locked-in emissions (future emissions generated by their activity). The commitment includes emissions from scopes 1 and 2.

The plan covers:

• Mining operations: Gabon (Comilog), Senegal (Eramet Grande Côte), New Caledonia (SLN), Argentina (Eramine), Indonesia (PT Weda Bay Nickel - value chain)
• Metallurgical operations: Norway (Sauda, Porsgrunn), France (Dunkirk), United States (Marietta)
• Internal logistics: rail transport and port operations

Net zero / carbon neutral target year

2035: Reducing absolute scopes 1 and 2 CO₂ emissions by 40% compared to 2019 baseline (3.65 Mt CO₂)

2050: The Group has set itself the goal of contributing to global carbon neutrality by 2050 through its direct action, and through the metals that the Group supplies to the energy transition industry.

Baseline and interim milestones

Baseline (2019): 3,650.5 kt CO₂e (scopes 1 & 2)

2024 results: 2,641.4 kt CO₂e (scopes 1 & 2), representing a -28% reduction from baseline

• 71% of the decrease explained by changes in activity and production
• 29% explained by decarbonisation actions (mainly energy efficiency and improved electricity emission factors)

2030 intermediate milestone: Continued progressive implementation of decarbonisation levers

2035 target: 40% absolute reduction in scopes 1 & 2 emissions vs. 2019

Paris alignment / SBTi status

SBTi validation: The 2035 targets (scopes 1 and 2) and 2025 targets (scope 3) were validated as "Target set" by the Science-Based Target initiative (SBTi) in September 2021, aligned with a "well below 2°C" trajectory.

Eramet is engaged in a process compatible with the goals of the Paris Agreement. In the absence of a 1.5°C sectoral trajectory applicable to the Group's activities, Eramet launched a study at the end of 2024, still ongoing, for a 1.5°C alignment. In 2026, the Group will propose a transition plan compatible with this 1.5°C trajectory.

Scope 3 commitments

2025 target: Get 67% of tier-one value chain partners to set their own emissions reduction targets compatible with the Paris Agreements

2024 result: 62.8% of suppliers and customers had made such a commitment (representing over 75% of the Group's total Scope 3)

This commitment covers a significant part of Eramet's scope 3 (more than 75% in 2024). It does not cover the reduction of Eramet's absolute scope 3 emissions.

Decarbonisation levers and pillars

Eramet is relying on four main decarbonisation levers:

1. Use of bio-reducers

Pyrometallurgical reduction processes traditionally use coke (coal derivative) as a reducing agent. Biogenic reducing agents are produced from renewable organic materials such as wood, agricultural residues or forestry waste. When heated in an oxygen-poor environment (pyrolysis), these materials are transformed into carbon-rich coal.

Key actions:

• Industrial trials successfully performed at Marietta (United States) and Comilog (Gabon) in 2024
• Studies on biomass sourcing and sustainable production criteria
• Target: around 200 kt of biogenic reducing agents by 2035
• 2026-2030: gradual roll-out of bio-reducing agents in metallurgical operations

2. CO₂ capture, use and storage (CCUS)

The Group is working on both carbon capture and utilisation (CCU) and carbon capture and storage (CCS) processes.

Key projects:

• LanzaTech partnership (Porsgrunn, Norway): Contract signed in 2024 for CCU plant. Eramet Norway will supply waste gas from its manganese alloy smelter to convert up to 30% of CO₂ into ethanol for use in fashion, personal care products, packaging and fuels
• Sauda, Norway: CCS pilot plant construction ongoing; capture trial campaign to start
• Feasibility studies: Industrial scale-up studies for CCS plant in Sauda

Timeline:

• 2026-2030: Complete construction and start CCS pilot in Sauda; continue feasibility studies for industrial scale-up
• 2031-2035: Start-up of CCS plants in Sauda and CCU plants in Porsgrunn if final investment decisions are made

These levers will mainly support the decarbonisation objective during the 2031-2035 phase.

3. Use of low-carbon energy sources

As of end-2024, 66% of electricity consumed by the Group was classified as low CO₂ emissions (hydroelectricity in Gabon and Norway, nuclear in France).

Key projects:

• Senegal (Diogo mining site): 20 MW hybrid solar power plant with 11 MW/11 MWh battery system, covering ~20% of energy needs, avoiding 25,000 t CO₂/year. Entry into service scheduled for 2025
• Exploration of renewable electricity sourcing in the United States
• Continued decarbonisation of electricity grids

Timeline:

• 2025: Start construction of Eramet Grande Côte solar power plant in Senegal; continue work on renewable electricity supply in Marietta
• 2031-2035: Commission new carbon-free or low-carbon electricity generation capacity at mining sites

4. Energy efficiency and electrification

Energy efficiency has been improved through:

• Energy monitoring systems at Comilog (Gabon)
• ISO 50001 certification of all mining and industrial sites
• Pyrometallurgical furnace relining (Marietta 2023, Dunkirk 2024)
• Replacement of historic SLN plant by new CAT (Temporary Docked Plant), reducing emissions by 50 kt CO₂/year

Future actions:

• Finalize installation and commissioning of energy recovery units in Sauda (2025)
• Development of electrification of vehicle fleets and machinery on mining sites
• Partial electrification of truck fleets on mining sites

CapEx / investment commitments

In total, the Group estimates that the proposed actions could represent cumulative investments of around €480 million for Eramet until 2035, to which investments from third parties may be added.

The Group does not have reliable financial data at this stage on expenditure and investments to implement its decarbonisation strategy and is collecting and verifying data so it can publish this information in future reporting periods.

For 2025, Eramet estimates that the resources to be committed to decarbonisation could be in the order of €40 million (CapEx, OpEx, project development and R&D work).

EU-ETS costs: Eramet must purchase emission allowances to offset the difference between its actual emissions and the free allowances allocated to it under the EU Emissions Trading System.

Relative weight of decarbonisation levers (2019-2035)

The Group's transition plan shows the relative contribution of each lever. The use of bio-reducers and CCUS represent the largest contributions to achieving the 40% reduction target by 2035, followed by low-carbon electricity and energy efficiency measures.

Phasing and timeline

2019-2024 (Progress made):

• Inventory of scope 1 & 2 GHG emissions fell from 3.65 Mt CO₂ to 2.64 Mt CO₂ (-28%)
• 66% of electricity consumed classified as low CO₂ emissions
• Industrial trials of bio-reducers at Marietta and Comilog
• LanzaTech contract signed for CCU project
• Solar power plant project launched in Senegal

2025 (Short-term action plan):

• Bio-reducers: Continue testing and finalize sustainable biomass criteria
• CCUS: Prepare implementation of LanzaTech CCU unit; commence CCS feasibility studies
• Low-carbon electricity: Start construction of Senegal solar plant; work on renewable supply in Marietta
• Energy efficiency: Finalize energy recovery units in Sauda
• R&D: In-depth work on bio-reducers, CO₂ capture and breakthrough processes
• Total resources: ~€40 million

2026-2030 (Short- and medium-term):

• Bio-reducers: Gradual roll-out in metallurgical operations; target 50-70 kt/year by 2030
• CCUS: Complete CCS pilot in Sauda; start feasibility studies for industrial scale-up; commissioning of LanzaTech CCU plant in Porsgrunn
• Low-carbon electricity: Commission Senegal solar plant; secure renewable electricity supply contracts (e.g., Marietta)
• Energy efficiency: Continue optimization and electrification of mining equipment
• PT Weda Bay Nickel (value chain): Gradual increase in biocarbon use

2031-2035 (Medium- and long-term):

• Bio-reducers: Continue deployment with target of around 200 kt by 2035
• CCUS: Start-up of CCS plants in Sauda and CCU plants in Porsgrunn (subject to final investment decisions)
• Low-carbon electricity: Commission new carbon-free generation capacity at mining sites; continued grid decarbonisation
• Energy efficiency: Development of fleet electrification on mining sites

The plan assumes SLN will return to normal operational conditions over the 2026-30 period and includes the start-up of Eramine (lithium) in Argentina.

Locked-in emissions and stranded assets

The commitment to reduce emissions by 40% by 2035 includes locked-in emissions in existing assets (future emissions generated by their activity). The development of Eramet's activities to meet expectations of energy transition markets will lead to an increase in the Group's intrinsic emissions, which requires decarbonising well over 40% to reach the target in 2035.

The Group assesses consequences taking into account market dynamics, with particular attention paid to the evolution of the regulatory framework, including the Carbon Border Adjustment Mechanism (CBAM) in the European Union, and potential effects on market structure, import flows and competitiveness of European industry.

Use of carbon credits / removals

Eramet does not buy or sell carbon credits. The Group aims to contribute to carbon neutrality of the industry by 2050 through the metals its activity makes available to energy transition sectors. The Group's transition plan is based solely on decarbonisation actions, not carbon offsets.

Internal carbon pricing

Eramet has an internal carbon "shadow price" integrated into the investment decision process:

• €50/t CO₂ for current investments (equipment with expected life < 10 years)
• €100/t CO₂ for long-term investments (capacity increases, new activities, greenfield facilities, technological breakthrough projects)

When investments concern sites where taxation actually exists (European sites), the profitability analysis with internal carbon price is compared with full cost, including foreseeable cost of applicable carbon tax.

Exclusion criteria

The Eramet Group is not affected by any of the 7 exclusion criteria applicable to "Paris Agreement" benchmarks listed in Article 12 of Delegated Regulation 2020/1818 of the European Union.

Plan review and dependencies

Certain parts of this plan concern SLN's industrial strategy, and their implementation is not dependent on Eramet today. This transition plan will be reviewed in 2025 as part of the review of the Group's CO₂ strategy, including methods of integrating SLN into the plan.

The options being considered are likely to result in significant capital expenditure and/or additional operating costs. Eramet is attentive to the potential impact of these costs on competitiveness, assessing consequences taking market dynamics into account.

Technological challenges

The decarbonisation of metallurgical processes presents significant technological challenges. Carbon has been at the heart of metallurgical processes for thousands of years, removing oxygen from metal oxides to obtain the desired metal. Several decarbonisation methods used by steel producers are included in Eramet's Roadmap (biocarbon, CCUS), but not all processes can be transposed directly. For example, reduction with hydrogen is not directly applicable to manganese for physics reasons and technological maturity.

This specific 2050 goal will partly call for the use, in the medium to long term, of technologies that are yet to be developed. However, Eramet can leverage, for a significant part of this effort, the technological progress made in connection with decarbonisation actions under its current roadmap.

Research and Innovation

Within the framework of its decarbonisation roadmap, Eramet Ideas has initiated innovative projects:

• Substitution of fossil reducers by bio-reducers
• Carbon dioxide capture studies
• Carbon capture, use and storage projects (LanzaTech collaboration)
• Water Resource Innovation Challenge partnership with EITRawMaterials
• Direct Lithium Extraction (DLE) technology development (Centenario, Argentina) - 50% more efficient than conventional evaporation, 60% water recycling

Climate Policy objectives

Eramet's Climate Policy (published 2023) provides for:

• Contributing to collective fight against climate change in main countries of operation
• Strengthening energy efficiency approach
• Recovering and developing raw material recycling in circular economy
• Favouring low-carbon energy sources and industrial processes under economically acceptable conditions
• Promoting R&D projects to reduce direct/indirect emissions
• Assessing GHG impact of projects
• Taking climate change into account in Risk Management Policy
• Integrating climate change into Strategy parameters

Performance metrics

2026 target metrics and 2024 results:

Carbon intensity metrics:

Total emissions:

• 2024: 2,641.4 kt CO₂e (scopes 1 & 2); 14,388.0 kt CO₂e (scopes 1, 2 & 3)
• 2023: 2,980.4 kt CO₂e (scopes 1 & 2); 18,406.1 kt CO₂e (scopes 1, 2 & 3)

Policies related to climate change mitigation and adaptation

Eramet has established a comprehensive Climate Policy published in 2023 (available on www.eramet.com) to address both climate change mitigation and adaptation.

Climate Policy

Scope: The Climate Policy applies to:

• All Group companies and their employees
• Eramet's main activities, covering mining and metallurgical operations in all countries where it operates
• Upstream and downstream value chains, with a global approach to reducing greenhouse gas emissions (GHG) and improving energy efficiency
• All Group sites (translated into the nine languages of the countries in which the Group operates)

Governance and oversight:

• Managed by the Director of Strategy, Innovation and Business Development
• Supported by strategic committees which meet quarterly
• The Board of Directors relies on the recommendations of its Strategy Committee and CSR Committee
• The CSR Committee specifically analyses the Group's progress in carbon emission reduction
• The Executive Committee manages the action plan, with quarterly project reviews by a strategic decarbonisation committee
• The decarbonisation committee comprises: the Decarbonisation Department, the Environment Department, the Central Technical Office, and the Purchasing Department

Key content and principles:

The Climate Policy establishes Eramet's guidelines for conducting operations and developing strategy, with five key environmental objectives:

1. Strict compliance with laws and regulations applicable to its activities
2. Implementing effective environmental management systems across all plants and transport/supply chains
3. Taking environmental issues into consideration early when designing and developing industrial and mining projects, based on national regulations, Group policies and international standards
4. Supply of metals necessary to ensure the energy transition and development of activities contributing to a more efficient and circular economic model
5. Voluntary and continuous reduction of the Group's environmental footprint

Specific commitments include:

• Contributing to the collective dynamic of the fight against climate change in main operating countries
• Strengthening the approach to improving energy efficiency and adapting energy progress targets according to technological advances, R&D and Innovation
• Recovering and developing raw material recycling channels in a circular economy approach, including gas emissions
• Favouring, under economically acceptable conditions, energy sources and industrial processes with zero or low carbon content
• Promoting Research and Development projects aimed at reducing direct or indirect emissions from processes or emissions induced by product use
• Assessing the impact of projects in terms of greenhouse gas emissions
• Integrating climate risks into overall management of technological, economic and societal risks

Link to international standards:

• Eramet is committed to respecting the Paris Agreement by limiting global warming to +2°C compared to pre-industrial levels
• The Group follows the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)
• Eramet voluntarily completes the CDP questionnaire on climate change each year
• Targets validated by the Science Based Targets initiative (SBTi) in 2021
• The Group's climate commitments are monitored as part of two Sustainability Linked Bonds (SLBs) issued in May 2023 and May 2024

Public availability: The Climate Policy is published on www.eramet.com and translated into the languages of the countries where the Group operates to ensure accessibility.

Monitoring and implementation:

• The policy is validated by the Executive Committee
• Implementation relies on the commitment of the Group's Environment Department and employees
• Eramet conducts regular training sessions and awareness-raising actions for employees and interested stakeholders
• Eramet publicly reports on progress through annual non-financial reporting
• The Group uses several tools including: best available techniques, internal carbon pricing, energy certification through ISO 50001 standard
• Climate objectives are integrated into employee incentive schemes
• Performance monitored through quarterly strategic decarbonisation committee meetings

Related policies: The Climate Policy complements the Environmental Policy (updated 2023, available on www.eramet.com), which clarifies Eramet's commitments to biodiversity protection, water resources protection, air quality conservation, safe management of mining tailings and waste-rock, mine rehabilitation, circular economy, and optimum beneficiation of deposits.

Note on adaptation: Eramet does not currently have a dedicated policy specifically for adapting to climate change, but the Group has committed to establish action plans to mitigate physical risks related to climate change at the most exposed sites from 2025. The Climate Policy includes principles for adapting to the consequences of climate change as part of its overall framework.

Actions and resources in relation to climate change policies

Overview

Eramet has drawn up an action plan to achieve its 40% reduction target for emissions by 2035 (compared to 2019). The main projects are focused on pyrometallurgical activities, which represent a significant portion of the Group's emissions (scopes 1 & 2 are related to pyrometallurgical processing of manganese and nickel ore).

For mining activities (around 10% of the Group's greenhouse gas emissions), other decarbonisation initiatives are underway or being studied, notably the production of photovoltaic-generated electricity at sites in Senegal and Argentina.

Main Decarbonisation Actions

Scope: Own operations

1. Sourcing or production of low-carbon electricity

• Renewable energy procurement study for the Marietta site (United States)
• Production of electricity using exhaust gases from the production of Manganese alloys
• Photovoltaic electricity generation at sites in Senegal and Argentina
• Commissioning of the Eramet Grande Côte solar power plant in Senegal (2025 priority)
• Continuing investigations into additional deployment of lower carbon-intensive electricity capacities at other Group facilities
• Decarbonisation of electricity grids to which facilities are connected

2. Replacement of fossil-based carbon-reducers with biocarbons

• Replacement of fossil-based carbon-reducers with biocarbons from biomass for manganese alloys
• 2025 priority: Industrial tests of bioreducers to conduct first campaigns initiated in 2024, assessing the influence of different types of biocarbon products on kiln and facility operation
• 2031-2035 target: Continue deployment of biocarbon with a target of around 200 kt of biogenic reducing agents by 2035
• Various supply models being considered, from external supply to self-production (as in Gabon)

3. Carbon Capture, Use and Storage (CCU/CCS)

• Pilot capture unit being installed at the Sauda site (Norway)
• Partnership concluded for the use of gases at the Porsgrunn site
• 2025 priorities:
  • Finalization of studies, pending investment decision, and start of construction of the CCS plant in Sauda, Norway
  • Deployment of the first phases of the CCU unit in Porsgrunn, Norway
  • Complete construction of the CCS pilot plant in Sauda, and start capture trial campaign
  • Continuing feasibility studies for industrial scale-up of the CCS plant in Sauda
• 2031-2035: Start-up of CCS plants in Sauda, and CCU plants in Porsgrunn, Norway (if final investment decisions are made)

4. Energy efficiency measures

• Production of electricity using exhaust gases from production of manganese alloys
• Electrification of vehicle fleets and machinery on mining sites
• PT Weda Bay Nickel is continuing to purchase electric lorries and possesses a fleet of several hundred units by the end of 2024

5. Mining-specific initiatives

• Partial electrification of truck fleets on mining sites
• Photovoltaic electricity production at Senegal and Argentina sites
• 2026 target: Reducing the carbon footprint in extraction activities by 10% (2024 result: -2%)

Value Chain Engagement (Scope 3)

Scope: Upstream and downstream value chain

• Commitment: Get 67% of tier-one value chain partners to set their own emissions reduction targets compatible with the Paris Agreements by end of 2025 (covers >75% of Group's scope 3)
• 2024 result: 62.8% commitment rate among Group's partners
• Information and collaboration initiatives with customers and suppliers to encourage action within their own scopes
• 2025 target: 67% of suppliers and customers committed (validated by SBTi)
• 2026 target: Maintain 67% commitment rate

Time Horizons

Short-term (2025):

• Commissioning of solar power plants
• Industrial biocarbon tests
• CCS pilot construction and trials
• Continue energy efficiency initiatives

Medium-term (2026-2030):

• Developing and validating the transition to net-zero manganese alloys
• Gradual roll-out of bio-reducing agents in manganese alloy furnaces
• Deployment of CCS/CCU facilities
• Return of SLN to normal operational conditions
• Start-up of Eramine in Argentina

Long-term (2031-2035):

• Deployment of ~200 kt biogenic reducing agents
• Start-up of CCS plants in Sauda and CCU plants in Porsgrunn (pending investment decisions)
• Commissioning of new carbon-free or low-carbon electricity generation capacity at mining sites
• Continued electrification of vehicle fleets and machinery

Resources Allocated

Financial resources:

• Projects are incorporated into Eramet's long-term planning and taken into account when assessing pyrometallurgical assets, particularly through the inclusion in CapEx of an internal carbon price of €100 per tonne
• Note: The Group lacks sufficiently reliable financial data to precisely identify the OpEx and CapEx committed solely for decarbonisation actions in 2024. Eramet is working to improve the traceability of these financial commitments for future reporting periods
• Does not currently reconcile future expenses with the Taxonomy; only 2024 financial year expenses are assessed

Non-financial resources:

• Decarbonisation Department created in 2023 to actively manage climate risks and:
  • Manage portfolio of decarbonisation initiatives to speed up roll-out of initiatives with best cost/benefit ratio
  • Monitor competitive environment
  • Actively promote Eramet products with low CO₂ footprint in value chains
• Partnerships: Collaboration with peers, academics, and suppliers for development of new technologies
• Governance: Strategic decarbonisation committee formed of Decarbonisation Department, Environment Department, and Central Technical Office; reviews progress quarterly at Executive Committee level

Link to Policies and Targets

• Actions linked to Climate Policy (published 2023, available on www.eramet.com)
• Support 40% reduction target for scopes 1 and 2 by 2035 (validated by SBTi in 2021)
• Support 2050 ambition to contribute to global carbon neutrality
• Aligned with Act for Positive Mining roadmap (unveiled November 2023)
• Compatible with goals of the Paris Agreement
• Actions support 2026 targets: reduce emissions per tonne to 0.221 tCO₂/t Group-wide (0.159 tCO₂/t excluding SLN); 3% annual efficiency improvement

Expected Outcomes / KPIs

• 2024 performance: 0.267 tCO₂/t produced (0.185 excluding SLN) vs. 2026 target of 0.221 tCO₂/t (0.159 excluding SLN)
• Biocarbon tests: Industrial validation of transition to near-zero alloys
• CCS/CCU: Pilot capture campaigns to validate technology for scale-up
• Value chain commitment: Track percentage of partners with emissions reduction targets (62% in 2024, target 67% by 2025)

Targets related to climate change mitigation and adaptation

Scope 1 & 2 Emissions Reduction Target (2035)

Target metric: Absolute CO₂ emissions (scopes 1 and 2)

Target value: 40% reduction in absolute emissions

Baseline year: 2019

Target year: 2035

Scope: All assets under Eramet's operational control, including locked-in emissions

Type: Absolute reduction target

Validation: Science-Based Target initiative (SBTi) validated as "Target set" in September 2021, aligned with "well-below 2°C" scenario

Progress to date: Not explicitly disclosed for the 2035 target in absolute terms

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Scope 3 Value Chain Engagement Target (2025)

Target metric: Percentage of tier-one value chain partners setting their own emissions reduction targets compatible with Paris Agreement

Target value: 67% of tier-one partners committed

Baseline year: Not specified

Target year: 2025

Scope: Covers more than 75% of Eramet's scope 3 emissions in 2024; particularly focused on customers (who represent >70% of scope 3)

Type: Engagement target (not absolute reduction)

Validation: SBTi validated as "Target set" in September 2021

2024 Progress: 62% of suppliers and customers committed (125% performance level vs. intermediate target)

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Act for Positive Mining Roadmap Targets (2026)

Carbon Intensity Target – Group Level

Target metric: CO₂ emissions per metric tonne produced (scopes 1 & 2)

Target value: 0.221 tCO₂/t (0.159 tCO₂/t excluding SLN)

Baseline year: 2023 (implied)

Target year: 2026

Type: Intensity-based target

2024 Progress: 0.267 tCO₂/t (0.185 excluding SLN); 0% performance level

Annual Efficiency Improvement Target

Target metric: Year-on-year efficiency improvement (excluding SLN)

Target value: 3% annual improvement

Target year: Ongoing through 2026

Type: Intensity-based annual improvement

2024 Progress: 0% efficiency improvement vs. 2023; N/A performance

Metallurgy Decarbonisation

Target metric: Develop and validate pathway to Near Zero Alloys (manganese)

Target year: 2026

Scope: Metallurgy operations (>80% of scopes 1 & 2)

Type: Qualitative development target

2024 Progress: Tests carried out; 100% performance level

Mining Carbon Footprint Reduction

Target metric: Carbon footprint reduction in extraction activities

Target value: 10% reduction

Baseline year: 2022 (implied from "by 2026 compared to 2022")

Target year: 2026

Type: Intensity-based reduction

2024 Progress: -2% reduction achieved; 80% performance level

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Long-term Ambition (2050)

Target metric: Contribute to global carbon neutrality

Target year: 2050

Scope: Direct action and through metals supplied to energy transition industry

Type: Qualitative ambition; depends on yet-to-be-developed technologies

Validation: Set in line with SBTi long-term target validation criteria

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Science-Based Target Alignment Study (Ongoing)

Note: The Group launched a study at the end of 2024, still ongoing, for 1.5°C alignment. At the time of SBTi validation (September 2021), the SBTi criteria did not require Eramet to set a target for the 2030 time horizon.

Energy consumption and mix

Methodology and scope

Eramet measures energy consumption monthly across all operational sites. The main energy categories are:

• Mining activity: Fuel for extraction and transport
• Pyrometallurgy activity: Electricity for furnaces, chemical energy for reactions, heat for drying materials

Energy consumption is measured using operational control approach, consolidating 100% of subsidiaries under Eramet's operational control. Energy flows are multiplied by standardized emission factors from recognized sources (Ademe, EPA, RTE, supplier measurements). The consolidation excludes energy content of reducers used in chemical reactions (coal and coke for reduction purposes).

Energy consumption by source (2024 vs 2023)

Energy mix shares

Electricity consumption

Note: 68% of electricity consumed in 2024 came from low-carbon sources (renewable and nuclear energy) when considering the specific nature of the average electricity mix of the grids to which Eramet's sites are connected (almost exclusively hydroelectricity in Gabon and Norway).

Energy intensity

Key variances explained

• Fossil fuels (↓19.8%): Reduction driven by suspension of mining activities in Gabon (Q4) and inactivity of New Caledonia mines for a significant part of the year. Senegal production increase offset by improved efficiency of the temporarily docked power plant in New Caledonia.
• Nuclear energy (↓45.0%): Dunkirk plant (France) completely shut down in 2024 for furnace replacement.
• Renewable energy (↓25.4%): Shutdown of one of two furnaces at Moanda Metallurgical Complex in September and reduced activity at Doniambo plant (New Caledonia).
• Natural gas and fossil-based electricity (↑4.5% and ↑6.0%): Marietta plant (United States) fully restarted production capacity after long maintenance shutdown in 2023.

Weda Bay Nickel (Indonesia) – minority interest

PT Weda Bay Nickel activity (proportionally consolidated in Scope 3 Category 15):

Note: This information is provided on a voluntary basis and is declarative by Eramet's partner.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 and 2 emissions performance (2019–2024)

Eramet reports its Scope 1 and 2 GHG emissions with and without SLN (Le Nickel-SLN in New Caledonia). The table below reproduces the reported figures:

Note on methodology and scope:

• The Group's greenhouse gas emissions (Scopes 1 & 2) are stated as ~90% related to pyrometallurgical processing of manganese and nickel ore, with ~10% from mining activities.
• Eramet has set a 40% reduction target for emissions by 2035, when compared to 2019 (baseline year). The reported intensity metric for 2024 is 0.267 tCO₂/t (0.185 tCO₂/t excluding SLN), targeting 0.221 tCO₂/t by 2035.
• SLN's carbon footprint is reported separately given the entity's operational and financial isolation (see CSR Roadmap table, objective 7).
• The report notes that around 68% of electricity consumed in 2024 came from low-carbon sources (renewable and nuclear energy).
• A -10% reduction in Scopes 1 and 2 CO₂ emissions was achieved between 2023 and 2024, with the 2024 carbon footprint stated as 2.6 MtCO₂eq (all activities) and 2.2 MtCO₂eq (excluding SLN).

Scope 1 sub-breakdown:
The report does not provide a detailed breakdown of Scope 1 emissions by category (stationary combustion, mobile combustion, process emissions, fugitive emissions).

Scope 2 emissions – location-based vs market-based

The report does not explicitly disclose separate location-based and market-based Scope 2 figures.

Scope 3 emissions

The report does not disclose detailed Scope 3 emissions by GHG Protocol category (categories 1–15). The CSR Roadmap (objective 7) mentions a commitment to have 67% of suppliers and customers commit to reducing their CO₂ footprint in accordance with the Paris Agreement (62% achieved by 2024), but no quantitative Scope 3 inventory is provided.

Total GHG emissions and intensity

No per-revenue intensity metric (e.g. tCO₂eq/M€) is disclosed.

Biogenic CO₂ emissions

The report does not separately disclose biogenic CO₂ emissions.

Regulated emissions (EU ETS)

The report does not separately disclose regulated emissions under the EU ETS or similar schemes.

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Methodology and scope notes:

• The Group states that its emissions are calculated based on production volumes and energy consumption data.
• The 2035 target of 0.221 tCO₂/t is based on an internal carbon price of €100 per tonne incorporated into CapEx planning.
• Climate risk analysis was conducted by AXA Climate in 2024, using SSP2-4.5 and SSP5-8.5 scenarios for 2030 and 2050 time horizons, assessing 25 strategic sites. This analysis is used for adaptation planning, not emissions accounting.
• The Group applies IAS 29 for hyperinflationary economies (Argentina) and changed functional currency for Argentine entities to USD in 2024, discontinuing IAS 29 treatment for Eramine.

Data completeness:
Eramet discloses Scope 1+2 emissions in aggregate and by operational perimeter (with/without SLN), with intensity metrics and a 2035 target. Scope 3 emissions are not quantified by category. Biogenic emissions, location-based Scope 2, and regulated emissions (EU ETS) are not separately reported.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Use of phase-in exemption

Eramet indicates in its materiality assessment table that E1-9 is subject to ongoing analysis. The company states:

• "Expected financial impacts of transition risks and significant physical risks and potential opportunities related to climate change (E1-9)" - Quantitative & qualitative - Analysis ongoing

This indicates the company is using the phase-in approach allowed for the first years of CSRD reporting.

Physical risks

Eramet updated its exposure to physical risks of climate change in 2024, drawing on AXA Climate's expertise.

Methodology

The analysis is based on:

• Two climate scenarios: SSP2-4.5 (moderate warming) and SSP5-8.5 (extreme warming), focusing on the most pessimistic scenario to anticipate extreme weather events
• Three time horizons: baseline (1985-2014), 2030, and 2050, relevant for budget planning and strategic investment decisions
• 25 strategic sites assessed, integrating geographic specificities and local vulnerabilities
• Climate models: CMIP5, CMIP6 and specialized tools (Aqueduct, Fathom, GEM) to quantify exposure to:
  • Chronic hazards: thermal stress, rainfall variability, sea level rise
  • Acute hazards: cyclones, storms, fires, floods, heat waves, landslides

Identified physical risks

For the time horizons and scenarios selected, the most significant changes in terms of climate hazards and infrastructure risks concern:

Forest fires:

• Gabon, Moanda plant: frequency and/or intensity increasing over time (2030, 2050)
• United States, Marietta industrial complex: frequency and/or intensity expected to increase over time (2030, 2050)

Operating losses from changing climatic conditions:

Extreme heat waves in:

• Indonesia
• Mining plateaus of Moanda in Gabon
• Senegal
• New Caledonia (mining site and plant)

With intensification of hazards over time (2030, 2050) and the pessimism of the scenario (SSP2-4.5, SSP5-8.5).

Drought:

• Senegal, with an expected increase in frequency of these episodes

Heavy precipitation:

• Indonesia with an increase in frequency expected for most of the intensities assessed

Financial effects of physical risks

The magnitude of the anticipated financial effects related to these risks is in the process of being analysed.

Transition risks

Internal carbon pricing

Eramet has implemented an internal carbon price mechanism. The company states that work is ongoing to:

• Measure the impact of the internal carbon price mechanism on Eramet's commitments and emissions
• Ensure traceability of positive impacts associated with using the internal carbon price in the company's investment application processes

This work is ongoing and Eramet will be able to propose this analysis in the next sustainability report.

Note: The internal price is used in investment profitability analyses and R&D studies, but is not applied as an expense to the sites making the investment.

Technological challenges of decarbonisation

The company notes that the industrial and technical challenges faced by the manganese or nickel industry are similar to those faced by the steel industry, as emissions are directly linked to the reduction process.

Climate-related opportunities

No quantified financial effects from climate-related opportunities are disclosed in the extracted sections.

Reconciliation with financial statements

Eramet states in its materiality table:

"The reconciliation of the economic valuations of climate risks and actions with the financial statements and the Green Taxonomy (E1-9)" - Quantitative & qualitative - Analysis ongoing

Future expenses and Taxonomy alignment

Eramet does not reconcile future expenses with the Taxonomy, only those associated with the 2024 financial year, which are not published for decarbonisation actions.

The actions implemented in 2024 and planned for 2025 to decarbonise the Group's activities and mitigate climate change are detailed in chapter 5.3.2.2 "Transition plan for climate change mitigation [E1 1]".

Policies related to pollution

Environmental Policy

Eramet's Environmental Policy (reviewed in 2023, available on www.eramet.com) addresses pollution prevention and control as part of its broader environmental commitments.

Scope:

• All Group sites and employees
• All mining sites and projects
• All industrial and mining sites

Governance:

• The policy is validated by the Executive Committee
• Implementation is overseen by the Environment Department
• Monitored by the CSR Steering Committee (which meets three times a year)
• The Executive Committee receives regular updates on environmental performance
• The Board of Directors' CSR and Strategy Committee reviews CSR aspects at each meeting

Key commitments and content:

Air quality:

• "Reduce the environmental impacts of its activities, in particular by reducing its atmospheric emissions, focusing on the most significant sources of impact with a view to engaging with neighbouring communities"
• Since 2013, Eramet has factored emission reduction into its environmental policy commitments
• Between 2018 and 2023, the Group reduced its channeled dust emissions by 77%
• Installation of purification systems including electrostatic precipitators, baghouse dust collectors, scrubbers, washing towers, activated carbon filters and demisters

Water pollution:

• Commitment to reducing the impact of activities on water resources and aquatic environments
• Continuous improvement in monitoring of water footprint (abstraction, uses, discharges)
• Optimisation of process water consumption and increased recycling
• Continuous improvement of rainwater management and wastewater treatment methods
• Prohibition of discharging mining waste ("deep-sea tailings placement") into the sea - this method is neither used at Group sites nor considered during development projects
• Prevention actions: installation of upstream double-walled retention and storage systems, effluent treatment plants using physicochemical processes and hydrocarbon separators
• Monitoring actions: all sites have measures to monitor impact on natural environments through piezometer networks (around one hundred installed) and surface water quality measurements

Public availability:

• Available on www.eramet.com under "Charter and policies – Eramet"

Links to international standards:

• Aligned with ISO 14001 certification (all industrial and mining sites undergo external audits)
• Water reporting procedures aligned with international standards, industry best practices and ICMM (International Council on Mining and Metals) recommendations
• CDP Water security questionnaire (awarded B rating in 2024)
• Air emissions standards aligned with best practices

Monitoring implementation:

• Robust ISO 14001 certified management system at each mining site
• Specific human and financial resources allocated
• Internal policy and standards including:
  • "Environmental Management" Key Standard (mandatory for all sites)
  • Water Management Standard (mandatory for all sites)
  • Internal thematic standards on atmospheric emissions management ("Standard Air")
  • Standards on hazardous materials management and water management
• Dedicated Environment IT system rolled out to all industrial and mining sites for collecting and consolidating environmental performance indicators
• Monthly monitoring of KPIs through Group reporting tool
• Roadmap reviewed during Quarterly Business Reviews and by CSR Steering Committee
• Incident notification and follow-up: significant pollution events reported within 24 hours using special reporting tool; sites must carry out investigation within two weeks
• Internal and external environmental audits covering all environmental issues
• Special environmental task force for airborne emissions to identify and share best practices
• Groups of experts responsible for mines and plants to identify and disseminate best practices in water management
• In 2023, nearly €20 million was invested in environmental improvements, mainly concerning prevention of water pollution at mining sites and rehabilitation work

Act for Positive Mining Roadmap (2024-2026)

The Group's Act for Positive Mining roadmap incorporates pollution prevention objectives:

Water pollution targets:

• Reduction of water footprint at sites most at risk: 60% water recycling for GCO (Senegal) and 80% for the lithium project in Argentina
• 100% of sites must have:
  • A water management plan incorporating water balance, identification of priorities, setting of improvement targets and preparation of action plans
  • Comprehensive monitoring of water discharges

Air pollution targets:

• A plan for managing and monitoring major diffuse emissions at all sites
• Monitoring relevant ambient air quality indicators for sites near inhabited areas

Scope:

• All Group sites
• Policy applies to direct activities (scope 1); does not include upstream and downstream activities in value chain

Governance:

• Progress monitored by the Executive Committee via feedback from roadmap managers
• CSR Steering Committee meets three times a year to review progress
• 26 targets across roadmap objectives

Emergency and Incident Management Policy

All Group industrial sites have emergency response procedures as part of their ISO 14001 certified environmental management system.

Key content:

• Each site identifies emergencies specific to its activities through environmental management system and environmental impact studies
• Emergency plans describe alert protocols, responsibilities, and measures to stop pollution sources or contain pollution
• Emergency plan format varies according to country-specific standards
• Plans describe scenarios of serious accidents/phenomena impacting industrial sites that could affect population and environment

Monitoring:

• Each site required to report all environmental incidents
• Events recorded on common Group reporting tool
• Events graded according to risk scale
• Events with impacts beyond site forwarded to head office within required timeframe

Supporting Standards and Guidelines

The Environmental Policy is supplemented by:

• Key Standard "Environmental Management" (mandatory for all Group employees at all controlled sites)
• Water Management Standard (mandatory for all sites)
• Standard Air (atmospheric emissions management, applicable to all Eramet sites)
• Water Management Plan Template
• Standards on hazardous materials management

These standards are:

• Aligned with IFC (International Finance Corporation) and IRMA (Initiative for Responsible Mining Assurance) standards
• Incorporate future European regulations (notably CSRD)
• Based on work of communities of experts and ICG (International Competence Groups)
• Integrated into the Eramet Management System and Eramet Production System (EPS)

Alignment with international frameworks:

• ISO 14001 certification mandatory
• ICMM (International Council on Mining and Metals) guidelines
• IFC Performance Standards
• IRMA standard requirements
• CDP Water Security questionnaire reporting
• Future CSRD requirements

Actions and resources related to pollution

Eramet applies a sequenced approach to pollution risks that aims to avoid, reduce, or even restore, where necessary, the affected sites.

This approach is based on the common components of Eramet's environmental management system, which includes:

• A dedicated organisation
• An internal policy and standards
• Reporting, controls and audits

The approach applies the mitigation sequence, which primarily targets avoidance, then mitigation and finally rehabilitation or offset actions.

Action area: Chemicals management

Eramet has implemented a rigorous approach to reduce risks, protect human health and preserve the environment. This approach is based on:

• Analysis of products used, ensuring a detailed understanding
• Proactive integration of regulatory requirements in terms of monitoring occupational exposures and assessing chemical risks, transforming them into a continuous improvement approach
• Life cycle analysis of products to improve understanding and limit the environmental and health impacts related to their transformation and end use
• Commitment to replacing substances of very high concern (SVHC) with less hazardous alternatives, while maintaining a high level of industrial performance and safety

Scope: Own operations (chemicals used in industrial processes, not in mining operations)

Action area: Airborne emissions

The Group has implemented atmospheric effluent treatment systems at sites to control dust and metal emissions. These include:

• Electrostatic precipitators
• Baghouse dust collectors
• Scrubbers and washing towers
• Specific treatment systems (activated carbon filters, demisters)

Best available techniques are implemented whenever possible, particularly for European sites where techniques associated with non-ferrous metal production are systematically implemented.

"Standard Air" (2023): Strengthened requirements for all Group sites, including:

• Management of channelled emissions
• Management of fugitive emissions
• Monitoring of ambient air quality for all sites near local residents

Scope: Own operations (pyrometallurgical activities and energy production plants)

Monitoring and results

Results of actions are monitored through:

• Systematic follow-up of key parameters specific to each activity
• Annual consolidation of key indicators
• Analysis and action plans if discrepancies are recorded
• Review at operational team and Executive Committee level

Resources allocated

Note: The document explicitly states: "The details of the financial resources allocated to each action are not available for 2024."

Targets related to pollution

Eramet undertakes to comply with the discharge thresholds prescribed by local regulations or environmental permits on all its sites.

In addition to these regulatory requirements, the Group imposes monitoring and reporting of airborne and water emissions for all its sites. Internal targets are set for different parameters (e.g. dust emissions).

Eramet has strengthened its commitments to environmental protection in its roadmap for 2024-2026 "Act for Positive Mining" by focusing on airborne atmospheric emissions and water discharges. To date, no targets have been published for SoCs and SVHCs.

Airborne emissions targets

Water discharges targets

Note: 2024 was described as a pivotal year for consolidating these targets, by improving knowledge of the sources and the monitoring requirements to be implemented.

Pollution of air, water and soil

Identification of pollutants

For more than three years, as part of its non-financial reporting, the Group has identified key pollutants that it considers are relevant to report in order to illustrate the impact of the activities associated with air and/or water pollution. The CSRD directive extends the list by referring to Regulation (EC) no. 166/2006 of the European Parliament and of the Council (European pollutant release and transfer register, the "E-PRTR regulation").

Pollutants monitored by the Group:

Reporting methodology

Except in specific cases detailed below, all emissions are quantified on the basis of the direct measurement of discharges carried out, at least, in accordance with the requirements applicable to each site. From these direct measurements, the quantities of pollutant emissions are consolidated by each site, then at Group level.

Between 2018 and 2023, Eramet reduced its channelled dust emissions by 77%.

Specific cases of quantification:

• Sulphur dioxide (SO2): SLN plant, SLN's temporary docked power plant (CAT) and Manganese Alloys sites in Norway quantify their SO2 emissions by material balance. In 2024, the CO2 quantification methodology was applied to SO2 at Norwegian Manganese Alloys sites (uncertainty of 0.55% for Sauda and Porsgrunn). For SLN sites, accuracy is 5.4% for the CAT and 25% for the plant.
• Nitrogen oxides (NOx): Sauda and Porsgrunn plants use an emission factor to calculate nitrogen oxide emissions related to flaring of process gases (EPA emission factor).

Total Group emissions

The consolidated pollutant emissions cover all Eramet sites concerned, where or not the E-PRTR reporting thresholds are exceeded.

Air Pollution - Airborne emissions:

*Pollutants which are reported over and above CSRD requirements, and considered relevant to be recorded because of the Group's activities

Additional airborne emissions (2024 only):

Water Pollution - Water discharges:

*Pollutants which are reported over and above CSRD requirements, and considered relevant to be recorded because of the Group's activities

Additional water discharges (2024 only):

Note: Total cyanides are reported annually by sites without an emission threshold. Free cyanides are regulated and make it possible to differentiate the bioavailable and toxic forms (free CNs) from less bioavailable forms (complexed CNs). The total amount of free cyanide emitted in 2024 by the 3 Norwegian sites amounted to 446 kg. All sites comply with the prescribed discharge limit.

2024 Results Analysis:

• Sulphur oxides (SO2): Significant reduction (-16%) linked to reduced activity in New Caledonia due to geopolitical context
• Nitrogen oxide (NOx): Slight increase (+4%) despite reduced activity; CAT emissions increased by 24% due to process optimization
• Dust and manganese emissions: Increase (dust +17%; manganese +10%) linked to malfunctions at CIM agglomeration line and CMM metallurgical plant in Gabon
• Nickel emissions: Increase linked to higher concentration measured on Caledonian power plant emissions
• Suspended solids and Nickel (water): Reduction proportional to decreased production at Doniambo plant
• Manganese (water): Increase due to extension of reporting scope (runoff discharges on Norwegian sites and Marietta site, leachate treatment plants)

Emissions to soil

No direct emissions to soil are quantified in the reporting. The Group exercises vigilance against potential impacts on soils and subsoils through investigation, monitoring and management of potentially impacted soils, rehabilitation of industrial land, decommissioning of landfills, and management of former mines.

None of the mines currently operated use hazardous substances for extraction activities or ore concentration, and deposits mined do not contain polluting or hazardous substances (except sometimes in trace amounts). Risks of soil pollution are therefore limited on mining sites.

Substances of concern and substances of very high concern

Approach and Methodology

Eramet has undertaken an initial mapping of raw materials and products used in its industrial processes, as part of its commitment to responsible management of the value chain and in compliance with the CSRD directive and ESRS standards. This approach focuses primarily on substances of concern (SoC) and substances of very high concern (SVHC), identified according to European regulatory frameworks.

The company, mindful of changing regulatory expectations and best practices in non-financial reporting, intends to expand this mapping in the coming years. The objective is to gradually expand its scope, in particular by integrating products outside the core business that could be used in secondary applications.

Substances of Concern (SoC)

A substance of concern (SoC) refers to any substance that may have negative effects on human health or the environment, and listed in Annex VI of the CLP Regulation. Appendix II of the ESRS, and more specifically Table 2, defines a substance as any chemical element and its compounds.

From a regulatory point of view, Eramet's finished products contain Nickel (Ni), which meets the criteria for a substance of concern (SoC). However, the Nickel ore present in the Group's operations is not a substance of concern as such, as it is a raw material integrated in a mineral matrix and not in an isolated chemical form. During the extraction phase, the Nickel ore has a low Nickel content (approximately 1%). Then, during the production phase, part of the ore is transformed into Ferro-Nickel (FeNi), used in various industrial applications. Another part of the ore is sold directly to customers in raw form, without further processing.

Nickel is a strategic metal with a wide range of industrial applications, including:

• Batteries and energy transition: A key element in Lithium-ion batteries used in electric vehicles and renewable energy storage. Demand for it is growing strongly with the global energy transition
• Stainless steel: Strengthens resistance to corrosion, essential for construction, infrastructure and automotive industries

As part of the CSRD requirements, Eramet assessed the amount of Nickel contained in ferroalloys and particularly in Ferro-Nickel (FeNi).

Nickel in Ferro-Nickel (SoC) - Quantitative Data

The data for the total quantities of Nickel that leave the Company's facilities in the form of discharge emissions are indicated in the previous section chapter on air and water pollution.

Substances of Very High Concern (SVHC)

Coal Tar Pitch is an essential component of electrodes used in silico-manganese, ferro-manganese and ferro-nickel production furnaces. When used in furnaces, Coal Tar Pitch breaks down, releasing hazardous substances, in particular Polycyclic Aromatic Hydrocarbons (PAHs), in industrial fumes.

Coal Tar Pitch (SVHC) - Quantitative Data

Management and Mitigation Measures

Coal Tar Pitch Management

Eramet is actively working on the continuous improvement of its filtration systems to minimize potential discharges, in particular by:

• Implementing strict measures to limit emissions related to the use of Coal Tar Pitch through advanced filtration systems that capture the emissions generated by the Group's furnaces
• Safely processing and storing dust from filtering to minimize any environmental impact

Aware of the challenges related to the use of Coal Tar Pitch, Eramet is also actively exploring more sustainable alternatives. Tests to replace Coal Tar Pitch-based electrodes with alternatives without this substance have begun in Norway. In 2024, 12% of our electrodes used are Coal Tar Pitch free.

Chemical Management Approach

Consistent with its commitments in terms of environmental and social responsibility, Eramet is committed to replacing substances of very high concern (SVHC) with less hazardous alternatives, while maintaining a high level of industrial performance and safety.

The Group's approach to chemical substances is based on:

• An analysis of the products used, ensuring a detailed understanding
• The proactive integration of regulatory requirements in terms of monitoring occupational exposures and assessing chemical risks, transforming them into a continuous improvement approach
• A life cycle analysis of products to improve understanding and limit the environmental and health impacts related to their transformation and end use

Data Limitations

Eramet acknowledges methodological limitations for substances of very high concern in its first-time ESRS application. The percentage of net turnover generated by products and services that are or contain substances of concern is compulsory for the 2027 reporting and is not yet disclosed.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Financial effects from pollution-related impacts

With regard to deposits, the sites concerned manage their operating and capital expenditure autonomously through their own budgets. Although the extraction of specific data is currently complex, a query will soon be established to enable an efficient consolidation at Group level.

Regarding major incidents, while internal reporting enables incidents to be monitored with a risk/impact matrix for their prioritization, this does not only target pollution and does not currently make it possible to identify operating and investment expenses incurred in connection with these incidents. However, the application will soon be implemented to allow consolidation at Group level.

Environmental provisions

Environmental provisions are included in the financial statements (see note 14 in chapter 2 Individual and consolidated financial statements).

Phase-in exemption

As indicated in the ESRS disclosure requirements table, Eramet applies the phase-in exemption for E2-6, with the following notation:

Policies related to water and marine resources

Eramet addresses water and marine resources through its broader Environmental Policy and supporting internal standards, rather than a standalone water-specific policy.

Environmental Policy (water-related commitments)

Scope:

• Direct activities (own operations)
• All industrial and mining sites
• Does not include upstream and downstream value chain activities

Key content and principles:

• Preserve quality water resources accessible to all
• Control and optimize water consumption
• Minimize impacts on water resources and water and marine environments
• Continuous improvement of monitoring activities aligned with ICMM recommendations
• Optimize process water consumption and increase recycling
• Continuous improvement of rainwater management and wastewater treatment
• Monitor discharge quality on all industrial sites (progressively deployed on mining sites)
• Monitor temperature of discharges for sites connected with sea discharges
• Implement reduction action plans on sensitive sites (large consumers, sites in high water stress or arid areas)

Governance:

• Environment Department responsible for the policy
• Supported by the Group's Technical Department

Implementation and monitoring:

• Monitoring and reporting aligned with ICMM guide recommendations
• Data collection on volumes abstracted, discharged, recirculated and stored
• Quality of discharges monitored against emission limit values and environmental permit conditions
• Environment Department monitors substance dangerousness with technical and scientific support from professional associations for Manganese, Nickel and Lithium

Supporting standards:

• Key Standard environment: Internal mandatory document for all sites
• Standard dedicated to water management (produced 2024)
• Water Management Plan Template (produced 2024)

Site-specific plans:

• Water intensity reduction plans for sites in water-sensitive areas: GCO (Senegal) and Eramine (Argentina)
• Targets set in "Act for Positive Mining" roadmap

Voluntary commitments:

Position against deep-sea mining:

• Announced July 2024
• Covers exploration and mining of seabed
• Ban on depositing mining residues in the sea (deep-sea tailings placement)
• Included in voluntary commitments

Public availability:

• Elements relating to policy, roadmap and results accessible on company website
• Information disclosed via Carbon Disclosure Program (CDP)
• CDP Water Security questionnaire responses (2024: B rating)
• Water-related information transmitted to stakeholders including communities at site level through dialogue mechanisms in accordance with IRMA standard

Link to standards:

• Aligned with ICMM (International Council on Mining and Metals) recommendations
• IRMA standard compliance for stakeholder engagement

Actions and resources related to water

Three-year action plan (2024-2026)

Eramet has undertaken a three-year action plan, from 2024 to 2026 inclusive, to meet the water targets of the "Act for Positive Mining" roadmap.

Scope: Scope 1: All sites and projects

Actions by year:

Training and technical support (2024)

• Environment Department training: Trained the entire environmental network on new reporting indicators, formalization of water balances and water management plans in a workshop
• External technical expertise mobilized to:
  • Review and amend the Group Guidelines and Template
  • Work specifically with the Gabon mining site and Senegal mining site, which are subject to high water stress in their water management plan

Innovation initiatives

International innovation competition (2023-2024)

• Launched in association with EIT RawMaterials to accelerate change in mining and metallurgical industry
• Objective: Reduce water abstraction, limit impact on aquatic environments, develop resilience to extreme weather events
• Winner (March 2024): Weeefiner, a Finnish company specializing in water treatment and metal recovery
• Pilot project: In progress at Porsgrunn plant in Norway (produces silicomanganese and ferromanganese) working on filtration of nickel in wastewater
• If results confirmed, solution can be rolled out to other Group sites

Eramet Ideas water roadmap

Led by Eramet's Research and Development Centre in coordination with Technical Department, Environment Department, sites and projects. Focus areas:

• Development of innovative processes to reduce the need for water
• Management of new technologies for filtration, effluent treatment and optimization of recycling loops
• Reinjection of brine into salars for the lithium industry
• Monitoring and modelling of hydrodynamic behaviour

Other initiatives:

• Eramet delegation present at Water Congress in Santiago de Chile (2024), 12th edition chaired by Chair of Eramet Ideas

Resources allocated

Details of the financial resources allocated to each action are not available for 2024.

Targets related to water

Eramet has disclosed two quantified targets related to water and marine resources, which are included in the "Act for Positive Mining" roadmap for the period 2024-2026.

Target 1: Water Recycling in Water-Stressed Areas

Target 2: Water Management Plans with Reduction Targets

Additional Commitments

The "Act for Positive Mining" roadmap also includes:

• Develop and implement formalised water management plans at all sites
• Achieve reduction targets for sites in Senegal and Argentina
• Report annually to CDP Water Security

Water consumption

Total water consumption

Group consumption (2024): 13.5 Mm³
Group consumption (2023): 12.2 Mm³

The Group's water consumption increased from 12.2 Mm³ in 2023 to 13.5 Mm³ in 2024, reflecting improved monitoring systems and data reliability efforts. An error was corrected in 2024 regarding 2023 discharge reporting (1.6 Mm³ wrongly declared), which corrected 2023 consumption from 10.6 Mm³ to 12.2 Mm³.

Water intensity

Water intensity (2024): 4,588.6 m³/€m
Water intensity (2023): 3,752.7 m³/€m

Water intensity increased by 22.3% due to improved monitoring systems and efforts to improve data reliability. Water intensity corresponds to total water consumption in m³ resulting from operations, expressed as turnover in millions of euros.

Water consumption in areas of water stress

Consumption in high water stress areas (2024): 0.9 Mm³
Consumption in high water stress areas (2023): 0.4 Mm³
Proportion of total Group consumption (2024): 7%
Proportion of total Group consumption (2023): 3%

The Senegal site (Eramet Grande Côte) was identified as presenting a high risk of water stress. The site's consumption of 0.9 Mm³ represents less than 3% of the Group's total consumption.

Water withdrawal by source

Abstractions by sites overwhelmingly concern seawater (81.9% of total), with surface waters representing approximately 13.7% and groundwater less than 3.9%. Freshwater abstraction (excluding seawater) totaled 53.0 Mm³ in 2024, compared to 52.4 Mm³ in 2023 and 50.6 Mm³ in 2022.

Breakdown by water quality:

Water withdrawal in water-stressed areas

Water discharge

Total discharge (2024): 278.8 Mm³
Total discharge (2023): 293.8 Mm³

The discharged volumes are published for the second time this year. Work is continuing to complete and make this data more reliable. The volume does not account for water discharged into mines which was not reported in 2024, implying higher consumption than the actual figure.

Breakdown by destination:

Breakdown by water quality:

Water discharge in water-stressed areas

Water recycled and reused

Group-level:

• Volume of recycled/reused water (2024): 94.4 Mm³
• Recycled/reused water rate (2024): 24%

Eramet Grande Côte (Senegal):

• Volume of recycled/reused water (2024): 11.4 Mm³
• Volume of recycled/reused water (2023): 6.2 Mm³
• Recycled/reused water rate (2024): 52%
• Recycled/reused water rate (2023): 41%
• Target for 2026: 60%

Eramine (Argentina - Lithium project):

• The project entered production in December 2024, so baseline data will not be available until end of 2025
• Target for 2026: 80%

The recycling/reuse rate corresponds to the volume of recirculated water divided by the sum of the volume of water abstracted and the volume of water recirculated. Water recirculation is a major driver of the reduction of the Group's water footprint.

Water storage

Total amount of water stored (2024): 3.5 Mm³
Total amount of water stored (2023): 3.5 Mm³
Changes in storage: 0.0 Mm³

Other managed waters

Volume (2024): 2.3 Mm³
Volume (2023): 1.5 Mm³

These other waters are actively managed (e.g., physically pumped or actively treated or abstracted for supply to local communities) but are not part of the sites' operations.

Scope and methodology

Reporting scope: All industrial sites (7) and mining sites (4) across the Group, covering manganese, nickel, mineral sands, and lithium activities. Main sites include Eramet Grande Côte (Senegal), SLN (New Caledonia), Centenario/Eramine (Argentina), Marietta (USA), and Comilog sites (Gabon).

Methodology: Active sites report their abstractions by source via the WeSustain internal portal, which allows consolidation at company level. The reporting frequency changed from half-yearly in 2023 to monthly in 2024. Water abstractions are monitored primarily by flow meters when there is a direct water intake, and by third party flow meters (with related invoice) when the water intake is managed by a third party. In other cases, they are calculated or estimated if none of the above options are available.

Water consumption is calculated by subtracting discharged water from abstracted water, in line with international standards and best practices in the mining and metals sector (ICMM standards). Quality of abstracted and discharged water is classified into two distinct categories based on their quality, defined in accordance with ICMM standards.

Data reliability improvements: The 2024 increase in consumption partly reflects ongoing work to improve the system following a 2023 mapping of water points and efforts to improve data reliability, particularly regarding discharged volumes. Some sites, particularly mines, have not yet been able to report on discharge metrics.

PT Weda Bay Nickel (value chain)

For PT Weda Bay Nickel's mining activities (part of Eramet's value chain), water withdrawals in 2024 totaled 600,000 m³ for mining activities. The water is mainly used for dust removal on mines and roads, and for domestic needs. The site has set up run-off water management with sedimentation basins, water diversion ridge, and buffer basins.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

Phase-in exemption applied

The CSRD rules allow for a phased compliance period of up to three years for certain disclosure requirements. The information relating to this chapter is only mandatory from the 2025 reporting period. Consequently, Eramet has opted for deferred publication in order to allow time to collect and validate this financial data.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Biodiversity in Corporate Strategy and Business Model

Eramet's goal is to upgrade all mining sites to the best international standards. This requires the deployment of scientifically robust approaches, methodologies and measurement tools that do not always exist at the international level. The strategy is defined in response to the impact, risk and dependency analyses carried out.

Priority is given to the Group's own activities, and more specifically to mining activities, which are the focus of biodiversity issues in the Group's value chain, based on the biodiversity footprint analysis performed in 2023.

Nevertheless, certain commitments have been extended to the PT Weda Bay Nickel mining site in Indonesia (a site which Eramet has a minority stake in - integrated into the value chain).

Biodiversity commitments and objectives were updated in 2024. They not only aim to promote responsible and sustainable management of operations, but also to align these efforts with the global objectives relating to the Earth's limits, thus ensuring a positive contribution to global environmental challenges.

New Voluntary Commitments

Eramet took the results of three assessments into account in order to adapt its biodiversity strategy and present new voluntary commitments in 2024.

The Group's commitments are broken down into a three-year action plan and are organised into five main categories:

• Governance: review of commitments and progress of the action plan three times a year by the CSR Committee, two members of which are from the Executive Committee; presentation of the results to the Executive Committee once a year; and involvement of the Group's managers in the implementation of the Act for Positive Mining roadmap, including objectives in the areas of land transformation, climate change, pollution, water, and the deployment of biodiversity action plans

• Strategy: contribution to the circular economy, alignment with international best practices in responsible mining and launch of a scientific partnership

• Action on the Group's impacts: prohibited areas and activities, preliminary studies, action plans for our mining operations at the heart of the action:

  • Create and document no take zones, with a ban on exploring and exploiting the seabed, World Heritage Sites, UNESCO Biosphere Reserves, and IUCN I-III protected and classified areas
  • Optimise and manage cleared areas
  • Gradually rehabilitate mining areas
  • Develop and implement biodiversity offsetting programmes

Alignment with International Standards

Work to upgrade biodiversity strategies and monitoring tools was launched at all the mining sites, with two biodiversity officers on each site and the support of specialized firms. The goal is to align with the IRMA standard and IFC performance standard No. 6, which notably means:

• Systematically involving stakeholders and local communities in the development of studies and action plans
• Qualifying habitats and assessing the presence of critical habitats with the support of local and international experts
• Identifying and mapping the services provided by nature (ecosystem services) in order to maintain them
• Quantifying the losses and gains in biodiversity (calculation method adapted to each site) and demonstrating no net loss, or even a net gain in biodiversity

Research and innovation tools and programmes (detection, monitoring, restoration, agroecology, etc.) are also being developed to improve the Group's expertise and mining practices with the help of scientific partners and internal teams, particularly those in charge of information systems, innovation and the Lékédi Biodiversity Foundation.

Independent Third-Party Review

The new commitments were submitted to the independent review of two organisations bringing together companies, academics and nature conservation organisations: Act4Nature International and Business for nature. Both organisations acknowledged the relevance of the commitments.

These organizations' methods are particularly demanding. They expect companies to demonstrate a structured approach at four levels:

1. Assessment: An in-depth assessment of impacts and dependencies on nature, involving a materiality analysis that allows prioritisation of actions and precise identification of the risks and opportunities related to biodiversity

2. Targets: The establishment of ambitious and measurable targets. It is not just about reducing negative impacts, but also about increasing positive contributions to nature

3. Actions: The implementation of concrete actions to transform operations, with the regular publication of the progress and results obtained

4. Leadership: Act4Nature International and Business for nature ensure the commitment of senior executives at the highest level. The preservation of biodiversity must not be considered to be a secondary project, but must be strategically integrated by the Company's management

Geographic and Value Chain Scope

Scope of Application:

• Scope 1: All mining sites and projects (New Caledonia, Gabon, Senegal, Argentina)
• Scope 1: All mining sites, rail transport and projects with a target of 1 for the rehabilitated to cleared ratio for mining activities over 2024-2026
• Scope 3: PT Weda Bay Nickel mining site (value chain)

Biodiversity Policy Framework and Targets

Use of Frameworks

Eramet applies:

• IRMA Standard (Initiative for Responsible Mining Assurance)
• IFC Performance Standard No. 6 (International Finance Corporation)
• Commitments reviewed by Act4Nature International and Business for nature
• Alignment with organizations including the International Union for the Conservation of Nature (IUCN) and the United Nations World Conservation Monitoring Centre (UNEP-WCMC)

Linkage to Nature-Related Risk Assessment

The strategy is defined in response to the impact, risk and dependency analyses carried out (presented previously and detailed in the next chapter). The Group's commitments align with global objectives relating to the Earth's limits, ensuring a positive contribution to global environmental challenges.

The commitments cover areas including land use and conversion, ocean protection, biodiversity conservation, freshwater management, and ecosystem services preservation.

Policies related to biodiversity and ecosystems

Environmental Policy

Eramet's environmental policy embodies its commitment to taking action to preserve biodiversity: integrate biodiversity into all its activities and develop plans for an overall net positive contribution to biodiversity.

Key commitments and principles:

• Apply the mitigation hierarchy "Avoidance, Minimization, Rehabilitation, Offsetting" to all mining projects
• Not carry out any mining and exploration activity in: (1) World Heritage sites and areas included in the official indicative list of a State party for inscription on the World Heritage list, (2) the protected areas of the International Union for Conservation of Nature (IUCN) of management categories I-III, (3) UNESCO Biosphere reserve core areas
• Prohibit the exploration and exploitation of the seabed (deep sea mining) and the discharge of residues at sea (deep sea tailing placement)
• Reduce impacts that cannot be avoided in order to reduce the duration, intensity and/or extent of such impacts
• Rehabilitate the areas impacted by its activities as soon as possible, with a focus on the reintroduction of local species
• Offset any significant residual impacts that cannot be avoided or reduced
• Contribute to improving scientific knowledge of the territories where the Group operates and to sharing naturalistic data with the scientific community
• Finance research, study and conservation programmes, particularly through its Lékédi Biodiversity Foundation (Gabon)

Scope:

The policy and guidelines focus on scope 1, where Eramet's challenges are concentrated.

Implementation and monitoring:

In 2024, the Group developed, implemented and communicated internally on three new standards detailing the requirements for:

• Preservation of biodiversity and ecosystem services
• Mining rehabilitation
• Water management

These standards are developed on the basis of the requirements of the IFC performance standard no. 6, the IRMA standard and the ICMM best practice guides. They are also tools for monitoring and controlling application. A review of the standards by a scientific partner is planned in 2025.

Link to international standards:

The standards are aligned with:

• IFC Performance Standard 6 methodology for assessment of critical habitats
• IRMA (Initiative for Responsible Mining Assurance) standard
• ICMM (International Council for Mining and Metals) best practice guides

Based on IRMA requirements, sites implement avoidance, reduction, rehabilitation and offset measures in the event of material residual impacts, aiming for no net loss of biodiversity or even a net gain.

Social dimension:

The social dimension of studies on biodiversity and the services provided by nature is specified in the biodiversity standard. Communities are involved in order to understand their use of natural resources, to hear their concerns, to assess the potential impacts of projects and operations, and to develop and share biodiversity and ecosystem services management plans.

Note on deforestation:

Eramet has not made a general commitment against deforestation. Each mining centre adopts a position based on the specific challenges of the region.

Actions and resources related to biodiversity

Mitigation hierarchy framework

All actions are based on the mitigation hierarchy "Avoidance, Minimization, Rehabilitation, Offsetting" approach, required for all Eramet sites and projects, with quantification of biodiversity losses and gains.

Avoidance measures:

• Project viability assessment (opting not to carry out project or part of project)
• Alternative technical solutions
• Alternative location: locating fixed installations in least sensitive habitats

Minimization measures:

• Installation of light deflectors
• Sedimentation basins to settle suspended matter before discharge
• Watering of tracks to limit dust spread
• Creation of wildlife corridors

Rehabilitation measures:

• Securing sites and managing runoff
• Revegetation and reforestation with endemic plants favored
• Performance monitoring and long-term sustainability tracking
• Target: Ratio of rehabilitated to cleared land ≥1 maintained across all mining sites

Offsetting measures (site-specific):

Biodiversity Action Plans (BAPs) aligned with IFC Performance Standard No. 6

Action: Update BAPs for all mining sites to comply with IFC PS6 and IRMA standard by end 2026

• Stakeholder consultation required
• Quantified biodiversity loss/gain approach
• Management and monitoring plans with effectiveness criteria
• Progress 2024: 45% of mining sites had BAP aligned with IRMA standard (target: 100% by 2026)
• Two action plans finalized (transport subsidiary and Gabon mining centre)
• Additional studies ongoing for Senegal site and second Gabon platform

Research and innovation programmes

Lékédi Biodiversity Foundation

• Annual operating budget: >€1 million
• Team: ~40 people (veterinarian, 8 keepers, 2 guides, 3 ecologists, anti-poaching team, park maintenance team)
• Reserve: 14,000 hectares in Gabon
• Active programmes: 4 (primate rehabilitation, savannah study, Mandrillus project, Gabon Green Generation)
• Partnerships: WWF, Gabonese Educational Institute, government bodies, research institutes, NGOs

Research partnerships:

• Partnership with CNRT (New Caledonia) on rare plant species
• Endemia association partnership for IUCN Red List assessments
• Scientific partnership to improve project robustness (agreement in discussion in 2024)
• Open Innovation Challenge launched October 2024

Site rehabilitation during and after operations

Target: Ratio of rehabilitated to cleared areas ≥1

• 2024 result: 0.69 ratio (below target)
• Gradual rehabilitation before, during and after operations
• Nurseries for reproduction of local species
• Prevention of exotic invasive species

Examples:

• Senegal (Grande Côte): dune reconstruction and replanting
• New Caledonia: 300 ha in high valleys, 121 ha at Pic Ninga (KBA)
• 315 hectares ready for restitution at end 2024 (awaiting authority response)

Water management actions

Action: Develop and implement water management plans at all sites by end 2026

• Group standard developed on Water Management in 2024
• Self-assessment of compliance for two mining sites in 2024
• Targets: 60% recycling in Senegal; 20% reduction in water intensity in Argentina
• Annual reporting to CDP Water Security (2024 score: B)

Awareness and training programmes

Internal:

• Communication policy sharing "Act for Positive Mining" roadmap with employees
• Network of biodiversity contacts on sites
• Resources: 10 people dedicated to biodiversity management/monitoring on site; 3 corporate support staff
• Biodiversity officers meet every 2-3 months

External:

• Eramet Biodiversity Day (3rd edition in Gabon)
• "Gabon Green Generation by Lékédi" programme: awareness and training for 1,100 young people in environmental conservation and green jobs
• Partnership with WWF and Gabonese Educational Institute
• Media engagement (television, press)

Value chain extension

PT Weda Bay Nickel (minority JV):

• BAP update to Eramet standards by end 2025
• IRMA audit launch by end 2026
• Habitat mapping, critical habitat assessment, ecosystem services studies ongoing
• Biodiversity loss/gain quantification method in development
• Offsetting feasibility study in progress

Governance and monitoring

Resources allocated:

• 2 CSR Committee members from Executive Committee
• Quarterly progress reviews
• 3 annual CSR Committee meetings
• Biodiversity performance included in variable remuneration of ~1,850 managers
• Environment Department provides technical support and monitoring

Standards development

2024: Three internal standards developed and circulated:

• Biodiversity Standard
• Rehabilitation Standard
• Water Management Standard

First IRMA audit completed at Eramet Grande Côte (Senegal) in January 2024 with extensive stakeholder consultation.

Prohibitions

• No deep-sea exploration or mining
• No discharge of residues at sea (deep sea tailing placement)
• No activities in UNESCO World Heritage sites, UNESCO Biosphere reserves, or IUCN protected areas categories Ia, Ib, II, III

Financial resources summary

• Lékédi Foundation annual operating budget: >€1 million
• Gabon offsetting: €8 million over 25 years
• New Caledonia research programmes: €17.5K (2024)
• Battery recycling project suspended October 2024 (uncertain raw material supply)

Implementation timeline

Three-year action plan (2024-2026) published on Eramet websites and validated by Act4Nature International and Business for Nature.

Targets related to biodiversity and ecosystems

Eramet has set targets for the 2024-2026 period included in the "Act for Positive Mining" roadmap. The targets are not currently aligned with SBTN ecological thresholds, though the company has assessed alignment requirements. Targets focus primarily on mining operations.

Target 1: Biodiversity Action Plans aligned with IFC Performance Standard No. 6

• Target metric: Percentage of mining sites with updated biodiversity action plans complying with IFC PS6 methodology
• Target value: 100% of mining sites
• Target year: 2026 (implicit from 2024-2026 period)
• Baseline year: 2023
• Baseline value: 37.5%
• Scope: All mining sites (4 sites)
• Type: Absolute (percentage coverage)
• Validation: IFC Performance Standard No. 6; reviewed by Act4Nature International and Business for Nature as SMART commitments
• 2024 progress: 45% of sites (80% level of performance)

Target 2: Ratio of rehabilitated to cleared land

• Target metric: Ratio of rehabilitated land to cleared land
• Target value: ≥ 1
• Target year: 2024-2026
• Baseline year: 2023
• Baseline value: 1.2
• Scope: All mining sites (4 sites) and projects
• Type: Intensity-based (ratio)
• Validation: Act4Nature International SMART commitment; aligned with IRMA Standard and IFC Performance Standard No. 6
• 2024 progress: Not disclosed in excerpt

Target 3: Scientific partnership launch

• Target metric: Establishment of scientific partnership (Y/N)
• Target value: Scientific partnership established
• Target year: Year-end 2024
• Baseline: Not specified
• Scope: Group level
• Type: Qualitative
• Validation: Part of Act4Nature International commitment

Target 4: Water management plans

• Target metric: Percentage of sites with water management plan
• Target value: 100% of sites with a water management plan; 60% recycling in Senegal and 20% reduction in water intensity in Argentina; B score on CDP Water Security
• Target year: Year-end 2026
• Baseline: Not specified
• Scope: All Group sites
• Type: Absolute (coverage) and intensity (reduction/recycling)
• Validation: CDP Water Security reporting

Target 5: Value chain (PT Weda Bay Nickel)

• Target metric: Update of Biodiversity Action Plan to Eramet standards; Launch of IRMA audit
• Target value: BAP updated; IRMA audit launched
• Target year: Year-end 2025 (BAP); Year-end 2026 (audit)
• Baseline: Not specified
• Scope: PT Weda Bay Nickel mining site (Scope 3 value chain)
• Type: Qualitative
• Validation: IRMA audit planned

Target 6: Lékédi Biodiversity Foundation budget

• Target metric: Annual operating budget for 14,000 ha reserve management
• Target value: €1 million annual budget
• Target year: From 2024 (ongoing)
• Baseline: Not specified
• Scope: Group level (Gabon reserve)
• Type: Absolute (budget)
• Validation: Act4Nature International commitment

Additional commitments (qualitative):

• Prohibition commitments: 100% of mining sites and projects with prohibitions on deep sea mining, seabed exploitation, discharge of residues at sea, and activities in UNESCO World Heritage sites, UNESCO Biosphere reserves, and IUCN protected areas categories Ia, Ib, II and III (from 2024)

Notes on SBTN alignment:

The company acknowledges that while SBTN methodologies define three main objectives for terrestrial ecosystems (no conversion, reduction of land footprint, landscape initiatives), an overall "non-conversion" objective is difficult to apply for the extractive industry. No ecological thresholds are currently defined for Mining & Metals under SBTN for land footprint reduction.

Impact metrics related to biodiversity and ecosystems change

Land Use and Transformation

Eramet's biodiversity footprint analysis, conducted in 2023 using Corporate Biodiversity Footprint (CBF) methodology (Iceberg datalab and ICare) and the STAR indicator, shows:

• Scope 1 represents 75% of the overall footprint, mainly due to mining sites (84%)
• Main impacts stem from land transformation and land use pressures contributing to habitat degradation
• Second biggest contributor: impacts related to greenhouse gas emissions
• Third contributor: impacts related to water consumption

Biodiversity Footprint by Scope: Results expressed in km².MSA.yr show predominant share of scope 1 in overall footprint, represented by land cover and clearing/restoration dynamics at mining sites. Scope 3 is the second largest contributor with three times less impacts on land use and climate change, as well as on water stress.

Operations in or near Protected Areas and Key Biodiversity Areas (KBAs)

Mining Operations:

Rail Transport (Setrag - Gabon):

Species Impact Metrics

Threatened Species Potentially Affected (by IUCN Red List Classification):

New Caledonia Specifics:

• KBAs of High valleys of Neaoua, Koua and Kouaoua rivers and Pic Ningua recognized for importance for bird conservation
• Dense evergreen forest of low and medium altitude, plus savannahs with gallery forests
• Pic Ningua rises to 1,343 metres with rainforests and niaouli savannahs
• SLN established three conservation areas ("Ecosystem Preservation Zones")
• Actions deployed on feral cats posing significant threat to bird populations (tracked using camera traps)

Senegal Specifics:

• Niayes KBA consists of string of permanent freshwater lakes and temporarily wet depressions extending from north-east suburbs of Dakar to ~60 km south-west of Saint-Louis

Restoration Metrics

2024 Performance:

Senegal - GCO Specific:

• In 2023: triggered land restitution cycle and returned 85 hectares of rehabilitated land to Senegalese Water and Forests Department
• At end of 2024: additional 315 hectares ready for restitution, awaiting formalization from authorities

Ecosystem Impacts

Pressures Assessed (per IPBES framework):

1. Land and sea use change - considering:

   • Land cover and rehabilitation/compensation use change dynamics
   • Noise and light pollution
   • Fragmentation (rail transport)
   • Water consumption
   • Dust and suspended matter emissions

2. Climate change - via greenhouse gas emissions

3. Pollution - particularly eutrophication, acidification and ecotoxicity

Qualitative Assessment:

• Overexploitation of resources (species management at sites)
• Invasive alien species (presence and management)

Methodology Notes

Biodiversity footprint calculated using:

• Corporate Biodiversity Footprint (CBF) methodology by Iceberg datalab and ICare
• STAR indicator (Species Threat Abatement and Restoration metric from IUCN Red List)
• IBAT platform (Integrated Biodiversity Assessment Tool) for vulnerability corrections
• Results expressed in km².MSA.yr (Mean Species Abundance)

Species data sourced from:

• Screening studies using internal tool querying international databases (including IBAT)
• National literature reviews
• Field studies forming baseline characterization

Dependency assessment performed using WWF Biodiversity Risk Filter (BRF) tool with data from WWF, IBAT, IUCN, UNEP-WCMC, ENCORE, RepRisk, FAO, World Bank and NASA.

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Phase-in exemption

The CSRD rules allow for a phased compliance period of up to three years for certain disclosure requirements. The information relating to this chapter is only mandatory from the 2025 reporting period. Consequently, Eramet has opted for deferred publication in order to allow time to collect and validate this financial data.

Anticipated financial effects status

According to the table in the document, E4-6 (Anticipated financial effects from water and marine resources-related impacts, risks and opportunities) is listed with:

• Type: Quantitative & qualitative
• Status: Analysis ongoing
• Timeline: Compulsory for the 2025 reporting

Policies related to resource use and circular economy

Eramet's policies and action plans relating to the use of resources and the circular economy are defined in connection with the IROs identified in the double materiality analysis.

Environmental Policy

Key content and principles:

• Commitment to optimize mineral resources and contribute to a circular economy
• For mining activities: commitment to optimum management and recovery of mining resources
• For industrial sites: incorporate as much secondary raw material as possible into inflows to avoid consuming virgin raw materials, and recover as much waste generated by own activities as possible
• Specific goal in the Act for Positive Mining roadmap for the period 2024-2026 on waste recovery
• Commitments to reduce water abstraction on all sensitive sites (large consumers or located in areas of water stress)
• Optimize process water consumption and increase recycling

Approval and oversight:

• Reviewed in 2023
• Integrated into the Eramet Management System
• Monitored by Environment Department with support of Technical Department, which reports to the CSR Committee and the Eramet Executive Committee

Scope:

• All Group sites (for environmental management)
• All Group mining activities (for mining-specific commitments)

Public availability:

• Referenced in section 5.2.2 "Policy and Guidelines"

Monitoring:

• Application is mandatory for all sites through Key Standard environment
• Eramet Production System (EPS) supports implementation, aiming to improve reliability of facilities
• Community of experts in geology, mine planning and mineral processing operating within "International Competence Groups" (ICG) share best practices and develop operational standards integrated into the Group's operating system

Prohibition against deep-sea mining and deep-sea tailing placement

Scope:

• All Group mining activities

Monitoring:

• Environment Department with support of Technical Department, which reports to the CSR Committee and the Eramet Executive Committee

Links to international standards:

• IRMA and ICMM standards
• Eramet procedure "Management of tailings storage facilities" including the fundamentals of the "Global industrial standard for the management of mine tailings" UNEP - ICMM
• IRMA standard for mines

Management of waste rock

Key content:

• Referenced in chapter ESRS E2 Pollution - 5.4.1.3.5 Specific case: Mining residues

Scope:

• All Group mining activities

Monitoring:

• Environment Department with support of Technical Department, which reports to the CSR Committee and the Eramet Executive Committee

Links to international standards:

• IRMA and ICMM standards
• Eramet standard "environmental management"
• IRMA standard for mines

Water management

Monitoring:

• Environment Department with support of Technical Department, which reports to the CSR Committee and the Eramet Executive Committee

Links to international standards:

• Eramet standard "Water management"
• IRMA standard

Actions and resources related to circular economy

5.7.1.3.1 Recovery of mineral resources

The recovery of mining resources is one of the Group's core businesses and a key component of the Group's contribution to the development of the circular economy. Maximum beneficiation of the mineral profile—mining ores at the lowest possible grade, or the recovery of materials previously considered to be tailings or waste—improves the environmental efficiency of mining operations by increasing the quantity of metal resources produced for the same environmental footprint.

Actions and resources:

• The Group relies on its Eramet Production System (EPS) to support this approach, which aims to improve the reliability of facilities
• Support from its community of experts in geology, mine planning and mineral processing operating within the framework of the "International Competence Groups" (ICG), who share best practices and develop operational standards integrated into the Group's operating system
• Moanda Industrial Complex (CIM) in Gabon (operational since 2000): process developed to process manganese-rich sands resulting from rehabilitation of the Moulili river. Extraction of previously unexploited ore fines has enabled increased recovery of mining resources and improved productivity of ore processing plants
• "Eliminate waste" roadmap developed by Eramet Ideas (research centre) in 2024 to reinforce and improve the structure of all waste recovery initiatives (prevention, reuse and recycling). This programme aims to identify opportunities for all of the Group's activities (mining and industries) and develop them up to the pilot demonstration stage

Scope: Own operations (all mining sites: mines and mineral and processing units)

Resources: Financial resources allocated to each action are not available for 2024 (footnote 1)

5.7.1.3.2 Recovery of industrial process waste

Waste from ore processing represents an annual quantity of approximately 3 million metric tonnes for all of the Group's metallurgical transformation plants. The waste is managed according to the waste management hierarchy.

Waste hierarchy and actions:

"Eliminate waste" programme of Eramet Ideas also applies to industrial process waste.

Pilot plant: Eramet commissioned a pilot plant at its "Research & Innovation" Centre in Trappes in November 2023 to test and optimize the production of battery-grade metallic salts.

Scope: Own operations (all metallurgical transformation plants)

Battery recycling project (suspended)

In October 2024, the Group announced the suspension of its battery recycling project in France. This decision was made in response to major uncertainties about the supply of raw materials to the plant and about recycling sales and off-take opportunities for metallic salts, due to the lack of ramp-up in Europe of battery factories and their components (precursors and materials for cathodes).

Eramet remains convinced of the need to develop a circular economy for critical metals and will continue to study the market fundamentals necessary for the competitiveness of such a project.

Scope: Downstream value chain (battery recycling)

Status: Project suspended in 2024

General note on resources

Details of the financial resources allocated to each action are not available for 2024 (as stated in footnote 1 on page 460).

Targets related to circular economy

Water recycling targets in water-stressed areas

Target metric: Water recycling/reuse rate at sites in water-sensitive areas

Target values:

• Eramet Grande Côte (Senegal): 60% recycling by end of 2026
• Eramine (Argentina lithium project): 80% recycling by end of 2026

Target year: 2026

Baseline year and value:

• Eramet Grande Côte: 41% in 2023
• Eramine: N/A (project entered production in December 2024, baseline will not be available until end of 2025)

Scope: Two mining sites in water-sensitive areas (own operations)

Type: Absolute targets (percentage of water recycled)

Validation: Targets were defined on the basis of the results of feasibility studies conducted by the Group's Technical Department and Research and Development Centre. Targets are voluntary and not imposed by law.

Progress to date (2024):

• Eramet Grande Côte: 52% (compared to 41% baseline in 2023)
• Eramine: N/A (entered production December 2024)
• Group overall recycling/reuse rate: 24% in 2024

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Industrial waste recovery

Target metric: Recovery rate of main process waste (slag, filtration dust and gas washing sludge) from industrial sites

Target value: Improve recovery rate by 10% per year in 2025 and 2026

Target year: 2026

Baseline year and value: 48% in 2023

Scope: All industrial sites (6 sites) - own operations. The waste types represent around 80% of total waste produced by Eramet's industrial sites.

Type: Absolute percentage improvement target

Validation: Voluntary target, established internally

Progress to date (2024): 54% recovery rate achieved, representing a 12% improvement compared to 2023 baseline. Gains mainly from increased volume of melting slag recycled, driven by dynamism of abrasive slag market in the USA.

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Mining resource recovery

Target metric: Proportion of materials sold in relation to quantity of materials extracted in-situ

Target value: Continuously monitor and improve (no specific quantified target disclosed)

Target year: Ongoing

Baseline year and value: Not disclosed

Scope: All mining sites (3 sites) - own operations

Type: Absolute ratio target

Validation: Internal monitoring standard

Progress to date (2024): 12.4% in 2024 (compared to 14.0% in 2023)

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Battery recycling (ReLieVe project)

Target metric: Develop a robust technical and economic model to industrially recycle EV batteries in Europe

Target value: Design a recycling unit targeting annual production of:

• 5,000 t of nickel
• 1,000 t of cobalt
• 5,000 t of battery-grade lithium carbonate

Target year: 2026

Baseline year and value: Not applicable (new project)

Scope: Group scope - projects

Type: Absolute production volume target

Validation: Internal project target, linked to circular economy commitment

Progress to date (2024): Decision to suspend the project taken in October 2024

E5-4 Resource inflows (Incoming resources)

The diagram below provides a simplified illustration of the inflows and outflows of resources at the Group's industrial plants.

Inflow resources mainly consist of:

• Raw materials: mainly ore and reducing agents
• Secondary materials: materials from the circular economy (waste produced by another plant, biofuel, etc.). The recycling by a plant of its own waste and by-products is not taken into account in the calculation.

Determination of inflow resources

The scope used is that of the metallurgical transformation sites. Mining activities are excluded because the purpose of these sites is to supply raw material (manganese and nickel).

The inflow resources taken into account include the raw materials loaded into the furnaces to produce metal alloys (ferromanganese, silicomanganese and ferro-nickel). These materials fall into three main categories:

• Sources of metal consisting of crude ore, sinter ore or rich slag. Manganese and nickel are both on the list of critical raw materials.
• Reducing agents such as coke and coal.
• Additional manufacturing resources required for manufacturing: silicon, chemical corrector (dolomite, magnesia).

Waste and co-products generated by other production sites are considered as inflow resources from the circular economy. The waste/by-products subject to internal recycling are excluded from the scope. The quantities used for the calculation are obtained either by weighing or by means of a material balance.

2024 Results

In 2024, the audit carried out for the Group's processing plants shows that:

This figure is dependent on many factors, such as the metal content of the ore or market opportunities. Thus, with a low metal content (around 2%) and a geographically isolated position (in New Caledonia), which is unfavourable to industrial ecology actions, SLN does not use significant quantities of secondary materials. In contrast, the Norwegian Kvinesdal plant used 41% of secondary inflow resources in 2024 thanks to co-products available locally from other ferro-alloy plants.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Phase-in exemption applied

The CSRD rules allow for a phased compliance period of up to three years for certain disclosure requirements. The information relating to this chapter is only mandatory from the 2025 reporting period. Consequently, Eramet has opted for deferred publication in order to allow time to collect and validate this financial data.

Waste

Waste Management Approach

Eramet's decarbonisation strategy includes the optimisation of existing assets and the development of new technologies in partnership with peers, academics and suppliers. The Group's decarbonisation trajectory depends on its ability to develop cross-functional, multi-year structuring projects, including the recovery of plant by-products as provided for in the CSR roadmap.

The Group promotes the circular economy through proper management of waste rock and tailings, ensuring the safety of local residents and employees, minimizing environmental impacts and promoting reuse in a circular economy approach (including water-based tailings). Four projects are being carried out on this subject at GCO, in New Caledonia, at SLN and at Comilog. The Group's roadmap contains targets on these subjects.

Eramet is committed to reducing the consumption of resources required for its activities and promoting eco-design to reduce environmental impacts throughout the product life cycle. This includes preventing the production of waste, in accordance with the waste management hierarchy, recovering waste otherwise, promoting non-toxic life cycles and, where appropriate, properly managing hazardous waste (with the exception of waste rock and tailings). The Group is developing recycling mechanisms that enable more efficient use of resources.

Waste Risk Profile

Potential negative impacts on the environment and the population exist due to a limited or inadequate waste and/or hazardous waste management system or the inability to prevent the generation of waste. Risks are related to waste management and the implementation and/or non-compliance with stricter regulations and standards in terms of the circular economy. However, economic opportunities exist, particularly related to waste reduction, in particular the recovery of plant by-products as provided for in the CSR roadmap.

Mining Waste Management

Potential negative impacts of waste rock and tailings (including aqueous tailings) exist, particularly on the safety of local residents and employees, as well as on the environment. Risks relate to the management of residues and potential accidents as well as the implementation and/or non-compliance of stricter regulations and standards in terms of the circular economy. Economic opportunities are related to the reduction of tailings waste.

Hazardous Materials Management

Potential negative impacts on the environment and the population exist due to a limited or inadequate waste and/or hazardous waste management system. The Group works to ensure the collection, treatment and disposal of waste, reduce, minimize and/or eliminate the quantity and toxicity of hazardous materials used, stored or disposed of, and prevent potential threats to the environment from hazardous waste that present substantial or potential risks to health and the environment.

Policies related to own workforce

Eramet has established several policies that apply to its own workforce. All Group policies are detailed on the Eramet website (Charter & policies – Eramet) and apply to all Group employees in all controlled subsidiaries.

Health Policy

Scope: All Group employees at all sites, as well as visitors and people living around the sites.

Key content: The Group's Health Policy seeks to contain health risks in order to minimise the frequency and seriousness of their consequences. While acknowledging that it would be impossible to totally eliminate all health risks, the policy focuses on risk containment.

Governance: The Group's management is responsible for this policy, which is applied and reviewed by the HR, Health and Safety Department.

Implementation means:

• Integration of health and working conditions into everyday life
• Drafting, dissemination and application of standards
• Development of a health action plan for each entity
• Harmonisation of methods for assessing the level of implementation of Health Fundamentals
• Personnel involvement (obtaining opinion of personnel representative bodies)
• Employee awareness
• Screening to enable early detection of health problems
• Information and traceability of exposure levels
• Continued scientific follow-up and benchmarking
• Development of a policy to combat addictive behaviour

IRO coverage: This policy covers the IROs concerning the safety of the "health and safety" issue identified in the dual materiality exercise.

Link to international standards: This document is not associated with an international standard or initiative.

Safety Policy

Scope: All Group employees on all sites, as well as on-site subcontractors.

Key content: Safety is defined as a fundamental value of the Eramet Group. The policy states that safety is the primary responsibility of every manager in the company, and that each one is responsible for their own safety and the safety of their employees and those around them. The Group is committed to achieving zero fatal accidents at its industrial and mining sites.

Governance:

• Signed by all members of the Executive Committee at the highest level of governance
• The Group's Safety and Prevention Department is responsible for this policy
• Since October 2019, the Safety and Prevention Director reports directly to the Group's Chief Operating Officer and functionally to the Chair and Chief Executive Officer of Eramet
• Site Managers implement guidelines at site level, assisted by a site Safety Manager/Coordinator

Link to international standards: The safety management system (SMS) is largely inspired by ISO 45001 international standards.

Implementation means:

• Clearly defined safety roles and responsibilities
• Sufficient resources dedicated to safety
• Appointment of a safety manager on each site
• Risks identified and classified according to criticality
• Work instructions for routine tasks; work permits for critical tasks
• Safety training for employees and subcontractors
• Safety information system rolled out across all industrial and mining sites
• Safety visits by management team
• Essential Safety Requirements

IRO coverage: This policy covers the IROs concerning human resources management of "Employee-related policies" and "Social dialogue" issues identified in the dual materiality exercise.

Human Resource Management Policy

Scope: All Group employees on all sites.

Key content: The Eramet Group invests in the talents of all employees and capitalises on their diversity. The Group wants employees to become players in a performance-orientated managerial culture that is demanding and caring. Eramet strives to uphold social dialogue as a critical lever for the Group's successful transformation.

Governance:

• The Group's Human Resources Department is responsible for this policy
• Reports to the Group's CEO
• Responsible for establishing and implementing the talent development framework
• Ensures objectives related to Human Resources Management are implemented and achieved

Implementation means:

• Support operational teams to create agile, high-performance and value-creating organisations
• Identify critical skills and key positions as part of People Reviews
• Develop employees' skills to enhance employability
• Develop cross-functional collaboration to boost internal mobility
• Offer variety of development opportunities
• Encourage and recognise individual and collective performance
• Offer competitive compensation in each country of operation

IRO coverage: This policy covers the IROs concerning human resources management of "Employee-related policies" and "Social dialogue" issues identified in the dual materiality exercise.

Human Rights Policy

Scope: The entire Group and all its controlled sites, without exception.

Key content: Published in 2019, this policy is part of the Eramet Group's ambition to be a responsible and sustainable company. It was developed in consultation with internal and external stakeholders (including NGOs and trade unions). The document is divided into three parts: protection of employees, protection of local communities and respect for human rights in the value chain.

The section on employee protection highlights commitments to:

• Workers' health, safety and security
• Decent working conditions and housing
• Prohibition of forced labour and child labour
• Prohibition of harassment and violence
• Prohibition of discrimination
• Respect for freedom of association
• Data protection and confidentiality

Governance:

• Signed at the highest level of governance by all members of the Executive Committee
• The Societal Impact and Human Rights Department is responsible for ensuring its implementation at Group level

Link to international standards: The commitments include major international conventions such as:

• ILO conventions
• United Nations Charter of Fundamental Rights
• United Nations Guiding Principles (as part of the Group's human rights due diligence)

Communication and monitoring:

• Compulsory display on all sites
• Regular training sessions by the Group's Human Rights Officer during field missions
• Compulsory internal e-learning on human rights for all connected employees
• Information and communication campaigns during special events such as International Human Rights Day
• In 2021, first assessment of sites' compliance with the Policy was performed
• By end of 2023, the Group achieved 100% compliance of sites with the Policy
• Compliance check continues with IRMA process implementation

Specific commitment on modern slavery: The policy has a specific commitment on modern slavery, particularly on the prohibition of forced labour and child labour. Two golden rules exist on these subjects to explain these concepts internally and provide examples to identify risky situations.

IRO coverage: This policy covers the IROs concerning human rights relating to "Social policies related to workforce", "Social dialogue", "Responsibility in the value chain", and "Impact on local communities" issues identified in the dual materiality exercise.

Taking action on material impacts on own workforce

Human Resources Roadmap 2020-2025

Eramet has built its Human Resources Management Roadmap 2020-2025 (available on www.eramet.com) on several key issues to get employees on board the Eramet adventure. The Group strives to make its international positioning a genuine opportunity for mutual development by exchanging experiences and cultures: in 2023, 92% of the Group's employees worked outside mainland France.

Scope: Own operations (Group-wide) Time horizon: 2020-2025 Link to policy: Links to HR strategy and managerial culture objectives

Diversity & Inclusion Action Plan 2024-2026

The D&I Group 2024-2026 roadmap aims to create positive impacts for employees based on three pillars:

1. Developing an inclusive working environment through webinars, training and D&I tools with a focus on gender equality, intergenerationality, disability and interculturality
2. Adopt zero tolerance towards all forms of discrimination and harassment through prevention, awareness-raising and support for employees who are victims or witnesses of inappropriate behaviour, training D&I and harassment counsellors, and an improvement in alert line service
3. Improving well-being at work to guarantee a quality of life

Scope: Own operations (France, Argentina, Indonesia, Gabon, Senegal initially; expanding globally) Time horizon: 2024-2026 Link to policy: Ethics Charter commitments on diversity, inclusion, and non-discrimination

Actions completed/ongoing:

• Mental health services deployed in mainland France, Argentina and Indonesia
• Improved infrastructure around mining sites (housing, toilets, leisure areas)
• D&I e-learning: Launched in 2020; 50.6% of employees completed training by 2024; new version launched replacing 2020 version
• "All Together" training: Mandatory D&I training for Top 120 (ELT) from 2022-2023
• D&I webinars offered to all employees on various topics (LGBT+ inclusion, multiculturalism, disability, women in mining, sport and inclusion)
• Face-to-face training conducted in France, Gabon, Senegal, Argentina and Indonesia on D&I, non-discriminatory recruitment, harassment prevention/management, and interculturality
• New tools introduced (2024-2025): Disability guide, Multicultural guide, Internal mobility guide, New D&I e-learning

Actions planned for 2025:

• Carry out a Group communication campaign on inappropriate behaviour
• Clarify and standardise the sanctions applicable at Group level in the event of non-compliance with the Ethics Charter
• Communicate the number of inappropriate cases reported via the hotline, the number of proven cases and the number of sanctions taken, on a regular and transparent basis
• Support the creation of mental health services in additional locations

Resources allocated:

• Non-financial: D&I representatives trained at subsidiaries; harassment representatives trained in subsidiaries; partnerships with external service providers

Women in Management Programme

Objective: 30% of women managers by 2026 (from 28.1% in December 2024)

Actions:

• "Women Friendly Indicator" (from 2023): Ensures minimum common standard at all sites (single-sex sanitary facilities, changing rooms, showers, PPE adapted to different body types)
• Regular People Reviews of women to highlight competent female candidates
• Internal promotion of collective agreements on gender equality (including equality index, equal pay)
• PowHer training/coaching dedicated to women for development
• Twin mentoring via internal WoMen@Eramet network
• Partnership with International Women In Mining (IWIM) to share best practices; participation in International Women in Resources Mentoring Program (IWRMP)
• Poster campaigns: "No room for prejudice" (2020), "Who runs the mine?" (2024)
• Awareness-raising for men during D&I field training
• Upstream promotion of mixed teams in mining industry among young people

Site-specific implementations:

• Argentina: Video campaign to promote diversity and inclusion of LGBT+ people
• Senegal: "Women-friendly" PPE deployed at Eramet Grande Côte
• Indonesia: Naluri mental health support service launched

Scope: Own operations (Group-wide) Time horizon: Target by 2026 Link to policy: Diversity & Inclusion commitments

Training and Skills Development

Training programmes:

• Executive Development Programme (EDP) - 9 months for senior executives
• Imagine programme - 18 months for Young Talents via distance learning
• "Propulse" scheme - coaching for Eramet Leadership Team (ELT) positions
• "Raise & Engage" programme - for middle and senior managers, deployed internationally since 2023
• Intercultural skills development - deployed on five continents
• WeLearn portal - self-service digital resources for managers globally
• Three specialized academies inaugurated for expertise-specific training

Training delivery:

• 2024 results: 208,832.9 hours of training (~23.7 hours per employee); 5,451 employees (62%) attended training; 19,643 work-study hours in France
• E-learning covering: integration, Health/Safety/Environment, Ethics & Compliance, D&I, Business and Digital Technology
• Digital content available in four languages

Scope: Own operations (Group-wide) Resources allocated:

• Non-financial: 208,832.9 training hours in 2024; dedicated training programmes and platforms

Employee Feedback and Onboarding

Onboarding survey launched January 2024:

• Digital and anonymous survey for all new employees with email addresses
• Two questionnaires: at 7 days and 3 months after arrival
• Available in six languages (English, French, Bahasa Indonesia, Chinese, Spanish, Portuguese)
• Assesses recruitment effectiveness, reception quality, team integration, mission clarity, environment understanding

Scope: Own operations (all sites worldwide) Time horizon: Ongoing from 2024 Link to policy: Strategy to promote management-led feedback and open communication

Social Dialogue Initiatives

Various site-specific actions:

Senegal (GCO):

• Salary policy agreement negotiation (2024/2025)
• Staff delegate elections - 26 delegates formed
• Training programme for delegates with Labour Inspectorate assistance
• Discussion workshops on: company agreement renewal, career management, protection/pensions, health insurance
• New GCO workers' solidarity fund established via company agreement (2024)

Argentina (Eramine):

• Collective agreement in final stage with salary negotiations

New Caledonia (SLN):

• Economic difficulties mitigation: 3-week shutdown with no reduction in employee pay; 38% took days off
• Thio mine damage: employees initially on short-time working with advance payment; placed on full unemployment from December 13

Scope: Own operations (site-specific) Link to policy: Social dialogue commitments

Human Rights Training and Awareness

"Understanding and integrating human rights in business" e-learning:

• Available since 2020
• Updated in 2024 to reach wider audience (6,000+ people - all connected employees)
• Available in four languages (English, French, Spanish, Norwegian)
• 2,000+ registered participants completed training by end-2024

2024 awareness sessions:

• 283 people trained on human rights issues at Eramine, Setrag, Comilog sites
• 11 internal auditors trained on modern slavery
• 44 people from various teams trained on indigenous populations
• 227 participants from all sites engaged in International Human Rights Day event (December)

Special training sessions:

• Anti-discrimination training (non-discriminatory hiring)
• Gender-based violence training in Gabon, New Caledonia, Argentina

Scope: Own operations (Group-wide) Resources allocated:

• Non-financial: 500+ people trained in 2024; e-learning platform; expert partnerships Link to policy: Human Rights Policy; Ethics Charter

Remediation and Grievance Mechanisms

Multiple complaint channels:

• Contact manager for quick resolution
• Contact specialized management teams
• Networks within Group (e.g., sexual harassment and sexist behaviour network)
• Integrity Line whistleblowing system - accessible 24/7 via website, intranet, telephone (22 countries)

Scope: Own operations (Group-wide) Link to policy: Ethics Charter; Human Rights Policy

Site-Specific Safety and Well-being Actions

Setrag (Gabon):

• Railway safety improvement plan since 2016
• 2024 investment: ~€65 million in renovation plan (up 30% vs 2023)
• Reduced incident frequency by 50%
• Enhanced inspection of embankments and structures
• Geotechnical studies monitoring
• 2025 planned: bypass commissioning in unstable areas; continuation of sleeper/track renewal

Eramet Grande Côte (Senegal):

• Railway safety measures: fencing installation, secure level crossings, guarded crossings
• Collaboration with prefectures, railway authorities, town halls, local populations

Resources allocated:

• Financial: €65 million capex in 2024 for Setrag railway safety Expected outcomes: Significant reduction in railway accident risks

Targets related to own workforce

Eramet has developed a social pillar called "take care of people" in its Act for Positive Mining roadmap. The objective is to ensure harmonious living together through safety, respect, support and development.

Target Area 1: Health and Safety

Scope: The Group confirms its absolute commitment to Safety with a comprehensive approach to health through the determination of a common social security protection base for employees, and the development of programmes dedicated to employee well-being.

Target Area 2: Inclusive Environment and Development

Building a diverse workforce is essential to keep up with the Group's evolving industrial footprint and the growing need for innovation. This objective maintains a target percentage of female managers already included in the 2018-2023 period, and introduces goals for employee development and youth employment.

Scope: Contributing to training to enhance local skills for the development of each country where the Group operates.

Target Type: All targets appear to be absolute targets (not intensity-based).

External Validation: Not mentioned; targets appear to be internal.

Characteristics of the undertaking's employees

Headcount and Employee Structure

Total Workforce (Fixed-term/Permanent)

Note: Eramet fixed-term/permanent workforce. The 2024 figure represents employees at 31 December 2024. The Group employed 8,828 people at 31 December 2024.

Geographic Distribution

The document references workforce across multiple geographic locations:

• France: Operations include management fee contracts, services companies (Eramet Services, Eramet Ideas, Eramet International), and various industrial sites
• New Caledonia: Le Nickel-SLN operations with approximately 98% Caledonian nationals referenced in employment context
• Gabon: Comilog operations
• Senegal: Grande Côte Operations (GCO) site employs approximately 2,400 people (including subcontractors), 98% of whom are Senegalese nationals
• Indonesia: PT Weda Bay Nickel operations
• Norway: Manganese alloys plants (Sauda, Porsgrunn)
• United States: Marietta manganese alloys site
• Argentina: Eramine Sudamerica (lithium project)

Workforce Changes

The total workforce decreased from 10,054 employees in 2023 to 8,828 employees in 2024, representing a reduction of 1,226 employees (-12.2%).

Specific Site Employment Data

Grande Côte Operations (Senegal)

• Total site employment: approximately 2,400 people (including subcontractors)
• Local national employment: 98% Senegalese nationals

Employment Context

The document indicates significant operational challenges in New Caledonia during 2024, including riots in May that led to cessation of mining production and impacts on workforce deployment. Mining activity was only partially resumed from mid-June at two sites (Tiébaghi and Népoui).

Share-Based Compensation Participants

Bonus share plans in place for employees and corporate officers:

Share-based payment expense: €10 million for 2024 financial year (€10 million for 2023).

Limitations

The disclosed employee data focuses on total headcount figures. Detailed breakdowns by gender, specific country-by-country distribution, employment contract types (permanent/temporary), employment types (full-time/part-time), turnover rates, and new hire statistics are not explicitly provided in the extracted sections. The document references workforce in various geographic locations but does not provide systematic tabular breakdowns meeting full ESRS S1-6 requirements.

Characteristics of non-employees in the undertaking's own workforce

Disclosure status

Eramet has opted for deferred publication of S1-7 metrics. The company states:

"The CSRD rules allow for a phased compliance period of up to three years for certain disclosure requirements. The information relating to this chapter is not mandatory for the 2024 reporting. Consequently, Eramet has opted for deferred publication in order to be able to collect and validate this data."

Definitions provided

The company distinguishes between employees and non-employees as follows:

Group employees are defined as having a direct employment contract with the Company, including full-time, part-time and temporary employees. They are paid directly by the Company and benefit from the social benefits and legal protections associated with their employee status.

Non-employees include workers not directly employed by the company but providing services or contract work (self-employed workers, temporary workers, International Interns (VIE), trainees, subcontractors).

Safety data coverage

While comprehensive S1-7 workforce metrics are deferred, the company does report that its safety management system covers 100% of non-employees working on Eramet Group sites:

"The safety management system covers 100% of employees (employees, temporary workers and subcontractors) who operate on the Eramet Group's sites. This information is also reported for other workers working on company sites, such as value chain workers, if they work at company sites."

Site-level workforce information

Limited non-employee workforce data is mentioned for specific sites:

Grande Côte Operations (GCO) - Senegal:

• The site employs approximately 2,400 people (including subcontractors)
• 98% are Senegalese nationals

Quantitative headcount and characteristics metrics to be disclosed in 2025 reporting.

Collective bargaining coverage and social dialogue

Collective bargaining coverage and social dialogue arrangements

100% of Eramet employees are covered by at least one agreement because there is, firstly, Eramet Global Care, and secondly, the agreements negotiated with their employee representative bodies at the local level.

Collective bargaining agreement coverage and workplace representation

Social dialogue bodies

European Works Council

Eramet has established a European Works Council. In accordance with Article L. 22-10-7 of the French Commercial Code and Article 10.9 of the Articles of Association, two directors representing employees were appointed, one by the Company Economic and Social Committee and the other by the European Works Council. Their term of office is four years from their appointment.

Franck Pecqueux was appointed by the European Works Council at its meeting on 12 November 2022 in accordance with Article 10.9 of the Articles of Association (expiry date: 11 November 2026).

100% of Eramet employees in the European Economic Area are covered by employee representatives.

Eramet Global Forum

The Eramet Global Forum, launched in June 2023, has 22 full members and one deputy member per country. These representatives are employees in the Group's main countries: France including New Caledonia, Gabon, Norway, Senegal and Argentina.

The Forum meets twice a year, in plenary meetings, to discuss and share strategic issues for the Group with the members of the Executive Committee. A six-member committee meets four times a year to advance specific topics, identify issues to be forwarded to management and disseminate information on the EGF's work to local elected representatives.

This body is the first of its kind for a mining player to create this type of body at international level.

Social dialogue in main subsidiaries

Comilog

Comosocial at Comilog was characterised by the organisation of the team, which now consists of four full-time members (one in 2023). The increase in the workforce has enabled the social dialogue committees' action plan drawn up with the unions at the end of 2023 to be addressed (68% at the end of October).

Three strike movements were observed on 20 June (4 p.m. - 13% of the workforce on strike), 26 September (24 hours - 20% of the workforce on strike) and 3 December (72 hours - 11% of the workforce on strike). Following the last strike, mediation under the supervision of the Minister of Mines was initiated with the signing of a mediation protocol on 30 December 2024.

Setrag

An Internal Complaints and Requests Management Mechanism (ICRMM) was set up in 2024 on the recommendation of the financial backers (FB) in order to diversify the channels available to employees for making complaints and requests. This mechanism encourages and promotes the involvement of all employees of SETRAG and service companies.

In 2024, the following concepts were also included in the company agreement:

1. Gender-Based Violence (GBV)
2. Harassment
3. Non-discrimination (sexual orientation, etc.)
4. Internal Requests and Complaints Management Mechanism (MGRPI)
5. Nationalisation of jobs

Eramet Grande Côte Opérations

Eramet Grande Côte Opérations continued its dialogue with employee representatives to promote social progress in 2024. The first part of the year was devoted to the negotiation of a salary policy agreement for the 2024/2025 year. After two rounds of staff elections, a delegation of 26 delegates was formed. A training programme for delegates has been built and four days of training have already been provided with the assistance of the Labour Inspectorate.

Eramine

The collective agreement is still ongoing and is in the final stage with salary negotiations. The aim is to sign the final agreement in the coming months.

Eramet Global Care

The social partners have successfully negotiated an initial agreement (Eramet Global Care) comprising three pillars which form a common basis of social protection applicable to all Group employees, without distinction:

1. Maternity and conditions for women in the workplace: guarantees 16 weeks of maternity leave paid at 100%
2. Death cover: provides all beneficiaries with death benefit equal to 12 months' salary in the event of the death of an employee
3. Access to healthcare: essential health cover for all Group employees (hospitalisation, routine and emergency care, maternity)

Diversity metrics

Gender distribution within senior management

The proportion of men and women on the Executive Committee remains stable within the Eramet Group. The proportion of women in the ELT (Executive Leadership Team) increased by points compared to last year.

The ELT designates a small group of employees holding strategic positions within the company. This group consists mainly of members of the management committees of the various entities of the Company as well as corporate positions. Some exceptions may include important positions with crucial issues for the company or the group. The ELT plays a key role in ensuring that the Group's strategy and standards are rolled out and applied in all Group entities and functions.

Average age and age distribution

As at 31 December 2024, the average age of the Group's employees was 40.8 years. Employees aged 50 and over represent 20% of the total workforce; those aged 30 and under represent 10% of the total workforce.

Eramet Group carefully monitors the evolution of the age distribution of its managerial staff, particularly in order to anticipate the retirement of its key employees. Since the "People Review" process was implemented at the local, Business Unit and Group level, Eramet has had succession plans updated every year for all its key positions.

Adequate wages

Benchmark used

Eramet conducted an analysis to ensure employee compensation exceeds legal and contractual minimum levels in force in the countries where it operates. The company explicitly states this approach "is consistent with the definition of 'decent wages' as specified in the CSRD, which is based on minimum wages set by legislation or collective agreements, and which differs from the notion of living wage defined by the International Labour Organization (ILO)."

No living wage benchmark (such as Fair Wage Network, WageIndicator, Anker Methodology, or similar) was applied.

Coverage

100% of employees are paid above the legal and contractual minimums in force.

The analysis covered all employees on fixed-term or permanent contracts present at 31 December 2024 who joined the Group before 1 January 2024. Excluded from the study: temporary workers, service providers, interns, work-study students, and International Volunteer (VIE) employees.

Geographic scope

All countries where Eramet operates (global coverage).

Methodology

Data was extracted from the Eramet Group HRIS (Human Resources Information System), in full-time equivalents. Where discrepancies with minimums were identified, each situation was examined in detail, including fixed and regular premiums where applicable.

Targets and commitments

No specific targets related to living wage disclosed.

Social protection

Coverage by major life event

Eramet conducted a detailed analysis to identify coverage of risks connected to loss of income within the Group, including both public programmes and internal measures.

Percentage of employees covered by social protection against loss of income:

Eramet Global Care agreement

In 2024, Eramet signed the Eramet Global Care agreement, the first global agreement establishing a common social protection framework. This applies to all Group employees. Eramet is the first mining company to propose such a programme.

The agreement is based on three major pillars:

1. Death coverage: guarantee death coverage equivalent to one year's salary for all employees
2. Maternity and working conditions for women: provide all employees with favourable provisions concerning maternity, childcare and adapted working conditions
3. Health and prevention: offer all employees essential health coverage and prevention measures

Deployment timeline:

• End-2024: at least 75% of employees covered by one of the categories
• End-2025: 100% of employees covered by categories 2 and 3
• End-2026: 100% of employees with full coverage on all categories

2024 result: Eramet Global Care agreement signed and 1 pillar deployed at 100% of sites (125% performance level)

Coverage by type and country

Illness: All Group employees benefit from medical coverage in line with market practices. In addition to regulatory provisions, companies in France, Norway, Indonesia and New Caledonia (41% of the workforce) offer additional schemes to better cover lost wages in the event of illness.

Unemployment: Apart from public provisions, no Group company provides specific measures related to loss of income due to unemployment. As Gabon and Senegal do not have unemployment benefits, 53% of the Group's employees do not benefit from coverage if they lose their jobs.

Work-related accidents and disabilities: All countries provide compensation with duration and amount varying by local regulations. Companies in France, Indonesia, Norway, New Caledonia and Brazil have additional insurance providing coverage beyond public provisions (nearly 40% of employees).

Maternity leave: As part of Eramet Global Care, the Group committed to guaranteeing at least 16 weeks of maternity leave to all employees. Key implementations in 2024:

• Setrag (Gabon, 18% of female workforce): added 2 weeks to reach 16 weeks total
• Comilog (Gabon, 18% of female workforce): plans to add 2 weeks in 2025
• PT EIM (Indonesia): added one additional month
• Eramet South Korea, Tokyo, Taiwan: committed to offering additional leave to reach 16 weeks
• Eramet Grande Côte (Senegal), Eramine (Argentina), Eramet Shanghai (17% of female workforce): introduced more favourable provisions than statutory maternity leave

Paternity leave: Group companies apply legal provisions. Some offer more favourable measures: Eramine (Argentina), PT EIM (Indonesia), Eramet South Korea, and Eramet India PL.

Retirement: All countries have pension plans established by public authorities. Some Group companies have supplementary schemes:

• France: Company Pension Scheme (PERECO) and Compulsory Company Pension Scheme (PERCO) financed by employer
• Comilog and Setrag: pension scheme for managerial employees, co-financed by employee and employer
• Eramet Grande Côte (Senegal): severance payment upon retirement based on seniority and compensation
• Eramet Norway: defined contribution scheme

Supplementary schemes for Chair and CEO

Christel Bories benefits from:

• Supplementary healthcare plan: employer contribution of €1,373.88 (2024)
• Supplementary disability and life insurance scheme
• Pension plan: employer contribution should have been €1,153.74 but was suspended in 2024 due to pension scheme surplus earnings (all beneficiaries affected)
• Life insurance (Article 82): Annual supplementary remuneration of 30.39% of total gross annual remuneration. For 2024, employer contribution totalled €532,190 (€266,095 to insurer + €266,095 to offset social/tax charges)

Health coverage

In 2024, 100% of the Group's employees are covered by health insurance.

Persons with disabilities

Employment and integration of people with disabilities

Scope: France only

Number of employees: 14 employees with disabilities on the France scope

Methodology and limitations

A disability is defined as a limitation of activity or a restriction of participation in life in society suffered by a person in his or her environment due to a considerable, lasting or permanent impairment of one or more functions: physical, sensory, mental, cognitive or psychic. A disability can also be a disabling health problem. Several disabilities can be combined, in which case we speak of multiple disabilities.

Country exclusions: The regulations of certain countries do not permit the accounting of employees with disabilities. Furthermore, the definition of disability and the cultural approach to this subject is specific to each country and therefore difficult to standardise.

Actions and future plans

On the majority of Group sites, there are various actions to promote the employment of people with disabilities: adapting premises, access ways and workstations, awareness campaigns, financing of hearing aids, contributions to organisations or associations dedicated to helping people with disabilities, participation in forums, etc.

For France, the objective is to encourage and support employees to take steps to recognise the status of disabled worker (RQTH). Actions to raise awareness of disability have been put in place, notably through the Olympic and Paralympic Games, the holding of a conference in September 2024, and the implementation of actions during the SEEPH (European Week for the Employment of People with Disabilities) 2024, which will be organised again in 2025.

Reporting status: As noted in the sustainability report roadmap, percentage of workers with disabilities (S1-12) is compulsory for the 2025 reporting, with publication for the France scope and action plan to cover the scope of the Group.

Training and skills development metrics

Performance and career development reviews

In 2024, 5,710 employees took part in regular assessments of their performance and career development, i.e. 24% of women and 76% of men (for interviews managed in Talent@Work, our Group HRIS).

Annual reviews (EAA): Annual appraisal interviews aim to assess the individual performance of each employee during the past year, and to set the objectives (if any), for the coming year. They are mandatory for all Group employees.

Mid-year interviews: These aim to discuss the employee's professional project and development: career development, mobility, professional development plans, training needs, etc. These are mandatory for all Group Managers, and are gradually being extended to non-managerial staff.

As part of the 2024-2026 CSR roadmap, Eramet aims for 90% of employees to have a development interview each year. For non-managers, this development interview takes place at the same time as the EAA. These interviews are managed and administered in Talent@Work, our Group HRIS. Nevertheless, a certain number of non-managerial employees are non-connected employees (without access to a computer or work telephone), and these interviews are therefore conducted in a more "traditional" way in paper format.

Training hours

Number of training hours provided

In 2024, Eramet Group employees received more than 208,832.9 hours of training, representing approximately 23.7 hours per employee for the year. Thus, 5,451 employees, i.e. 62% of the total number of employees, attended a training course in 2024.

Work-study hours: Close to 19,643 work-study hours were also performed in France in 2024 within the Eramet Group, compared to 16,000 hours in 2023.

Training programmes

The Group develops training programmes specially designed for its employees to:

• Facilitate their integration
• Strengthen their managerial skills
• Encourage the sharing of best practices
• Structure and deploy appropriate development pathways

Eramet attaches particular importance to programmes focused on safety, the reinforcement of behavioural skills and the development of business skills. Special attention is paid to operational excellence and change management.

Leadership and management programmes include:

• Executive Development Programme (EDP) - 9 months, for senior executives
• Imagine - 18 months via distance learning, for Young Talents
• Propulse - for Eramet Leadership Team (ELT) positions
• Raise & Engage - for middle and senior managers, deployed internationally since 2023
• Management Fundamentals - for local managers, deployed in Africa, France, Indonesia and the United States since 2024

Three academies were inaugurated in 2023 and 2024: Sales Academy, Procurement Academy, and Supply Chain Academy.

Digital learning: The e-learning offer covers five areas:

• Integration of new employees
• Health, Safety and Environment
• Ethics & Compliance
• Diversity & Inclusion
• Business and Digital Technology

Digital content is available in four languages. Every Group manager has access to the WeLearn portal, offering self-service access to a wide range of digital resources (articles, videos, MOOCs, online courses).

Health and safety metrics

Coverage of health and safety management system

The safety management system covers 100% of employees (employees, temporary workers and subcontractors) who operate on the Eramet Group's sites. This information is also reported for other workers working on company sites, such as value chain workers, if they work at company sites.

Safety metrics – Eramet Group (excluding PT Weda Bay Nickel)

Safety metrics – PT Weda Bay Nickel

Definitions

TF1 (also known as TRIR): Workplace accident frequency rate of Eramet employees, temporary staff and subcontractors. Frequency rate of workplace accidents (fatal + with sick leave), expressed as the number of accidents per million hours worked.

TF2 (also known as TRIR): The workplace accident frequency rate is the number of workplace accidents (fatal + with sick leave + without sick leave) occurring during a given period, divided by one million hours worked.

Severity Rate (SR): Number of days not worked due to occupational accident × 1,000 / number of hours worked. The number of days not worked corresponds to the number of calendar days (Saturday, Sunday and public holidays included, excluding the day of the accident) on which the Eramet employee is absent as a result of the work accident (this does not include subcontractors).

These indicators have been established according to the definition of the International Labour Office (ILO) and according to the ICMM's guidelines.

Health metrics

In 2024, 100% of the Group's employees are covered by health insurance.

Eramet does not have a reliable tool to collect and monitor health-related data at all its sites. The Group is therefore unable to provide the number of cases of occupational illnesses or information related to deaths due to occupational illnesses. A digitisation plan for the health services of sites is in progress, which aims to obtain reliable data, carry out precise monitoring and implement the necessary actions.

Work-life balance metrics

Family leave entitlement and uptake

Within Eramet, 100% of employees are entitled to family leave.

In 2024, 744 employees took family leave, of which:

• 29% were women
• 71% were men (calculated)

This leave includes maternity, paternity, parental leave (birth or adoption) and caregiver leave (including sick child).

Maternity leave provisions

As part of Eramet Global Care, the Group has committed to guaranteeing at least 16 weeks of maternity leave paid at 100% to all its employees.

Maternity leave coverage by entity:

• Setrag (Gabon): Added 2 weeks to reach a total of 16 weeks (female workforce represents 18% of Group's female workforce)
• Comilog (Gabon): Plans to add two additional weeks to statutory maternity leave in 2025 (female workforce represents 18% of Group's female workforce)
• PT EIM (Indonesia): Adding one additional month
• Eramet South Korea, Eramet Tokyo, Eramet Taiwan: Committed to offering additional leave to reach 16 weeks
• Eramet Grande Côte (Senegal), Eramine (Argentina), Eramet Shanghai: Introduced more favourable provisions than statutory maternity leave (combined female workforce represents 17% of Group's female workforce)

Paternity leave provisions

Group companies apply the legal provisions concerning paternity leave. Some companies propose more favourable measures:

• Eramine (Argentina)
• PT EIM (Indonesia)
• Eramet South Korea
• Eramet India PL

Social protection coverage

Work-life balance initiatives

The Group promotes local initiatives to support work-life balance, including:

• Teleworking systems and agreements deployed across several entities
• Reorganisation of working time
• Allocation of universal service employment vouchers (CESU) for domestic help (childminding, tutoring, housework)
• Inter-company daycare
• Sabbatical leave for personal projects

During annual appraisal interviews, particular attention is paid to organisation of work, workload and work-life balance. Monitoring units have been set up at various sites in mainland France and New Caledonia to anticipate psychosocial risk situations.

Methodology note: Family leave data is managed through the Group's HRIS system. Some non-connected employees have interviews conducted in paper format.

Compensation metrics (ESRS S1-16)

Pay gap

Applicable scope and calculation methodology

For the calculation of the Gender Pay Gap indicator, Eramet selected entities and scopes with more than 400 employees, in order to ensure that the results were relevant. Staff in training (interns and work-study students), external staff and employees on fixed-term contracts were excluded from the calculation. This indicator includes the gross annual fixed salaries in full-time equivalent, converted into euros, taken from the HR Information System and converted back into hourly rates as required by the standard. In 2025, Eramet will conduct a feasibility study on extending the calculation base to include variable remuneration.

Results

The Group gender pay gap, based on the average of gross hourly remuneration converted into euros without geographical distinction is -19%, suggesting that women receive on average 19% more remuneration than men within the Group.

This result is mainly due to the geographical and functional breakdown of the workforce. In the mining sector, operational and manual positions, mainly held by men, are located in countries with lower standards of living, while women are more present in qualified positions in higher-paid areas. The method of calculating the metric does not take differences in the cost of living between countries, nor the breakdown of headcount by type of position into account. This result therefore above all reflects the structure of jobs within the Group without highlighting inequalities.

Eramet does not use the method recommended by the ESRS S1 to manage the pay gap, but an alternative approach where the gap is measured by hierarchical level and geography. This alternative calculation shows the following differentials:

Remuneration ratio

Calculation methodology

The remuneration ratio is an essential metric for assessing the fairness and consistency of the Company's remuneration policy. The calculation methodology is based on a detailed approach that takes the different components of remuneration paid during 2024 into account.

Calculation of the numerator (Chair and CEO):

• Fixed remuneration 2024
• Variable remuneration paid in 2024 in respect of 2023
• Contributions to the supplementary pension plan
• Performance shares granted during the same periods and valued at their fair value on the grant date

Calculation of the denominator (employees):

• Fixed remuneration 2024
• Variable remuneration paid in 2024 in respect of 2023
• Exceptional remuneration linked to job constraints
• Contributions to the supplementary pension plan
• Employee savings plans (incentives, profit-sharing and contributions)
• Performance shares granted during the same periods and valued at their fair value on the grant date

Applicable scope

The scope of analysis used to calculate the fair pay ratio includes all consolidated entities located in mainland France, namely: Eramet SA, Eramet Ideas, Eramet Services, and Comilog Dunkirk. Since 2024, this scope has been extended with the integration of SLN (Société Le Nickel), in order to broaden the calculation base and strengthen representativeness by including employees based in New Caledonia. Thus, the ratio is calculated on a scope covering approximately 27% of the Group's total workforce.

Results

Methodology

Eramet chose not to integrate all of the Group's international entities for several reasons:

• Significant differences in living standards between countries: The Eramet Group operates in countries with significant disparities in living standards. These differences make pay comparisons irrelevant and risk skewing the results of the fair pay ratio.

• Different compensation structures between countries: Compensation models and benefits vary widely by country. Taking them into account would require in-depth studies to identify comparable items, which exceed the data currently available. This complexity could affect the reliability of the information provided.

• Desire to guarantee reliable and representative data: By limiting the scope to entities located in countries where the remuneration structures are consistent and comparable, we ensure that the information is reliable. The integration of international data, as it stands, could lead to erroneous interpretations or inaccurate information.

A feasibility study will be conducted in 2025 to analyse how to extend this metric to a wider population.

The employees taken into account are all employees on permanent and fixed-term contracts (excluding interns and temporary workers) continuously present during the years mentioned. The remuneration taken into consideration includes gross annual remuneration (fixed and variable), employee savings (incentive schemes, profit-sharing, employer contributions), as well as the free and performance shares allocated, valued at their fair value on the grant date.

Incidents, complaints and severe human rights impacts

Incidents reported through whistleblowing platform (2024)

Definitions:

• A reported incident corresponds to a report sent to the Group's whistleblowing platform for which the informant chose the category that best corresponds to the reported facts
• A closed incident corresponds to an alert for which the investigation has been completed and conclusions have been made
• An established incident corresponds to an alert whose reported facts were verified during the investigation
• An incident of bullying also includes intimidation and violence in the workplace
• An incident of sexual harassment and sexist acts also includes sexist acts and gender-based violence

Other complaints and human rights impacts

There were no complaints through other channels such as the OECD contact points.

In the context of the mapping of human rights risks, the risk of modern slavery was not identified within the Group's workforce.

No serious incident contrary to the declarations of the International Labour Organization (ILO), the guiding principles of the United Nations and those of the OECD was noted in 2024.

Value chain workers

The risk of forced labour and child labour has been identified in the mapping of human rights risks for the value chains in Gabon, Senegal, Indonesia and China. The Human Rights Policy applies to subcontractors and the value chain through the Supplier Code of Conduct and contains a specific commitment regarding modern slavery, including prohibition of forced labour and child labour.

Policies related to value chain workers

Eramet discloses several policies that apply to value chain workers, particularly suppliers and subcontractors.

Human Rights Policy

Scope: The policy contains a commitment to respect human rights in the value chain. The commitments are included in the Supplier Code of Conduct, which Eramet asks eligible suppliers to sign (according to the Know Your Supplier procedure).

Key content / principles: The policy aims to ensure Eramet is part of a value chain responsible for international standards and best practices. It contains a specific commitment regarding modern slavery, and specifically on the prohibition of forced labour and child labour.

Link to international standards: The policy is aligned with international standards and best practices. The Group applies due diligence in accordance with the UN and OECD Guiding Principles to its value chain.

Monitoring: Two golden rules exist on modern slavery subjects to explain these concepts internally and provide examples that enable employees to identify at-risk situations, including in their relations with subcontractors. The Group's Human Rights risk mapping was updated in 2023 with a study of 11 sites in 8 countries, with special focus on risks associated with modern slavery, particularly forced labour and child labour.

Supplier Code of Conduct

Scope: The majority of suppliers are affected by this code. The eligibility threshold is defined in the Know Your Supplier procedure and is based on annual expenditure incurred or estimated with the supplier (€1,000 threshold). This threshold means that more than 85% of the supplier panel are eligible. Since 2024, for any new creation, each eligible supplier must sign the Supplier Code of Conduct.

Key content / principles: The code formalizes the Group's desire to strengthen its requirements and expectations in terms of sustainable development and ethics vis-à-vis its suppliers. Eramet sets out its requirements and best practices in terms of responsible purchasing. The code states that the Group "will exclude all contractual relationships with suppliers that are found not to comply with regulations on forced labour, child labour or minimum working age, discrimination, violence or found to be" [incomplete in excerpt]. The code reiterates the Group's commitments to human rights (citing the Ethical Charter and Policy).

Governance: The Group Purchasing Department is responsible for the Code of Conduct and its implementation.

Public availability: Eligible suppliers sign this document during the contracting process.

Monitoring: A compliance campaign has been launched for long-standing suppliers (particularly those created before the implementation of the Know Your Supplier procedure) and an internal management tool has been developed to monitor the progress of this compliance across the entire panel of eligible suppliers. An evaluation is performed for suppliers who decline CSR assessment or refuse to sign the Code of Conduct. Several options can be considered including on-site audit, taking equivalent evaluations/internal CSR questionnaire into account, studying the supplier's Code of Conduct and their compliance with it, or terminating the relationship with the supplier.

Responsible Purchasing Policy

Scope: The scope of this policy extends to all Group subsidiaries (mainly managed by the Group) and therefore all relationships with all suppliers.

Key content / principles: The policy aims to develop purchasing excellence, i.e. create sustainable performance, make responsible purchases, develop a community of excellence, strengthen the supplier relationship and manage risks proactively. The policy includes commitments to:

• Align with best practices by concretely integrating responsibility criteria in calls for tenders and the choice of suppliers (CSR criteria, carbon impact, local impact, etc.)
• Compliance with the requirements of the IRMA (Initiative for Responsible Mining Assurance) standard
• Dedicated business procedures for purchasing teams, ensuring a relevant, operational purchasing methodology aligned with best practices

Governance: The Group Purchasing Department defines the Group's ambition through this responsible purchasing policy.

Link to international standards: The policy is in line with the requirements of the IRMA (Initiative for Responsible Mining Assurance) standard. However, the document is not associated with any international standard or initiative [this appears contradictory in the excerpt].

Ethical Charter

Scope: Applies to suppliers and subcontractors.

Key content / principles: The charter covers human rights issues such as discrimination, health, safety and harassment, as well as reliable and fair trading.

Monitoring: For certain suppliers and subcontractors (following the KYS procedure), key documents such as the Ethics Charter are communicated and signed by the service provider company during the contracting process.

Whistleblowing System (Integrity Line)

Scope: The Integrity Line system is the Group's whistleblowing mechanism, available to external stakeholders, including contractors and suppliers.

Key content / principles: The system enables value chain workers to raise concerns.

Note on Weda Bay

The document notes that Eramet's purchasing processes and standards do not apply to Weda Bay, which is a minority subsidiary whose purchases are managed by the IWIP industrial park. This limits the Group's level of control and guarantee over this part of the value chain, though safety standards are rigorously applied.

Taking action on material impacts on value chain workers

Eramet differentiates between on-site subcontractors and off-site subcontractors and suppliers in managing impacts on value chain workers.

Actions for on-site subcontractors

Communication of commitments

• What it does: For certain suppliers and subcontractors (following the KYS procedure), key documents such as the Ethics Charter and the Supplier Code of Conduct are communicated and signed by the service provider company during the contracting process
• Objective: To communicate to partners the Group's commitments in terms of CSR and human rights, and the behaviour expected in the relationship to ensure compliance with these commitments in the value chain. To send the same messages on what is allowed or not to all workers on site, and to inform them about the available remedies in the event of violation of the internal rules
• Scope: Upstream value chain (on-site subcontractors)

Internal organisation – Safety rules

• What it does: The same safety rules are mandatory on all sites for both subcontractors and Group employees. All site workers must take part in safety induction sessions before each supply of a service begins, and subcontractors or day labourers must also have a medical check-up before the start of each assignment
• Objective: To ensure that the Group's safety standards are respected by all workers on site and that the same level of protection is given to everyone
• Scope: Upstream value chain (on-site subcontractors)

Reporting incidents

• What it does: Different ways of reporting incidents are available. If, for example, a subcontractor raises an unpaid wage issue, the subsidiary may ask the subcontracting company for explanations to verify this point and ask for the situation to be remedied. With regard to safety incidents, there is no differentiation between whether the incident affects an employee, a temporary worker or a subcontractor, and the situations are treated in the same way
• Scope: Upstream value chain (on-site subcontractors)

Verification and investigation

• What it does: Impact identification through reporting of issues directly to site staff (e.g. risk of discrimination or harassment, impacts related to safety and health), security incidents reported in the tool for managing and monitoring safety actions, or use of the Integrity Line whistleblowing system. Verification and investigation actions are set up following these reports to determine whether the impact is established and to be able to remedy it
• Scope: Upstream value chain (on-site and off-site subcontractors)

Remediation

• What it does: The Group's subsidiaries do not always have a wide margin of manoeuvre to remedy situations caused by companies in the value chain. In the event that the incident relates to a health or safety issue, the only thing that will not be monitored by the subsidiaries is the return to work of the subcontracted employee; in other cases, the Group raises awareness and requests remediation, but this is not guaranteed due to the service provider company's independence
• Scope: Upstream value chain (on-site subcontractors)
• Limitations: Room for manoeuvre limited; service providers are independent entities

Actions for off-site subcontractors and suppliers

• What it does: The same actions are set up for off-site subcontractors, but the feedback is given almost exclusively through Integrity Line, and the room for manoeuvre to investigate and remedy situations is even more limited
• Scope: Upstream value chain (off-site subcontractors and suppliers)
• Limitations: Very limited ability to investigate and remedy situations

CSR and ethics assessments (linked to supplier management)

• What it does: CSR assessments and/or ethics screenings are conducted, which may be supplemented by due diligence measures. Results allow the Responsible Purchasing Committee to define the degree to which suppliers identified as at risk are in compliance or in breach, and decide upon risk management actions
• Monitoring: Implementation of the CSR Roadmap is subject to half-yearly reporting to the Group's Executive Committee and annual reporting to the Board of Directors' Strategy and CSR Committee
• KPIs: Performance indicators for updating risk mapping and rollout of supplier assessments are monitored by the Responsible Purchasing Committee. Indicators related to the CSR Roadmap monitor the compliance rate of Group suppliers identified as at risk
• Scope: Upstream value chain (suppliers and subcontractors)
• Governance: Purchasing, Legal, Ethics and Compliance, Safety, Social Impact and Human Rights and Group CSR departments are involved

Water management plan (affecting value chain workers)

• What it does: All sites must develop and implement a water management plan by 2026, which will include the impact of Eramet's activities on water consumption
• Time horizon: Medium-term (by 2026)
• Scope: Own operations (with potential indirect impacts on value chain)

Site-specific initiatives

PT Weda Bay Nickel (Indonesia) – Traffic management

• What it does: No concurrent activity between roads used by local communities and those used for mining transport operations. Roads used for mining transport are sprayed regularly to reduce dust
• Scope: Own operations (affecting value chain workers and communities)

Eramine (Argentina) – CARE/APELL programme

• What it does: Since 2022, involvement in the CARE programme (global voluntary initiative of the chemical industry aimed at continually improving health, safety and environmental protection). Sessions with CSR, Health & Safety and Logistics experts explaining how chemicals are transported, preventive measures and actions to limit incidents. In 2024, the Logistics and Roads Department continuously lectured to subcontractors and suppliers on steps to properly deliver effective training to drivers. Apell (replacing CARE) local awareness-raising and emergency preparedness meetings held in April 2024 in San António de Los Cobres and Campo Quijano with 52 participants
• Stakeholders engaged: Kolla community, schools, Salta Chamber of Transport, Traffic Department, National Gendarmerie, subcontractors and suppliers
• Time horizon: Ongoing; interviews planned in Santa Rosa de los Pastos Grandes and Estación Salar de Pocitos in 2025
• Scope: Upstream value chain (subcontractors and suppliers in transport and logistics)

Limitations noted: The Group acknowledges that it "only has real room for manoeuvre for the upstream value chain, within the framework of ongoing services, for the subsidiaries that it controls" and that "there is no procedure to remedy or enable significant negative impacts on the value chain to be remedied other than the safety procedures presented in ESRS S1 and the whistleblowing system management procedure."

Targets related to value chain workers

Supplier CSR Assessment Target

Additional context:

• The target is part of the Act for Positive Mining roadmap
• High-risk suppliers identified through cross-referencing three criteria: CSR risk in supplier's business sector, CSR risk in supplier's country, and estimated annual expenditure
• 127 high-risk suppliers identified through CSR purchasing risk mapping carried out in 2023
• Methodology for 2024 result: (suppliers assessed + those with whom commercial relationship has been terminated) / total suppliers considered to be high-risk
• Action includes completing EcoVadis assessment or internal CSR questionnaire; if not completed, business relationship is not continued
• This work has been a key subject in 2024 and will continue for the next two years

Policies related to affected communities

Eramet addresses affected communities through multiple policy documents that form part of its human rights due diligence system aligned with international standards including the World Bank Performance Standards, UN Guiding Principles, and OECD Guidelines.

Human Rights Policy

Key content and principles:

The Group's Human Rights Policy includes a specific pillar dedicated to local communities, setting out commitments regarding:

• Respect for indigenous populations
• Respect for the identity, culture, heritage, traditions and customs of all impacted communities
• Establishment of dialogues and complaint management mechanisms
• Compliance with resettlement, relocation and land acquisition standards
• Reduction of environmental impacts and nuisances (pollution, health and safety, access to resources, etc.)
• Security risks due to the activity of site security forces

Scope:

The Policy applies to all sites controlled by the Group.

Governance and oversight:

• At the Executive Committee level, compliance is the responsibility of the Director of Sustainable Development and Corporate Commitment
• The Group Societal Impact and Human Rights Department manages and deploys strategies for Community Relations, Respect for Human Rights, Philanthropy and Sponsorship, and dialogue with civil society and NGOs

Supporting framework:

To ensure application of these commitments, the Group implements:

• Key Standard on human rights - details the safeguards to be put in place by entities
• Key Standard on community relations - establishes the framework for managing site-community relationships in compliance with international standards
• Golden Rules on Human Rights and Community Relations - sets foundations and do's and don'ts that all operational staff must know
• Business procedures in Community Relations - intended to standardise operational practices

Linkage to international standards:

These documents are an integral part of the Group's due diligence system in accordance with:

• World Bank Performance Standards
• UN Guiding Principles
• OECD Guidelines

No proven cases of violation of these guidelines were identified in 2024.

Monitoring and implementation:

The Group Societal Impact and Human Rights Department:

• Defines standards and procedures applicable across the entire Group in coordination with site managers and ensures their monitoring
• Coordinates associated action plans by relying on local teams and provides them with support and expertise
• Implements appropriate training for maintaining skills and adapting to the Group's changing challenges
• Consolidates reporting of societal expenditure (impact management and positive contribution)
• Develops contributory CSR programmes

The due diligence process includes:

1. Assessing - through risk mapping, impact studies, resettlement action plans, livelihood restoration plans, perception studies, dialogue and consultation meetings, and complaint management mechanisms
2. Implementation - specific engagement plans for indigenous populations to obtain free, prior and informed consent

Continuous assessment processes include interviews with community representatives (around 30 interviews conducted with external stakeholders including communities) and ongoing studies as part of community relationships.

Taking action on material impacts on affected communities

Overview

Eramet has implemented a comprehensive community relations framework structured around its "Act for Positive Mining" strategy. The approach focuses on:

• Managing negative impacts on local populations
• Establishing transparent and constructive dialogue with affected communities
• Investing in local development through community initiatives

Key Actions and Programmes

1. Community Investment Programme

Scope: All mining and industrial sites (Indonesia, New Caledonia, Argentina, Gabon, Senegal, Norway, Dunkirk)

Resources allocated (2024):

• €11 million: community investment and sponsorship (Group-level)
• €5 million: PT Weda Bay Nickel
• Total: €16 million

Focus areas:

• Education
• Health
• Sport & culture
• Infrastructure
• Support for economic diversification

2. Eramet Beyond for Contributive Impacts Programme (launched 2022)

Objective: Create sustainable jobs outside the Group's value chain and support economic diversification

Resources allocated (2024):

• €4.7 million (included in the €11 million Group community investment)

Expected outcomes (targets by end of 2026):

• 6,000 jobs created or supported over the long term (excluding the Group's value chain)
• 500 young people supported in training leading to qualifications (50% from local communities, 50% girls)

Three economic development levers:

• Capacity building (training, coaching)
• Access to financing (microfinancing, introduction to business angels)
• Access to markets (introduction to clients, supply chain support, self-promotion)

Three axes of action:

• Economic diversification
• Reduction in educational and gender inequalities
• Environmental resilience

2024 results:

• 181,242 project beneficiaries
• 1,847 new jobs supported
• 271 young people supported through scholarships

3. Gabon - CSR Funds and Local Community Development Funds (FDCL)

Scope: Comilog and Setrag operations in Gabon

Resources allocated (2024):

• Comilog total: €11.6 million (€4.1 million FDCL + €8.7 million CSR fund)
• Setrag: €340,000

CSR Fund structure:

• Contribution rate: 2% of Comilog's operating income annually
• Governed by partnership management committee (Comilog, Eramet, Gabonese State representatives)

Projects implemented (2024):

• 21 projects at Comilog focusing on employability and infrastructure

Specific initiatives:

Digital Training Centre (Fablab):

• Free training in digital professions for local people
• 35 young people trained (2,900 training hours)
• Skills: design/graphics, web/mobile development, electronics/robotics

Paving Stone Manufacturing Plant (Konda):

• Operational since March 2021
• 39 employees
• Production used for Moanda road rehabilitation

Education Infrastructure:

• 4 additional classrooms constructed
• Media library in Bakoumba
• Multimedia room at Zachary Maïka high school
• Construction of high school of excellence in Moanda (started 2024)
• IT equipment provided to schools
• Didactic materials to Lauriers College
• Benefits: >2,200 primary and high school students

Road Rehabilitation:

• 12 kilometres rehabilitated in 2024
• 20 km total since 2020
• Estimated beneficiaries: >50,000 people

Public Lighting:

• 430 solar streetlights installed in 2024
• 1,900 total streetlights (1,330 solar) rehabilitated/installed
• Coverage: Moanda, Mounana, Bakoumba and surrounding villages
• Estimated beneficiaries: ~50,000 people

Health Infrastructure:

• Rehabilitation work and equipment provision for Departmental Hospital of Moanda (opening scheduled 2025)
• Telehealth project with next-generation scanner (commissioned 2023)

Setrag programmes:

• Training for young unmarried mothers with disabilities (hairstyling/aesthetics)
• Gender-Based Violence (GBV) awareness campaigns: 2,200+ people reached
• Water access: borehole construction for Eljireh orphanage (55 beneficiaries)

Total Gabon beneficiaries: >77,000 people

4. New Caledonia (SLN) - Community Investment

Context: Programme limited in 2024 due to political crisis

Resources: Not specified for 2024

Projects completed:

• 20 medical practices equipped with emergency kits
• Drinking water supply network for Poum municipality
• Néoua tribe Chapel in Houaïlou
• Driving licence programme for young people in Thio

Total beneficiaries: >1,500 people

5. Indonesia (PT Weda Bay Nickel) - Community Engagement

Resources allocated: €5 million (2024)

Engagement activities:

• 108 community meetings held in 2024
• Topics: impact management, participatory environmental monitoring, complaint-handling, visits by local authorities

6. Argentina (Eramine) - Indigenous Community Consultation

Scope: Lithium project development

Engagement approach:

• Free, Prior and Informed Consent (FPIC) process
• Regular community assemblies
• Dialogue with Santa Rosa de los Pastos Grandes and Centenario Ratones communities
• New exploration project launched in Salar de Arizaro/Tolar Grande

Communication channels:

• Community meetings with authority participation
• Email communications
• Governmental meetings
• Consultation and complaints procedures
• Active participation in environmental monitoring

7. Senegal (GCO) - Community Engagement

Engagement:

• Resettlement programmes
• Dedicated consultation activities
• IRMA external audit process begun in 2024

8. IRMA Standard Deployment

Scope: All mining sites

Timeline: Commitment by end of 2026

Progress (2024):

• 3 sites in self-assessment process
• GCO: first independent audit in finalization (corrective plan developed)
• PT Weda Bay Nickel, Eramine, Comilog: preparing for independent audit by end of 2026

9. Local Employment and Subcontracting

Scope: All operations

Results (2024):

Gabon (Comilog + Setrag):

• 3,700+ direct employees (>98% Gabonese)

• 10,400 jobs including subcontractors

• 500 people employed on CSR infrastructure sites

New Caledonia (SLN):

• 1,900+ employees (89% Caledonian)

• 2,600 jobs including subcontractors

• 45% of purchases in New Caledonia (>€200 million)

Senegal (GCO):

• 837 employees (99% Senegalese)

• 2,500 jobs including subcontractors

Argentina (Eramine):

• 480 employees (97% Argentine)

• 3,100 jobs including construction subcontractors

Local purchasing:

• Mining activities: >50% purchases in country of operation
• Comilog/Setrag: 65% local purchases

10. Training and Education Programmes

Moanda School of Mines and Metallurgy (E3MG) - Gabon:

• Partnership with Gabonese State since 2016
• 33 diplomas awarded in 2024 (8 engineers, 25 professional licenses)
• 35 students enrolled for 2023-2024

Setrag Pre-employment Training (2023-2024):

• 80+ young people trained
• Programmes: railway management, track supervision, technical roles

11. Complaint Management Mechanisms

Scope: All sites

Framework:

• New business procedure on complaint management mechanisms (2024)
• Requirement for regular consultation with affected communities
• Monitoring of interaction tone since 2021
• Specific provisions for vulnerable populations
• Non-retaliation policy

Examples:

• GCO: Comic strip produced to explain complaints mechanism
• Community offices established at various localities (Comilog, SLN)
• 21 local monitoring committees in Gabon (6 members each including village/district chief, 2 women, 2 young people)

Link to Policies and Targets

Policies:

• Human Rights Policy (specific pillar on local communities)
• Key Standards on human rights and community relations
• Golden Rules on Human Rights and Community Relations

Targets (Act for Positive Mining roadmap 2024-2026):

• Objective 3: 6,000 jobs created/supported; 500 young people in training
• Objective 8: Human rights approach development
• Objective 10: IRMA standard deployment at all mining sites

Governance:

• Sustainable Development Directors responsible for community relationship management
• Societal Impact & Human Rights Department (DISDH) owns EMS process for community relations

Effectiveness Evaluation

Monitoring approach:

• New business procedure on governance of community relations data (2024)
• Standardized monitoring and evaluation of community projects
• Measurement indicators: analysis, results, performance, efficiency
• Tools: Safee, Power BI, Triskell
• DISDH assessment of all major subsidiaries planned for 2025
• Stakeholder perception surveys to be repeated in 2025

Priority Human Rights Risks Addressed

1. Community safety: Transport-related risks (train/car accidents)

   • Action plans systematically implemented following accidents in 2024

2. Impacts on indigenous peoples: Managed through community impact management processes

3. Cumulative impacts: Addressed through dialogue and complaint management at Eramet Norway, Comilog Dunkirk, and Weda Bay (noise, dust, safety concerns)

Targets related to affected communities

Setrag

Resettlement and livelihood restoration programmes

• Target metrics: Number of households to be compensated, number of people to be compensated, number of women to be compensated, number of vulnerable people to be compensated, surface area of land affected, number of households to be physically relocated, number of people to be physically relocated, number of women to be physically relocated, number of vulnerable people to be physically relocated and the equivalent in economic travel; by locality
• Target type: Absolute values measured in number of people
• Target period: Multi-year basis over the period of implementation of the RAP or PRMS
• Baseline: Not disclosed
• Scope: Setrag operations, by locality
• Monitoring: Targets are regularly monitored annually
• Validation: RAPs and PRMSs are built by experts and submitted to public consultation during their construction and during a feedback meeting to affected stakeholders
• Progress: As this management method began in 2024, only two mining sites have deployed it in a structured manner. The rest of the subsidiaries start implementation in 2025

Complaints resolution

• Target metric: Number of days of resolution (all types of complaints combined)
• Target value: Not quantified (target was determined as an improvement on the previous year's score)
• Baseline: Previous year's score (not quantified)
• Scope: Setrag operations
• Monitoring: Measured annually
• Objective: Ensure compliance with the Host Communities Key Standard and the new business line procedure for managing complaints
• Progress (2024): The target has not yet been achieved at Setrag

GCO

Rail and road safety awareness campaigns

• Target metrics: Number of people informed, number of women informed, number of young people informed, number of vulnerable people informed
• Target type: Absolute values measured in number of people
• Target period: Drawn up annually for each locality affected
• Baseline: Based on stakeholder mapping, which involves discussions with interested parties
• Scope: By locality (Diourmel, Lompoul, Foth, Gouyette Chrif)
• Objective: Respect the Human Rights Policy and the Host Communities Key Standard and Human Rights on community safety

Progress (2024):

• Road safety: Raised awareness among more than 460 people out of the 400 target in the villages of Diourmel, Lompoul and Foth (115% achievement)
• Rail safety: Achieved only 60% of target for awareness-raising on rail safety in Gouyette Chrif

Positive impacts - Local procurement

Target metric: Percentage of amount spent on purchases spent locally

Progress (2024):

• Setrag (Gabon): 75% of the amount spent on purchases were spent in Gabon in 2024, i.e. more than €300 million
• GCO (Senegal): 60% of the amount spent on purchases were spent Senegal in 2024, i.e. nearly €100 million
• Eramine: 75% of the amount spent on purchases (data incomplete in excerpt)

Policies related to consumers and end-users

Eramet provides several publications relevant to consumers and end-users on its website www.eramet.com. The following documents, further detailed in chapter 5.8 Company workforce [ESRS S1], are intended to be of interest to direct and indirect customers:

Ethics Charter

Public availability: Available on the Group's website (www.eramet.com)

Scope: Available to everyone, including direct and indirect customers

Content and principles: Customers are informed of the existence of the Ethics Charter as it is mentioned in the General Terms and Conditions of Sale. A link to the Group's Ethics Charter is provided for customers in the General Conditions of Sale.

General Terms and Conditions of Sale

Public availability:

• Simplified version indicated on the back of each customer invoice
• Complete version accessible via link on the front of each invoice
• Available online on Eramet's website

Scope: Applies to all customers

Human Rights Policy

Scope: The Group considers that all its business partners (customers, suppliers, subcontractors and partners) must share the same principles and values as those mentioned in this policy

Content and principles: The document explains that Eramet's goal is to be part of a value chain that respects human rights and shares these principles with customers, suppliers, subcontractors and partners.

Know Your Customer Procedure

Scope: Applies to all customers managed by Eramet and its subsidiaries

Governance: Cases where an ethical risk is identified are analysed by the Responsible Sales Committee, which includes the Legal Department, the Environment Department and the ESG Performance Team

Content and principles:

• Reflects Eramet's desire to develop and implement relevant and effective measures to identify, reduce, and if possible, eliminate legal, financial or reputational risks related to business relationships and negative impacts they can generate
• Formalizes CSR and Ethics risk analysis measures to assess the position of customers in these areas
• Ensures that practices and behaviour of third parties do not generate similar risks to those assessed by the Group in its own activities
• Specific goals include protection of the environment and respect of Human Rights and ethics in business relationships

Monitoring implementation:

• E-learning course based on this Group-wide procedure rolled out to sales teams
• Since 2018, the Group has been using a specialised database provided by an external service provider for initial screening of third parties
• All customers are continuously monitored via this screening tool
• Sales teams are instantly informed of any change in a third party's situation and can revise the rating accordingly
• When a risk arises from screening, the Ethics and Compliance Department is contacted by the Sales Department

Taking action on material impacts on consumers

Know Your Customer (KYC) Process

Description: Ethics and CSR assessments carried out for all direct customers according to a four-level typology.

Scope: Direct customers to which Eramet sells commercial products (manganese alloys and ore, Nickel, Mineral Sands and Lithium). Applies to all customers of the Sales Department based in Paris.

Assessment Results (2024):

Performance: At year-end 2024, 1,426 customers had been assessed using this procedure since the launch of the initiative. Around 97% of the assessment results were in conformity with the Group's commitments (green or yellow rating).

Governance: During 2024, the Responsible Sales Committee met several times to decide on cases where risks had been potentially identified. In parallel, the Ethics Department received cases from the Sales Department for an opinion and arbitration of negative information reported.

Risk Management Actions for Non-Compliant Customers:

• Strengthened ethical statements or clauses are included in offers and other contractual material
• The file is submitted to the Committee for prior approval for each new offer in order to closely monitor any changes in the negative information identified
• A third-party evaluation questionnaire is sent to the customer to obtain additional information

Resources: Non-financial resources include the Responsible Sales Committee and Ethics Department involvement.

Link to Target: Supports the target that 100% of customers are assessed each year on their CSR compliance and ethical commitment (see S4-5). The objective was achieved at the end of December 2024, as it was in 2023.

Note on End Users

Eramet has not set a target directly for end users, owing to its distance from the market, the opacity of the value chain and its very limited responsibility.

Targets related to consumers

Eramet has set one target related to consumers (direct customers):

Customer CSR and Ethical Assessment Target

End Users

Eramet has not set a target directly for end users, owing to its distance from the market, the opacity of the value chain and its very limited responsibility.

Business conduct policies and corporate culture

Eramet has established a comprehensive business conduct framework governed by its Ethics Charter and supported by multiple policies accessible to all employees through the Eramet Management System (EMS). The Ethics Charter and key policies are publicly available on the company website (www.eramet.com).

Ethics Charter

Scope: All Group employees and external stakeholders

Key commitments:

• Diversity and inclusion of employees
• Safety of employees
• Health and safety of the working environment
• Prevention of all forms of discrimination
• Fight against all forms of harassment
• Fair social dialogue
• Respect for privacy and personal information of employees
• Development of communities
• Development of relationships of respect and trust with all stakeholders
• Respect for and protection of the environment
• Relationship with customers
• Reliable and accurate market information and prevention of insider trading
• Prevention of corruption
• Prevention of all forms of money laundering
• Combating conflicts of interest
• Compliance with competition rules
• Respect for confidentiality and industrial property
• Preservation of Eramet's image and reputation

Governance: The Ethics Charter oversees the Group's management system and is guaranteed by the Chair and CEO.

Public availability: Available on www.eramet.com and via the internal Eramet Management System (EMS)

Monitoring: Employees receive theme-specific e-learning courses on ethics annually. The Ethics and Compliance Department coordinates implementation.

Anti-Corruption Policy and Code of Conduct

Scope: All Group employees and business partners

Key content:

• Zero tolerance concerning corruption
• Ban on facilitation payments
• Ban on inappropriate political activities
• Ban on manipulation of tendering processes
• Rules on gifts and invitations
• Rules on donations and sponsorship
• Rules on conflicts of interest
• Rules on lobbying
• Rules on intermediaries
• Rules on mergers and acquisitions

Links to international standards: Complies with requirements of France's Sapin II Law of 9 December 2016

Public availability: Ethics Charter and Anti-Corruption Policy accessible on www.eramet.com

Governance: Ethics and Compliance Department, with full-time Compliance Officer, Ethics and Compliance Coordinators, and Ethics and Compliance Ambassadors

Monitoring:

• Anti-corruption compliance programme rolled out in 2018 based on three pillars: organisation, guidelines and tools
• Permanent ethics and compliance controls integrated into the Group's internal control framework
• Annual second-level controls on all concerned sites covering Ethics Charter, Anti-Corruption Policy, gifts and invitations, conflicts of interest and whistleblowing system
• Mandatory anti-corruption e-learning for all connected employees (renewed every 18 months; 100% pass rate required)
• Specialized training for purchasing and sales functions (identified as most exposed to corruption risk)
• Anti-corruption performance metrics included in variable remuneration calculations at certain sites

Human Rights Policy

Scope: All Group operations and value chain (suppliers and subcontractors through Suppliers' Code of Conduct)

Key commitments:

• Commitment to respect human rights in the value chain
• Specific commitment on modern slavery, prohibition of forced labour and child labour
• Alignment with best practices by integrating responsibility criteria in calls for tenders
• Alignment with IRMA (Initiative for Responsible Mining Assurance) standard requirements

Links to international standards:

• International Bill of Human Rights
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• ILO recommendations

Public availability: Available on www.eramet.com

Monitoring:

• Human rights risk mapping updated in 2023 covering 11 sites in 8 countries
• Action plans developed for each identified risk
• E-learning module "Understanding and integrating human rights in business" launched in 2020, updated in 2024, available in four languages
• Over 2,000 participants completed the training by end of 2024
• Regular awareness-raising sessions (283 people trained in 2024 on human rights issues)
• Internal audits collaborate with Social Impact and Human Rights Department

Environmental Policy

Scope: All Group companies and employees

Public availability: Available on www.eramet.com

Climate Policy

Scope: All Group operations

Public availability: Available on www.eramet.com

Safety Policy

Scope: All entities and subcontractors

Key commitments:

• Safety defined as a core Group value
• Target of zero fatal accidents at industrial and mining sites
• Target TF2 accident frequency rate of less than 1

Governance: Signed by members of the Group Executive Committee and management committees of each site. Safety and Prevention Director reports directly to the Group's Chief Operating Officer and functionally to the Chair and Chief Executive Officer.

Public availability: Available on www.eramet.com

Monitoring:

• Variable remuneration of eligible staff includes two safety criteria (serious accidents and frequency rate; closure of preventive actions)
• Safety information system rolled out across all industrial and mining sites
• Regular safety visits by management teams

Health Policy

Scope: All Group operations

Public availability: Available on www.eramet.com

Human Resource Management Policy

Scope: All Group employees

Public availability: Available on www.eramet.com

Key framework: Human Resources Management Roadmap 2020-2025 focusing on talent development, diversity, social dialogue, and organizational culture

Risk Management Policy

Scope: All Group operations

Public availability: Available on www.eramet.com

Responsible Lobbying Policy

Scope: All Group lobbying activities in all countries of operation

Key objectives:

• Ensure continuity of operations at Group sites
• Defend Eramet's ambitions as a player committed to energy transition and responsible mining
• Strengthen dialogue with French, European and international institutions

Governance: Managed by Corporate Affairs Department, which reports to the Sustainability and Corporate Engagement Department

Public availability: Available on www.eramet.com

Monitoring:

• Lobbying activities published on dedicated platforms (High Authority for Transparency and Public Life in France and Transparency Register of the European Union)
• Corresponding budgets allocated to lobbying disclosed
• Persons in charge of lobbying receive necessary skills training

Digital Usage Policy

Scope: All employees of each Eramet Group company, regardless of status (employees, temporary workers, interns, service providers), and all persons with access to communication tools or IT resources

Key principles: Based on principles of loyalty and trust; defines general conditions of use of Information and Communications Technologies (ICT)

Public availability: Available on www.eramet.com

Supporting standards: Key Standards for Group Information Systems Management, Application Portfolio Management, IS Security Governance and Use of digital tools

Suppliers' Code of Conduct

Scope: All suppliers, subcontractors and service providers. Applicable to suppliers exceeding €1,000 annual expenditure threshold (covering approximately 85-90% of supplier panel)

Key expectations:

• Human Rights and working conditions
• Environment and products
• Good business practices
• Compliance with principles of Group's Ethics Charter and Human Rights Policy

Public availability: Available on www.eramet.com

Monitoring:

• Mandatory signature for all new eligible supplier creations since 2024
• CSR and ethics assessments via Know Your Supplier (KYS) procedure
• Over 8,000 suppliers continuously assessed via SRM (Supplier Relationship Management) tool
• EcoVadis assessments or internal CSR questionnaires for high-risk suppliers
• Compliance campaign for long-standing suppliers
• Group may terminate contractual relationships with suppliers found non-compliant with forced labour, child labour or minimum working age regulations
• Responsible Purchasing Committee monitors supplier compliance

Tax Policy

Scope: All Group entities

Key objectives:

• Securing and streamlining Group taxation
• Compliance with tax obligations

Governance: Group Tax Department collaborates with Legal Department. Internal procedures including key control mechanisms established with Internal Audit Department.

Whistleblowing System (Integrity Line)

Scope: All internal employees and external stakeholders (suppliers, subcontractors, customers, local communities)

Coverage: Reports on corruption, bribery, money laundering, fraud, theft, conflicts of interest, sanctions violations, anti-competitive practices, discrimination, harassment, sexual harassment, human rights violations, personal data breaches, environmental violations, health and safety violations, security breaches, and other conduct contrary to Group policies

Access: Available 24/7 via website https://eramet.integrityline.org/, by telephone via free numbers (22 countries), and displayed via QR codes on posters at all Group sites

Protection measures:

• Total confidentiality for whistleblowers
• Option to remain anonymous (where allowed by local law)
• No retaliatory measures for good faith reporting
• Hosted by external service provider complying with GDPR
• Investigators have enhanced confidentiality obligations

Governance: Managed by Ethics and Compliance Department. Chief Compliance Officer reports to Chair and CEO. Statistics sent to Executive Committee. Ad hoc reporting to Board of Directors during Audit, Risks and Ethics Committee meetings.

Monitoring:

• 116 reports received in 2024 (4% decrease from 2023)
• 15% of reports from external stakeholders
• 50 reports closed during 2024, with 8 confirmed as well-founded
• Investigation process completed within 3 months with feedback to reporter
• Study on confidence in the system conducted in 2021, 2022 and 2023

Integration into incentive schemes

The Board of Directors annually assesses achievement of performance criteria for annual and long-term variable compensation, which includes CSR roadmap performance, safety, and decarbonisation objectives. Variable remuneration of eligible staff includes safety criteria (serious accident and frequency rate, closure of preventive actions) and at certain sites includes completion rate of ethics and compliance training programmes.

Incidents of corruption or bribery

Confirmed incidents

In 2024, the Group was not convicted of any breach of legislation relating to acts of corruption or the fight against corruption.

No serious incidents contrary to the declarations of the International Labour Organization (ILO), the guiding principles of the United Nations and those of the OECD were noted in 2024.

Whistleblowing system reports

The Group received 116 reports through its Integrity Line whistleblowing system in 2024, a slight 4% decrease compared to 2023, but a rise of 27% compared to 2022. Of the 50 reports closed during the year, 8 were considered well-founded.

The breakdown of confirmed reports by Duty of Care categories is provided, though specific corruption/bribery incidents are not separately quantified in the available excerpts.

Investigation and speak-up mechanisms

Eramet provides an Integrity Line whistleblowing system available to all internal and external stakeholders in 22 countries and 13 languages. The system ensures confidentiality and, where local law permits, anonymity. Whistleblowers are protected against retaliation when acting in good faith.

When a report is made, acknowledgment of receipt is sent within seven days. Reports undergo an admissibility check, pre-analysis, and internal investigation. The Ethics and Compliance Department appoints investigators, and external providers may be engaged when necessary. Feedback is provided to reporters within three months.

The Group has an anti-corruption compliance programme based on risk mapping (updated in 2024), policies and procedures, whistleblowing system, training programmes, third-party assessment system, and control and audit guidelines. All eligible employees (according to Know Your Supplier procedure) must sign the Supplier Code of Conduct, which states the Group will exclude contractual relationships with suppliers found not complying with regulations on forced labour, child labour, or minimum working age.

Targets

Quantitative targets for anti-corruption have not been defined in 2024. Action plans drafted in 2025, following the new corruption risk mapping, will make it possible to establish quantitative targets.

Political influence and lobbying activities

Political engagement approach

Lobby refers to any action of influence or information initiated by a representative of the Group's interests to a public official, in France or abroad, aimed at guiding a public decision. Lobbying aims to defend the Group's interests and provide public decision-makers with technical expertise on the consequences and practical scope of current or proposed legislation.

The purpose of the Group's lobbying activities is to ensure the continuity of its operations at the Group's various sites, to defend Eramet's ambitions as a player committed to energy transition and responsible mining, and to strengthen dialogue with French, European and international institutions.

Lobby activities are managed by the Corporate Affairs Department, which reports to the Sustainability and Corporate Engagement Department. It serves as the link with the different Group entities based on the topics at hand. The Chair and CEO, the members of the Executive Committee, the Communications Department, the Environment Department, the Strategy Department, the Energy, Decarbonisation and Human Rights Department etc., as well as the Site Managers, are regularly asked to participate in various activities: presentation and explanation of the issues involved in its activities, participation in government-led projects, sectoral or geographical working groups, visits to plants or replies to requests for information, particularly during public consultative processes.

Ethical standards and guidelines

Eramet has put in place a Responsible Lobbying Policy governing the Group's lobbying activities. Through this policy, the Eramet Group undertakes to:

Respect:

• The institutional rules governing lobbying and business relationships, and the application of the most stringent international standards such as those of the OECD, ILO (International Labour Organisation), Global Compact, IRMA
• National regulations and/or codes of ethics, in particular the French law of 9 December 2016 on transparency, the fight against corruption and the modernization of economic life

Communicate:

• Up-to-date, objective and verifiable information by providing public officials and authorities in its areas of competence with appropriate expertise based on reliable information, without seeking to obtain information or decisions in a dishonest manner or by exerting any pressure whatsoever

Publish:

• Its lobbying activities on dedicated platforms, and notably in France, those of the High Authority for Transparency and Public Life and of the Transparency Register of the European Union, as well as the corresponding budgets allocated to lobbying by its human resources and those of the main associations and professional federations which Eramet is a member of

Ensure:

• That the persons in charge of lobbying have the necessary skills to perform their duties, receive the necessary guidance and receive regular training in their field of action
• Compliance by its employees with the principles of this Policy, the Ethics Charter, the Human Rights Policy, the Environmental Responsibility Policy, the Anti-Corruption Policy and the Purchasing Policy, and to submit them to their potential service providers

Political contributions

In accordance with the Group's Ethics Charter, Eramet maintains total political neutrality in the countries where the Group operates.

When the Group enters into contracts with public, state or regional authorities to contribute to the financing of development projects, it is prohibited from making any contributions or providing services to public office holders, political parties or organisations.

Eramet did not make any financial or in-kind political contributions during 2024.

The Group respects the right of its employees to participate individually in local political and civic life, provided that employees clearly separate their personal political activities from their duties within the Group.

EU Transparency Register

At the European level, Eramet declares its lobbying activities each year on two platforms:

• The directory of the High Authority for Transparency and Public Life (HAVTP) for France (https://www.hatvp.fr/fiche-organisation/?organisation=632045381##)
• The European Union Transparency Register (https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=645370511725-71)

Up-to-date and verifiable information on actions carried out are published in the register in the same way as allocated budgets, which are primarily linked to contributions in different professional structures.

Trade association memberships

Several members of the Executive Committee and/or directors represent the Group on the governance and management bodies of professional federations. This is the case, for example:

In France:

• Conseil national de l'industrie (CNI – National Industry Council)
• Alliance des Minerais, Minéraux et Métaux (A3M – Ores, Minerals and Metals Alliance)
• Comité Stratégique de Filière Mines et Métallurgie (CSF – Strategic Committee for the Mining and Metallurgy Industry)

In Europe:

• Euroalliages
• Eurométaux

Other countries:

• Majority of the countries where the Group operates

In France, Christel Bories, as Chair of the Comité Stratégique de la Filière Mines et Métallurgie (CSF – Strategic Committee for the Mining and Metallurgy Industry), is regularly called upon to represent the interests of the sector in dealing with the administrative authorities in France. The CSF highlights the priorities and ambitions of the industry to government authorities and oversees a multi-year roadmap in partnership with the State.

Allocated budgets are primarily linked to contributions in different professional structures (published in transparency registers).

Lobbying activities and stakeholders

Numerous initiatives were taken in 2024:

• In Gabon: consultations were organised between Comilog, Setrag and the government authorities (acting as supervisory authorities and co-shareholders) for the management of the concession framework of mining, rail and maritime transport operations, the implementation of CSR funds, and also the Lékédi Biodiversity Foundation

• In Indonesia: the development plan for mining activities (permits, environmental authorizations, etc.) in PT Weda Bay Nickel, as well as the new projects and the closure of the Sonic Bay project, were the subject of numerous interactions with the Indonesian government

• In Argentina: Eramet has remained in regular contact with the local authorities, former and current Argentinian government officials, and the French and European authorities in the country to discuss the roll-out of the first industrial phase and the development of the second phase of the Centenario mining project

• In New Caledonia: conciliation talks were held on several occasions with the French government and local elected representatives in order to ensure the long-term future of the sector in New Caledonia

• In Senegal: the progress of operations in the north of the concession, in a new region, and the growth of production volumes required the granting of new authorisations by the various ministries concerned

• In Chile: the Group's development projects in the lithium activities required regular interactions with local and national authorities

• In France: in the context of "France 2030", the "simplification" law and the implementation of the Green Industry law, Eramet, as well as its subsidiaries, continued to mobilize to solicit and obtain support in order to contribute to the challenges of strategic autonomy through the development of its lithium extraction project in Alsace and the recycling of electric vehicle batteries in Dunkirk (until the suspension of the project)

Focus areas and advocacy topics

At the European level, 2024 was marked by a transitional political period, with the election of a new European Parliament in June and the appointment of a new European Commission in December 2024. The main lobbying themes at the European level in 2024 were:

• Defending the European ferroalloys industry: Regulation 2023/956 establishing a border carbon adjustment mechanism (MACF) raises a number of uncertainties that threaten the European industry, in particular the competitiveness of ferroalloy production. Link with dual materiality: "Climate change mitigation": a poor application of the MACF risks leading to "carbon leakage", if the European production sites, which use low-carbon energy in Norway and France, are threatened by foreign competition that use much more carbon-intensive energy

• Enabling the development of battery recycling in Europe: as part of the recycling project led by the Group until October 2024, Eramet warned of the risk of critical metals (blackmass) leaving the European continent, threatening the supply, and therefore the economic viability, of the project. Link with dual materiality: "Management of waste and hazardous materials", "Responsibility in the value chain", "Climate change mitigation": Eramet advocated for black mass to be classified as "hazardous waste" at the European level, and for it to remain in Europe, to be recycled

• Financing mining projects: the Group develops projects in Europe and internationally and advocates for appropriate financial support from public authorities in the face of aggressive competition from non-European players (China, the United States, etc.)

• Establishment of a level-playing-field on ESG criteria: the Group defends an ambitious approach to develop the supply of responsible metals in order to improve the sector's practices while protecting its competitiveness. Link with dual materiality: "Responsibility in the value chain", "Climate change mitigation", "Water resources", "Impact on biodiversity", "Impact on local communities", "Management of mining waste", "Management of waste and hazardous materials", "Fight against corruption"

Key appointments in 2024

In 2024, the Group appointed:

• Romain Charvet as Head of Public Affairs France and Europe from the office of the Deputy Minister for French Overseas Departments and Collectivities, Jean-François Carenco after a favourable opinion from the High Authority for Transparency in Public Life (HATVP)
• Paul Bosc Bierne as Chief of Staff of the CEO from the office of the Minister Delegated to the Ecological Transition and Regional Cohesion Minister, in charge of transport, after a favourable opinion from the High Authority for Transparency in Public Life (HATVP)

Pierre-Alain Gautier, Group Director of Public Affairs, was a member of the Board of Directors of the public body BRGM (Bureau de Recherche Geologie et Minières) in 2024.

Payment practices

Late payment disclosure (Article D. 441-I French Commercial Code)

The following table presents invoices received and issued that were outstanding at the end of the financial year and past due:

Invoices received and not settled at end of financial year

Invoices issued and not settled at end of financial year

Invoices excluded from calculation

• Number of invoices excluded: 0 (both received and issued)
• Total amount of invoices excluded inc. tax: 0 (both received and issued)

Reference payment periods

Payment periods used to calculate late payments: Contractual periods (for both invoices received and issued)

Process and ongoing initiatives

The Group has set up procedures covering the Budget to Pay (B to P) process to ensure payments in accordance with contractual commitments. A performance management tool is being implemented to measure late payments.

A tool called SPARTA is under development to provide global and synthetic views of payment practices. Implementation is planned for 2025 with successive rollout across sites throughout the year. The multiplicity of ERPs, absence of a Group purchases full-suite, and limited extraction capacity have made comprehensive payment term analysis complex to date.

Legal proceedings: No legal proceedings for payment default involving the Group have been identified.

Supplier relationship management

The Group maintains a responsible purchasing policy requiring CSR criteria (minimum 5% weighting) and carbon criteria (minimum 5% weighting) in tenders over €500,000. A purchasing risk mapping in 2023 identified 127 high-risk suppliers from a CSR perspective, all of whom were requested to complete EcoVadis assessments or internal CSR questionnaires.