Policy Statement on Theft of PGM-Bearing Materials
Version: V1.0
Effective Date: January 1, 2026
Scope of Application: All platinum group metal (PGM) supply chains of the Company, including platinum, palladium, rhodium and related PGM-bearing materials
Reference Standard: LPPM RPG5 (5th Edition) Step 1.1 "Policy Statement on Theft of PGM-Bearing Materials"
I. Policy Statement
Inteplatinum Co., Ltd. has zero tolerance for any form of theft of PGM-bearing materials and firmly opposes the entry of stolen PGMs into our supply chain. We recognize that high-value PGM-bearing materials such as automotive catalysts are prime targets for criminals, and the illegal trade in stolen materials seriously erodes the reputation of the PGM industry as well as its recyclability and environmental benefits.
To this end, the Company has established and strictly implements the following commitments:
II. Specific Commitments
A. Enhanced Due Diligence on Suppliers
Enhanced Due Diligence (EDD) must be conducted on suppliers that have not publicly committed to adopting responsible supply chain policies similar to or based on OECD Annex II.
EDD includes but is not limited to: review of legitimacy of supplier material sources, on-site visits, management interviews, verification of VAT/tax records, etc.
B. Handling of Suppliers Suspected of Dealing in Stolen Materials
For suppliers suspected of dealing in stolen PGMs, the Company will:
Conduct immediateinvestigation;
Suspend cooperation asappropriate pending further due diligence results;
Immediately terminate thecooperative relationship and report to relevant authorities in accordancewith the law if theft is confirmed.
C. Cooperation with Government Authorities
The Company commits to fully cooperating with law enforcement agencies, regulatory authorities and industry associations to seek to end the trade in stolen PGMs, and will provide necessary records and information support.
D. Cash Payment Ban
All PGM-related payments by the Company are settled through bank channels via corporate accounts, and cash settlement of any kind is refused.
III. This Policy Applies to:
Primary PGMs
Recycled PGMs (includingbut not limited to automotive catalysts, industrial waste, jewelry scrap,electronic waste, etc.)
Closed-loop/tollprocessing agreements
Subsidiaries, jointventures, metal dealers, bullion dealers (no exceptions)
IV. Responsibility and Implementation
表格
Responsible Party | Responsibilities |
Board of Directors/Compliance Officer | Oversee the implementation of this policy, approve handling of high-risk suppliers |
Procurement and Supply Chain Department | Implement this policy in supplier admission and annual review |
Compliance Department | Organize EDD, investigate suspected theft, report to authorities |
Finance Department | Strictly enforce the cash payment ban |
V. Violation Handling
Any employee, supplier or partner found to be involved in the theft of PGM-bearing materials will be subject to: immediate termination of business relationship, reservation of legal recourse rights, and reporting to LPPM and relevant authorities.
VI. Policy Publication
This policy statement will:
Be incorporated intosupplier contracts or legally binding documents
Serve as required readingfor annual training