Labor & Ethics Policy

Effective 4/1/2015

Fine Metals Corporation is committed to being socially and environmentally responsible, and as such, is committed to regulatory compliance in regard to labor and ethics laws and continuous improvement in all areas. It is the policy of Fine Metals Corporation to comply with U.S. law regulating the export or re-export of commodities, technology, defense articles, defense services, and activities relating thereto.

Fine Metals Corporation voluntarily and fully supports the Electronic Industry Citizenship Coalition’s Code of Conduct and actively pursues conformance with the Code and its standards in accordance with our management system herein described and encourages our suppliers to do so as well.

Our Labor and Ethics Policy follows the Code and is made up of five sections. Sections A, B, and C outline standards for Labor, Health and Safety, and the Environment, respectively. Section D adds standards relating to business ethics; Section E outlines the elements of our system to manage conformity to our Policy and the Code.

A. Labor

Fine Metals is committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. Recognized standards have been used as references in preparing this Policy and are further amplified in our Employee Handbook.

The labor standards are:

1) Freely Chosen Employment

Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons are not used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There are no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities.

As part of the hiring process, workers are provided with a job description in their native language that contains a description of terms and conditions of employment. All work is voluntary and workers are free to leave work at any time or terminate their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to employees’ identity or immigration documents, such as government-issued identification, passports or work permits, unless the holding of work permits is required by law. Workers are not required to pay employers or agents recruitment fees or other aggregate fees in excess of one month’s salary. All fees charged to workers are disclosed and fees in excess of one month’s salary are returned to the worker.

2) Young Workers

Child labor is not used in any stage of manufacturing. The term “child” refers to any person under the age of 14, or under the age for completing compulsory education, or under the minimum age for employment. Workers under the age of 18 (Young Workers) do not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Fine Metals ensures the proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Fine Metals provides appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

3) Working Hours

Workweeks are not to exceed the maximum set by local law. Further, a workweek is not more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers are allowed at least one day off every seven days.

4) Wages and Benefits

Compensation paid to workers complies with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers are compensated for overtime worked in excess of 40 hours in a workweek at 1.5 times their regular hourly rates. Deductions from wages as a disciplinary measure are not permitted. For each pay period, workers are provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor are within the limits of the local law.

5) Humane Treatment

Fine Metals does not condone any harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements are clearly defined and communicated to workers in our Employee Handbook.

6) Non-Discrimination

Fine Metals is committed to a workforce free of harassment and unlawful discrimination. The Company does not tolerate discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Workers are provided with reasonable accommodation for religious practices. In addition, workers or potential workers are not subjected to medical tests or physical exams that could be used in a discriminatory way.

7) Freedom of Association

In conformance with local law, the Company respects the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment. While the Company recognizes the above, it does not believe any outside representation is necessary.

B. Health and Safety

Fine Metals recognizes that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. The Company also recognizes that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace.
Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing this Policy.

The health and safety standards are:

1) Occupational Safety

Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. Workers are encouraged to raise safety concerns.

2) Emergency Preparedness

Potential emergency situations and events are identified and assessed, and their impact minimized by the implementation of emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans. Such plans and procedures focus on minimizing harm to life, the environment and property.

3) Occupational Injury and Illness

Procedures and systems are in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.

4) Industrial Hygiene

Worker exposure to chemical, biological and physical agents is identified, evaluated, and controlled. Engineering or administrative controls are used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is protected by appropriate personal protective equipment programs.

5) Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is identified, evaluated and controlled.

6) Machine Safeguarding

Production and other machinery have been evaluated for safety hazards. Physical guards, interlocks and barriers are provided and properly maintained where machinery presents an injury hazard to workers.

7) Sanitation, Food, and Housing

Workers are provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. No housing is provided to workers.

8) Health and Safety Communication

Fine Metals provides workers with appropriate workplace health and safety training in their primary language. Health and safety related information is clearly posted in the facility.

C. Environmental

Fine Metals recognizes that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are minimized while safeguarding the health and safety of the public. Recognized management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing this Policy.

The environmental standards are:

1) Environmental Permits and Reporting

All environmental permits (e.g. discharge monitoring), approvals and registrations are obtained, maintained and kept current and their operational and reporting requirements are followed where and when required.

2) Pollution Prevention and Resource Reduction

The use of resources and generation of waste of all types, including water and energy, are reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

3) Hazardous Substances

Chemicals and other materials posing a hazard if released to the environment are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

4) Wastewater and Solid Waste

Fine Metals has implemented a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). Wastewater generated from operations, industrial processes and sanitation facilities are characterized, monitored, controlled and treated as required prior to discharge or disposal. In addition, measures have been implemented to reduce generation of wastewater.

5) Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are characterized, routinely monitored, controlled and treated prior to discharge when and where required.

6) Materials Restrictions

Fine Metals adheres to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.

7) Storm Water Management

The Company prevents illegal discharges and spills from entering storm drains.

8) Energy Consumption and Greenhouse Gas Emissions

The Company continuously looks for cost effective methods to improve energy efficiency and to minimize its energy consumption and greenhouse gas emissions.

D. Ethics

To meet social responsibilities and to achieve success in the marketplace, Fine Metals Corporation and its agents uphold the highest standards of ethics. Many of these topics are amplified in our Employee Handbook.

1) Business Integrity

The highest standards of integrity are upheld in all business interactions. The Company has a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. All business dealings are transparently performed and accurately reflected on Fine Metal’s business books and records. Monitoring and enforcement procedures are implemented to ensure compliance with anti-corruption laws.

2) No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.

3) Disclosure of Information

Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

4) Intellectual Property

Intellectual property rights are respected; transfer of technology and knowhow is done in a manner that protects intellectual property rights; and, customer information is safeguarded.

5) Fair Business, Advertising and Competition

Standards of fair business, advertising and competition are upheld.
Appropriate means to safeguard customer information is available.

6) Protection of Identity and Non-Retaliation

Policies that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are maintained, unless prohibited by law. Fine Metals has communicated a procedure for personnel to raise any concerns without fear of retaliation.

7) Responsible Sourcing of Minerals

Fine Metals has a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. The Company exercises due diligence on the source and chain of custody of these minerals and makes its due diligence measures available to customers upon customer request.

8) Privacy

Fine Metals is committed to protecting the reasonable privacy expectations of personal information of everyone it does business with, including suppliers, customers, consumers and employees. The Company complies with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

E. Management System

Fine Metals has established a management system whose scope is related to the content of this Policy. The management system is designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to Fine Metals’ operations and products; (b) conformance with this Policy; and (c) identification and mitigation of operational risks related to this Policy. It should also facilitate continual improvement.

The management system contains the following elements:

1) Company Commitment

Fine Metals Corporation is committed to be socially and environmentally responsible to regulatory compliance and continuous improvement as expressed in our Company mission statement and values.

2) Management Accountability and Responsibility

Fine Metals has identified senior executive and Company representatives responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.

3) Legal and Customer Requirements

Fine Metals has a process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Policy.

4) Risk Assessment and Risk Management

Fine Metals has implemented a process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with its operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance is in place.

5) Improvement Objectives

The Company has given the Safety and Compliance Officer written performance objectives, targets and implementation plans to improve its social and environmental performance, including a periodic assessment of its performance in achieving those objectives.

6) Training

Programs for workers to implement Fine Metal’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements are held on a recurring basis.

7) Communication

A process for communicating clear and accurate information about the Company’s policies, practices, expectations and performance to workers, suppliers and customers.

8) Worker Feedback and Participation

Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Policy and to foster continuous improvement.

9) Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Policy and customer contractual requirements related to social and environmental responsibility.

10) Corrective Action Process

A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

11) Documentation and Records

Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

12) Supplier Responsibility

A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Policy.


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