Policies & reports

These policies govern Power Elements, Inc. and all our subsidiaries. Select a policy or report to read it in full and download a copy.

Policies

Code of Conduct
Power Elements, Inc. · 6 November 2026
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1. Why we have this Code

Power Elements mines, refines and trades critical minerals in places where the way a company behaves matters as much as what it produces. Our customers, communities, investors and regulators rely on us to do what we say, and to be able to prove it. This Code sets out the standards of behaviour that make that possible. It turns our three values into rules that everyone at Power Elements is expected to follow.

2. Who this Code applies to

This Code applies to Power Elements, Inc. and every company it owns or controls ("Power Elements", "we"), and to every director, officer, employee, temporary worker and contractor of those companies, wherever they work. We expect agents, consultants and others who act on our behalf to meet the same standards, and we ask the same of our suppliers through our Supplier Code of Conduct.

Where local law sets a higher standard than this Code, we follow the law. Where this Code sets a higher standard than local law, we follow this Code.

3. Our values

Protect and improve human rights. We protect the rights of everyone our work touches, from the people at our sites to those along our supply chain.

Create fair value and transparent supply chains. We create value at the source, and we make every step of our material's journey from mine to customer visible and verifiable.

Work towards zero waste. We design our mining and refining so that what one process leaves behind becomes feedstock for another.

4. Making the right decision

No code can cover every situation. When you are unsure, ask yourself:
- Is it legal, and is it consistent with this Code and our policies?
- Would I be comfortable if it were reported accurately in the press, or explained to a regulator, an auditor or a member of the community where we work?
- Could I show the evidence for what I did, and why?
If the answer to any of these is no, or you are not sure, stop and ask your manager, the Compliance team (compliance@powerelements.com) or use Speak up.

5. Our people

5.1 Safety first

No production target, deadline or cost saving justifies putting anyone at risk. Everyone at our sites follows the safety rules and procedures that apply to their work, wears the protective equipment provided, and has the right and the duty to stop work they believe is unsafe, without penalty.

5.2 Respect, fairness and equal opportunity

We treat each other with dignity. We do not tolerate harassment, bullying, intimidation or discrimination of any kind. Decisions about recruitment, pay, promotion and discipline are based on merit, ability and conduct.

5.3 Human rights at work

We do not use child labour or forced, bonded or trafficked labour, and we do not work with anyone who does. We respect the freedom of our people to join, or not to join, a workers' organisation. Our commitments are set out in full in our Human Rights Policy.

6. Integrity in business

6.1 Bribery and corruption

We never offer, give, ask for or accept a bribe, a kickback or a facilitation payment, directly or through anyone else. Gifts and hospitality must be modest, infrequent, given openly and never intended to influence a decision. Our Anti-Bribery and Corruption Policy applies in full.

6.2 Conflicts of interest

You must avoid situations where your personal interests, or those of your family or close associates, conflict, or appear to conflict, with the interests of Power Elements. Declare any actual or potential conflict to your manager and to Compliance as soon as you become aware of it, and do not take part in the decision it affects.

6.3 Sanctions, export controls and money laundering

We comply with the sanctions and export-control laws that apply to us and we do not help anyone evade them. We know who we deal with before we deal with them, and we do not accept or make payments we cannot explain. Our Sanctions and Export Control Policy and our Know-Your-Counterparty Policy apply in full. We do not pay or accept cash for minerals.

6.4 Fair competition

We compete on the quality, reliability and price of what we offer. We do not agree prices, divide markets or customers, rig bids or exchange competitively sensitive information with competitors.

6.5 Fraud and accurate records

Every record we keep, from a mine log or a laboratory assay to an invoice, a financial statement or a traceability entry, must be complete, accurate and made at the time. We never falsify, backdate, alter or destroy records, and we never misrepresent the origin, quantity or quality of material.

6.6 Inside information and dealing in securities

In the course of your work you may learn information about Power Elements, or another company, that is not public and that could affect the value of its shares or other securities. You must not deal in those securities, or encourage anyone else to, while you hold that information, and you must not pass it on except as your role requires.

7. Our material and our supply chain

The integrity of our supply chain is the basis of our business. We source and handle material only in line with our Supply Chain Policy, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the Responsible Minerals Assurance Process. Every movement of material is recorded in our traceability system as it happens. Any attempt to disguise the origin of material, or to bypass our traceability controls, is gross misconduct.

8. Communities and the environment

We engage openly and respectfully with the communities around our sites, as set out in our Community Engagement Policy. We minimise our environmental footprint, prevent pollution and work towards zero waste, as set out in our Environmental Policy. Anyone affected by our operations can use our Grievance and Complaints Mechanism.

9. Company assets, information and technology

9.1 Protecting what is ours

Use company property, funds, equipment and time for legitimate business purposes, and protect them from loss, damage, misuse and theft.

9.2 Confidential information and personal data

Keep confidential information confidential, during and after your time with Power Elements. Handle personal data only as our Data Protection Policy allows.

9.3 Technology and artificial intelligence

Power Elements runs on an AI operating layer, and we use AI tools widely. You remain responsible for the work you produce with them. Check what an AI tool gives you before you rely on it, do not put confidential information or personal data into tools the company has not approved, and remember that a material decision about a person, a counterparty, a payment or safety is always taken by a named person, not by a system.

10. Speaking for the company

Only people authorised to do so may speak for Power Elements to the media, investors, analysts or the public, or post on its behalf. What we say publicly must be accurate, supportable and consistent with what we report elsewhere.

11. Political activity

We do not make political donations on behalf of Power Elements without the prior approval of the Board, and only where lawful and publicly disclosed. You are free to take part in political activity in your own time and in your own name.

12. Speaking up

If you see or suspect a breach of this Code, of our policies or of the law, you must report it. You can raise it with your manager, with Compliance, or through Speak up (speakup@powerelements.com), where you can report in confidence and, where the law permits, anonymously. Our Whistleblowing and Speak-up Policy explains how reports are handled.

We do not tolerate retaliation against anyone who raises a concern in good faith, or who helps with an investigation. Retaliation is itself a breach of this Code.

13. Breaches of this Code

Breaching this Code, or our policies, may lead to disciplinary action, up to and including dismissal or the end of a contract, and where the law has been broken, we may refer the matter to the relevant authorities.

14. Responsibility, waivers and review

Every manager is responsible for making sure their team understands this Code and for setting an example. The Board oversees this Code through its Governance, Ethics & Responsible Sourcing Committee. Any waiver of this Code for a director or executive officer may be granted only by the Board and will be disclosed. This Code is reviewed at least once a year.
Ray Power, Chief Executive Officer
Human Rights Policy
Power Elements, Inc. · 6 November 2026
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Human Rights Mission Statement

Power Elements, Inc. ("Power Elements") is a new generation of company driven not only by profit, but also the advancement of human rights both locally and internationally. The mining industry has often lacked a commitment to protect employees and local communities. This is a situation we aim to change.

At a minimum, Power Elements will avoid causing or contributing to adverse human rights impacts through its own activities, and address such impacts if or when they occur as transparently and quickly as possible. We will also seek to prevent or mitigate adverse human rights impacts that are linked to our operations or services. On a larger scale, and as outlined in our Human Rights Policy, we will prioritise human rights considerations throughout our strategic decision-making, operations and business relationships. As our operations grow, so will our ambition to do the right thing by the people who are part of our exciting journey.

Introduction

Power Elements is committed to being at the forefront of human rights protection within the mining industry both with regards to its employees and to the local communities in which it operates. Power Elements upholds universally accepted human rights standards in all of its operations, as reflected in the applicable provisions of the:
- Universal Declaration of Human Rights;
- International Covenant on Civil and Political Rights;
- International Covenant on Economic, Social and Cultural Rights; and the
- International Labor Organizations Convention's Declaration on Fundamental Principles and Rights at Work.
In addition to adherence to the instruments listed above, Power Elements declares its commitment to incorporating where possible the best international voluntary practices and industry-specific initiatives, including:
- The 10 Principles of UN Global Compact;
- The Guiding Principles and the UN Guiding Principles on Business and Human Rights (based on Principle 1 of the UN Global Compact);
- The UN norms on the responsibilities of transnational corporations and other business enterprises with regard to human rights;
- The Extractives Industries Transparency Initiative; and
- The International Council on Mining and Metals ("ICMM") Voluntary Principles on Security and Human Rights.
Where national law provisions are more stringent than international best practice standards, Power Elements will ensure that national law standards are implemented.

At a minimum, Power Elements will:
- avoid causing or contributing to breaches of human rights through its own activities, and address such impacts if/when they occur; and
- seek to prevent or mitigate breaches of human rights that are directly linked to its operations or services.
Specific Human Rights Commitments

1. Equality and Non-Discrimination

Power Elements is committed to equality of opportunity for all of its employees, and will not discriminate on the basis of race, colour, gender, nationality, sexual orientation, gender identity, religion, political opinion, nationality, social origin, indigenous status, disability, age or other factor unrelated to the individual's ability to perform work. Any employee who believes they have been a victim of discrimination will have access to appropriate confidential grievance mechanisms without fear of reprisal.

2. Child Labour

Child labour deprives children of the many virtues of childhood, including the opportunities for social development and regular schooling. Power Elements is committed to a zero tolerance policy against child labour throughout our activities. Juveniles under the age of 18 are prohibited from engaging in employment or work which by its nature or circumstance is likely to jeopardise their health and safety.

3. Forced Labour

Forced labour affects millions of people across the world and is particularly prevalent within certain industries, including the mining industry. Power Elements will exercise diligence in ensuring that it does not use or benefit from any type of forced labour including: bonded labour, involuntary prison labour, debt bondage or human trafficking in its mines. Power Elements will not tolerate the use of any form of forced labour by its business partners or subcontractors, and if such practices are discovered take steps to terminate the business relationship.

4. Freedom of Association and Right to Organise

Power Elements respects the freedom of association of its employees. Employees are free to join or not to join labour organisations of their choice to represent them in accordance with local laws without fear of reprisal, intimidation or harassment. Power Elements is committed to an open and constructive dialogue with its employees and their representatives and to cooperating with such representatives in good faith.

5. Occupational Health and Safety

Operating within the extractives industry entails particular responsibilities on employers to guarantee safe and healthy working conditions for its employees. Power Elements will monitor and seek to reduce accidents and injuries to health arising in the course of employment. It will minimise the causes of workplace hazards through the provision of adequate training on all aspects of the workplace environment including the use of tools, machinery and equipment. Workers whose positions involve exposure to hazardous substances or conditions will be provided with all protective equipment necessary, at no cost to the individual. Power Elements recognises that workers have the right to remove themselves from work situations where imminent and serious health dangers are reasonably perceived, without undue consequences.

6. Wages and Compensation

Power Elements commits to paying employees the prevailing industry wage in compliance with local laws, and to ensuring that its employees can have an adequate standard of living. Men and women are entitled to equal pay for equal work regardless of whether this right is enshrined in local laws.

7. Working Conditions

It is in the interest of Power Elements to ensure that employees enjoy fair working conditions. It is our belief that fair working conditions encourage a happy, healthy and motivated workforce. All employees are entitled to a written contract of employment, with agreed terms and conditions, and to reasonable rest breaks, access to toilets, rest facilities and potable water at their site of employment. Regulations regarding sick leave, holiday and overtime will comply with national laws or benchmark industry standards.

8. Harassment

Power Elements is committed to a workplace free from harassment. Each employee is entitled to be treated with respect and dignity, and abuse of any kind – whether verbal, physical, or psychological – will not be tolerated. Any employee who feels that they have been a victim of harassment, will have access to appropriate confidential grievance mechanisms without fear from reprisal.

9. Respect for "Free, Prior and Informed Consent"

Power Elements will uphold the principle of "free, prior and informed consent" of local and indigenous communities. To do so, Power Elements commits itself to maintaining an effective channel of communication with indigenous populations. Before beginning any project affecting local lands and territories, a process of stakeholder analysis and stakeholder engagement will take place, particularly when any project concerns the development, utilisation or exploitation of mineral, water or other resources. Any local community representative who believes they have been wronged by the application, or nonapplication of this process, will have access to appropriate, confidential grievance mechanisms without fear of reprisal.

10. Security and Human Rights

Power Elements is committed to ensuring that any public or private security firms engaged in maintaining the safety and security of mining operations adhere to strict operational constraints in keeping with the recommendations on the Voluntary Principles on Security and Human Rights. As such, individuals credibly implicated in human rights abuses will not be engaged to provide security services for Power Elements. Force may be used only by public or private security firms when strictly necessary and to an extent proportional to the threat. In the eventuality that the use of force is unavoidable, medical aid must be provided to injured persons, including to offenders. Force should not be used to interfere with employees exercising their rights of freedom of association and collective bargaining.

Operational Commitments

1. Grievance Mechanisms

Power Elements will ensure that both employees and stakeholders within local communities have access to appropriate grievance mechanisms. Power Elements' grievance mechanisms are designed to resolve complaints and disputes effectively and in line with human rights principles. Employees have the right to submit complaints anonymously if they prefer to, and will not endure any form of retaliation for filing a grievance.

2. Right to an Effective Remedy

Power Elements is committed to providing access to an effective remedy to those who have been adversely affected by the Company's activities. The remedy shall be made available to both its employees and individuals in communities where Power Elements operates. Modalities will differ depending on local circumstances and the nature of the wrongdoing, but may include: apologies, restitution, rehabilitation, financial or non-financial compensation, and the prevention of future harm through guarantees of non-repetition.

3. Monitoring Human Rights in the Supply Chain

When one of Power Elements' business partners is associated with a human rights abuse, the Company is exposed not only to operational and reputational risks, but also legal risks, including complicity in such abuses. To avoid this risk, Power Elements will endeavour to work with business partners who share its ethical values. When entering into a new business relationship, Power Elements will include a human rights risk assessment element into its due diligence procedure and periodic reviews of the business relationship will continually monitor any adverse human rights related risks. Power Elements aims to ensure that all business partners, whether suppliers, contractors or joint venture partners are made aware of Power Elements' Human Rights Policy. Our contractual terms with business partners will always contain an ethical policy, including a statement on human rights. Non-conformance with this policy may ultimately result in the termination of the contractual relationship.

Any questions relating to this policy or infractions which should be reported shall be directed towards the Compliance Manager on: compliance@powerelements.com or the company CEO, Ray Power on: ray.power@powerelements.com.
Ray Power
Supply Chain Policy
Power Elements, Inc. · 6 November 2026
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Trade in conflict minerals is a persistent problem in certain African states where mineral wealth has been proven to perpetuate conflict and fuel human rights atrocities.

Columbite-tantalite (coltan), cassiterite, wolframite and gold, or their derivatives, including tantalum, tin, and tungsten, originating from conflict afflicted areas can make their way into the supply chains of the products used around the world. It is the policy of Power Elements, Inc. and its subsidiaries, referred to henceforth as "Power Elements", to avoid supplying, purchasing, or processing, any minerals that directly or indirectly finance or benefit armed groups from conflict-affected regions.

Therefore, Power Elements is fully committed to compliance with the position of the Organization for Economic Co-operation and Development (OECD) concerning responsible supply chain management, the Dodd-Frank Act and the EU Conflict Minerals Regulation to avoid the use of ores and metals that finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries. Power Elements commits to refraining from any act which contributes to the financing of conflict and complies with relevant United Nations sanctions resolutions or, where applicable domestic laws implementing such resolutions. This policy applies to all minerals, specifically tantalum and tin which may be processed or refined at our facilities.

Power Elements ensures full compliance with the national and international laws and regulations.

In support of this responsible sourcing policy, Power Elements will:
- Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Afflicted and High-Risk Areas including all risks identified in Annex II and require our suppliers to do likewise with their suppliers.
- Adopt risk management procedures in order to minimize the different types of risks within its operations and whole logistics supply chain with special accent concerning serious abuses such as human right violations, forced and child labor, war crimes and similar serious violations of the humanitarian law such as, but not limited to, widespread sexual violence, genocide, or payments to non-state armed groups. Furthermore, Power Elements will utilise the risk management process to understand the presence of public and private security forces in the areas in which a supplier is operating. If it is discovered that there is a reasonable risk that a supplier is sourcing from, or are linked to, any party committing such abuses, Power Elements shall immediately suspend or discontinue the relationship with the party concerned.
- Shall take all reasonable steps to contribute to the elimination of money laundering.
- As some conflict minerals may also contain radioactive materials, such as thorium and uranium, Power Elements will require that all shipments falling into the Class 7 category adhere to the appropriate national and international regulatory frameworks.
- Will work with governments, communities, and NGOs, in countries and areas affected by conflict minerals, to develop initiatives and strategies to provide more transparency and accountability in the supply chain whilst lessening the financial and bureaucratic constraints imposed on miners and artisanal workers in the industry.
- Undertake all adequate action in case a serious/severe violation is suspected or detected. The identification and registration of any potential risks or incidents within the upstream and downstream of the logistic supply chain will be properly registered and all the proper measure undertaken.
- Not engage in any activity that benefits from, or attempts to, disguise the origin of minerals, to misrepresent taxes, fees, and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.
- Commit to transparently report on the implementation of this policy by making available reports concerning progress and performance in the implementation of this policy to our customers, relevant stakeholders and the public via our website.
- Communicate this policy to all customers, sub-contractors and suppliers as part of the contracting process.
- Only engage with suppliers that are fully compliant with this process. Non-conformance with this policy may ultimately result in the termination of the contractual relationship and further communication.
Employees, members of the public, suppliers and stakeholders are encouraged to contact the Compliance Desk, compliance@powerelements.com, should you have any comments, queries or concerns about this policy or any action or inaction related to it.
Ray Power, Chief Executive Officer
Due Diligence and RMAP Procedure
PowerX Ltd · 6 November 2026
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Introduction

Power Elements, Inc. and its subsidiaries worldwide ("Power Elements" or the "Company") has multiple company policies accepted, with the Supply Chain Policy being of great importance due to nature of the business Power Elements is in.

Following the Supply Chain Policy, (as well as all other policies), is mandatory for any Power Elements employee, from Board members, Directors, Managers to field officers and production staff, as well as Suppliers and Subcontractors.

PowerX Ltd. is a subsidiary of Power Elements and follows all of its policies but, additionally, has its own Due Diligence policy to ensure the sourcing of non-conflict minerals.

1. Establish strong company management systems – OECD Step 1

1.1. Adopt a responsible supply chain policy

PowerX Ltd. as a subsidiary of Power Elements, is fully committed to being in compliance with the position of the Organisation for Economic Co-operation and Development (OECD) concerning responsible supply chain management, the Dodd-Frank Act, and the EU Conflict Minerals Regulation, to avoid the use of ores and metals that have OECD Annex II risks associated with them, including financing or benefiting armed groups in conflict-affected and high-risk areas. Power Elements commits to refraining from any act which contributes to the financing of conflict and complies with all relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

PowerX Ltd. has, for these reasons, established a system of internal control over the minerals in its possession, (chain of custody and traceability), and established an on-the-ground assessment process.

PowerX Ltd. demands that all its Suppliers are familiar with Power Elements' Supply Chain Policy, adhere to it, and acknowledge at the initial stage of signing any agreement between Power Elements and the potential Supplier.

The Power Elements Supply Chain Policy is published on Power Elements' web page and is reviewed annually and updated on an as needed basis.

1.2. Management structure to support supply chain due diligence

PowerX Ltd. performs desktop Due Diligence on its suppliers as well as an on-the-ground assessment process, (OGAP). The execution of OGAP is carried out by trained, experienced, and competent personnel (Traceability and Digitalisation officers) who, through reporting to their Line Managers on national levels, and the Company Purchasing Manager on an international level, provide reporting into the Head of Sales and Traceability who oversees Power Elements' ore purchasing operations, compliance, and conformance of sourced materials on national and international levels. Meetings between teams carrying out the OGAP and their superiors are held weekly. Any actual or potential risks are reported up the chain of command within Power Elements to the Head of Sales and Traceability.

All existing and newly hired personnel are trained on Due Diligence procedures and all other job-role relevant Company policies with an emphasis on the implementation of Supply Chain Policy and Procedures.

1.3. Monitoring of performance

PowerX Ltd. reviews its Due Diligence and OGAP system at least once per year, monitoring its adequacy and effectiveness in the region and markets where PowerX Ltd. is sourcing from or selling products to. If required, proactive measures are taken within the one-year period between planned reviews. Should an unanticipated development occur a reactive measurement will follow in the shortest achievable time.

1.4. Internal material control

1.4.1. Material control systems. PowerX Ltd. operates its own laboratory to determine the quality of materials that are offered to, or purchased by PowerX Ltd. Standard operating procedures, (SOPs), cover all aspects of the material control system, from compliance control, mass balance control, acceptance and reporting. PowerX Ltd. will also recognise laboratory measurements of its sister company, PowerM Ltd.

All assayed batches are given a unique identification number corresponding to the date, weight, grade, mine(s) of origin and values stored. All records are retained digitally for a period of 5 years. Internal material control continuously monitors inventory via receipts, physical inspection and inventory logs. Within these systems, any mass balance discrepancies are investigated.

1.4.2. Mass balance calculation. PowerX Ltd. has a mass balance control system. All raw materials and their usage are closely monitored to corroborate the mass balance alongside ore concentrates.

1.5. Engagement with suppliers

Prior to doing business with the suppliers, PowerX Ltd. requires the completion of a Know Your Counterpart, (KYC), digital form, which will ensure all relevant data is acquired on the supplier, its ownership structure and other relevant information to enable screening for sanctions, blacklists or records which denote high risk.

Suppliers are paid via bank Transfer or issued cheques guaranteeing financial traceability. PowerX Ltd. does not permit the use of cash to pay for minerals.

PowerX Ltd. is actively facilitating government agencies in charge of the mining sector development in Rwanda to further engage with suppliers on mine development, environmental sustainability and other impact initiatives which contribute to transparency and relationship building in the supply chain.

Working with the Suppliers allows PowerX Ltd. to make regular mine-site visits and provide due diligence reports based on those visits. Findings from these mine site visit reports are shared with Buyers downstream, or relevant industry recognised bodies, as necessary.

Reports on work and engagement with local communities are not publicly shared for community protection reasons but are regularly shared with the Company's Independent Chairman and key company stakeholders, such as lenders or advisory personnel, as well as being made available to any mandated auditor.

1.6. Company level grievance mechanism

Power Elements has developed and adopted a Grievance mechanism that allows the company employees or any 3rd party to express their thoughts and concerns, regardless of their language and digital literacy. The triggering of the grievance mechanism is explained in detail in the Grievance Mechanism procedure.

2. Identify and assess risk in the supply chain – OECD Step 2

2.1. Identify the scope of the risk assessment of the supply chain

2.1.1. Identification of suppliers. Prior to engaging into any discussion, when contacted by a potential Supplier, the latter has to provide documents that reveal who the company beneficiaries are, their mining license information and/or mineral trade licenses. All of the gathered information is checked against the EU sanctions list and the US OFAC sanctions list. Origin, routes and trader's geographical location are also verified to determine if their material is sourced from a CAHRA source and if they trigger any potential red flags, as defined by OECD Due Diligence Guidance for Responsible supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

2.1.2. Identification of material category and source. Power Elements currently sources primary materials only, due to the technological focus of its refining process. The primary material sourced is tantalum bearing concentrate. This primary material is sourced from Large Scale Mines (LSM) and Artisanal and Small Scale Mines (ASM).

2.1.3. Identification of conflict affected and high risk areas. Identification of CAHRA is performed using the 'CAHRA Assessment Form' which is signed off by the Head of Sales and Traceability.

The CAHRA procedure for each country PowerX Ltd. sources from is performed at least once per year or more if political situations dictate as much.

PowerX Ltd. performs OGAP of all the sites PowerX Ltd. is sourcing from at least once a year for each Supplier, effectively carrying out Enhanced Due Diligence as per RMAP definition. In cases when on-site assessments in CAHRAs is not possible due to security concerns for periods longer than a year, despite the Company's best efforts, a visit should be made at the first possible date and a desktop assessment will be conducted and recorded.

2.1.4. Determine scope of risk assessment.

2.1.4.1. Review for discrepancies. Any discrepancies that raise suspicion, such as inconsistent quality from the same mine, or output being higher than estimated mine capacity during mine visit, are investigated by Power Elements' technical and compliance team.

2.1.4.2. Determine plausibility. Key issues PowerX Ltd. considers throughout the process are: (i) Potential Supplier response rates; (ii) confidentiality requirements; (iii) missing and incorrect data; and (iv) the discovery of red flags that warrant further investigation or which may result in the termination of Due Diligence and all communications with the supplier. Refusal or inability to provide basic paperwork is an indication that the supplier and its material most likely do not exist, is illegal, or is attempting to disguise sanctioned beneficial ownership.

After the data is received, it is assessed for its accuracy, plausibility, consistency, gaps and reasonableness. The compliance team has the technical capability of Power Elements at its disposal, to turn to for consultancy in case of inconsistencies or unreasonable data. PowerX Ltd. assesses supplier-provided data, defines the potential risks, and makes a decision whether communication and due diligence with a Potential Supplier should continue or whether communication should cease. In case of the latter decision, PowerX Ltd. terminates communication with the Potential Supplier who has not passed the screening for a minimum of 6 months.

2.1.4.3. Assess red flags. PowerX Ltd. assesses OECD defined red flag criteria. If red flags are raised, they are investigated, assessed and reported to the Head of Sales and Traceability, who then, if needed, can further escalate the report to the Company CEO for final decision making on subsequent action.

Any material coming from Countries without known mines producing 3TGs should be immediately red flagged and investigated if new, previously unknown, mines have opened in the country of claimed origin. If a mine is proven to exist, continue with Due Diligence and OGAP steps, if not, cease communication with the would-be-suppliers.

Reports on findings can be passed on to the downstream companies via the blockchain secured platform in use.

2.1.4.4. Determine sourcing risk level. To determine source risk level, Power Elements is using the CAHRA assessment form. This form leads an evaluator to the internal company portal with data relevant for determining CAHRA status.

2.1.5. Map the factual circumstances of the supply chain.

2.1.5.1. Chain of custody. PowerX Ltd. is using its own, proprietary Due Diligence and CoC system but may draw information from third party systems as it deems suitable to improve the reliability of data for cross-referencing purposes.

2.1.5.2. Conducting on-the-ground assessments. PowerX Ltd. performs the OGAP. These processes are performed by teams consisting of experienced and competent personnel.

2.1.6. Assess risks in the supply chain.

2.1.6.1. Mine site inspection. Using the OGAP, PowerX Ltd.'s policy is to send a Traceability Officer to each mine site PowerX Ltd. is doing business with at least once a year, usually within a 3 month period after a delivery takes place if the supplier is part of any RMI recognised upstream assurance mechanism. If not, then the OGAP mine visit will take place prior to the first delivery. Observations and acquired data are recorded to a mine site due diligence reporting system using a cloud based service which operates both offline and online. PowerX Ltd. accepts Mine Site Due Diligence visits performed by its sister company PowerM Ltd. as its own reports.

3. Risk mitigation – OECD Step 3

3.1. Report findings to senior management

A Traceability Officer at national level carries out mine site visits a minimum of once per year for each mine. After the mine visit is complete, a report is produced. The report is verified and approved by the Purchasing Manager and signed by Head of Sales and Traceability. The Mine visit Report is logged and saved for a minimum of 5 years.

In case of any discrepancies or any violations of PowerX Ltd., or Power Elements' policies are detected, PowerX Ltd. Senior management shall be immediately informed and all activity with the entity in question is suspended.

3.2. Adopt a risk management plan

All PowerX Ltd. employees whose roles include trade, processing or shipments of concentrates or refining processes of conflict minerals are acquainted with company's Supply Chain and Risk Management policies and their fundamental principle that it will only source minerals from conflict free certified mines with full traceability.

3.3. Implement risk management

PowerX Ltd. carries out its own due diligence process in the Logistic supply chain which may include relevant industry recognised bodies. Furthermore, PowerX Ltd. will publicly report on its supply chain Due Diligence policies and practices and will expand the scope of sustainability, corporate social responsibility or annual reports to cover additional information in the mineral supply chain due diligence.

In instances of discrepancies or violations of any of PowerX Ltd.'s policies, and after examining all the facts, PowerX Ltd. will consult with suppliers and affected stakeholders, including local and central governmental authorities, international or civil society organisations and affected third parties, where appropriate, and agree on the strategy for measurable risk mitigation in the risk mitigation plan.

3.4. Undertake additional fact and risk assessments

PowerX Ltd. has developed its own Due Diligence and OGAP program with local authorities within the country where most of the mineral concentrates for PowerX Ltd.'s refinery come from. The program is a combination of desktop Due Diligence, mandatory mine site visits supported by a Blockchain platform.

4. Carry out independent third-party audit – RMAP audit – OECD Step 4

As PowerX Ltd. is operating in US defined CAHRA region, RMI performs annual 3rd party audits on PowerX Ltd.'s sourcing and smelting of conflict minerals.

5. Report annually on supply chain due diligence – OECD Step 5

PowerX Ltd. will prepare an Annual Report and publish the report on their company web page. The report will contain the information identified below:
1. Company Management Systems: Set out the company's supply chain due diligence policy; explain the management structure responsible for the company's due diligence and who in the company is directly responsible; describe the control systems over the mineral supply chain put in place by the company, explaining how this operates and what data it has yielded that has strengthened the company's due diligence efforts in the reporting period covered; describe the company's database and record-keeping system and explain the methods for disclosing all suppliers, assuring certainty of origin to Power Elements' refinery, to downstream actors; disclose information on payments made to governments in line with EITI criteria and principles.
2. Company risk assessment in the supply chain: Publish the risk assessment with due regard taken of business confidentiality and other competitive concerns. Outline the methodology, practices and information yielded by any on-the-ground assessments; explain the methodology of company supply chain risk assessments.
3. Risk management: Describe the steps taken to manage risks, including a summary report on the strategy for risk mitigation in the risk management plan, and capability-training, if any, and the involvement of affected stakeholders. Disclose the efforts made by the company to monitor and track performance.
Ray Power, CEO
Supplier Code of Conduct
Power Elements, Inc. · 6 November 2026
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1. Purpose and scope

This Supplier Code of Conduct sets out what Power Elements, Inc. and the companies it owns or controls ("Power Elements") expect of the businesses that supply us. It applies to every supplier of minerals and concentrates, and to every supplier of goods, services, transport, equipment and labour, together with their own employees, subcontractors and suppliers who work on our business ("Suppliers").

It sits alongside our Supply Chain Policy and our Due Diligence and RMAP Procedure, which govern how we source minerals, and our Know-Your-Counterparty Policy, which governs how we check who we deal with. Suppliers are asked to acknowledge this Code before we contract with them, and it forms part of our contracts.

2. Legal compliance

Suppliers must comply with all laws and regulations that apply to them, including those on labour, health and safety, the environment, mining, export, tax, anti-bribery, anti-money laundering, sanctions and export controls. Where this Code sets a higher standard than local law, Suppliers meet this Code.

3. Responsible sourcing of minerals

Suppliers of minerals and concentrates must:
- carry out due diligence consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including all the risks identified in its Annex II, and require the same of their own suppliers;
- not tolerate, profit from, contribute to or facilitate torture, cruel, inhuman or degrading treatment, forced or compulsory labour, the worst forms of child labour, gross human rights violations, war crimes, crimes against humanity or genocide;
- not provide direct or indirect support to non-state armed groups, or to public or private security forces that illegally control, tax or extort money from mine sites, transport routes or traders;
- pay all taxes, fees and royalties due to governments for the extraction, trade and export of minerals, and never misrepresent them;
- never disguise or misrepresent the origin, quantity or quality of material, mix material of unknown origin into declared lots, or bypass the traceability controls we require;
- record every lot in our traceability system, Original Evidence, as it is produced and moved, and give us and the Rwanda Mines, Petroleum and Gas Board access to the mine-site records, production logs and licences we need to verify them;
- allow our traceability officers to carry out on-the-ground assessments at their sites.
4. Labour and human rights

Suppliers must:
- not use child labour; no person under 18 may do hazardous work, and no person below the legal minimum working age may be employed at all;
- not use forced, bonded, prison or trafficked labour, and not retain workers' identity documents or charge them recruitment fees;
- pay at least the legal minimum wage and any legally required benefits, on time and in full, and keep working hours within legal limits;
- give every worker a written contract they understand;
- respect workers' freedom to join, or not to join, a workers' organisation and to bargain collectively;
- treat every worker with dignity, without harassment, abuse or discrimination;
- respect the rights of local communities, including their access to land and water, and the principle of free, prior and informed consent where it applies.
5. Health and safety

Suppliers must provide a safe and healthy workplace, identify and control hazards, provide suitable protective equipment free of charge, train workers in the risks of their work, and allow workers to stop work they believe is unsafe without penalty. Serious accidents and incidents on our business must be reported to us promptly.

6. Environment

Suppliers must hold the environmental permits their work requires, prevent pollution, manage water, waste and hazardous materials safely and lawfully, rehabilitate land as their licences require, and work with us to reduce waste and energy use. Shipments of material classified as radioactive (Class 7) must meet all applicable national and international transport rules.

7. Business integrity

Suppliers must:
- not offer, give, ask for or accept bribes, kickbacks or facilitation payments, directly or through anyone else, in their dealings with us or with public officials on our behalf;
- not offer our employees gifts or hospitality beyond modest, occasional courtesies;
- declare any conflict of interest, including any family or financial relationship with a Power Elements employee;
- not deal with persons or territories subject to sanctions that apply to them or to us, and comply with export-control rules;
- not take part in money laundering, and accept that we pay for minerals only by bank transfer to an account in the Supplier's own name;
- keep accurate books and records of their dealings with us;
- protect our confidential information and any personal data we share, and use them only for the purpose they were shared.
8. Verification and remediation

We verify compliance with this Code through desktop due diligence, on-the-ground assessments, document checks and, where we consider it necessary, independent audits. Suppliers must cooperate, provide accurate information and give access to sites and records on reasonable notice.

Where we find a breach, we will work with the Supplier on a corrective action plan with clear deadlines, unless the breach is serious. If we find a serious breach of section 3 or 4, or a Supplier fails to correct a breach, we will suspend or end the relationship, in line with our Supply Chain Policy and the OECD Guidance.

9. Raising concerns

Suppliers, their workers and anyone affected by their work can raise a concern about Power Elements, or about a Supplier's conduct on our business, in confidence and, where the law permits, anonymously, through Speak up (speakup@powerelements.com). Suppliers must not retaliate against anyone who does so, and must give their own workers an effective way to raise grievances.

10. Review

This Code is reviewed at least once a year. Questions about it can be sent to compliance@powerelements.com.
Ray Power, Chief Executive Officer
Know-Your-Counterparty Policy
Power Elements, Inc. · 6 November 2026
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1. Purpose

Power Elements trades critical minerals across borders, through regions the OECD classes as conflict-affected and high-risk. Knowing exactly who we are dealing with, who owns and controls them and where their money and material come from is how we keep our supply chain clean and how we comply with anti-money laundering, sanctions and responsible sourcing requirements. This policy sets out how Power Elements, Inc. and the companies it owns or controls ("Power Elements") identify, verify, screen, approve and monitor counterparties.

2. Scope

This policy applies to every counterparty with which Power Elements enters, or intends to enter, a business relationship, including:
- suppliers of minerals and concentrates, and the mines, cooperatives and traders behind them;
- customers, including refiners, manufacturers, traders and government or industrial buyers;
- agents, brokers, intermediaries, logistics providers, financiers and joint-venture partners;
- investors and lenders;
- material suppliers of goods and services.
We apply the same checks to our own group companies and partners that we ask of our customers.

3. Principles
- No relationship without checks. We do not contract, ship, take delivery, pay or receive payment until the checks in this policy are complete and the counterparty has been approved.
- Risk-based. The depth of our checks matches the risk the counterparty presents.
- Automated screening, human approval. Screening is automated and continuous; every decision to approve a counterparty is taken by a named, authorised person and recorded.
- Evidence over assertion. We verify what we are told against original documents and independent sources.
4. Access tiers

Counterparties progress through four tiers, the same tiers that govern access across our website. Each tier unlocks more of our information and services.
1. Tier 0, anonymous. Public information only.
2. Tier 1, identified. The person and the organisation they represent have identified themselves with a verified business email.
3. Tier 2, onboarded and screened. The counterparty has provided the information in section 5 and passed screening.
4. Tier 3, approved. A named approver has reviewed the file and approved the relationship. Only approved counterparties can contract with us.
5. Information we collect

For an organisation, we collect and verify at least:
- full legal name, registration number, registered address and principal place of business;
- certificate of incorporation or equivalent, and evidence of good standing;
- the names of directors and senior managers;
- its ownership and control structure, down to every individual who ultimately owns or controls 25 per cent or more, or 10 per cent or more for high-risk counterparties, or who otherwise exercises control (the "beneficial owners"), with identity documents for each;
- the nature of its business, the countries it operates in and, for trading counterparties, the expected volumes, products and end use;
- bank account details in its own name;
- for mineral suppliers, mining or trading licences, mine locations, production capacity and the chain of custody of the material offered;
- for customers of controlled items, end-user and end-use declarations.
For an individual, we collect and verify their identity, address and, where relevant, source of funds.

6. Screening

Every counterparty, its directors and its beneficial owners are screened before approval and continuously afterwards against:
- the sanctions lists of the United Nations (including the Democratic Republic of the Congo sanctions list), the United States, the United Kingdom and the European Union, and of any other country whose sanctions apply to the transaction;
- export-control restricted-party lists;
- lists of politically exposed persons and their close associates;
- adverse media, including reports of corruption, fraud, money laundering, human rights abuses or links to armed groups;
- the red flags set out in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
7. Risk assessment and enhanced due diligence

Each counterparty is rated low, medium or high risk, taking into account its ownership, its countries of operation and of origin of material, the product, the payment route and the screening results. Enhanced due diligence applies to every high-risk counterparty, and always where:
- a director or beneficial owner is a politically exposed person;
- material originates from, or passes through, a conflict-affected or high-risk area;
- the ownership structure is complex, opaque or changes without explanation;
- payments are requested to or from third parties, or to accounts in other countries;
- screening returns a possible match or relevant adverse media.
Enhanced due diligence may include source-of-funds and source-of-wealth checks, independent verification of ownership, site visits, on-the-ground assessments and senior management approval.

8. Approval

Approval to move a counterparty to Tier 3 is given by:
- for trading counterparties and mineral suppliers, the Head of Traceability;
- for investors, lenders and financiers, the Chief Financial Officer;
- for any high-risk counterparty, a politically exposed person, or any case where screening has raised an unresolved concern, the Chief Executive Officer in addition.
No one may approve a counterparty in which they have a personal interest.

9. Refusal and exit

We will not start, or will end, a relationship where:
- a counterparty, director or beneficial owner is subject to sanctions that apply to us;
- the counterparty refuses or is unable to provide the information we require, or we cannot verify it;
- we find a reasonable risk that the counterparty is linked to any of the serious abuses listed in Annex II of the OECD Guidance;
- we suspect money laundering, fraud or the misrepresentation of the origin of material.
A potential supplier that fails screening is not reconsidered for at least six months. Where the law requires, we report suspicions to the relevant authorities, and we never tell a counterparty that a report has been made.

10. Ongoing monitoring and review

Screening runs continuously for every approved counterparty. Counterparty files are reviewed at least once a year for high-risk counterparties, every two years for medium-risk and every three years for low-risk, and whenever a material change occurs, such as a change of ownership, a new product or a new country of origin.

11. Records

We keep all counterparty files, screening results, approvals and decisions for at least five years after the relationship ends, or longer where the law requires. Personal data in those files is handled in line with our Data Protection Policy.

12. Responsibilities and review

Compliance owns this policy and its procedures. Every employee who deals with counterparties must follow it. Breaches are handled under our Code of Conduct. This policy is reviewed at least once a year. Questions can be sent to compliance@powerelements.com.
Ray Power, Chief Executive Officer
Anti-Bribery and Corruption Policy
Power Elements, Inc. · 6 November 2026
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1. Introduction

Power Elements, Inc. ("Power Elements"; the "Company"; "We") demands the highest standards of integrity and ethical conduct in its business dealings. We will not tolerate any bribery or corrupt practices related to our business activities from our employees or business partners. We are committed to transparent reporting and to taking all other reasonable measures which avoid Power Elements' involvement in bribery or corruption.

Bribery and corruption undermine the rule of law and the principle of fair competition. Such activities entrench bad governance, hindering efforts to alleviate poverty and often contributing to economic instability and human rights abuses. Whilst the risk of bribery exists in all geographies, sectors and transactions, Power Elements understands that steps can be taken to mitigate the inherent risk of corrupt behaviour. This Anti-Bribery and Anti-Corruption Policy (the "Policy") aims to inform Power Elements management, employees and business partners about our intention to closely monitor corruption risk and to take immediate action if evidence of corrupt activity is suspected.

2. Objective of the Policy

The objective of this Policy is to provide a procedure by which Power Elements and its subsidiaries conducts its business, ensuring honest and ethical business practices which reflect the highest standards of integrity and in compliance with all applicable laws and regulations.

3. Application of the Policy

This Policy applies to all Power Elements employees, contract staff or business partners working on our behalf ("Power Elements Employees"). Power Elements Employees must never accept or give a bribe, facilitation payment, kickback or other improper payment under any circumstances.

This includes transactions with:
- (a) foreign or domestic government officials; or
- (b) any private company or person.
This applies:
- (a) in the conduct of domestic or international business; and
- (b) where payment is received directly or where it is received through a third party (agent, contractor, representative, distributor, or business partner).
4. Management Responsibilities

Power Elements' management takes responsibility for encouraging a transparent and ethical culture at Power Elements. Their role includes:
- (a) Regularly undertaking periodic and high-level risk assessments of its business activities;
- (b) Responsibility for ensuring that the Policy is well communicated to Power Elements Employees, contractors, suppliers and business partners alike;
- (c) Encouraging trust and dialogue with employees, so that they can voice their concerns if they witness any dishonest activity; and
- (d) 'Leading by example', behaving with utmost integrity at all times.
5. Prohibited Behaviour

Power Elements prohibits the following behaviour from Power Elements Employees:
- (a) Bribery of national public officials or private sector counterparts, including facilitation payments;
- (b) Bribery of foreign public officials and officials of public international organisations;
- (c) Embezzlement of property in the private sector;
- (d) Abuse of function;
- (e) Illicit enrichment;
- (f) Laundering or concealment of proceeds of crime; and
- (g) Obstruction of justice.
6. Prevention of Improper Payments

Power Elements strictly prohibits the use of improper payments. This includes:
- (a) The improper or concealed use of 'kickbacks', subcontracts, purchase orders, consultancy agreements or payment of agents to secure business or profit; or
- (b) The direct or indirect offer, payment, soliciting or acceptance of bribes. For the avoidance of doubt this includes:
To directly or indirectly offer, give or agree to give or offer a loan, reward, advantage or benefit of any kind to a public official, political party, party official or political candidate as consideration for an act or omission by the recipient in connection with the performance of the recipients duties or functions with the government. Examples include applications for environmental permits, customs procedures or judicial proceedings.

To induce an official to use his or her position to influence any acts or decisions of government for the purposes of obtaining an advantage in the course of business; or to agree, or comply, with any demands for a bribe made by a public official.

7. Gifts and Hospitality

Power Elements recognises that reasonable and proportionate gifts and hospitality are a legitimate contribution to good business relationships between Power Elements and its business partners. However judgement must be used to ensure these are reasonable and ethical. For instance:
- (a) The cost or expense of a gift, meal or entertainment must be reasonable and in good faith directly connected to a legitimate business promotional activity or the performance of existing contracts;
- (b) When considering what is a reasonable expense, Power Elements Employees should consider the frequency with which such expenses are incurred for a particular official;
- (c) Power Elements Employees are forbidden from soliciting gifts or hospitality, and Power Elements Employees must endeavour to avoid conflicts of interest and the appearance of conflicts of interest;
- (d) Some examples of impermissible gifts include:
  
  (i) Any gift or entertainment that would be illegal (anything offered to a government official in breach of local or international bribery laws);
  
  (ii) Gifts or entertainment involving parties engaged in a tender or competitive bidding process;
  
  (iii) Any gift of cash or cash equivalent (such as gift certificates, loans, stock, stock options);
  
  (iv) Any gift or entertainment that is a 'quid pro quo' (offered for something in return); or
  
  (v) Any entertainment that is indecent, or sexually oriented.
8. Supply Chain Risk Management

When selecting potential business partners, Power Elements endeavours to work with those that are likeminded in their approach to maintaining high ethical standards as well as demonstrated legal and regulatory compliance. Power Elements will include risk management measures in its procurement practices, for example:
- (a) Power Elements' contractual terms will contain an ethical policy, including a statement on bribery and corruption.
- (b) Before entering into a new contractual relationship, Power Elements will undertake:
  
  (i) A risk assessment; and
  
  (ii) A due diligence review of the business partner.
Once the business relationship is successfully approved, periodical review of the business relationships will be ongoing, although the level of oversight required will vary depending on the risks identified upon initial assessment.

9. Training and Communication of the Policy

A copy of this Policy has or will be made available to all Power Elements Employees as well as its auditors, legal counsel and other advisors. It is also posted on the website at www.powerelements.com.

Power Elements will provide periodic compliance training on this Policy and good practices. The aims of the training are:
- (a) to ensure that the Policy is consistently taken into account by Power Elements Employees during all their business dealings; and
- (b) to provide practical assistance to Power Elements Employees on how they should respond and exercise good judgment to situations where it may be unclear what qualifies as improper payments or corruption.
10. Reporting Violations

Power Elements Employees that become aware of actions which could constitute a violation of this Policy are required to report it to their immediate supervisor. However, if the Power Elements Employee is not comfortable reporting the matter to their immediate supervisor, or does not feel their immediate supervisor has taken sufficient action, they are encouraged to report the matter to the Head of Compliance:

Compliance Manager, compliance@powerelements.com

No Power Elements Employee will suffer undue consequences for:
- (a) reporting suspected or actual violations; nor
- (b) if Power Elements loses business opportunities as a result of his or her refusal to pay or accept bribes.
11. Consequences of Non-Compliance with Policy

Any Power Elements Employee who is found to be giving or taking bribes or partaking in any other corrupt acts will be subject to disciplinary action which may ultimately lead to dismissal. The violation of this Policy may also be a violation of certain laws and, if appropriate, Power Elements may refer the matter to the appropriate regulatory authorities which could lead to criminal proceedings.

12. Remedial Measures

Should evidence of corrupt practices be uncovered, Power Elements will consider a full range of remedial measures including but not limited to:
- (a) Voluntary restoration of damages or loss caused by the offence;
- (b) Recovery of ill-gotten gains (e.g. proceeds of the corrupt act);
- (c) Acceptance of an external compliance monitor; or
- (d) Corrective organisational actions (e.g. removal or other disciplinary measures against responsible employees).
13. Review of Policy

This policy will be reviewed and evaluated regularly by the Board of Directors and the Management. The review will consider:
- (a) Whether the Policy is effective in ensuring compliance by Power Elements Employees; and
- (b) Any updates and recommendations from recognised international anti-bribery and corruption NGOs and bodies, for example:
  
  (i) Extractive Industries Transparency Initiative ("EITI");
  
  (ii) Guidelines relating to Principle 10 of the United Nations Global Compact;
  
  (iii) the United Nations Convention against Corruption ("UNCAC"); and
  
  (iv) Council of Europe Conventions regarding corruption.
14. Queries

Should you have any concerns or queries regarding this policy or believe that you may have become aware of any breach thereof, you are encouraged to contact the company compliance officer or the Chief Executive Officer, Ray Power, on ray.power@powerelements.com.
Ray Power
Sanctions and Export Control Policy
Power Elements, Inc. · 6 November 2026
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1. Purpose

Power Elements sells tantalum, niobium and other critical minerals to customers around the world. Sanctions and export controls decide who we may deal with, what we may ship and where. Breaching them can lead to criminal penalties, loss of banking and of access to markets, and lasting damage to the trust our customers place in us. This policy sets out how Power Elements, Inc. and the companies it owns or controls ("Power Elements") comply.

2. Scope

This policy applies to every director, officer, employee and contractor of Power Elements, and to agents and intermediaries acting for us. It covers every purchase, sale, shipment, payment, financing, investment and service, including the transfer of technology, software and technical data.

3. Our commitment

We comply with all sanctions and export-control laws that apply to us. These include, in particular:
- sanctions adopted by the United Nations Security Council, including the measures relating to the Democratic Republic of the Congo;
- the sanctions of the United States, including those administered by the Office of Foreign Assets Control, and the Export Administration Regulations;
- the sanctions and export controls of the United Kingdom and of the European Union;
- the laws of Rwanda and of every other country in which we operate, from which we export or to which we ship.
Because Power Elements, Inc. is a United States company, United States sanctions apply to it and to its staff who are United States persons, and some United States sanctions programmes extend to the companies it owns or controls outside the United States. We therefore apply United States, United Kingdom, European Union and United Nations sanctions across the whole group, whatever the nationality of the company or person involved.

We do not attempt to evade or circumvent sanctions or export controls, and we do not help or advise anyone else to do so.

4. What we do not do

Unless a licence or exemption has been obtained and confirmed in writing by Compliance, we do not:
- deal, directly or indirectly, with any person or entity on a sanctions list that applies to us, or with any entity owned 50 per cent or more, in aggregate, or controlled by such persons;
- deal with, or ship to or from, any country or territory subject to comprehensive sanctions under the regimes in section 3 (Compliance maintains the current list);
- make funds, material or economic resources available to a sanctioned person, directly or through others;
- export, re-export or transfer any controlled item, software or technology without the licence it requires;
- supply any item where we know or suspect it is intended for weapons of mass destruction, their delivery systems or a prohibited military end use or end user;
- take part in, or agree to, any boycott that the law of the United States prohibits.
5. How we comply

5.1 Screening

Every counterparty, its directors and beneficial owners, and every bank, carrier, vessel, port and intermediary involved in a transaction, is screened before the transaction and continuously afterwards, as set out in our Know-Your-Counterparty Policy.

5.2 Product classification

Before a product is first exported, Compliance confirms its export-control classification in each relevant jurisdiction and records whether a licence is required for any destination, end user or end use. Classifications are reviewed whenever a product specification changes.

5.3 End use and end user

For every customer we obtain the end use and end user of the material and, where the classification or the destination requires, a signed end-user statement. We assess whether the stated end use is plausible for the customer, the product and the quantity.

5.4 Contracts

Our sales and purchase contracts include sanctions and export-control clauses that require compliance, allow us to suspend or end the contract if a counterparty becomes sanctioned, and prohibit re-export in breach of applicable law.

5.5 Red flags

Stop and refer to Compliance if, for example:
- a customer is reluctant to give end-use or end-user information, or the end use does not fit its business;
- the delivery address, route or payment route is unusual, or passes through a third country without a clear commercial reason;
- payment is offered from, or requested to, a third party;
- the customer asks for unusual labelling, splitting of shipments or changes to documents;
- a vessel's identity, flag or tracking history raises questions.
5.6 Licences and records

Licences are applied for and held by Compliance. We keep records of every export, classification, licence, screening result and end-user statement for at least five years, or longer where the law requires.

6. Responsibilities

The Board oversees this policy through its Governance, Ethics & Responsible Sourcing Committee. Compliance owns this policy, maintains the screening and classification procedures, advises on licences and trains everyone whose role involves trade, logistics or payments, at least once a year. Every employee is responsible for following this policy and for raising red flags.

7. Reporting concerns and breaches

Report any suspected breach, or any concern, to Compliance (compliance@powerelements.com) or through Speak up (speakup@powerelements.com). Where we identify a breach, we take legal advice and consider voluntary disclosure to the relevant authorities. Retaliation against anyone who raises a concern in good faith is a breach of our Code of Conduct.

8. Consequences

Breaching this policy may lead to disciplinary action, up to and including dismissal, and may expose individuals to personal criminal liability.

9. Review

This policy is reviewed at least once a year, and whenever a relevant sanctions regime changes materially.
Ray Power, Chief Executive Officer
Environmental Policy
Power Elements, Inc. · 6 November 2026
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Power Elements, Inc. and its subsidiaries ("Power Elements") is committed to environmental protection as an inherent part of its sustainability programme and will uphold this policy throughout all decision making processes.

Principles:
- Identify, assess, and minimise environmental footprint;
- Comply with all applicable national and international environmental legislation;
- Prevent pollution whenever and wherever possible.
- Strive toward 100% renewable energy sources in mining and manufacturing.
The established principles and objectives of Power Elements and its subsidiaries are achieved through implementation of the Environmental Management System according to the ISO14001:2004 Standards Requirement.

To fulfil these principles, Power Elements commits to:
- Promote environmental awareness among our employees and encourage them to work in an environmentally responsible manner;
- train, educate and inform our employees about environmental issues that may affect their work or health;
- reduce waste through re-use and recycling and by purchasing recycled, recyclable, or refurbished, products and materials where these alternatives are available, economical and suitable;
- promote efficient use of materials and resources throughout our facility including water, electricity, raw materials and other resources, particularly those which are non-renewable;
- avoid unnecessary use of hazardous materials and products, seek substitutions when feasible, and take all reasonable steps to protect human health and the environment when such materials must be used, stored and disposed of;
- where required by legislation, or where significant health, safety, or environmental hazards exist, develop and maintain appropriate emergency and spill response programmes;
- communicate our environmental commitment to clients, customers, and the public, and encourage them to support it;
- strive to continually improve our environmental performance and minimise the social impact and damage of activities by periodically reviewing our environmental policy in light of our current and planned future activities.
If you become aware of an environmental infraction by Power Elements then we urge you to contact the Chief Executive Officer, Ray Power, on ray.power@powerelements.com to ensure it is properly dealt with.
Ray Power
Community Engagement Policy
Power Elements, Inc. · 6 November 2026
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Purpose

The purpose of this Community Engagement Policy is to establish guidelines for effective engagement with the local communities wherein Power Elements and its subsidiaries operate. This policy is designed to ensure that our organisation engages with the community in a transparent, respectful, and collaborative manner.

Policy statement

Power Elements is committed to building strong relationships with the community. We recognise that the community is an important stakeholder and we believe that its participation is critical to the long-term success of our organisation. We will engage with the community in a transparent, respectful, and collaborative manner.

Guidelines
1. Transparency: We will provide timely and accurate information to the community about our organisation's goals, objectives, and activities. We will be open and honest in our communication with the community, accepting engagement through various channels (direct, email, phone or via 3rd party).
2. Respect: We will treat all members of the community with respect and dignity. We will listen to their concerns and opinions, and we will respond in a timely and courteous manner.
3. Collaboration: We will work collaboratively with the community to identify and address community needs and priorities. We will seek input from the community in our decision-making process. Where possible, we will employ local community members, especially for temporary jobs that do not demand skilled labor and where that unskilled labor can replace machinery without tempering budget goals and projects' timelines.
4. Accessibility: We will ensure that our engagement activities are accessible to all members of the community, including those with disabilities and those who speak languages other than English.
5. Diversity and Inclusion: We will respect and value the diversity of the community and ensure that our engagement activities are inclusive and equitable.
6. Feedback: We will actively seek feedback from the community about our engagement activities, and we will use this feedback to improve our engagement practices. For this purpose, a Grievance mechanism procedure with instructions on how to trigger it is visibly displayed at all of our facilities.
7. Continuous Improvement: We will regularly review and evaluate our engagement practices, especially when the grievance mechanism is triggered, to ensure that they are effective and aligned with our organisation's goals and objectives.
Implementation

This policy applies to all employees, volunteers, and contractors of Power Elements and its subsidiaries. It is the responsibility of all employees, volunteers, and contractors to follow this policy and ensure that our engagement activities are conducted in accordance with these guidelines.

Conclusion

Our organisation is committed to building strong relationships with the community. We believe that effective community engagement is critical to our success, and we are committed to engaging with the community in a transparent, respectful, and collaborative manner.
Ray Power, CEO
Grievance and Complaints Mechanism
Power Elements, Inc. · 6 November 2026
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1. Introduction

Intended for: This Grievance and Complaints Mechanism (Mechanism) is intended for any employee of Power Elements, Inc. (Power Elements) and all of its subsidiaries, or any affected persons within the company or outside the company or whistle-blowers.

2. Legitimacy

Power Elements has adopted this grievance mechanism with the aim of giving the above-mentioned individuals or groups the opportunity to express their views, comments, concerns or complaints without experiencing any negative consequences.

All existing workers and new hires are or will be given a hard or soft copy of the Grievance and Complaint Mechanism Policy.

All Managers, Supervisors and Workers must be familiar with the procedure of the mechanism and its activation.

When the grievance mechanism is triggered, Power Elements management is obligated to respond and take action.

3. Accessibility

The Mechanism itself is publicly displayed in a clearly visible place within all Power Elements entities, with soft and hard copy forms available, through which the Mechanism can be triggered and the policy read.

The Mechanism is published in English and applicable local languages used in any of Power Elements' entities.

Managers and Supervisors shall hold Information sessions on how to use the Mechanism as part of operational meetings with the aim of educating and renewing the knowledge of the Mechanism's usage, especially when hiring young workers, seasonal workers, and/or migrant workers.

4. Transparency

After the Mechanism is triggered, no disclosure of names and practical details about the grievance should be shared with anybody outside of Power Elements' committee handling the complaint. To uphold a commitment to problem solving within Power Elements transparently, however, Power Elements will publish:
- The date of the complaint.
- The description of the complaint (in general terms, without specifics that could reveal the identity of the person triggering the Mechanism).
- The investigation and conciliation measures taken and the final resolution.
- The date of the resolution.
The above-mentioned data is published with the purpose of proving Power Elements is following its own Grievance and Complaints Mechanism.

5. Dialogue

Since Power Elements operates in an international environment, it is inevitable that employees will encounter cultural differences at some point. These cultural differences must be respected.

In order to properly manage and understand complaints, Power Elements undertakes that the person receiving and being responsible for examining each complaint will be from or substantially familiar with the local cultural environment and will lead the Corrective Action Process following the complaint. At the same time, the person in charge of receiving the grievances should be competent in conflict management in the workplace, conciliation, and mediation.

In case Power Elements will not be able to find a resolution to the complaint, Power Elements will seek external support from consultants or stakeholders who specialise in conflict resolution.

6. Types of grievances
- Company's Infrastructure: If any of the company's facilities are not sufficient to safely conduct work.
- Personnel relations: Any personnel conflict in the workspace.
- Contractual rights: If any clause of the employment contract or company policy is violated.
- Human and labour rights: any discrimination based on gender, religion, or place of origin, or the working conditions do not adequately protect workers.
- Customary rights: Violation of local customs allowed by local labour laws, for example, requested time to pray or to participate in community activities has not been allowed.
- Miscellaneous: Any complaint Manager, Supervisor or Worker believes should be raised.
7. Grievance mechanism procedure

In order to avoid unnecessary escalation in the event of disturbing situations, it is recommended that employees adhere to the following steps and complaint channels:

Talking to supervisor: Prior to escalating a situation, it is suggested that an employee holds an open and constructive meeting about a grievance with their immediate supervisor or manager.

Right to appeal: If the meeting with a direct supervisor does not provide an amicable solution to a problem, any employee can trigger the Mechanism via email to speakup@powerelements.com or a hard copy letter to the Human Resources Manager. Complaints will reach the appropriate person responsible for processing complaints through any of the channels mentioned.

Access to support: The person triggering the Mechanism has the right to be accompanied by a fellow person from the company. The escort of a fellow employee is allowed in order to make workers more comfortable with the process.

8. Steps for handling grievances from workers

Email: When triggering Mechanism via email speakup@powerelements.com the recipient must confirm email was received.

Hard copy: Copies of grievance forms are available in places with easy and private access for employees. A mailbox for submitting a hard copy complaint must be located at each of Power Elements' entity offices. Access to the mailbox is given to Safety Manager only.

All grievances should be resolved as quickly and effectively as possible. Unless exceptional circumstances apply, a grievance should be resolved within six months of receipt. Where a grievance cannot be resolved within this timeframe, the complainant shall be informed of the reason for the delay and provided with an updated expected timeframe for resolution.

9. Analysis

The corrective action process that follows complaint includes the following steps:
- Review and document the problem and related corrective action.
- Contain or temporarily fix the problem.
- Investigate the root cause of the problem.
- Propose an appropriate solution that will prevent the problem from happening again; this will often mean a change to the business process in the company.
- Report on the actions actually taken, internally inform and educate employees if any business processes are amended due to corrective actions.
- After an appropriate period of time, assess whether the actions taken were successful in preventing recurrence and document the evidence to support this assessment.
9.1. Integration with Risk Identification Process

Insights from root cause investigations, proposed solutions, and grievance resolutions (including patterns from multiple cases) shall be documented as incident reports and shared with the Risk Management Committee (via the Head of Sales & Traceability) within 5 working days of case closure. This feedback will inform risk evaluations, mitigation strategies, and monitoring under the Risk Mitigation Policy (Sections 4 and 8), ensuring that best practices and lessons learned are incorporated into the due diligence management system.

10. Mediation

After an analysis is complete, the person that submitted the grievance is invited to the meeting by email or letter in case email is unavailable.

The invitation will include:
- The day of the meeting.
- The place.
- Who else will be present (if applicable).
The Employee submitting the grievance is allowed to bring a companion to this meeting. Meeting and all solutions to the problem are minuted. After the proposals have been suggested, a representative of Power Elements shall seek the employee's approval/acceptance of any of the proposals.

11. Closing the grievance case and publishing conclusions

After the mediation meeting, the solution for the grievance will be posted within 3 working days on the notice boards to inform workers, with full respect of the involved parties' privacy.

Power Elements shall maintain a log of all grievance submissions and their resolutions in its digital records.

12. Appeal

Disagreement on the analysis and proposed corrective actions, as well as any delay in the implementation of agreed upon corrective measures, are grounds for Employee's further appeal. The Power Elements Management team is required to investigate an appeal in the shortest possible time frame to secure the integrity and purpose of Grievance Mechanism.

If the management of the company does not investigate the Appeal, the Employee may seek other channels of appeal outside the Company.

As a last resort, if no other solution can be found, the problem is resolved through local labour legislation and local courts.

13. Community complaint

Power Elements' subsidiaries' Managers are required to maintain contact with the local community's representatives to see if Power Elements' operations negatively effect the local community and, if they do, make reasonable attempts to mitigate those effects.

At the gates of each subsidiary's operation, viewable to the public, is an explanation that a complaint by community members may be made by email to speakup@powerelements.com.
Ray Power, CEO
Whistleblowing and Speak-up Policy
Power Elements, Inc. · 6 November 2026
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1. Purpose

We want to know when something is wrong at Power Elements, so that we can put it right. This policy explains how anyone can raise a concern, how we handle it, and how we protect the people who speak up. It applies to Power Elements, Inc. and every company it owns or controls ("Power Elements").

2. Who can speak up

Anyone. That includes our directors, employees, temporary workers and contractors, former employees and job applicants, suppliers and their workers, customers, investors, people who live near our sites, and anyone else who has a concern about our conduct.

3. What you can raise

You can raise any concern that something wrong has happened, is happening or is likely to happen in connection with Power Elements, including:
- bribery, corruption, fraud, theft or money laundering;
- breaches of sanctions or export controls, or doubts about the origin of material;
- risks to health and safety;
- harm to the environment;
- human rights abuses, including forced or child labour, harassment and discrimination, and the unfair treatment of workers or communities;
- false or misleading records, accounts, traceability data or public statements;
- breaches of our Code of Conduct, our policies or the law;
- retaliation against someone who has spoken up;
- the deliberate concealment of any of these.
Personal grievances about your own employment, such as a dispute about pay or a working relationship, are usually best handled through your manager or under our Grievance and Complaints Mechanism, unless they also involve one of the matters above.

You do not need proof. You need only an honest and reasonable belief that something is wrong.

4. How to raise a concern

You can raise a concern:
- with your manager, or with any senior manager you trust;
- with Compliance, at compliance@powerelements.com;
- through Speak up, by email to speakup@powerelements.com, or through the other channels listed on the Speak up page of our website.
If your concern involves senior management or a director, you can raise it directly with the chair of the relevant Board committee, through Speak up.

You can give your name, ask for your identity to be kept confidential, or, where the law of the relevant country permits, stay anonymous. If you stay anonymous, please give enough detail for us to investigate, and use a channel that lets us ask you follow-up questions.

5. How we handle a concern
1. Acknowledgement. We acknowledge every report within seven days.
2. Assessment. Compliance assesses the report and decides how it should be investigated. A report about Compliance, or about a member of senior management or the Board, goes directly to the chair of the relevant Board committee.
3. Investigation. Every investigation is carried out by people independent of the matter reported, with outside specialists where needed. Anyone named in a report is treated fairly and is presumed not to have done wrong until the facts are established.
4. Feedback. We tell you how the matter is progressing and, within three months of acknowledgement, what action has been taken or is planned, so far as we can without breaching the rights of others or the law.
5. Closure and action. Where wrongdoing is found, we act on it, including disciplinary action, changes to our controls and, where required, reports to the authorities.
6. Oversight

The Board oversees this policy. Concerns about financial reporting, accounting, internal controls or audit are overseen by the Audit Committee. All other concerns are overseen by the Governance, Ethics & Responsible Sourcing Committee. Each committee receives a report on the number, type and outcome of concerns at least once a quarter. We publish the number of concerns raised and resolved each year, without identifying anyone.

7. Confidentiality

Your identity, and any information that could identify you, is shared only with the people who need it to handle the concern, unless you agree otherwise or the law requires its disclosure. Records of concerns are kept securely and handled in line with our Data Protection Policy.

8. Protection from retaliation

We will not tolerate any form of retaliation against anyone who raises a concern in good faith, or who helps with an investigation, even if the concern turns out to be mistaken. Retaliation includes dismissal, demotion, loss of work or contracts, harassment, intimidation and any other unfair treatment. Anyone who retaliates will face disciplinary action, up to and including dismissal or the end of a contract.

If you believe you have suffered retaliation, report it through Speak up.

Deliberately making a report you know to be false is a breach of our Code of Conduct.

9. Reporting outside the company

Nothing in this policy, or in any agreement with Power Elements, prevents anyone from reporting a concern to a regulator, law enforcement or other competent authority, or from exercising any right they have under the law. People who speak up are entitled to the protection of the whistleblowing laws that apply to them, which include Rwanda's law on the protection of whistleblowers, the United Kingdom's Public Interest Disclosure Act 1998, United States federal and state whistleblower protections and, where they apply, the laws implementing the European Union Whistleblower Directive.

10. Review

Compliance owns this policy and reviews it at least once a year.
Ray Power, Chief Executive Officer
Data Protection Policy
Power Elements, Inc. · 6 November 2026
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1. Purpose

Power Elements holds personal data about employees, job applicants, contractors, counterparties and their owners and staff, investors, community members and visitors to our sites and website. This policy sets out how Power Elements, Inc. and the companies it owns or controls ("Power Elements") collect, use, protect and share that data, so that we respect people's privacy and comply with the data protection laws that apply to us.

2. Scope

This policy applies to all personal data processed by or for Power Elements, in any form, and to every director, officer, employee and contractor who handles it. Personal data is any information relating to an identified or identifiable living person.

The laws that apply to us include Rwanda's Law No. 058/2021 relating to the protection of personal data and privacy, the United Kingdom General Data Protection Regulation and Data Protection Act 2018, the European Union General Data Protection Regulation where it applies, and the privacy laws of the United States and of its states, including Texas, where they apply. Where these laws differ, we meet the strictest standard that applies.

3. Principles

We process personal data only:
- lawfully, fairly and transparently, on a lawful basis, and having told people what we do with their data;
- for specified purposes, and not in ways incompatible with those purposes;
- to the minimum needed for those purposes;
- accurately, keeping data up to date and correcting it when it is wrong;
- for no longer than necessary, in line with our retention schedule;
- securely, protected against unauthorised access, loss or damage;
- accountably, keeping records that show how we comply.
4. Lawful basis and sensitive data

Each use of personal data must have a lawful basis, such as a contract with the person, a legal obligation (including our obligations to screen counterparties against sanctions lists), our legitimate interests where they are not overridden by the person's rights, or consent. Sensitive data, including data about health, biometrics or criminal records, is processed only where the law expressly allows it, with additional safeguards.

5. Transparency

We tell people, at the time we collect their data, who we are, what we collect, why, who we share it with, how long we keep it and what their rights are. Our privacy notices, including the notice on our website, are kept up to date.

6. Individuals' rights

We respect people's rights under the laws that apply to them, including the rights to be informed, to access their data, to have it corrected or deleted, to object to or restrict its processing, to data portability and not to be subject to decisions based solely on automated processing that significantly affect them. Requests are answered within the time the law requires and, in any event, within one month. Requests can be made to privacy@powerelements.com.

7. Automated processing and AI

Power Elements uses automated tools and artificial intelligence across its operations, including for counterparty screening. No decision that has a legal or similarly significant effect on a person, such as approving or refusing a counterparty, hiring or ending employment, is taken by a system alone; a named person reviews and takes the decision. Personal data is entered only into tools that Power Elements has approved and assessed for data protection.

8. Security

We protect personal data with technical and organisational measures suited to the risk, including access limited to those who need it, multi-factor authentication, encryption, logging and regular testing. Staff are trained before they are given access to personal data, and at least once a year.

9. Processors and sharing

We share personal data only where we have a lawful basis to do so. Any service provider that processes personal data for us does so under a written contract that requires it to act only on our instructions and to keep the data secure. We do not sell personal data.

10. International transfers

Power Elements operates in Rwanda, the United Kingdom and the United States, so personal data moves between countries. We transfer personal data only where the law permits, using the safeguards it requires, such as adequacy decisions, approved contractual clauses and, for data from Rwanda, the authorisation of the National Cyber Security Authority where required.

11. Retention

We keep personal data only for as long as we need it for the purpose for which it was collected, or for as long as the law requires. Counterparty due diligence records are kept for at least five years after the relationship ends. Our retention schedule sets the period for each category of data, and data is securely deleted or anonymised at the end of it.

12. Data protection by design and impact assessments

We build data protection into new systems, products and processes from the start. Before we begin any processing that is likely to result in a high risk to people, we carry out a data protection impact assessment.

13. Personal data breaches

Anyone who suspects a personal data breach must report it immediately to privacy@powerelements.com. We assess every breach, contain it, and notify the relevant supervisory authority and affected people where the law requires and within the time it requires, including 48 hours in Rwanda and 72 hours under the United Kingdom and European Union GDPR. Every breach is recorded.

14. Registration and accountability

Each Power Elements company registers with the data protection authorities where the law requires, including the National Cyber Security Authority in Rwanda. We keep records of our processing activities. The Chief Financial Officer is accountable to the Board for data protection, supported by a designated data protection lead, and a data protection officer is appointed wherever the law requires one.

15. Breaches of this policy and review

Breaching this policy may lead to disciplinary action, up to and including dismissal. This policy is reviewed at least once a year.
Ray Power, Chief Executive Officer

The Grievance and Complaints Mechanism can also be downloaded in Kinyarwanda.

Reports

PowerX Ltd — RMAP due diligence report, 2025

PowerX Ltd · Year 2025 · published 4 August 2026

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Responsible Minerals Assurance Process due diligence public report

1. Company information


Company name	POWERX Ltd.
CID number	CID004054
Company HQ address	KG608 St., No.: 4, Kacyiru, Kigali, Rwanda
Refinery address	Bugesera Special Economic Zone, Bugesera, Rwanda
3TG material processed	Tantalum
Company registration number	108118012
Type of business	Tantalum Refinery
Current refinery status	Active by RMI
Period covered by this report	Year 2025

PowerX Ltd. joined RMI in October 2022 and received its conformant status on 12th May 2023.

PowerX Ltd. Tantalum Refinery is located in Rwanda, and throughout 2025, was sourcing from Rwandan coltan mines exclusively. To follow OECD's and RMI's guidelines on sourcing conflict minerals responsibly, PowerX Ltd. is performing what is understood in the RMI guidelines as "enhanced due diligence". This enhanced Due Diligence (DD) is performed because PowerX Ltd is physically present in the Great Lakes Region of Eastern Africa and the mines supplying coltan to the refinery are located in a CAHRA region.

2. RMAP assessment

PowerX Ltd. has been a member of the Responsible Minerals Initiative (RMI) since October 2022, and by 12th of May 2023, held "Conformant" status on RMI's list of smelters, which it has held up to date.

PowerX Ltd underwent its third Responsible Minerals Assurance Process (RMAP) between the 14th and 16th of July 2025. The period covered in this third assessment was 1st May 2024 to 30th June 2025. This third assessment is valid for one year. The evaluation was conducted by BDO. The assessment summary report is publicly available here.

PowerX Ltd is committed to having these assessments done on an annual basis to validate conformance with RMAP protocols and current global standards on responsible sourcing of conflict minerals.

3. Corporate supply chain policies

PowerX Ltd. ensures full compliance with national and international laws and regulations. In support of this responsible sourcing, PowerX Ltd. follows its parent company's Supply Chain Policy, which is, among other policies, available on the company's webpage (https://pwr.ltd/sustainability). For evaluation purposes, PowerX has an internal CAHRA procedure and Due Diligence process that conforms to the RMAP standard. Between these policies and processes and being physically present in the African Great Lakes region, which allows enhanced in-person Due Diligence assessments, PowerX can ensure it is only receiving minerals that are verified to be free of any OECD Annex II risk.

4. Management system

General management

All PowerX Ltd. employees whose roles include trade, processing, shipments of concentrates, or refining processes of conflict minerals are acquainted with the company's Supply Chain and Risk Management policies and their fundamental principle that it will only source minerals from verified mines with no OECD Annex II risks present and with full traceability of minerals' origin available.

Staff who are educated and competent in conducting due diligence and performing mine site assessments of mines' Employees are:

Head of Sales and Traceability,
Production Manager
Security Officers

PowerX Ltd. performs desktop Due Diligence on its suppliers (Know Your Counterparty (KYC)) as well as an On-the-Ground Assessment Process (OGAP). All suppliers are less than 200km from the Refinery. During these OGAPs, PowerX checks the legal status of entities and daily mining logs to compare the mine's output with deliveries from that mine. PowerX also interviews key and random employees of the mine, checks health and safety measures, and inquires about any non-government armed groups operating in the area. The execution of OGAP is carried out by experienced and competent personnel (Head of Sales and Traceability, Production Manager, Security Officers). These officers report to the Production Manager on a national level, and the Company Head of Sales and Traceability on an international level. The officers provide reports to the Head of Sales and Traceability, who oversees PowerX's ore purchasing operations, compliance, and the conformance of sourced materials. Meetings between teams carrying out the OGAP and their superiors are held weekly. Any actual or potential risks are reported up the chain of command within PowerX Ltd. to the Head of Sales and Traceability.

All existing and newly hired personnel are trained on Due Diligence procedures and all other job-relevant Company policies with an emphasis on implementing Supply Chain Policy and due diligence procedures.

In 2025, PowerX exclusively utilised its own government-licensed Due Diligence and Traceability system in Rwanda. This system meets the OECD requirement for third-party oversight, as it operates under a license issued by the Rwanda Mines Board (RMB), with RMB agents assigned to witness and verify production records and chain of custody events.

Internal system of control

PowerX Ltd. reviews its Due Diligence and OGAP systems at least once per year, monitoring their adequacy and effectiveness in the region and markets to which PowerX Ltd. is sourcing or selling products to. If required, proactive measures are taken within the one-year period between planned reviews. Should an unanticipated development occur, a reactive measurement will follow in the shortest achievable time.

PowerX Ltd. operates its own laboratory to determine the quality of materials that are offered to, or purchased by PowerX Ltd. Standard Operating Procedures (SOP's), cover all aspects of the material control system, from compliance control, mass balance control, acceptance, and reporting.

Supplier engagement

PowerX Ltd. is actively facilitating government agencies in charge of the mining sector development in Rwanda to further engage with suppliers on mine development, environmental sustainability and other impact initiatives which contribute to transparency and relationship building in the supply chain.

Working with the Suppliers allows PowerX Ltd. to make regular mine-site visits and provide due diligence reports based on those visits. Findings from these mine site visit reports are shared with buyers downstream or relevant industry-recognised bodies, as necessary.

Reports on work and engagement with local communities are not publicly shared for community protection reasons but are regularly shared with the Company's Independent Chairman and key company stakeholders such as lenders or advisory personnel as well as being made available to any mandated auditor.

Grievance mechanism

PowerX Ltd. follows its Parent company's Human Rights Policy which defines that both employees and stakeholders within local communities have access to appropriate grievance mechanisms. The policy is publicly available on the company's website.

Record keeping

All of the company's records are retained digitally and in hard copy for a minimum period of 5 years. Internal material control continuously monitors inventory via receipts, physical inspection and inventory logs. Within these systems, any mass balance discrepancies are investigated.

5. Risk identification and mitigation

PowerX follows an in-house supplier evaluation process which is in line with the Company Supply Chain Policy, the OECD Guidance for Responsible Supply Chain of Minerals from Conflict-Free and those from High Risk Areas, with the goal to stop and prevent trade in minerals where funds from those minerals support conflict and/or gross human rights abuses.

PowerX Ltd. is fully committed to conformance with the position of the Organisation for Economic Co-operation and Development (OECD) concerning responsible supply chain management and supporting their customers' compliance with the Dodd–Frank Act, and the EU Conflict Minerals Regulation and avoids the use of ores and metals that finance or benefit armed groups or are linked to gross human rights abuses. PowerX Ltd. is committed to refraining from any act which contributes to the financing of conflict and complies with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

All potential suppliers are first introduced to the Supply Chain Policy. They undergo the Supplier Evaluation process, which consists of 'Risk assessment and CAHRA country/region identification of material source', to identify any potential OECD Red Flags and categorise them. Based on this characterisation, PowerX performs risk response planning of the supplier and then determines whether it rejects or accepts the supplier. Every new supplier goes through this process, and once verified as acceptable on a desktop Due Diligence level, is visited in person by PowerX Ltd.'s competent personnel who perform Mine Site Due Diligence, verifying a number of issues including the plausibility of mine's output, making sure there is no child or forced labour present, that employees are paid according to local labour laws, and that no armed groups benefit in any way from Mine's activities.

PowerX Ltd. assesses gathered data, defines the potential risks, and makes a decision based on the company's Risk Mitigation Policy, whether the communication and due diligence process with a potential supplier should continue, be temporarily suspended or whether the company should disengage. In case of the latter decision, PowerX Ltd. terminates communication with the potential supplier who has not passed the screening for a minimum of 6 months.

In 2025, PowerX Ltd. sourced concentrate from mines located in Rwanda, which is defined as a CAHRA. In all deliveries, PowerX followed the prescribed procedures and made Due Diligence visits to mining sites to verify the legal status, the origin of materials delivered, the chain of custody mechanisms used, working conditions etc. The mines passed the Due Diligence process and are considered acceptable suppliers for the period of 12 months since the day the Due Diligence visit was done. Due Diligence Reports' findings are made available to PowerX Ltd.'s clients downstream. Even though the Company is not a member of EITI, PowerX Ltd will disclose information on any payments made to Governments to be in line with EITI criteria as needed.

Prepared by Primož Meze, Head of Sales and Traceability. Signed by Ray Power, CEO.

PowerM Ltd — RMAP due diligence report, 2024

PowerM Ltd · Year 2024 · published 10 February 2025

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Responsible Minerals Assurance Process due diligence public report

1. Company information


Company name	POWERM Ltd.
Company HQ address	KG608 St., No.: 4, Kacyiru, Kigali, Rwanda
3TG material processed	Tantalum and Tin
Company registration number	104977989
Type of business	Tantalum and Tin mine, processing facility
Current status	Active
Period covered by this report	Year 2024

2. Short summary

PowerM Ltd operates its own mining site, which has transitioned from an artisanal/small-scale pilot plant to a fully mechanised mine in Q4 of 2023. Because of this transition, PowerM made a business decision to cease sourcing minerals from third parties as of mid-2023.

The company maintains its procedures relating to the responsible sourcing of conflict minerals in the event that it decides to resume purchasing from third parties in the future.

The Board of PowerM Ltd have carefully reviewed the end-of-year audit for 2024 and is satisfied that all requirements to comply with the OECD Framework for Conflict Minerals were upheld during the period.

3. Corporate supply chain policies

PowerM Ltd. ensures full compliance with national and international laws and regulations. In support of this responsible sourcing, PowerM Ltd. follows its parent company's Supply Chain Policy, which is among other policies available on the company's webpage (https://pwr.ltd/sustainability). For evaluation purposes, PowerM Ltd. has an internal CAHRA procedure and Due Diligence process that conforms to the RMAP standard. Between these policies and processes and being physically present in the African Great Lakes region, which allows enhanced in-person Due Diligence assessments, PowerM can assure it would only receive minerals that are verified to be free of any OECD Annex II risk if the decision to restart buying from 3rd parties is made.

4. Management system

General management

All PowerM Ltd. employees whose roles include trade, processing, shipments of concentrates, or refining processes of conflict minerals are acquainted with the company's Supply Chain and Risk Management policies and their fundamental principle that it will only source minerals from verified mines with no OECD Annex II risks present and with full traceability of minerals' origin available.

Staff who are educated and competent in conducting due diligence and performing mine site assessments of mines Employees are:

Head of Sales and Traceability,
Traceability and Digitalisation officer

PowerM Ltd., when still trading, performed desktop Due Diligence on its suppliers (Know Your Counterparty [KYC]) as well as an On-the-Ground Assessment Process (OGAP). During these OGAPs, PowerM checks the legal status of entities and daily mining logs to compare the mine's output with deliveries from that mine. PowerM also interviews key and random employees of the mine, checks health and safety measures, and inquires about any non-government armed groups operating in the area. The execution of OGAP is carried out by experienced and competent personnel (Traceability and Digitalisation officers). These officers report to the Company Head of Sales and Traceability on an international level. The officers provide reports to the Head of Sales and Traceability, who oversees PowerM's ore purchasing operations, compliance, and the conformance of sourced materials. Meetings between teams carrying out the OGAP and their superiors are held weekly. Any actual or potential risks are reported up the chain of command within PowerM Ltd. to the Head of Sales and Traceability.

All existing and newly hired personnel are trained on Due Diligence procedures and all other job-relevant Company policies with an emphasis on the implementation of Supply Chain Policy and due diligence procedures.

In 2024, PowerM Ltd recorded its production data and chain of custody information digitally using the Original Evidence software platform. Original Evidence is licensed by PowerM's sister company, PowerX Ltd, under its Due Diligence and Traceability license issued by Rwanda Mines, Petroleum and Gas Board ("RMB" or the "Regulator").

Internal system of control

PowerM Ltd. reviews its Due Diligence and OGAP systems at least once per year, monitoring its adequacy and effectiveness in the region and markets to which PowerM Ltd. is sourcing or selling products to. If required, proactive measures are taken within the one-year period between planned reviews. Should an unanticipated development occur, a reactive measurement will follow in the shortest achievable time.

PowerM Ltd. operates its own laboratory to determine the quality of materials that are offered to, or purchased by PowerM Ltd. Standard Operating Procedures (SOP's), cover all aspects of the material control system, from compliance control, mass balance control, acceptance, and reporting.

Evaluation by recognised upstream assurance mechanisms

PowerM's traceability papers within the Original Evidence platform were incorporated into the external evaluation of PowerM's client-smelter audit by the Responsible Minerals Initiative and were satisfactorily conformant.

Supplier & buyer engagement

PowerM Ltd. is actively facilitating government agencies in charge of the mining sector development in Rwanda to further engage with suppliers on mine development, environmental sustainability and other impact initiatives which contribute to transparency and relationship building in the supply chain.

Working with the Suppliers and Buyers allows PowerM Ltd. to make and host regular mine-site visits and provide due diligence reports based on those visits. Findings from these mine site visit reports are shared with buyers downstream or with relevant industry-recognised bodies as necessary.

Grievance mechanism

PowerM Ltd. follows its Parent company's Human Rights Policy, which defines that both employees and stakeholders within local communities have access to appropriate grievance mechanisms. The policy is publicly available on the company's website.

Record keeping

5. Risk identification and mitigation

PowerM follows an in-house supplier evaluation process which is in line with the Company Supply Chain Policy, the OECD Guidance for Responsible Supply Chain of Minerals from Conflict Free and those from High Risk Areas, with one goal to stop and prevent trade in minerals where funds from those minerals support conflict and/or gross human rights abuses.

PowerM Ltd. is fully committed to conformance with the position of the Organisation for Economic Co-operation and Development (OECD) concerning responsible supply chain management and supporting their customers compliance to the Dodd–Frank Act, and/or the EU Conflict Minerals Regulation and to avoid the use of ores and metals that finance or benefit armed groups or linked to gross human rights abuses. PowerM Ltd. is committed to refraining from any act which contributes to the financing of conflict and complies with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

All potential suppliers are first introduced to the Supply Chain Policy. They undergo the Supplier Evaluation process, which consists of 'Risk assessment and CAHRA country/region identification of material source', to identify any potential OECD Red Flags and categorise them. Based on this characterisation, PowerM performs risk response planning of the supplier and then determines if action is needed to mitigate identified risk, reject, or accept supplier. Every new supplier goes through this process, and once verified as acceptable on a desktop Due Diligence level, is visited in person by PowerM Ltd.'s competent personnel who perform Mine Site Due Diligence, verifying a number of issues including plausibility of mine's output, making sure there is no child or forced labor present, that employees are paid according to local labor laws, and that no armed groups benefit in any way from Mine's activities.

PowerM Ltd. assesses gathered data, defines the potential risks, and makes a decision whether the communication and due diligence process with a potential supplier should continue or whether the communication should cease. In case of the latter decision, PowerM Ltd. terminates communication with the potential supplier who has not passed the screening for a minimum of 6 months.

In 2024, PowerM Ltd. didn't source concentrate from any 3rd party mines. All production and traceability papers and reports were duly signed by the Regulator and the Original Evidence platform. PowerM successfully passed the Due Diligence visits of its clients and is considered an acceptable supplier. Any Due Diligence and Traceability data can be made available to PowerM Ltd's downstream clients.

Prepared by Primož Meze, Head of Sales and Traceability. Signed by Dr Matevž Uroš Pavlič, General Manager.

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