As Meta Nickel Cobalt, we believe that we can achieve the goals we set within the Smart Life 2030 strategy only by creating an inclusive value chain. With this understanding, we manage our entire supply chain in accordance with environmental, social, and governance (ESG) principles.

MAJOR ABUSES AND VIOLATIONS

When sourcing products from conflict-affected and high-risk areas* (CAHRA) or operating in these areas, we do not tolerate any form of forced labor, including all forms of forced labor such as any kind of forced labor that may manifest itself as working against one's own will, without the person's free will, or under threat of punishment, as well as the worst forms of child labor, sexual violence, and other severe human rights abuses such as war crimes, other serious international humanitarian law violations, crimes against humanity, and genocide. We do not engage, support, or benefit from these practices.

DIRECT OR INDIRECT SUPPORT TO NON-STATE ARMED GROUPS

We do not tolerate any form of support, whether direct or indirect (supply of minerals, payment, or any form of logistical support or equipment provision), to non-state armed groups controlling mining areas or transport routes, illegally taxing or levying illegal taxes on export companies or international traders. We do not support these practices.

ILLEGAL PRACTICES OF SECURITY FORCES

We acknowledge that the role of public or private security forces working in mining areas, transport routes, or places where mining trade is carried out is solely to protect human rights, ensure the safety of mining workers, equipment, and facilities, and enforce the application of laws. We do not support any form of support, direct or indirect, to security forces that engage in illegal taxation or extortion in places where mining trade is carried out, or impose illegal taxes or taxes on export companies and international traders. We acknowledge that the duty of security forces is to ensure the enforcement of laws, including protecting human rights, and we commit to taking steps to ensure that security forces do not hire units or personnel responsible for human rights violations and adopt screening/audit policies.

FALSE STATEMENTS AND BRIBERY

We do not engage in any form of bribery to mislead the public about the origin of minerals or payments made to governments for taxes, fees, and royalties related to mining, trade, processing, transport, and export activities.

TAX, WAGE, AND PRIVILEGE PAYMENTS

In conflict-affected and high-risk areas (CAHRA's), we ensure that taxes, fees, and privileges related to mining, trade, processing, transport, and export activities are paid to the relevant states. In line with our company's position in the supply chain, we share such payments with the public in accordance with the principles set out in the Extractive Industries Transparency Initiative (EITI).

OCCUPATIONAL HEALTH AND SAFETY

We provide a healthy and safe working environment for all our employees by taking measures to manage risks that may cause work accidents and occupational diseases.

ENVIRONMENT

In line with the Smart Life 2030 strategy, we conduct our activities in a way that creates value for the environment with innovative business models inspired by nature. In this regard, we follow the European Green Deal and Sustainable Development Goals, aiming to prevent environmental impact-related pollution and support environmental protection.

Through waste energy utilization, greenhouse gas emission reduction, and waste reduction projects, we prevent environmental impact-related pollution and support environmental protection.
By turning to renewable energy sources to reduce natural resource use and energy consumption, we contribute to reducing greenhouse gas emissions and protecting nature.

As Meta Nickel Cobalt A.Ş., Turkey's first nickel and cobalt processing facility involved in exploring, extracting, and processing ore using R&D, innovation, and technology for the production of Mixed Hydroxide Product (MHP) containing nickel and cobalt, we believe that sustainable living is a fundamental right for every individual and living being. In alignment with the Smart Life 2030 strategy, we acknowledge the necessity of building an equal, inclusive, and fair life. Accordingly:

We are aware that each of the following working conditions is a crime against humanity and a violation of human rights:

Child Labor, which deprives children of their childhood, diminishes their potential and dignity, and negatively impacts their physical and mental development.
Freedom Violation, where individuals are compelled to work without receiving appropriate wages or recognition.
Dependency Issue, characterized by living in conditions akin to slavery or being entirely subject to a more powerful entity.
Forced or Compulsory Labor, where individuals are coerced or compelled to work under threat of punishment without their full consent.
Debt Bondage Labor, where debts are paid not with money but directly with labor and productive power.
Human Trafficking, involving the transportation of individuals for labor or activities benefiting others, enforced through coercion or deception.
In conflict-affected and high-risk areas (CAHRA) around the world, especially in mining activities, we are conscious of the prevalence of human rights violations, including human trafficking, all forms of inappropriate labor practices, and human rights abuses such as sexual violence.

In our operations and at any stage of our supply chain:

We commit to not being directly and/or indirectly complicit in human rights crimes or violations.
We remain vigilant against risks related to living, working conditions, and human trafficking.
We promptly report identified crimes related to living, working conditions, and human trafficking to the relevant authorities.
We refrain from any involvement in crimes that may compromise the company's reputation related to living, working conditions, and human trafficking.
We provide an equal, fair, and safe working environment for all employees.
We act in compliance with legal and/or international regulations.
We adhere to Zorlu Holding Ethical Principles and Zorlu Holding Supply Principles.
We ensure a conducive environment for reporting irregularities.
We take appropriate sanctions in accordance with laws and/or company regulations for reported irregularities.
AS EMPLOYEES OF META NICKEL COBALT, THIS RESPONSIBILITY IS AN INTEGRAL PART OF OUR DUTY.

At Meta Nickel Cobalt Inc., in line with our Smart Life 2030 sustainability strategy, we embrace a stakeholder-based approach, considering our impact on the environment, society, and the ecosystem in every business endeavor. We strive to contribute to every individual and community in our value chain. With this perspective, we develop policies that create value for our local stakeholders in the regions where we operate and inclusively involve them in all processes in our practices.

Within this framework, Meta Nickel Cobalt Inc. adopts the principle stated in the International Labour Organization's (ILO) Convention No. 169, which grants indigenous peoples the right to determine their own priorities in the development process as it may affect their lives, beliefs, and institutions. We conduct our activities in line with this principle.

In parallel, Meta Nickel Cobalt Inc., in regions where the company operates, commits to:

Respecting traditions and contributing to the preservation of these traditions,
Supporting social, economic, and cultural rights,
Supporting local practices related to the use of natural resources,
Maintaining continuous communication and collaboration to establish a sustainable relationship,
Contributing to improving the quality of life and supporting community development,
Committing to prevent and minimize potential negative impacts arising from our activities through collaboration.