Conflict Minerals Policy

Compliant with EU Regulation 2017/821 and UN/OECD Due Diligence Guidelines

Purpose

This policy outlines Rose Holm A/S’s commitment to being responsible for sourcing of minerals and to preventing the use of raw materials that contribute to conflict, human rights abuses, or unethical practices in any part of our supply chain.

Scope

This policy applies to all suppliers, subcontractors, and business partners providing materials, components, or products that may contain tin (Sn), tantalum (Ta), tungsten (W), and gold (Au) – collectively referred to as 3TG minerals.

Regulatory Framework

Rose Holm A/S adheres to:

– The EU Regulation (EU) 2017/821, establishing due diligence obligations for importers of tin, tantalum, tungsten, and gold originating from conflict-affected or high-risk areas.

– The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition).

– The United Nations Guiding Principles on Business and Human Rights (UNGPs).

Commitment

Rose Holm A/S is committed to:

1. Avoiding the use of conflict minerals that directly or indirectly finance armed groups, human rights abuses, or illegal mining activities.

2. Implementing due diligence processes to trace the origin of 3TG minerals in our products and supply chain.

3. Engaging suppliers to ensure that they source minerals only from smelters and refiners that are certified as conflict-free by recognized industry programs (e.g., RMAP – Responsible Minerals Assurance Process).

4. Promoting transparency and requiring suppliers to disclose the country of origin and smelter information for all relevant materials.

5. Taking corrective action where suppliers fail to demonstrate responsible sourcing or compliance with this policy.

6. Reporting publicly on progress and measures related to responsible mineral sourcing when required by law or customer agreements.

Supplier Expectations

All suppliers to Rose Holm A/S must:

– Have their own conflict minerals policy consistent with this one.

– Complete a Conflict Minerals Reporting Template (CMRT) or equivalent disclosure upon request.

– Cooperate with audits and due diligence inquiries related to mineral sourcing.