January 6, 2018

INTRODUCTION AND PURPOSE

The Piraiki Metal’s employees are of great value and the key to our success. The Group must strive to provide a workplace where employees can fulfil their potential in an open and inspirational working environment. We must maintain a strong commitment to high standards that deliver a fair, respectable and safe workplace for all employees in the company.

The purpose of this policy is to define the labour and human rights standards to which all employees in the Piraiki Metal are entitled

REQUIREMENTS

1. NON-DISCRIMINATION

1.1. The Piraiki Metal does not tolerate any form of discrimination against our employees based on race, colour, gender, language, religion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, age, disability, or other distinguishing characteristics.

1.2. Any employment-related decisions, from hiring to termination and retirement, must be based solely on relevant and objective criteria.

2. FORCED LABOUR

2.1. The Piraiki Metal does not tolerate any form of forced labour, including bonded labour, indentured labour and slave labour, or human trafficking. Workers must be allowed to move around freely and leave their place of work when their shift ends.

3. CHILD LABOUR

3.1. The Piraiki Metal does not tolerate the hiring of child labour under any circumstances. The minimum age for full-time employment must be 18 4. FREEDOM OF

4. ASSOCIATION AND COLLECTIVE BARGAINING

4.1. The Piraiki Metal must respect employees’ rights to form, join or not join a labour union, or other organisation of their choice, and to bargain collectively in support of their mutual interests without fear of punitive actions such as intimidation, harassment or termination of employment.

5. HARASSMENT

5.1. Piraiki Metal companies must protect workers from any acts of physical, verbal, sexual or psychological harassment, bullying, abuse or threats in the workplace by either their fellow workers or their managers.

6. WORKING HOURS, BENEFITS AND WAGES

6.1. Piraiki Metals must adhere to all applicable laws or industry standards, whichever may be more stringent, relating to wages, working hours, overtime and benefits.

6.2. Employees must not be required to work more than 48 hours a week, including overtime, on a regular basis (or more than the limits on regular hours and overtime allowed by local laws and regulations). Wages for overtime must be paid in legal tender on a regular basis.

6.3. Wage deductions as a disciplinary measure must not be permitted unless provided for by national law. Employees must be entitled to at least one day off in seven, and must be given reasonable breaks while working and sufficient rest periods between shifts.

6.4. Piraiki Metal must be committed to continuously developing employee skills and capabilities, and to providing opportunities for career advancement.

6.5. In the event of major layoffs, the Piraiki Metal must, as a minimum, satisfy applicable laws and industry standards.

7. LEAVE

7.1. Piraiki Metal must ensure that all employees have the right to sick leave and annual holiday, as well as parental leave for employees who have to care for a new-born or newly adopted child as provided by national legislation. Employees who take such leave must not face dismissal or threat of dismissal.

8. EMPLOYEE CONTRACTS/LETTERS

8.1. All employees must be provided with a written, understandable and legally binding employment contract/letter.