Communication

D Block Metals Grievance procedure is posted on our website.   A link to the procedure is listed on our Purchase Orders. Our employees are regularly trained on this procedure.

D Block Metals Grievance Process

•  For a relevant Incident or Grievance,  raised during an audit,  reported via Grievance Mechanism, or from other sources; i.e.. reports, news, partner info
• ID the nature of the complaint, log into tracking tool, assess the risk as either; Out of Scope, High Risk, Medium Risk, or Low Risk

Nature of Grievance

The nature of grievances may be, but are not limited to, the following:

1. Any upstream Smelter or Refiner within the Supply Chain
2. Any downstream Customer(s)
3. Operations of D Block Metals within RMI/RMAP Standards
4. D Block Metals RMI/RMAP policies or procedures
5. Inappropriate claims or references

Submission Process

1. Incidents are to be submitted to the D Block Metals, LLC. Grievance Mechanism page on the company website, [email protected]. They will be directed to an email box, designated specifically for this purpose. Incidents may also be raised through other means, such as public reports and news articles monitored by D Block Metals staff and/or shared by D Block Metals members, partners, and stakeholders, etc. All incidents are logged in the D Block Metals Tracking Tool for Incidents and Emerging Risks by the company presidents designated employee. The designated employee reviews each submission and, where needed, refers it to the appropriate party for additional review and resolution. Incidents involving D Block Metals operations and program will be escalated to the company president. D Block Metals aims to investigate incidents in a fair, balanced, and transparent manner and to resolve the issues efficiently and effectively.

Anonymous Reporting and Whistleblower Protections

This mechanism allows for anonymous reporting of incidents. For anonymous submissions contact information is not required, only comments section should be filled out. While providing contact information is encouraged, as it allows for further follow up during the incident resolution process, anonymous submissions will be investigated in the same manner as all other submissions.

Whistleblower protections, including maintaining confidentiality of incident source upon request and treating such submissions in a confidential and sensitive manner, unless disclosure is required by law, will be offered to those individuals who disclose concerns pursuant to this policy provided the disclosure is made in good faith; and in the reasonable belief of the occurrence of serious malpractice or wrongdoing.

Whistleblowers who disclose information in good faith will be protected irrespective of the quality of the evidence provided or the outcome of any review or subsequent investigation undertaken by D Block Metals. The identity of the whistleblower if shown on any submitted documents will be removed by the recipient.

An exception on the above will be necessary if the source is required to be disclosed as part of a legal process under the relevant laws. In these cases, effort will be made to protect the source from retaliation in collaboration with the relevant authorities, and in conformity with national and international procedures that may apply.

Receipt of Incident

D Block Metals receives incident information from a variety of sources including, but not limited to; auditors, individuals, industry associations, employees, the media, and various personnel throughout the supply chain.  The incident may be submitted through the grievance mechanism page on the D Block Metals company website, or directly to company staff.

Initial Response

At the time of an incident receipt, the presidents designated employee (DE) will determine if the incident is within the scope of this policy.  The determination will be logged:

• If in scope:
• The DE will notify the complainant of the D Block Metals Grievance Process.
• The DE will solicit consent from the complainant to log the grievance and will notify the complainant that the grievance is being logged.
• The DE will check if the grievance is intended to be anonymous.
• The DE will log incidents received into the D Block Metals Tracking Tool for Incidents and Emerging Risks, unless the incident is determined to be out of scope.
• The DE will annotate corroborating information when available.
• The DE will assess the seriousness of the incident and categorize the incident as green, yellow, or red according to the below criteria.
• If the DE determines that the incident is out of scope, no further action is needed.

• Each of the incidents will have one of the following categorizations attached to it:
• Green – Low risk; incident logged with no further action required
• Yellow – Medium risk; requires further investigation and may be escalated or deescalated accordingly.
• Red – High risk; requires further investigation and will be immediately discussed with company president.

The following table will demonstrate the use of the color categorization system pertaining to incidents or grievances.

Incident Review Procedure for GREEN-Low Risk:

Review:

Beyond basic review of the provided information, the DE will not review additional information for incidents that have been identified as Green-low risk.

Follow Up Actions and Closure:

• No further investigation or corrective actions are needed.
• If the source is not anonymous, the DE will contact the source to inform them of the determination no later than 5 business days after the green-level risk determination.
• Explore possible continual improvement opportunity.
• Mark incident as closed.
• Maintain incident file for one year.

Incident Review Procedure for YELLOW-Medium Risk:

Review

• If the source is not anonymous, the DE will reach out to the source for additional information and/or clarification if needed.
• If the respondent is a D Block Metals affiliate, the DE will contact the respondent.
• If the incident may have legal ramifications, the DE will send all information to the company president for further action.

Follow Up Actions and Closure

• If the above outreach indicates that the incident is likely not accurate or has been resolved or corrected, the DE will de-escalate the incident to Green and follow that risk levels procedures.
• If the above outreach indicates that the allegation is likely accurate, but needs more verification, then the DE will escalate the incident to Red and follow that risk levels procedures.
• If the above outreach indicates that the allegation is accurate, the DE will proceed to the incident response options:
• Follow up with the source and/or respondent if more information is needed.
• Request documented corrective actions from the respondent, as needed.
• Review corrective actions, follow up with respondent if further actions are required.
• If corrective actions are satisfactory, mark the incident as closed.

Incident Review Procedure for RED-High Risk:

Review

• If the source is not anonymous, the DE will reach out to the source for additional information and/or clarification.
• If the respondent is a D Block Metals affiliate, the DE will contact the respondent.
• If the incident may have legal ramifications, the DE will send all information to the company president for further action.

Follow Up Actions and Closure

• If the above outreach indicates that the incident is likely not accurate or has been resolved or corrected, the DE will de-escalate the incident to Green and follow that risk levels procedures.
• If the above outreach indicates that there is a likely chance the incident is accurate but more verification is needed:
  • The DE will conduct further research and inquiry
  • The DE will consult with the Company President to discuss the incident and appropriate response.
  • Begin an investigation to assess the truthfulness and accuracy of the allegations and recommend appropriate actions.

• If the above outreach indicates that the allegation is accurate, the DE will proceed to the incident response options:
  • Follow up with the source and/or respondent if more information is needed.
  • Request documented corrective actions from the respondent, as needed and applicable.
  • Review corrective actions, follow up with the respondent if further actions are needed.
  • If corrective actions are satisfactory, mark incident closed.

Incident Response Options and Closure

When incidents have been reviewed by the company president, investigated, or discussed with relevant experts; D Block Metals will take those parties’ recommendations into consideration.

Incident responses will vary from case to case, but will include one or more of the following actions:

• D Block Metals will contact Auditors within ten business days if the incident may have an impact on the process or findings of an audit, including but not limited to:
  • Completeness and Scope of Audit
  • Corrective Actions, including remediation
  • Quality
• D Block Metals may take the following actions relating to upstream suppliers and downstream customers:
  • Request relevant information, especially under circumstances of cross-recognition.
  • Enter into Non-Disclosure Agreements.
  • Share relevant information not in violation of existing non-disclosure agreements.
  • Encourage development of a joint or independent, short or long-term response or action plan.
  • Encourage enhanced due diligence.
  • Recommend changes to standards or procedures.
• D Block Metals may take the following actions relating to an employee disclosure:
  • The DE may issue an employee’s-only statement regarding the incident when appropriate through workgroups, newsletters, and training.
  • When an incident report involves a specific employee, inform the company president and forward the report to the aforementioned entity.
• D Block Metals may take the following actions relating to public disclosure:
  • The DE may issue public statements regarding the incident when appropriate. Any public disclosure will have prior approval by the company president and be disseminated through the appropriate channels.

Incident Response Timeline

• D Block Metals will review, investigate, and recommend an initial incident response within forty-five business days of the determination of the High-Risk Level.
• The respondent will then be allotted an additional forty-five business days for corrective actions, which will include the following phases:
  • Respondent to provide a response to D Block Metals on the incident (five business days)
  • Respondent to outline actions to be taken (ten business days)
  • Respondent to demonstrate implementation of corrective actions with supporting documentation (thirty business days)
• D Block Metals will verify the response and seek to close the incident within twenty business days after the respondent’s submission.

D Block Metals may extend the incident review timeline for incidents that require a more in-depth analysis, and will communicate with relevant parties accordingly.

Respondents may request reasonable extensions to their responses or corrective action timeline if a reasonable extension is necessary to finalize those actions.

The incident will be marked as closed once it is resolved through the process outlined above, determined low-risk, or out of scope.  Once the incident has been closed, with the approval of the D Block Metals leadership, the DE will update the status in the D Block Metals Tracking Tool for Incidents and Emerging Risks.

Lessons Learned and Continuous Improvement

Based on the above, the DE will generate a list of trends, lessons learned, and recommended changes to standards, procedures, and systems on an annual basis for discussion with D Block Metals leadership.