Conflict Minerals Policy

In politically unstable regions, the mineral trade can be used to finance armed groups, promote forced labor and otherhuman rights abuses, and support bribery and money laundering.

The main uses of so-called "conflict minerals (3TG)" such as tin (Sn), tungsten (W), tantalum (Ta) and gold (Au) are inthe automotive industry (production of electronic components, sensors and other parts in vehicles), electronic devices(mobile phones, laptops, etc.), aerospace equipment manufacturing, medical devices and equipment, industrialmachinery/equipment manufacturing and jewelry production. It is difficult for customers and consumers to knowwhether a product they are buying is financing conflict, human rights abuses and crimes in other countries.Beyçelik Gestamp adopts that conflict minerals should under no circumstances be sourced from conflict-affected andhigh-risk areas (CAHRA-Conflict-affected and high-risk areas) and aims to ensure that its products and processes do notcontain minerals sourced from organizations that directly or indirectly finance conflicts and conflict-affected high-riskareas.

Even if Beyçelik Gestamp does not purchase conflict minerals directly from any source, it is aware of the possibility ofthese minerals being a part of its supply chain. Being aware of this, Beyçelik Gestamp is committed to sourcing theseminerals responsibly by integrating the "OECD Compliance Guidance on Responsible Supply Chain for Minerals fromConflict-Affected and High-Risk Areas"1 into its procurement processes.

Within this framework, Beyçelik Gestamp asks its Business Partners (suppliers, distributors, dealers, authorized servicesand all other third parties with whom it has a business relationship and all kinds of representatives, subcontractors,consultants, etc. acting on behalf and account of the company),

• Meet international responsible sourcing standards in the supply of conflict minerals in accordance with theOECD's "OECD Compliance Guidelines for Responsible Supply Chains for Minerals from Conflict-Affected andHigh-Risk Areas",
• Work to adopt similar conflict minerals policies consistent with Beyçelik Gestamp Conflict Minerals Policy andBeyçelik Gestamp Supply Chain Compliance Policy,
• Identify products in which conflict minerals can be used and review their sources of supply for these products,and cooperate with their own suppliers for this purpose,
• Beyçelik Gestamp expects its employees to apply to Beyçelik Holding Ethics Committee (Ethics Hotline), tocooperate with Beyçelik Gestamp to prevent the risk and to terminate their cooperation with risky suppliers ifnecessary, if they are aware of any action that is thought to be contrary to Beyçelik Gestamp Conflict MineralsPolicy or if they detect a negative situation or risk related to conflict minerals in the supply chain.

Beyçelik Gestamp's employees and managers in the regions where Beyçelik Gestamp operates are obliged to act inaccordance with Beyçelik Gestamp Conflict Minerals Policy, to implement and support Beyçelik Gestamp's relevantprocedures and controls in line with the requirements of this policy.

All Business Partners with whom we have a relationship of supply of goods or services are also expected to act incompliance with the principles and principles in Beyçelik Gestamp Conflict Minerals Policy and necessary steps are takento ensure this.