Supplier Code of Conduct

1. Scope and Supplier Responsibility

This Supplier Code of Conduct (“Supplier Code”) sets minimum expectations for R3 Lithium, Inc. (“R3Li”) suppliers of goods and services, including their personnel, agents, labor providers and subcontractors (collectively, “Suppliers”). Suppliers must comply with applicable law and contractual requirements and maintain management systems proportionate to their risks. Suppliers are expected to communicate equivalent requirements to relevant sub-tier suppliers.

Where this Supplier Code establishes a higher voluntary standard than local law, R3Li expects the supplier to meet the Supplier Code to the extent lawful. Nothing in the Supplier Code requires conduct prohibited by applicable law.

2. Labor and Human Rights

• Freely chosen employment. No forced, bonded, indentured, trafficked or involuntary prison labor; no coercive retention of identity documents; no worker-paid recruitment fees; freedom to leave employment subject to lawful notice.

• Child labor and young workers. No child labor; minimum age is the greater of applicable law, compulsory-schooling age or 15. Workers under 18 may not perform legally prohibited hazardous work.

• Wages and hours. Comply with applicable minimum wage, overtime, working-time, break, leave and benefits laws; provide accurate and timely wage statements; no unlawful disciplinary deductions.

• Humane treatment. No violence, sexual harassment, abuse, corporal punishment, coercion, bullying or threats.

• Non-discrimination. No unlawful discrimination or harassment; provide legally required accommodations.

• Freedom of association. Respect lawful worker rights to organize, bargain collectively, communicate about working conditions and refrain from protected activity without retaliation.

3. Health and Safety

Suppliers must provide a safe and healthy workplace, obtain and maintain required permits, assess hazards using the hierarchy of controls, provide required PPE and training, maintain emergency preparedness, investigate incidents and near misses, and provide workers a safe means to report hazards. Worker housing or accommodation supplied by the employer must meet applicable health, fire, sanitation and safety requirements. Suppliers must promptly report to relevant authorities and to R3Li all incidents and near misses that occur on an R3Li-managed site or during transportation or handling of R3Li material or equipment and must cooperate with such authorities and with R3Li in any related inquiries or investigations.

4. Environment and Battery-Material Stewardship

• Maintain required environmental permits, approvals, monitoring and reports.

• Lawfully identify, characterize, label, store, transport, recycle and dispose of hazardous materials and wastes.

• Prevent unauthorized releases and maintain spill prevention, emergency response and remediation capabilities appropriate to operations.

• Track and seek to reduce material energy, water, waste and greenhouse-gas impacts; provide reasonably requested data supporting R3Li life-cycle, recycled-content or carbon accounting.

• For batteries, black mass and other regulated materials, comply at all times with applicable dangerous-goods, hazardous-materials, waste, transport, export/import and recycling requirements.

5. Ethics, Anti-Corruption and Accurate Records

Suppliers must prohibit bribery, kickbacks, extortion, embezzlement and improper payments. Suppliers may not offer anything of value to a public official or private person to obtain an improper advantage. Books, invoices, customs declarations, origin records, certificates and other business records must be accurate and not misleading. Suppliers must not offer R3Li personnel anything of value that may be perceived to exceed locally-customary customer-relations standards. This considers both value and frequency. Suppliers must retain accurate records of all benefits extended to R3Li personnel and provide such records upon request.

6. Antitrust and Fair Competition

Suppliers must comply with competition laws and must not coordinate with others on prices, bids, customers, territories, output, wages, hiring or other competitively sensitive matters. Suppliers must not facilitate prohibited coordination through trade associations, algorithms, consultants, brokers or other third parties.

7. Privacy, Cybersecurity, Confidentiality and AI

Suppliers must protect R3Li confidential information, personal data and systems using reasonable administrative, technical and physical safeguards and comply with applicable privacy and cybersecurity laws. Suppliers may not input R3Li confidential, personal, export-controlled, privileged or proprietary information into public or unapproved generative-AI systems. Use of AI in delivering goods or services to R3Li must comply with contract requirements and must not impair R3Li’s intellectual-property, confidentiality, security or regulatory rights.

8. Responsible Sourcing and Traceability

Suppliers of minerals, battery materials, recycled feedstocks or products containing relevant minerals must conduct risk-based due diligence consistent with R3Li’s Responsible Sourcing Policy and, where applicable, OECD mineral guidance. Suppliers must provide reasonably requested origin, chain-of-custody, processor/refiner, recycled-content and due-diligence information.

• Do not knowingly source materials that directly or indirectly finance non-state armed groups or are associated with serious human-rights abuses.

• Promptly disclose credible forced-labor indicators, UFLPA Entity List exposure, CBP detention/WRO issues, sanctions concerns or material origin/traceability discrepancies affecting R3Li goods.

• Support lawful customer requests concerning 3TG/conflict-minerals reporting and other responsible-minerals due diligence.

9. Trade Compliance and Sanctions

Suppliers must comply with applicable U.S. and international sanctions, export controls, anti-boycott, customs and import laws. Suppliers must provide accurate classification, country-of-origin and other trade data reasonably required by R3Li and must not route transactions through intermediaries to evade legal restrictions.

10. Management Systems, Audit and Records

Suppliers must maintain policies, responsible management personnel, risk assessments, training, worker grievance channels, corrective-action processes and records proportionate to their risks. R3Li may request evidence of compliance and, subject to contract and reasonable safeguards for confidentiality and safety, may conduct or commission assessments or audits.

Suppliers must preserve relevant records for the longer of any period required by law or contract and cooperate with reasonable investigations. Audit rights do not shift responsibility for compliance from the supplier to R3Li.

11. Reporting, Non-Retaliation and Remediation

Suppliers must provide workers a channel to raise concerns without retaliation and must protect confidentiality where practicable. Suppliers and their personnel may also report concerns through R3Li’s designated compliance reporting channel. Suppliers must promptly investigate substantiated issues, implement corrective action and provide remediation appropriate to affected workers or communities.

12. Enforcement

R3Li may require corrective-action plans, enhanced diligence, training, independent verification, suspension of new business or termination for noncompliance. R3Li will consider severity, recurrence, supplier cooperation, remediation, legal requirements and potential adverse consequences of disengagement.

13. U.S./California Disclosure Support

Suppliers must provide information reasonably requested to support R3Li compliance with applicable U.S. forced-labor, customs, conflict-minerals and supply-chain transparency requirements. If R3Li is subject to the California Transparency in Supply Chains Act, supplier cooperation may include verification, audit, certification and training-related information necessary for R3Li’s public disclosure.

Definitions

1. Supplier: Any entity that provides goods, services, labor, materials, equipment, logistics, software, or consulting to R3Li, including its personnel, agents, labor providers, and subcontractors. See: supplier obligations

2. Sub‑Tier Supplier: Any third party engaged by a Supplier to support R3Li‑related activities, including contractors, processors, refiners, logistics providers, or service partners. See: sub-tier oversight

3. R3Li Material: Any product, raw material, battery material, black mass, feedstock, equipment, or item owned, controlled, transported, processed, or handled on behalf of R3Li.

4. Personnel: Employees, temporary workers, contractors, interns, labor‑hire workers, or any individual performing work for or on behalf of a Supplier.

5. Hazardous Materials: Chemicals, substances, wastes, or regulated materials defined as hazardous under applicable environmental, dangerous‑goods, waste, or transport laws. See: hazardous materials compliance

6. Dangerous Goods: Materials classified under applicable transport regulations (e.g., DOT, IATA, IMDG) requiring special handling, packaging, labeling, or documentation.

7. Personal Data: Any information relating to an identified or identifiable individual, including names, contact information, identification numbers, device identifiers, or other regulated data elements.

8. Confidential Information: Non‑public business, technical, financial, operational, or strategic information belonging to R3Li, including trade secrets, intellectual property, specifications, pricing, and internal communications.

9. Generative AI Systems: Machine‑learning or artificial‑intelligence tools capable of producing text, code, images, or other outputs. This includes public or unapproved AI systems into which Suppliers may not input R3Li confidential, personal, export‑controlled, privileged, or proprietary information. See: AI compliance

10. Forced Labor Indicators: Conditions identified by U.S. CBP, ILO, or other authorities suggesting coercion, restriction of movement, debt bondage, document retention, or other prohibited labor practices. See: forced labor compliance

11. Responsible Minerals: Tin, tungsten, tantalum, gold (“3TG”), cobalt, lithium, graphite, nickel, manganese, or other minerals subject to OECD due‑diligence guidance, conflict‑minerals rules, or R3Li’s Responsible Sourcing Policy.

12. Traceability Data: Origin, mine site, processor/refiner, recycled content, chain‑of‑custody, transport, or other documentation required to verify lawful sourcing and compliance with UFLPA, CBP, OECD, or other regulatory frameworks. See: traceability requirements

13. Management System: Policies, procedures, training, controls, grievance channels, corrective‑action processes, and oversight mechanisms used by Suppliers to ensure compliance with this Supplier Code.

14. Incident: Any injury, illness, environmental release, spill, near miss, security breach, privacy event, or compliance concern occurring on an R3Li‑managed site or during handling of R3Li materials.

15. Remediation: Actions taken to correct violations, mitigate harm, and provide appropriate remedy to affected workers, communities, or stakeholders.

Legal and Best-Practice Reference Notes

These references identify principal authorities and current compliance developments considered in this update; they are not an exhaustive statement of applicable law.