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Chicago White Metal’s Environmental, Social, and Governance Policy

Introduction

The purpose of this document is to provide information about Chicago White Metal’s (CWM’s) Environmental, Social, and Governance (ESG) policies. It reflects CWM’s policies on human rights, environmental and social responsibility, ethics, and compliance with applicable laws and regulations. It reflects our internal values and the expectations of our management, associates, suppliers, and customers.

Since the founding of Chicago White Metal Casting, Inc. in 1937, the company’s development has been based upon a strong philosophical belief in the dignity and worth of the individual. This has been the cornerstone for decisions and actions concerning our business, people, growth and profit objectives, and working environment. This essential philosophy has endured as CWM has evolved from its small pioneering origins.

At CWM, business relationships are more productive and effective when built on trust, mutual respect, and shared values.

Equal Employment Opportunity Statement

CWM provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, genetic information, marital status, amnesty, or status as a covered veteran in accordance with applicable federal, state and local laws. CWM complies with appropriate state and local laws governing nondiscrimination in employment. This policy applies to all terms and conditions of employment, including hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, compensation, and training.

Health and Safety

CWM requires that employees are provided with a safe and healthy workplace in accordance with all relevant laws and regulations. We have established and implemented comprehensive health and safety programs that cover incident reporting and investigation, chemical safety, ergonomics, and other relevant topics.

Employee Attributes

Many different kinds of people can be significant contributors to our business. Nonetheless, extraordinary energy and inquisitiveness, the willingness to get involved, and the mature self-confidence required to “take a chance” are often as important as specific knowledge in solving problems. In addition, we seek to align ourselves with people with positive attitudes. In the face of adversity, we embrace those who see opportunities and seek solutions rather than problems and failure. We welcome and will advance those team members who bring optimism and constructive thinking to their interactions with all associates, customers, and suppliers, not allowing rank bias to affect their attitude. Thus, we seek these attributes in each person that we hire, as well as those who are already employed with CWM.

Respect for Everyone, Inclusivity

CWM believes that everyone deserves to be treated with equal respect. This includes refraining from any form of harsh or inhumane treatment, such as physical abuse, sexual harassment, corporal punishment, mental or physical coercion, or verbal abuse of workers. We aim to foster an environment that values and nurtures unique talents and contributions from every individual within a culture of inclusivity. While we understand this is a perpetual journey, we are committed to cultivating and empowering change by building an inclusive workplace where all talents can thrive.

Nondiscrimination

CWM is dedicated to creating a workplace free from unlawful discrimination and harassment. In recruitment and employment practices such as promotions, training, and rewards, CWM refrains from discriminatory actions based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, or marital status. Moreover, employees or potential employees are not subjected to medical tests that could be used in a discriminatory manner.

Cultural Pillars & Mission Statement

CWM has developed five Cultural Pillars (CP’s) that represent our values and act as a code of ethics for employees. They serve as guiding principles for conducting business and interacting with our team members, customers, suppliers, and the communities in which we operate.  These CP’s are:

Positive Attitude: Adopting a positive attitude as a way of life fosters optimism, provides motivation to accomplish goals, and can become contagious (in a good way).

Respect: Respect involves treating all those around you equally, genuinely listening to others when they speak, acknowledging and greeting people every day, and practicing the art of “please” and “thank you.”

Commitment: Meeting commitments is crucial as it reflects our reliability and trustworthiness. Missing commitments not only diminishes credibility but also wastes valuable time for both others and ourselves. To avoid forgetting commitments, it is essential to document them diligently.

Cater Equally to All: At CWM, it is imperative that we cater equally to all without favoring rank, as catering to rank is not a pathway to success and advancement; in fact, it perpetuates a form of discrimination. Providing outstanding service to everyone is a fundamental principle, even though breaking this cycle can be challenging due to centuries of societal conditioning.

Transparency: Being transparent is a key element in our success as it builds trust with all those we serve, removes uncertainty when we communicate openly, and enables others to have clear expectations.

CWM’s mission is to create success by enriching the lives of others, including our Chicago White Metal associates and their families, our customers, suppliers, and those who live and work in our surrounding communities.

Forced or Involuntary Labor

CWM strictly prohibits engaging in any form of forced or involuntary Labor. This includes forced, bonded, or indentured Labor, involuntary prison labor, slavery, or trafficking of persons. CWM does not transport, harbor, recruit, transfer, or receive vulnerable individuals by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation. All work must be voluntary, and employees can terminate their employment at any time.

Child Labor

The employment of children is strictly forbidden at Chicago White Metal. The term “child” pertains to anyone younger than 16 years old. However, legitimate workplace apprenticeship programs that adhere to all laws and regulations are encouraged.

Hours of Work

Under normal circumstances, the duration of a workweek, including overtime, should be at most 60 hours, and employees must have at least one day off every seven days. It is strictly prohibited to exceed the maximum number of work hours permitted by relevant laws and regulations.

Wages and Benefits

CWM pays their employees at least the minimum wage mandated by applicable laws and regulations and provides all legally required benefits. Employees are compensated with a premium rate for their overtime hours on top of their regular pay. Moreover, CWM offers vacation time, personal time, time off for jury duty, and holiday time off that comply with or exceed the relevant local laws and regulations.

Anti-Harassment

CWM is committed to a work environment where everyone is treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, CWM expects all relationships among persons in the office will be business-like and free of bias, prejudice, and harassment.

Freedom of Association

Workers’ freedom to associate freely, including the choice to join or not join labor unions, seek representation, and participate in workers’ councils, must be respected in accordance with local laws. Employees must be able to communicate openly with management and share grievances related to working conditions and management practices without fear of harassment, intimidation, or retaliation.

Protection of the Environment

CWM prioritizes environmental protection. CWM complies with all relevant environmental laws, regulations, and standards to meet the minimum requirements, including but not limited to chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits, and environmental reporting. CWM establishes and maintains an environmental management system that complies with ISO 14001. We are committed to continually improving our environmental performance, reducing our energy consumption and carbon footprint, and fostering a culture of sustainability that delivers value and health for our business, associates, and community.

Conflict Minerals

CWM acknowledges the significant legal and non-legal risks of sourcing tin, tantalum, tungsten, and gold as stipulated in the Dodd-Frank Act Section 1502. CWM certifies that all materials and components supplied to or produced by CWM comply with the Act’s reporting requirements, irrespective of the country or countries in which it operates. For these minerals, CWM expects our suppliers, where applicable, to conduct a reasonable inquiry into the country of origin and perform due diligence to establish the conflict status of the mine or smelter. This information must be provided to CWM.

Laws and Regulations

CWM will comply with all Federal, State, County, and Municipal laws and regulations where we conduct business.

Anti-Corruption & Business Ethics

CWM and its associates conduct all business in accordance with the highest ethical standards and follow a strict code of ethics. CWM strictly complies with all laws and regulations relating to bribery, corruption, and prohibited business practices. This includes:

The laws and regulations of the United States, particularly the Foreign Corrupt Practices Act (FCPA), and the anti-corruption laws and regulations of other countries where CWM and CWM suppliers operate.

Any arrangements involving payment, offer, or promise of improper benefits or advantages with an expectation of receiving something in return, commonly referred to as “quid pro quo,” including any form of bribery. Additionally, facilitation payments made to expedite routine government actions are strictly prohibited.

Service to our Customers

CWM has an obligation to provide our customers with excellent service. Customers are at the heart of our business; without these partnerships, Chicago White Metal would not exist. Our commitment to customers is to be responsive to their needs, listen to and act upon concerns they bring to our attention, and provide them with services and products that meet or exceed their expectations.