Sumitomo Metal Mining Group’s Tailings Facility Management Policy

1. Purpose

The aim of this Policy is to ensure the safe management of tailings facilities in mines operated by Sumitomo Metal Mining Co., Ltd. and its subsidiaries (hereinafter the “SMM Group” or “we”). The SMM Group conducts sound and effective management of its tailings facilities in accordance with this Policy in order to protect the environment, ensure the safety of local communities, and promote sustainable business activities.

2. Scope of Application

This Policy applies to the SMM Group’s entire business operation, including all executives and employees of the SMM Group, as well as contractors under the SMM Group's day-to-day operational direction.
We will apply this Policy to the management of our tailings facilities both in Japan and overseas. In addition, we will provide support for the safe management of tailings facilities in our joint ventures which we do not directly operate or manage.

3. Governance and Promotional Structure

The Executive Officer in charge of the Safety & Environment Control Department who supervises the Environmental Preservation Subcommittee, a subordinate body of the Sustainability Committee, will report regularly to the Sustainability Committee, which is overseen by the Board of Directors, on the status of compliance with this Policy and promote initiatives for the overall management of tailings facilities. In addition, the Executive Officer will keep the Board of Directors informed on the safety and integrity of tailings facilities along with their environmental and social performance.

4. Policy Principles of Tailings Facility Management

The SMM Group is committed to complying with all national laws, regulations, and administrative rules applicable to tailings facilities, agreements with stakeholders and communities, and the Global Industry Standard on Tailings Management (GISTM). As a member of the International Council on Mining and Metals (ICMM), we also aligned this Policy with the approach outlined in the ICMM’s Tailings Governance Framework: Position Statement and Conformance Protocols.
In addition, the SMM Group has adopted the following principles with respect to tailings facility management:

• We will manage the SMM Group’s tailings facilities after careful consideration of the level of risk present at each facility; and
• We will protect the health and safety of employees, contractors, and the public.

5. Allocation of Management Resources

The safe management of tailings facilities is essential for our business, and the SMM Group will promote the responsible management of tailings facilities across all of our operations. We will ensure that the necessary management resources are available to minimize the risk and environmental impacts of our tailings facilities throughout their entire lifecycle, including planning, design, construction, operation, closure and post-closure.

6. Engagement

The safe management of tailings facilities is critical to the communities in which we operate. We will engage directly with community stakeholders on the design, management, and review of tailings facilities. We will also maintain an Environmental Management System (EMS), allocate appropriate resources, including training to ensure employee competence, and strive to implement initiatives for responsible tailings facility management through communication and an organizational culture of early recognition, prevention, and resolution of problems.
We will maintain a communication process for all personnel involved in the planning, design, construction, operation, closure and post-closure of tailings facilities to provide them with the relevant information for their role and help them understand their responsibilities to all the relevant stakeholders.

7. Preparation for and Response to Emergencies

We will prepare for emergencies, including large-scale accidents such as catastrophic failures, and if a failure were to occur, we will work tirelessly on our emergency response and recovery.

8. Review and Reporting

The SMM Group will perform a regular review of this Policy, and will aim to implement continuous improvements by incorporating recommendations for the safety and integrity of tailings facilities. The SMM Group will also transparently disclose information about our tailings facilities in accordance with the principles and requirements of the GISTM.
Any changes to this Policy must be approved by the Board of Directors.

This Policy was discussed within the Sustainability Committee, and was approved by the Board of Directors of Sumitomo Metal Mining Co., Ltd.

August 1 ,2024
President and Representative Director
Nobuhiro Matsumoto