SUPPLY CHAIN RISK MANAGEMENT AND MITIGATION POLICY

SUPPLY CHAIN RISK MANAGEMENT AND MITIGATION POLICY
Date: January 2024

Risk: Bribery, Fraudulent Misrepresentation, Money Laundering, and Taxation 'White Collar Due Diligence Risks'

Atlantic Dream RDC is dedicated to mitigating risks associated with bribery, fraudulent misrepresentation, money laundering, and taxation within our supply chain. To achieve this, we undertake the following measures:

Know Your Customer (KYC) Process: We conduct a comprehensive KYC process on all stakeholders in our upstream supply chain, adhering to enhanced due diligence requirements outlined by relevant authorities.
Membership in Traceability Organizations: We require all upstream suppliers to be members of internationally recognized traceability organizations, ensuring that procured minerals are certified conflict-free, verified by independent third-party audits.
Supplier Education and Collaboration: We educate and collaborate with our upstream suppliers to equip them with the necessary tools and knowledge to conduct their own due diligence, thereby fostering a responsible mineral supply chain.
Contractual Documentation Requirements: We incorporate contractual obligations for supply chain documentation, as outlined in Atlantic Dream RDC's Documentation Requirements.
Transparent Transactions: While acknowledging the necessity of cash transactions in certain regions, we mandate that all transactions are recorded with verifiable proof, subject to verification by independent third-party auditors if necessary.
Reporting of Suspicious Activity: Any suspicious behavior or indications of fraudulent or criminal activity are promptly reported to local, regional, or international authorities, depending on the severity of the risk.
Disclosure of Financial Information: We commit to disclosing information on taxes, fees, royalties, and levies paid to state authorities for mining, handling, transporting, trading, or exporting minerals. We expect the same transparency from our upstream suppliers.

Risk: Non-Adherence to Transportation Regulations

Misrepresentation of Radioactivity Readings and False Declarations: Misrepresentation of cargo, particularly regarding radioactivity readings and false declarations for transporting dangerous cargo, poses significant governmental, health, and environmental risks.

Management Approach:

Collaboration with Independent Inspectors: Atlantic Dream RDC collaborates with independent inspectors to ensure accurate representation of radioactivity readings on materials. In case of identified risks, we work closely with upstream suppliers to address packaging and transportation concerns, closely monitoring progress to mitigate risks effectively.

Moreover, Atlantic Dream RDC is committed to fostering a culture of transparency in reporting incidents and risks within our supply chain. Guidelines on managing these risks are outlined in our Code of Conduct document, which is a prerequisite for engaging in business with our company.