SUPPLY CHAIN POLICY of Ricci Carlo srl

Ricci Carlo srl of Valenza designs and manufactures precision components in precious metal through plastic deformation and machining. The ethical principles underlying the company are aligned with Annex II of the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”; the company therefore commits as follows:

Regarding serious abuses associated with the extraction, transport or trade of minerals
We will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:
▪ any forms of torture, cruel, inhuman and degrading treatment;
▪ any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of any penalty and for which said person has not offered himself voluntarily;
▪ the worst forms of child labour;
▪ other gross human rights violations and abuses such as widespread sexual violence;
▪ war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

Regarding risk management of serious abuses
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses.

Regarding direct or indirect support to non-state armed groups
We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals.

Direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to non-state armed groups or their affiliates who:
▪ illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain;
▪ illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded;
▪ illegally tax or extort intermediaries, export companies or international traders.

Regarding risk management of direct or indirect support to non-state armed groups
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups.

Regarding public or private security forces
We agree to eliminate direct or indirect support to public or private security forces who:
▪ illegally control mine sites, transportation routes and upstream actors in the supply chain;
▪ illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded;
▪ illegally tax or extort intermediaries, export companies or international traders.

We recognise that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.

Where we or any company in our supply chain contract public or private security forces, we commit to or will require that such security forces be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support or take steps to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired. We will support efforts, or take steps, to engage with central or local authorities, international organisations and civil society organisations to contribute to workable solutions on transparency, proportionality and accountability in payments made to public security forces for the provision of security. We will support efforts, or take steps, to engage with local authorities, international organisations and civil society organisations to avoid or minimise the exposure of vulnerable groups, in particular artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.

Regarding risk management of public or private security forces
In accordance with the company’s specific position in the supply chain, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified above, where a reasonable risk is identified. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.

Regarding bribery and fraudulent misrepresentation of the origin of minerals
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.

Regarding money laundering
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

Regarding the payment of taxes, fees and royalties due to governments
We will ensure that all taxes, fees and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industries Transparency Initiative (EITI).

Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money laundering and payment of taxes, fees and royalties to governments
In accordance with the company’s specific position in the supply chain, we commit to engage with suppliers, central or local government authorities, international organisations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken within reasonable timeframes. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.

Valenza , 15/09/2026

The Management