Supply Chain Sustainability: Elimination of Discrimination

Issued on behalf of the following Toyota Tsusho Europe Region companies:

Toyota Tsusho Europe, Toyota Tsusho Europe, Green Metals France, Green Metal Czech, Green Metals Poland, Toyota Tsusho Otomotiv Sanayi ve Ticaret, Toyota Tsusho UK and Green Metals UK.

Table of Content

1. Introduction
2. Toyota Tsusho Europe Region Approach to Sustainability
3. Supply Chain Sustainability Behavioral Guidelines
4. Glossary

1. Introduction

The Toyota Tsusho Group was established in Japan in 1948 and, over the years, has pursued business growth across a wide range of markets and business fields. In recent years, the global Group has placed stronger emphasis on enhancing its corporate value by conducting environmentally conscious business and fostering people who contribute to society, with the aim of realizing its mission of "Passing on a better Earth to the children of the future." This stronger emphasis has also been positively adopted by companies operating within our Europe Region.

As the Toyota Tsusho Group and companies within the Toyota Tsusho Europe Region handle a wide range of products and services sourced from across the globe, securing a sustainable supply chain is one of our key priorities.

Companies within our Europe Region have already been working with suppliers on sustainability-related issues. Building on these foundations, we are now accelerating and clarifying our requirements for suppliers through these "Toyota Tsusho Europe Region Supply Chain Sustainability Behavioral Guidelines".

We kindly ask our suppliers to put these Guidelines into practice within their own organizations, cascade them throughout their own supply chains, and encourage their suppliers to adopt and act upon the same principles.

Some of our suppliers may also be asked to demonstrate compliance by:

Providing information (self-assessments, survey responses, related documentation)
Supporting audits (either remotely, or on-site)
Promptly reporting and correcting issues that violate these Guidelines or applicable laws.

Toyota Tsusho Europe Region intends to make compliance with these Guidelines a key requirement in its general terms and conditions when entering into agreements with suppliers. We encourage our global network of suppliers to embrace these Guidelines, and we will proactively support suppliers on our shared journey to make supply chains more sustainable.

August 2026
Toyota Tsusho Europe Region
Chief Executive Officer
Eiji MATSUZAKI

2. Toyota Tsusho Europe Region Approach to Sustainability

Toyota Tsusho Europe Region has been committed to enhancing its corporate value by conducting environmentally conscious business and fostering people who contribute to society, with the aim of realizing the wider Toyota Tsusho global mission of "Passing on a better Earth to the children of the future." Today, the world is facing a range of challenges, including extreme weather events caused by climate change, deforestation, resource depletion, and human rights issues. In this context, environmental and social considerations are no longer simply additional factors in corporate activities; they have become prerequisites and, in many cases, a central focus of business.

In response, companies within the Toyota Tsusho Europe Region have evolved the activities that were once positioned as "Corporate Social Responsibility" (CSR) and have strengthened efforts to realize a sustainable society from the three perspectives of environment, society and governance, all with a long-term view.

Within the Toyota Tsusho Europe Region, sustainability is synonymous with good management. It reflects the Group's purpose and ideal image, and through the pursuit of our global mission, we aim to generate economic value while treating environmental and social factors as preconditions for business—thereby enabling Toyota Tsusho companies within the Europe Region to achieve sustainable growth together with society.

A careful process has been completed to translate our Europe Region company materiality into practical priorities that reflect the region's business environment, customer expectations, and evolving regulatory landscape.

Based on the double materiality assessment, Toyota Tsusho Europe Region has identified nine material topics that are most significant to our sustainability landscape. These topics are linked to the European Sustainability Reporting Standards (ESRS).

Environment	Climate change (ESRS E1) Pollution (ESRS E2) Circular economy (ESRS E5)
Social	Health, safety and compliance for own workforce (ESRS S1) Working conditions for own workforce (ESRS S1) Equal treatment & opportunities for own workforce (ESRS S1) Health & Safety for value chain workers (ESRS S2) Working conditions for value chain workers (ESRS S2)
Governance	Good governance & preventing corruption (ESRS G1)

The identified material topics serve as a guiding framework for our efforts to develop a more resilient, transparent and sustainable value chain. They support the transition to low-carbon and circular business models and help embed environmental, social and governance principles into our day-to-day business operations and supplier relationships across Europe.

To help translate some of these material topics into practical business actions, Toyota Tsusho Europe Region has established five task forces: Battery, Renewable Energy, Hydrogen, Circular Economy, and Economy of Life. These task forces support the practical implementation of our sustainability priorities.

At the same time, Toyota Tsusho Europe Region has established regional policies that provide a common framework for environmental, social and governance expectations across the region. These Guidelines are therefore aligned with relevant Toyota Tsusho Europe Region policies. In particular:

Sustainability	Toyota Tsusho Europe Region Sustainability Policy
Environment	Toyota Tsusho Europe Region Environmental Policy
Social	Toyota Tsusho Europe Region H&S Policy Toyota Tsusho Europe Region Human Rights Policy
Governance	Toyota Tsusho Europe Region Anti-Bribery Policy Whistleblowing Policy and Guideline Toyota Tsusho Europe Region Code of Conduct & Ethics (COCE)

3. Supply Chain Sustainability Behavioral Guidelines

Sections 3.1 and 3.2 below outline the sustainability requirements followed by Toyota Tsusho European Group companies. Suppliers are requested to create their own guidelines that comply with these Toyota Tsusho requirements and to ensure compliance with them, together with ongoing continuous improvement.

Section 3.3 explains in more detail how Toyota Tsusho Europe Region may request evidence, monitor supplier implementation, address any non-compliance, and support improvement.

3.1. Sustainability requirements for suppliers

3.1.1 Respect for human rights

We understand and support the "Toyota Tsusho Group Human Rights Policy," and will strive to put it into practice.
We will respect the human rights of employees and will never subject employees to inhumane treatment, such as abuse, physical punishment, or harassment.
We will endeavor to identify potential adverse impacts on human rights in business activities, and establish, continuously implement and work to prevent or mitigate such impacts through a human rights due diligence framework.
We respect internationally recognized human rights standards, including the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
We will strive to disclose the actions taken to respect human rights.
We will develop or maintain practical remediation mechanisms, including grievance channels, to address adverse human rights impacts and enable appropriate corrective action where needed.

3.1.2 Prevention of forced labor and child labor

We do not tolerate any form of modern slavery or forced labor, and we recognize that all work must be voluntary. We also guarantee employees' right to freely terminate their employment.
As part of the hiring process, we will provide all employees with an employment contract written in their native language that includes employment terms in full compliance with all applicable laws and regulations.
When employing migrant workers, including foreign nationals, we will strive to prevent practices that may lead to forced labor, such as requiring the surrender of official identity documents or work permits, or charging recruitment fees and other expenses that are considered inappropriate under international norms.
We do not tolerate child labor and do not allow children to work from a young age as it deprives them of educational opportunities and impedes their development.
The minimum working age shall be the highest age prescribed by applicable laws and regulations, local legal requirements, or the age for completing compulsory education.
We do not assign employees under the age of 18 to hazardous work.
We allow labor in the form of vocational training and apprenticeships only within the scope permitted by the applicable laws and regulations of each country.

3.1.3 Prevention of Excessive Working Hours and Unfairly Low Wages

We will appropriately manage employees' working hours, including overtime, holidays, and leave, and strive to reduce excessively long working hours. We will comply with all applicable wage-related laws and regulations in each country, including those governing overtime pay, legally mandated benefits, minimum wage requirements and wage deductions. We will not engage in unfair wage deductions and will strive to provide wages that exceed both the legal minimum wage and a living wage.
We will ensure that wages, benefits, compensation elements and deductions are communicated to employees clearly, regularly and in accordance with applicable laws and regulations.

3.1.4 Elimination of Discrimination and Harassment

We will not engage in any form of discrimination or harassment based on gender, age, place of origin, nationality, race, color, ethnicity, religion, gender identity, sexual orientation, pregnancy, disability, political opinion, or any other status.
We will foster an inclusive workplace culture where employees are treated with dignity and respect, and where employment decisions, including hiring, promotion, compensation, training, assignment, discipline and termination, are made fairly and without discrimination.
We will establish appropriate procedures for reporting, escalating, investigating and resolving harassment or bullying concerns, and will protect persons who raise concerns in good faith from retaliation.

3.1.5 Respect for freedom of association

We recognize, support and respect the right of employees to freely associate or not to associate based on applicable laws and regulations of the countries in which we are engaged in business activities.
We guarantee the right of employees to communicate openly and directly with management without fear of retaliation, intimidation, or harassment.

3.1.6 Ensuring Health & Safety

We will prioritize employee health and safety, and we will strive to provide a safe, hygienic and healthy work environment.
We will utilize occupational health and safety management systems to maintain and further improve safety and hygiene standards.
We will identify, assess and control occupational health and safety risks, including risks of workplace accidents, occupational diseases, ergonomic hazards and psychosocial risks, and implement appropriate preventive and corrective measures.
We will provide employees with appropriate personal protective equipment, clean sanitary facilities, drinking water and safe access to emergency equipment, and ensure that employees can raise safety concerns without fear of retaliation.
We will provide all employees with the necessary and sufficient health and safety education and training in appropriate languages to promote a comfortable and healthy working environment.
We will conduct training and implement measures in appropriate languages to minimize harm to life, the environment, and property in emergencies, including the installation of proper fire alarms, fire extinguishing equipment, and emergency exits.
We will support employee health through initiatives such as providing opportunities for health promotion and raising awareness about disease prevention.
We will record, investigate and take corrective action for work-related injuries, illnesses, incidents and near misses, and use lessons learned to prevent recurrence.

3.1.7 Consideration of the global environment

We understand and support the Toyota Tsusho Europe Region Environmental Policy and will strive to put it into practice by complying with applicable environmental laws, regulations, international standards and customer requirements, and by maintaining an effective environmental management system that promotes employee awareness and continuous improvement across our operations and supply chains.
We will support climate action and contribute to a carbon-neutral society by measuring, reducing and, where requested, reporting greenhouse gas emissions across relevant scopes and operations, including materials, production, logistics, packaging, use, recycling and disposal.
We will promote energy efficiency and the use of renewable energy where feasible to support greenhouse gas reduction and decarbonization efforts.
We will promote life cycle thinking, circular economy initiatives and resource efficiency by reducing resource use and waste, improving recyclability and recoverability, increasing recycled or renewable content where feasible, and providing recycled-content or recyclability data when requested. We will ensure safe treatment and disposal of waste in accordance with applicable laws and regulations.
We will manage water resources responsibly by minimizing water consumption, improving wastewater management, considering local water risks, and ensuring that discharged substances do not adversely affect aquatic ecosystems.
We will consider biodiversity and nature-positive outcomes in relevant business activities, balance biodiversity conservation with business operations, and consider animal welfare where animal testing or animal-derived materials may be relevant.
We will strive to prevent deforestation and ecosystem conversion in relevant supply chains and, where applicable, provide requested information to support deforestation-free sourcing and traceability.
We will prevent and reduce pollution and manage chemical substances responsibly by controlling air emissions, water pollutants and soil contamination; substituting or minimizing hazardous materials; complying with REACH, CLP and equivalent local regulations where relevant; avoiding prohibited or restricted substances; and providing accurate SDS, labelling, IMDS data, declarations, test reports or updated safety documentation when requested.
We will disclose environmental information in a timely, accurate and appropriate manner when required by law, customers or Toyota-related entities.

3.1.8 Fair trade and anti-corruption

We will prohibit bribery and corruption in any form, whether direct or indirect, active or passive, and whether involving public officials or private parties. This includes facilitation payments, improper gifts, hospitality, entertainment, donations, sponsorships, and benefits provided through third parties.
We will maintain accurate books, records and accounts, and will not conduct off-the-book, fictitious, falsified or misleading transactions.
We will comply with competition laws and will not engage in cartels, collusive bidding, private monopolies, unreasonable restraints of trade or unfair trade practices. Suspected violations should be reported promptly and in good faith.
We will comply with export control and import regulations, establish appropriate controls to determine whether products, technologies, or services are subject to restrictions, and maintain documentation of such checks where required.
We will avoid conflicts of interest and promptly report situations where personal, financial or close personal relationships may influence, or appear to influence, business decisions involving Toyota Tsusho Europe Region, Toyota entities or business partners.

3.1.9 Ensuring Quality and Safety

We ensure the quality and safety of our products and services.
We will comply with applicable laws, regulations, industry standards and customer requirements related to the quality and safety of products and services.
We will establish and maintain appropriate quality management processes to prevent defects, ensure traceability where required, and continuously improve product and service quality.
We will promptly communicate any quality or safety concerns that may affect products or services and implement appropriate corrective and preventive actions to prevent recurrence.

3.1.10 Contribution to local communities

We will protect the rights and lifestyles of local communities and contribute to those communities as a responsible member of society.
Where operations may affect Indigenous peoples or local communities, we will respect their rights, cultures and traditions and consider the principles of free, prior and informed consent where relevant.

3.1.11 Responsible Procurement

We understand, support, and strive to implement the Toyota Tsusho Europe Region Approach to Responsible Procurement, and we conduct procurement activities that consider potential adverse impacts arising from the use of products associated with environmental and social issues.
We will conduct responsible sourcing with particular attention to raw materials that may be associated with human rights, environmental or conflict risks, including 3TG, cobalt, mica, natural rubber, natural graphite, lithium, nickel and other relevant materials.
We will apply risk-based due diligence in line with internationally recognized frameworks, such as OECD guidance where relevant, and support supply chain transparency by providing, confirming, correcting and submitting accurate requested supply chain information, including conflict minerals reporting templates, supply chain mapping data or equivalent documentation needed to assess human rights, labour, environmental and legal compliance risks.

3.1.12 Information Security

We will obtain, use and manage confidential and personal information only by legitimate means and within authorized limits, and protect it against unauthorized access, disclosure, misuse or loss.
We will protect intellectual property rights owned by or attributable to the company.
We will respect intellectual property rights of third parties and will not infringe patents, designs, trademarks, copyrights, software licences or other protected rights.

3.2 Sustainability Management System requirements

3.2.1 Responsibility of Management

Management shall approve the company's policies on environmental and social responsibility, designate responsible personnel, and establish a management system to implement related activities.
Management shall regularly evaluate the effectiveness of activities conducted under the established management system.

3.2.2 Kaizen (Continuous Improvement) Objectives

We will set clear objectives and action plans related to environmental and social responsibility and evaluate them on a regular basis.

3.2.3 Education and Training

We will provide ongoing training programs for employees to implement our policies, initiatives, and objectives in accordance with these Guidelines.
We will provide role- and risk-based training to relevant employees so that they understand their responsibilities regarding environmental and social responsibility, human rights, labour standards, health and safety, compliance, information security and responsible procurement.
We will maintain appropriate records of training participation and, where relevant, evaluate the effectiveness of training to support continuous improvement.

3.2.4 Speak Up, Grievance Mechanism and Protection Against Retaliation

We will maintain accessible, confidential and effective channels for employees, suppliers and other stakeholders to raise concerns or grievances regarding misconduct, bribery, conflicts of interest, legal breaches, harassment, violations of these Guidelines, or actual or suspected violations of international codes of conduct or relevant domestic standards. Reports made in good faith will be handled seriously, objectively and confidentially, with appropriate follow-up, corrective action and protection against retaliation.

3.2.5 Information Disclosure and Stakeholder Engagement

We will disclose information related to the matters listed above in a timely, accurate and appropriate manner, and promote mutual understanding and trust-based relationships with stakeholders through open and constructive communication.

3.3 Compliance with These Guidelines

3.3.1 Compliance with Sustainable Purchasing Requirements

Suppliers are expected to demonstrate compliance with these Guidelines by providing requested evidence and information in a timely and accurate manner.
Where required by customers, regulations or Toyota Tsusho Corporation, such evidence may include SAQ responses, environmental management certificates, chemical compliance data, SDS, IMDS records, recycled-content declarations, conflict minerals reports, supply chain mapping data or other supporting documentation.
Suppliers are expected to respond to requests, surveys, assessments and corrective action plans within the required deadlines and provide complete, accurate and up-to-date information.
Suppliers are expected to communicate these Guidelines and relevant sustainability requirements to their own suppliers and business partners and take reasonable steps to promote compliance throughout their supply chains.

3.3.2 Monitoring

We will work together with our suppliers to support the continuous improvement of their environmental and social responsibility initiatives and performance. We will deepen communication with our suppliers and conduct regular surveys to understand their level of compliance with these Guidelines. We may also visit suppliers to confirm activities on site where necessary, based on the activity area and business content. If monitoring is conducted in the form of a third-party audit, we kindly ask for your cooperation.
Suppliers are expected to provide access to relevant information, records, documents, personnel and sites reasonably necessary to verify compliance with these Guidelines, while respecting confidentiality and applicable laws.

3.3.3 Remedy

If any issues arise that are contrary to these Guidelines, please report them promptly and work together with us to pursue kaizen (continuous improvement).
We may reconsider our transactions with your company if we do not observe appropriate efforts to make improvements.

4. Glossary

Term	Definition
3TG	Tin, tantalum, tungsten and gold.
CLP	CLP Regulation 1272/2008 on classification, labelling and packaging is a European Union regulation that aligns the EU system for the classification, labelling and packaging of chemical substances and mixtures with the Globally Harmonized System (GHS). Its aim is to facilitate global trade, harmonized communication of information on the hazards of chemicals, and regulatory efficiency. It complements the REACH Regulation and replaces the system contained in the Dangerous Substances Directive 67/548/EEC and the Dangerous Preparations Directive 1999/45/EC.
ESRS	European Sustainability Reporting Standards – EU standards defining sustainability reporting requirements under the CSRD.
ESRS E1	Climate change – covers climate-related impacts, risks and opportunities.
ESRS E2	Pollution – covers pollution prevention and control.
ESRS E5	Resource use and circular economy – covers resource use, waste prevention and circular economy.
ESRS S1	Own workforce – covers the company's own workforce.
ESRS S2	Workers in the value chain – covers workers in the value chain.
ESRS G1	Business conduct – covers ethics, anti-corruption and governance practices.
ILO	International Labour Organization.
IMDS	International Material Data System – a standardized system for collecting material data in the automotive industry. Suppliers are requested to enter data on product materials and contained chemical substances using a standardized format and process.
OECD	Organisation for Economic Co-operation and Development.
REACH	European Regulation 1907/2006 on the registration, evaluation, authorization and restriction of chemicals.
SAQ	Self-Assessment Questionnaire used to assess supplier performance and compliance with sustainability, environmental, social, governance and responsible procurement requirements.
SDS	Safety Data Sheet in accordance with European Commission Directives 2001/58/EC, 1999/45/EC, 1967/548/EEC and amendments published in the Official Journal of the European Union. It describes the essential information required for the safe handling of chemical substances.
Toyota Tsusho Europe Region	Refers to the European regional organization and companies of the Toyota Tsusho Group, including Toyota Tsusho Europe, Toyota Tsusho UK, Green Metals companies and Toyota Tsusho Otomotiv Sanayi ve Ticaret.
Toyota Tsusho Group	Refers to Toyota Tsusho Corporation and its consolidated subsidiaries and affiliated companies worldwide.
UN	United Nations.