Compliance Management System Grievance Mechanism

I. Purpose

PT. QMB New Energy Materials is committed to establishing and continuously improving a comprehensive compliance management system on a global scale. This ensures that the company's operations comply with applicable laws, industry standards, and internal compliance policies. We encourage employees, partners, and other stakeholders to report any potential violations of compliance requirements in order to jointly maintain a fair, just, and transparent business environment. This grievance mechanism is established to:
1. Promote a corporate culture of compliance, enhance corporate governance, and ensure the effectiveness and transparency of compliance management;
2. Identify and rectify compliance risks in a timely manner to prevent illegal and non-compliant behavior;
3. Protect the rights and interests of grievance reporters by ensuring the strict confidentiality of grievance information and preventing individuals from being subjected to any form of retaliation or adverse consequences.

II. Scope of Application

This grievance mechanism applies to all employees, partners, suppliers, and other stakeholders of the company. It covers all processes including R&D, production, procurement, human resources, environment, and safety. Key focus areas include, but are not limited to:
1. Anti-corruption and anti-commercial bribery
2. Anti-monopoly practices
3. Export controls and economic sanctions
4. Labor and employment issues
5. Intellectual property protection
6. Information security and cybersecurity
7. Environmental, Health, and Safety (EHS)
8. Corporate governance matters

III. Grievance Channels

1. Grievance Email: esgqmb@gem.com.cn
2. Written Submissions: Grievances may be submitted by mail to the company headquarters, labeled “Compliance Grievance,” and accompanied by relevant supporting evidence.
   Address: ESG Promotion and Public Relations Department, PT. QMB New Energy Materials, Indonesia Morowali Industrial Park.
3. Anonymous Submissions: Individuals may choose to submit grievances anonymously. The company guarantees that all anonymous grievances will be properly reviewed and processed.

IV. Grievance Acceptance and Handling Process

1. Initial Review: Upon receiving a grievance, the compliance department will conduct a preliminary review to determine whether to accept it and will notify the reporting party within one (1) working day.
2. Investigation and Handling: If the grievance meets acceptance criteria, the compliance department will collaborate with relevant units to investigate and will provide progress updates and handling measures within fifteen (15) working days.
3. Possible Outcomes:
   1. Accept the grievance and implement corrective measures;
   2. Accept the grievance without corrective measures (with explanation);
   3. Reject the grievance (with justification provided);
   4. Refer the matter to relevant departments at GEM Co., Ltd.
   5. Post-Investigation Measures: The company will implement corrective and preventive actions based on the investigation results to avoid recurrence of similar issues.

V. Confidentiality and Protection of Grievance Reporters

1. Confidentiality: All grievance-related information is treated as confidential and will not be disclosed without proper authorization.
2. Non-retaliation: Any form of retaliation against those who submit grievances is strictly prohibited.
3. Legal Support: If the rights or interests of a grievance reporter are violated, the responsible party will be held accountable in accordance with applicable laws.

VI. Time Limit for Submitting Grievances

Grievances should be submitted within a reasonable time after the issue becomes known. As a general rule, the company will not accept grievances concerning incidents older than one (1) year, unless special circumstances apply.

Thank you for your support and cooperation in maintaining a healthy, transparent, and compliant corporate environment!