Last Amended: February 6, 2023

Purpose:

It is acknowledged by the precious metals recycling industry that theft of regulated metal is a growing
problem for which legitimate businesses must remain vigilant. This policy is intended to confirm PGM of
Texas, LLC and group companies’ commitment and due diligence in the prevention of stolen material
entering the supply chain and further communicate the expectations of all employees and business
partners in that commitment.

Definitions:

“Regulated Metal” – Any item, including catalytic converters and copper, made up of or containing
metals that are commonly regulated by law.

Application:

This policy applies to all PGM Group employees and business partners.

Policy:

PGM expects our employees and business partners to act with honesty and integrity in the performance
of any and all business activities. By performing work on behalf of or doing business with PGM, you
acknowledge your role and responsibility to responsible sourcing efforts, which include but are not
limited to the following:

• Adhering to all federal, state, and local laws when dealing in transactions of regulated metal.
• Maintaining an active awareness for changes in laws and promptly incorporating measures for compliance.
• Raising awareness for any and all suspicious activity to the PGM management team and local authorities as applicable.
• Promoting proactive solutions and partnerships to stay informed of potential criminal activity in your area.
• Ensuring you represent the company in professional and ethical manner.
• Implementing applicable anti-money laundering laws and best practices.
• Performing reasonably diligent inquiries to verify customer identities.
• Following any and all company procedures related to your performance with the company.