Grievance Mechanism

Submission and consideration of complaints

NPM Silmet is committed to maintaining a legitimate, accessible, predictable, equitable, transparent, and rights-compatible grievance mechanism for internal and external stakeholders.

Employees, suppliers, contractors, customers, communities, and other interested parties may raise concerns related to:

  • Human rights;
  • Labour practices;
  • Occupational health and safety;
  • Environmental impacts;
  • Business ethics and integrity;
  • Responsible minerals sourcing;
  • Supply chain due diligence;
  • Violations of applicable laws, regulations, or company policies.

Reports may be submitted through the following channels:

E-mail: grievance.silmet@neomaterials.com

Postal Address:

NPM Silmet OÜ
Kesk 2
40231 Sillamäe
Estonia

Anonymous Reporting

Stakeholders may submit grievances anonymously through the grievance contact channels identified in this Policy, including by e-mail at grievance.silmet@neomaterials.com or by post to NPM Silmet OÜ, Kesk 2, 40231 Sillamäe, Estonia, without providing their name, employer, contact details, or other identifying information. The reporter is not required to disclose their identity when submitting a concern.

Anonymous submissions are accepted and will be reviewed, investigated, and processed in accordance with the NPM Silmet Grievance Mechanism Procedure. The absence of the reporter’s identity will not affect the Company’s ability to accept and process anonymous grievances to the extent possible.

All grievances are handled confidentially by authorized personnel to the extent possible.

NPM Silmet prohibits retaliation against any individual who raises a concern or participates in a grievance process in good faith.

All grievances are assessed and addressed through a structured review, investigation, corrective action, escalation, and appeal process, where applicable.

The effectiveness of the grievance mechanism is reviewed periodically as part of NPM Silmet’s responsible sourcing due diligence program and continuous improvement activities.