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ESG · SUSTAINABILITY POLICY

Sustainability policy statement.

Published policy. Defined commitments. Named responsible parties. An escalation pathway that flows to the group compliance counsel and, where appropriate, to external audit.

GTX / Green Transitional Metals Pte. Ltd. publishes this sustainability policy to set out the commitments that govern the commercial operation of the Singapore entity and its interface with the parent, the custodian, and the industrial customers we supply.

1. Governance

The Commercial Director of GTX Singapore (Arvinder Sood) holds operational accountability for sustainability performance. The Group Compliance & Regulatory Counsel (Cristina Donna Rubino) holds policy-level oversight and coordinates with external counsel (CMS DeBacker, Dentons, CNPLaw LLP) on all regulatory matters. Matters requiring escalation above the operational line go to the Group Chief Executive (Carlo Guido Della Peruta).

2. Responsible sourcing

GTX draws its raw nickel from the parent reservoir held and Swiss-vaulted at Helvetic Securgest SA in Lugano. The reservoir has been independently valued and its provenance is attestable through chain-of-custody documentation available to industrial buyers under NDA. GTX does not source from conflict-affected or high-risk areas.

3. Environmental commitments

  • Scope 1 and Scope 2 emissions for the Singapore operating footprint are measured from 2026 onwards and reported annually.
  • Conversion-process water recycling target: ≥ 90% closed-loop by 2028.
  • Waste-nickel recovery target: ≥ 95% by 2028.
  • All external logistics on verified low-carbon shipping and freight wherever commercially available.

4. Social commitments

  • Operation under Singapore Ministry of Manpower Code of Conduct and the ILO Fundamental Conventions.
  • Fair-wage and safe-workplace commitments are non-negotiable supplier-onboarding conditions.
  • No supplier operating in a jurisdiction subject to binding trade sanctions without explicit external-counsel clearance.

5. Governance commitments

  • Publication of annual ESG report aligned with TCFD / ISSB / GRI frameworks from FY2027.
  • Third-party audit from FY2028 onwards (Tier-1 auditor to be appointed via group process).
  • Open channel for whistle-blower and grievance reporting via the Group Compliance & Regulatory Counsel.

6. Customer and partner commitments

GTX customers receive a certificate of conformity with every shipment, a quarterly audit trail under long-term supply agreements, and, upon request under NDA, access to the chain-of-custody documentation linking their consignment to the parent-reservoir batch identifier.

7. Review and update

This policy is reviewed annually. Material updates are published here with the effective date. The most recent revision is dated 17 April 2026.

Signed by the commercial directorate and group compliance counsel · 17 April 2026.

Policy enquiries and grievance reporting.

Compliance office