• Company Information
  Mitra Stania Prima, which was established in 2004, is located in Kawasan Industri Jelitik Sungai Liat Bangka, Indonesia, and specializes in processing tin products, including smelting, refining, and casting ingots. The company’s operations are exclusively focused on processing tin ores that are sourced from its own mining concession IUP located in Mapur Kab. Bangka – Indonesia.The company is also affiliated with two in-house companies, namely PT. Mitra Stania Kemingking and PT. AEGA PRIMA. These companies hold mining concession IUP; IUP for PT. Mitra Stania Kemingking, located in Kemingking Kab. Central Bangka-Indonesia, and IUP for PT. Aega Prima, located in Belinyu Kab. Bangka-Indonesia.

• Company RMAP Assessment Summary
  PT. Mitra Stania Prima CID001453 has undergone an RMAP assessment for the tin mineral smelting and refining company on 30 November – 1 December
  2019 and on 2 – 3 March 2023. The assessment period was from 13 December 2017 to 21 December 2018 and from 22 December 2018 to 31 January 2023.
  The assessment was conducted by Febryan Muhajid Panatagama of SCS and Afrizal Adrianto of Arche Advisors.
  

• Company Supply Chain Policy
  In order to demonstrate our full commitment to the responsible sourcing of conflict minerals from Conflict-Affected and High-Risk Areas, including tin mineral as our main field. PT. Mitra Stania Prima has a policy that follows the OECD Due Diligence Guideline which can be accessed at the following link:
  https://msptin.com/Supply-Chain-Policy.pdf PT. Mitra Strania Prima strongly condemns all activities and will refuse any material which we assessed benefitted or supported armed rebels/terrorist groups through illegal finance or other activities or involved serious human rights violations associated with the extraction, handling, transport or trade of minerals, including:

• • • Serious abuses (i.e., torture, cruel, inhuman and degrading treatment; forced for compulsory labour; worst forms of child labour; human rights violations and abuses such as widespread sexual violence; war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide)
    • Direct or indirect support to public or private security forces.
    • Bribery and fraudulent misrepresentation of the origin of minerals.
    • Money laundering.
    • Non-payment of taxes, fees and royalties to governments.

• Company Management systems
  Management structure
  PT. Mitra Stania Prima follows through on its commitments to Supply chains policy and an internal procedure for due diligence as:

1. 1. PT. Mitra Stania Prima Chief Executive Officer Mr. Aryo P.S. Djojohadikusumo is responsible to oversee the due diligence program and risk management design and implementation.
   2. PT. Mitra Stania Prima has assigned RMAP Manager and Smelter Manager, Mr. Sugeng Riyadi, to coordinate the work of the Procurement, Receiving
      and Warehousing, Production, and Quality Control Departments, respectively, to follow up on their roles and responsibilities to implement
      the due diligence program, report any red flag and potential risk identified.
   3. PT. Mitra Stania Prima conducted due diligence management system training once a year with the relevant employee as required in due diligence guidance. Regularly reminded to provide feedback to the due diligence program, all new staff and the key staff from relevant departments have to refresh training a minimum once a year to manage their prominent understanding of the company RMAP due diligence management system.
   4. PT. Mitra Stania Prima records any report or feedback on the due diligence system will be documented and recorded for follow-up action and will be maintained by the due diligence program manager.

Internal system of control

PT. Mitra Stania Prima will only consume Indonesian tin ore from its own mining concessions in Mapur Kab. Bangka and affiliated with PT. Mitra Stania Kemingking, Kemingking/Kepoh Kab. Central Bangka and PT. AEGA PRIMA, Belinyu Kab. Bangka. All deliveries must indicate the source with the Delivery Order with the number of trucks, driver’s name, date of delivery, and rough quantity. All tin ores received by the smelter will be weighed against the delivery order, and take a representative sample and weighed. The department will perform a mass balance assessment throughout the production process to ensure the recovery target is met. Warehouse staff are trained only to accept tin ores from their mines.

PT. Mitra Stania Prima refers to the RMI grievance mechanism to collect information from interest parties. All complaints received by the related administrator via email [email protected] and the website https://msptin.com/ will be reported to the CEO and the manager of the due diligence program to find solutions and take action to handle and identify the related risks.

Record keeping system
In line with Indonesian regulations, the smelter must keep the record for 5 years. All records are properly used and safely stored in hardcopy and softcopy where applicable.

• Risk Identification
  a. PT. Mitra Stania Prima uses the following procedure to identify Conflict-Affected and High-Risk Areas (CAHRAs) and assess red flags:

First, identify the country of origin, including the region and transit routes/countries.
PT. Mitra Stania Prima uses the following five internationally recognized resources which RMI-RMAP approves from the following link:
https://bit.ly/PTMSPCHARAManagement

a. Global Peace Index (Presence of Conflict)
The Global Peace Index (GPI) measures more than just the presence or absence of war. It captures the absence of violence or the fear of violence across three domains: Safety and Security, Ongoing Conflict, and Militarization. Both the Ongoing Conflict and Safety and Security domains recorded deteriorations, with only the militarization domain recording an improvement. In 2023, Indonesia had a global average score equal to 1.8 out of 5. It ranks number 53 out of 163 countries and is in the High state of peace defined by the Global Peace Index. We determine if a country if Indonesia is not a high-risk country and as it is not classified in Low Category.

 Source: Global Peace Index 2023

b. Corruption Perception Index (Governance Parameter)
The CPI aggregates data from several different sources that provide perceptions among business people and country experts of the level of corruption in the public sector. CPI standardizes data sources to a scale of 0-100. This standardization is done by subtracting the mean of each source in the baseline year from each country’s score and then dividing it by the standard deviation of that source in the baseline year. This subtraction and division using the baseline year parameters ensure that the CPI scores are comparable year on year since 2012. After this procedure, the standardized scores are transformed to the CPI scale by multiplying them with the value of the CPI standard deviation in 2012 (20) and adding the mean of the CPI in 2012 (45), so that the dataset fits the CPI’s 0-100 scale. In 2022, Indonesia has score equals to 34. We determine if a country has a score under 20, it will be stated as a High-Risk Sourcing.

Source: Corruption Perception Index 2022

c. United Nation Development Program of International Human Development Indicators which is Human Development Index (Human Right Parameter)
Human Development Index (HDI) is a composite index measuring average achievement in three basic dimensions of human development – a long and healthy life, knowledge, and a decent standard of living. Based on Human Development Report 2021, there are four groups of Human Development:

• Very high human development
• High human development
• Medium human development
• Low human development.

In 2021, Indonesia had a score equal to 0.7 or in the High Human Development category. We determine if a country is in the low human development category, it will be stated as High-Risk Sourcing.

Source: UNDP 2021

d. Identifying Conflict Affected and High-Risk Areas for EU importers of minerals.
The European Union (EU) is committed to ensuring that its imports of minerals and metals are sourced responsibly and align with EU policies on conflict prevention and development. Regarding to, Regulation (EU) 2017/821 it requires EU importers of tin, tantalum, tungsten and gold (and the minerals containing them) to carry out supply chain due diligence based on the five-step approach established in the OECD guideline. The list of CAHRAs as of 2021 are: Afghanistan, Burkina Faso, Burundi, Cameroon, Central African Republic, Chad Colombia, Democratic Republic of the Congo, Egypt, Eritrea, Ethiopia, India, Libya, Mali, Mexico, Mozambique, Myanmar, Niger, Pakistan, Philippines, Somalia, South Sudan, Sudan, Turkey, Ukraine, Venezuela, Yemen & Zimbabwe.

We determine that sourcing from those 29 countries will be considered as High-Risk Sourcing.

e. Dodd Frank Act
United States Dodd Frank Act section 1502 requires listed companies to disclose whether they use “conflict minerals” (tin, tungsten, tantalum and gold) and whether those minerals originated in the Democratic Republic of the Congo (DRC) or its adjoining countries.

We determine that sourcing from the Democratic Republic of the Congo and or its adjoining countries as High-Risk Sourcing.

We determine that if 1 of the mentioned criteria results in high-risk findings, sourcing status will be considered as High-Risk; the identification process will continue to step 2, that is CAHRAs identification using resources. If two or even three of the three criteria result in high-risk findings, then the area will be considered CAHRAs. We will not source material from CAHRAs. This procedure will be used to review any new supply chain when our resources are insufficient, cannot produce anymore or no longer economical.

Second, CAHRAs identification using resources and risk mitigation.
Our standard process for Supplier Selection and Qualification (evaluating/ selecting suppliers per ISO standard), due to the additional risk related to responsible sourcing of tin ore, further reviews and documentation are included in the selection of prospective new suppliers of tin ore.

All supplier of tin ore is required to complete an extended supplier form as well as sign a supplier declaration stating that any material sold to us is sourced according to our Supplier Policy, Code of Product, Responsible Sourcing Policy and will cooperate with requests for additional information on the origin of the product sold to us. The format of all the documents needed will be created when the CAHRAs procedure can be implemented.

As we source tin minerals from our own mines and affiliated companies which are located in Indonesia, a non-High-Risks country, there are no risks associated with CAHRAs. But for future possibilities that we will procure tin minerals from other affiliated companies where risks are found, we will identify and follow up according to the rules and suggestions from RMI Organization.

• Risk Mitigation
  a. Grievance Mechanism
  We ensure that our Report & Complaint Team will take follow-up actions upon any harmful complaint to the company. The scope of complaints includes the following:

1. 1. Deviation from the prevailing laws and regulations
   2. Misuse of position for other interests outside the company
   3. Extortion
   4. Cheating
   5. Conflict of interest
   6. Customer complaints (either from buyers or from suppliers/vendors)
   7. Potential risks identified in the supply chain policy
2. Reporting mechanism
   1. Reporters
   2. Reporting supporting data
   3. Submission of complaints by reporters
   The reporter makes a complaint and sends it via :
   Website: msptin.com
   Email: [email protected]
3. We carry out a follow-up process for complaints:

1. 1. The report & complaint team receives complaints and records them.
   2. Reports submitted without the reporter’s identity will be processed following a review of the evidence presented to confirm it is correct.
   3. The report & complaint team provides feedback to the reporter and forwards the violation report to the management.
   4. The management receives a violation report from the report & complaint team, which is reviewed together to find solutions to the report.
   5. If the report is proven to be accurate, then the management will ask the related parties to complete the violation report immediately.
   6. The violation report will be closed if the report is not proven or valid.
   7. All reports related to supply chain risks will be reported to RMAP Senior Manager.
   8. All reports will be settled in maximum 10 working days or according to the complexity of the problem.

The company protects whistle-blowers as follows:
1. The company guarantees the confidentiality of the reporter’s identity.
2. The company provides complete protection for whistle-blowers from all forms of threats, intimidation, or other unpleasant actions from any party.
3. The company protects parties who help provide information related to the complaint.
4. Sanctions for false reporting if the submitted reporting is not based on good faith, has no basis, or contains elements of false evidence, slander, or defamation, then the reporter may be subject to sanctions under the applicable provisions.

This Public Report will be reviewed annually by our RMAP Manager.

PT Mitra Stania Prima
Sungailiat , 18 December  2023

Aryo P.S. Djojohadikusumo
Chief Executive Officer