Mining Principle

How We Do It

The process of mining and smelting of tin is relatively simpler than the process required of other minerals (gold, copper nickel, iron ore, etc) and the steps consist as follow:

Removal of the overburden covering the tin ore and waste disposal at a proper designated site.

Extract and transfer the ore to a field processing plant for removal of the impurities of the tin ore using one of two available methods (or both), as follow:

The field processing plant (known as the “washing plant”) uses high-pressure water to force the ore slurry on the sluice box where the waste material (silica) is then separated by gravity force from the tin ore.

The tin smelting process consists of multiple stages to achieve high-purity tin production. Initially, tin ore undergoes a drying phase in a rotary dryer to reduce its moisture content. The dried ore is then mixed with anthracite coal, which acts as a reducing agent, and flux, which regulates the slag composition. This prepared mixture is subsequently fed into an electric furnace operating at temperatures between 1200-1400°C, where reduction reactions occur, producing crude tin with an initial purity of approximately 99.85%.

Following the smelting stage, a refining process is conducted to further remove residual impurities, including arsenic (As), nickel (Ni), iron (Fe), and copper (Cu). This is accomplished by introducing refining agents such as aluminum (Al) and sulfur (S) to facilitate impurity segregation. Additionally, lead (Pb) and bismuth (Bi) contaminants are removed through a crystallization process. The refined tin, now achieving a purity level of up to 99.9%, is cast into ingots, labeled as MSP (Market Standard Purity), systematically stacked, and bundled into one-ton packages, ready for export.

Throughout the entire process, from the field to the final ingot production, the sample of material will be analyzed and tested in laboratories located in each site to ensure standards are being maintained.

We Are Certified

ISO 9001:2015, ISO 14001:2015, ISO 45001:2018, & ISO/IEC 17025:2017

MSP operates a tin mining, smelting, and refining facility certified to ISO 9001:2015 (Quality Management System), ISO 14001:2015 (Environmental Management System), ISO 45001:2018 (Safety Management System), & ISO/IEC 17025:2017 (Testing Laboratory) located in an industrial complex near the city of Sungailiat, Bangka Island.

PROPER Environment (Company Performance Rating Program in Environment Management)

PROPER is an assessment of a company’s environmental management performance that requires a measurable indicator by the Ministry of Environment of the Republic of Indonesia. The purpose of this assessment is to increase the role of companies in environmental management as well as to create stimulant effects in compliance with environmental regulations and to add value to natural resource conservation, energy conservation, and community development. PT Mitra Stania Prima (MSP) succeeded in obtaining the GREEN PROPER award from the Ministry of Environment and Forestry (KLHK) of the Republic of Indonesia in 2023.

RMAP (Responsible Minerals Assurance Process)

PT. Mitra Stania Prima operates in line with the Responsible Minerals Assurance Process (RMAP) requirements.
RMAP requires companies to be assessed every three years, which we are currently undertaking. To check our latest status, please visit the RMAP website.

GREEN PROPER
2024

RESPONSIBLE MINERALS INITIATIVE

ISO 45001:2018
SAFETY MANAGEMENT SYSTEM

ISO 9001:2015
QUALITY MANAGEMENT SYSTEM

ISO 14001:2015
ENVIRONMENTAL MANAGEMENT SYSTEM

ISO/IEC 17025:2017
LABORATORIUM PENGUJI

KOMITE AKREDITASI NASIONAL
FEBRUARY 28, 2025

Responsible Mineral Policy

PT Mitra Stania Prima (MSP) is committed to responsible sourcing and production of tin in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‑Affected and High‑Risk Areas and the Responsible Minerals Assurance Process (RMAP) 2025 Standard.

MSP solely sources and processes tin ore concentrate (primary material) from mining permit holders (IUP) owned by the company and/or affiliated companies. The company therefore operates an internal upstream mechanism equivalent to RMAP requirements to ensure that all inputs are legitimate, conflict‑free and traceable.

Scope of Policy:

This policy applies to all activities of PT MSP related to procurement, processing, storage, and sale of tin products. It covers due diligence measures across the internal supply chain from the mine to the smelter and extends to cooperation with external warehouses for finished products.

Compliance with OECD DDG & RMAP Tin Standard
Internal Primary Sourcing MSP only sources tin ore from its own and affiliated IUPs, excluding third-party, scrap, or recycled materials.
Protection of Human Rights and rejection of serious abuses (torture, forced or child labour, murder, sexual violence).
Grievance Mechanism accessible to all stakeholders (grievance@arsari.co.id)
Mass Balance and Traceability system to reconcile inputs, outputs and inventories
Warehouse Control (Clearance Warehouse) including segregation, labelling, documentation and periodic audits.
Secondary Material Guidance: MSP does not receive or process scrap or recycled tin. The company commits to verify that all materials are primary.
Internal Upstream Mechanism Equivalency: MSP applies due diligence to its own and affiliated IUPs, including CAHRA screening, KYC, plausibility assessment and
internal
Step 5 Reporting and Continuous Improvement: MSP publishes an annual due diligence report outlining risks identified, mitigation actions and progress.
Anti‑Corruption and Anti‑Bribery: MSP strictly prohibits bribery, corruption and fraudulent misrepresentation of mineral origin.
Non‑involvement with Armed Groups and Security Forces Abuses: MSP ensures no payments, services or support are provided to non‑state armed groups or
public/private security forces involved in abuses.
Anti‑Money Laundering and Tax Compliance: MSP complies with all applicable anti‑money‑laundering laws and ensures full payment of taxes, fees and royalties
MSP maintains a zero-tolerance policy toward any Annex II risks. If such risks are identified, MSP will immediately suspend and terminate all sourcing activities

Continual Improvement
This policy shall be reviewed and calibrated at least once every year as part of PT Mitra Stania Prima’s internal review mechanism, to ensure alignment with due diligence results, the latest RMAP standards, as well as changes in supply chain conditions and national regulations.

Declaration & Signature
This policy is effective as of 3 December 2025 and supersedes any previous versions.

PT Mitra Stania Prima
Sungailiat , 3 December 2025

Aryo P.S. Djojohadikusumo
Chief Executive Officer

Annex A – Warehouse Guidance (Clearance Warehouse)

MSP collaborates with the Clearance Warehouse appointed by the Ministry of Trade to store tin ingots prior to MSP’s trading activities on the exchange. Warehouse control measures include the segregation and labeling of each lot, verification of legal ownership and supporting documents (warehouse receipts, import/export permits, release orders), periodic mass-balance reconciliations, and routine site visits. For warehouses located in CAHRA-designated areas, additional on-site assessments are conducted

Annex B – Secondary Material Guidance

MSP declares that it does not receive or process secondary or recycled tin materials. The smelter only processes primary tin ore concentrate from its own IUPs and affiliated companies. MSP therefore classifies the Secondary Materials Guidance as Not Applicable but commits to monitor and verify that no secondary materials enter its supply chain.

Annex C – Internal Upstream Mechanism Equivalency

MSP applies an internal upstream due diligence mechanism equivalent to RMAP requirements. This includes identifying all mining permit holders (IUP) within the corporate group, conducting Know Your Counterparty (KYC) checks, verifying legal ownership and licences, performing Conflict‑Affected and High‑Risk Area (CAHRA) screening, conducting plausibility and mass balance assessments against production data, and carrying out internal audits and site visits

Annex D – OECD Annex II Risk Policy Alignment

This annex outlines how the MSP policy addresses each risk category defined in Annex II

OECD Annex II Risk

Category	MSP Response
Serious human rights abuses (torture, forced labour, child labour, murder, sexual violence)	MSP rejects and disengages from any supply chain associated with serious human rights abuses and protects the rights of workers and communities
Direct or indirect support to non‑state armed groups	MSP prohibits any direct or indirect support to non‑state armed groups; the company sources only from its own and affiliated IUPs.
Abuses committed by public or private security forces	MSP ensures no payments, services or support are provided to public or private security forces involved in abuses; any incidents trigger investigation and corrective action.
Bribery and fraudulent misrepresentation of mineral origin	MSP enforces a zero‑ tolerance policy on bribery and fraud; we conduct KYC checks and implement strong internal controls to prevent misrepresentation of origin.
Money laundering	MSP complies with anti‑ money‑laundering laws, maintains financial transparency and conducts enhanced due diligence to detect suspicious transactions.
Non‑payment of taxes, fees and royalties	MSP ensures full payment of all taxes, fees and royalties and supports transparency in fiscal contributions to host governments.

CAHRA Policies and Procedures of PT. Mitra Stania Prima

1. CAHRA Policy and Commitment
Mitra Stania Prima (MSP) maintains a Responsible Mineral Supply Chain Policy in alignment with the OECD Due Diligence Guidance and the Responsible Minerals Assurance Process (RMAP) Standard. This policy establishes the company’s commitment to ensuring that all tin mineral sources are derived from conflict-free areas and do not contribute to armed conflict or serious human rights violations. The policy is developed with reference to the OECD Policy Model Annex II and encompasses the consistent implementation of the OECD five step due diligence framework across company operations. The scope of the policy covers all activities from procurement, processing, and storage to the sale of tin products, including the internal supply chain from mine to smelter.

Key commitments under MSP’s CAHRA policy include:

Compliance with OECD Guidance and RMAP: The company is committed to following the OECD five-step framework and meeting all RMAP requirements, including adopting the definition of Conflict-Affected and High-Risk Areas (CAHRAs) as defined by the OECD. The policy aims to source only conflict-free minerals and ensure proactive and ongoing due diligence.
Top Management Approval: The policy is signed and endorsed by the President Director and has been effective since 3 December 2025. Top management commitment is demonstrated through the provision of necessary resources and authority for due diligence implementation. The policy is publicly available (https://msptin.com/mining-principle/#supply-chain-policy) and communicated to all suppliers. Compliance requirements are also included in supplier agreements/contracts
Human Rights Protection and Prohibition of Serious Violations: MSP affirms a zero-tolerance stance toward any form of human rights violations in its supply chain, including strict prohibitions against murder, torture, forced labor, child labor, sexual violence, and other severe abuses. All suppliers are required to respect human rights, and any serious violation will result in termination of the supply relationship.
No Support to Armed Groups: The policy prohibits any form of support to non-state armed groups or security forces (public or private) involved in violations. MSP ensures that no payments or assistance can fund conflict or armed groups.
Anti-Corruption, Fraud, and Illicit Financing: The company prohibits bribery, corruption, falsification of mineral origin, and money laundering in operational activities or by business partners. All transactions are subject to transparency checks. MSP mandates full and transparent payment of taxes, royalties, and other official fees to the government, as a commitment to prevent illicit financing and ensure benefits for the state.
Grievance Mechanism and Transparency: MSP provides a grievance mechanism accessible to employees, suppliers, or other stakeholders (grievance@arsari.co.id) to report suspected policy violations. The company is committed to objectively addressing all complaints while protecting the confidentiality and rights of the complainant. Additionally, the company will publicly report its due diligence performance in accordance with OECD Step 5, including publishing the annual due diligence report on the corporate website.

This CAHRA policy is reviewed periodically, at least annually, to ensure it remains relevant to evolving risks and regulations. Reviews are conducted by senior management responsible for the company’s RMAP compliance. Through the above policy and commitments, MSP affirms its support for ethical mining and mineral trading practices in accordance with international standards, and is prepared for verification through RMAP audits.

2. CAHRA Identification Procedure

This procedure is designed to identify countries or regions classified as Conflict-Affected and High-Risk Areas (CAHRAs) within MSP’s supply chain, in accordance with the OECD Due Diligence Guidance Step 2 implementation and the requirements of the RMAP Standard. The procedure includes a risk assessment methodology based on publicly available data, criteria for determining high-risk areas, and the frequency of review. Every new supplier or raw material source is evaluated using this procedure before entering the supply chain, to ensure compliance with the policy outlined above.

2.1 High-Risk Area Identification Method
The initial step involves identifying the country of origin of the tin mineral, as well as the sub national origin (province/district) and transit routes through which MSP collects source information for each shipment of tin concentrate from suppliers. The data reviewed includes mine-of-origin documentation, country of mining, transportation routes, and the location of the receiving smelter. This preliminary information serves as the basis for assessing whether the country or region falls into a high-risk category.

Once the country/region of origin is established, the area risk assessment is conducted by comparing the conditions of the country against recognized international risk data sources. The assessment covers three main aspects required by RMAP: conflict/security, governance, and human rights, along with supporting factors (e.g., financial aspects and local context). The analysis is conducted as a desk study using the most recent publicly available data and is subsequently documented in the Risk Assessment Form.

2.2 Credible and Open Data Sources Used
MSP utilizes credible international data sources recognized by industry initiatives (RMI/RMAP) to assess conflict, governance, and human rights aspects in a country. The main sources employed include:

Global Peace Index (GPI): A global peace index measuring the level of security and conflict within a country. The GPI provides an overview of the presence or absence of armed conflict and the general level of violence. For example, Indonesia has a GPI score of 1.79 (2025), classified as a “High State of Peace,” indicating the country is not considered high-risk for conflict. Countries with poor GPI scores (low peace category) are identified as high-risk in terms of conflict.

https://www.visionofhumanity.org/maps/#/

Fragile States Index (FSI): An index measuring the political, economic, and social pressures of a country, including security and social cohesion. A high FSI score (e.g., “Alert” category) indicates weak governance and potential for conflict; therefore, countries with very high FSI scores are considered high-risk

https://fragilestatesindex.org/analytics/fsi-heat-map/

Corruption Perceptions Index (CPI): An index by Transparency International measuring perceived levels of corruption, serving as an indicator of governance and corruption. The lower the CPI score (0–100), the higher the perceived level of corruption. MSP sets a specific CPI threshold: countries with a CPI score below 20 are categorized as high-risk in terms of governance. (For illustration, Indonesia’s CPI score was 37 in 2024; it is not considered highly corrupt and therefore not classified as a high-risk source.

https://www.transparency.org/en/cpi/2024

Freedom in the World (Freedom House): Scores of civil and political liberties reflecting the human rights and freedom situation. Countries rated as “Not Free” or with very low scores indicate serious human rights issues and are categorized as high-risk. Supplementary Source – Human Development Index (HDI, UNDP): Measures progress in education, health, and economy as a proxy for fundamental rights. Countries in the “low” HDI category are also considered high-risk. For example, if a country falls into the lowest human development category, MSP classifies it as High-Risk Sourcing with respect to human rights.

https://freedomhouse.org/country/indonesia/freedom-world/2025

https://hdr.undp.org/data-center/specific-country-data#/countries/IDN

European Union CAHRA List: An indicative list of conflict-affected/high-risk areas published by the European Commission in accordance with Regulation (EU) 2017/821. As of 2025, 28 countries are included, such as Afghanistan, Burundi, Central African Republic, Colombia, Democratic Republic of the Congo (DRC), Egypt, Eritrea, Ethiopia, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Kenya, Lebanon, Libya, Mali, Mauritania, Myanmar (Burma), Nigeria, North Korea, Pakistan, the Philippines, Somalia, South Sudan, Sudan, Syria, and Venezuela. Any mineral sourced from one of these EU CAHRA listed countries is automatically considered High-Risk. https://www.cahraslist.net/cahras

Dodd-Frank Act (USA): Section 1502 of the Dodd-Frank Act identifies the DRC and its neighboring countries as conflict regions related to 3TG minerals. Therefore, supplies originating from the DRC or the nine directly bordering countries (Angola, Burundi, Rwanda, Uganda, South Sudan, Tanzania, Zambia, Republic of the Congo, Central African Republic) are considered high-risk and prohibited. https://www.iea.org/policies/16713-dodd-frank-wall-street-reform-and-consumer-protection-act

Financial Risk & Sanctions Indicators: MSP also considers illicit financing and financial crime risks associated with a source. Sources such as the Basel AML Index (country level money laundering risk) and FATF (Financial Action Task Force) data are used as references. Additionally, international sanctions lists (OFAC US, UN, EU) are reviewed to determine whether the country of origin or related entities are subject to sanctions. Countries or suppliers appearing on trade sanctions lists are automatically flagged as high-risk (e.g., UN embargoed countries are treated as high-risk similarly to CAHRAs).

https://index.baselgovernance.org/ranking

The data sources mentioned above are updated periodically; MSP uses the most recent available data (e.g., the current year or previous year indices). A combination of primary international sources (such as GPI, CPI, HDI) and credible secondary sources (e.g., U.S. Department of State human rights reports, CrisisWatch, etc.) is utilized to ensure a comprehensive assessment. Consequently, MSP’s CAHRA identification method meets RMAP requirements for using a wide range of information sources covering conflict, governance, and human rights aspects.

2.3 Risk Criteria and Determination Approach
Based on data from the sources mentioned above, MSP applies risk assessment criteria to determine whether a country/region is classified as a CAHRA. Specific thresholds are established for each indicator. For example, a GPI score below a certain category, a CPI score below 20, a “Not Free” freedom status, or a low HDI category will trigger a high-risk flag for the corresponding aspect. Additionally, the presence of a country on official lists (EU CAHRA list or DRC-adjoining countries) is automatically considered a High-Risk indicator.

The approach adopted is conservative: if at least one primary criterion indicates high-risk, the country is considered temporarily as High-Risk Sourcing and requires further review (next steps). However, if two or more indicators simultaneously meet high-risk criteria, the country/region is directly classified as a CAHRA. MSP policy stipulates that materials from confirmed CAHRAs will not be sourced; such sources are rejected at this evaluation stage.

Conversely, if all primary indicators are at safe levels (low/medium) and no other red flags exist, the country is deemed non-CAHRA (low risk). The assessment results are recorded in MSP’s internal CAHRA list, which identifies countries considered high-risk. In accordance with RMAP standards, MSP’s internal CAHRA list at minimum includes countries required by regulation (DRC + 9 neighboring countries, and relevant EU CAHRA list). Additionally, MSP may include other areas deemed sensitive based on its own evaluation (e.g., specific regions within non-CAHRA countries if significant local conflict exists).

CAHRA designation also considers the local scale: sub-national analysis is conducted if a country is not nationally high-risk but certain provinces have conflicts or violations (this sub-national analysis remains separate from subsequent due diligence following CAHRA designation).

2.4 Review Frequency and Responsibilities
Review Frequency: The CAHRA list and country risk assessments are reviewed at least annually or immediately in the event of significant developments (e.g., outbreak of new conflicts, coups, or drastic changes in index rankings). Annual routine reviews ensure that changes in global conditions are reflected in the procedure (for instance, if a country is newly added to the EU CAHRA list, MSP will update its assessment accordingly).

Responsibilities: MSP appoints the Senior RMAP Manager as responsible for the implementation and monitoring of this CAHRA procedure. The Senior Manager leads a cross-functional due diligence team (involving logistics, procurement, compliance, legal departments, etc.) that evaluates new sources, accesses index data, and validates the risk assessment results. All updates to the CAHRA list are approved by top management. In practice, the Senior RMAP Manager prepares the annual CAHRA evaluation report for the Board of Directors and recommends policy changes as necessary.

This CAHRA identification procedure is documented as part of MSP’s Supply Chain Standard Operating Procedure (SOP). The latest version has been effective since 3 December 2025 and will be reviewed annually by the Senior RMAP Manager in accordance with internal provisions. Through this process, MSP ensures that the CAHRA identification approach remains up-to-date and aligned with RMAP guidance.

3. CAHRA Risk Scoring Matrix Template

To facilitate consistent assessments, MSP uses a CAHRA Risk Scoring Matrix that consolidates various indicators into major categories. Each category is assigned a quantitative score and a specific weight, resulting in a composite assessment of a country’s or region’s risk level. The matrix helps categorize areas objectively as High/Medium/Low Risk.

The CAHRA risk matrix, key indicators, scoring system, and weights are as follows:

Risk Category	Key Indicators	Weight	Assessment Criteria (Score)
Conflict & Security	– Armed conflict incidents – Peace level (Global Peace Index score)	20%	Low (1): No active conflict, GPI in high peace category. Medium (3): Localized tension or conflict, GPI moderate. High (5): Active armed conflict or war, GPI very poor.
Governance & Corruption	– Political stability & rule of law – Corruption level (CPI or Governance WGI Index)	20%	Low (1): Effective governance, high CPI (≥50). Medium (3): Governance weaknesses, CPI moderate (20–49). High (5): Failed/fragile governance, rampant corruption (CPI < 20).
Human Rights	– Human rights & civil liberties situation (Freedom House status, human rights reports) – Basic welfare (Human Development Index)	20%	Low (1): Good human rights record, country “Free”, high HDI. Medium (3): Localized human rights issues, country “Partly Free”, medium HDI. High (5): Widespread human rights violations (authoritarian/conflict), country “Not Free”, low HDI.
Financial Aspect	– Risk of illicit financing (money laundering, conflict funding) – Compliance with taxes/royalties in country of origin	20%	Low (1): No major money laundering indications; supplier compliant with taxes/royalties. Medium (3): Vulnerable financial sector, FATF grey-listed; some tax compliance issues. High (5): Country under international financial sanctions; prevalent shadow finance practices; evidence of supplier tax evasion.
Local Context	– Local security conditions in mining areas – Presence of illegal armed actors	20%	Low (1): Stable mining area, no local security disturbances. Medium (3): Sporadic security disturbances (e.g., illegal mining or local protests). High (5): Mining area high-risk, presence of illegal armed groups or serious communal conflict.

Explanation: Each category is scored 1 (Low), 3 (Medium), or 5 (High) based on objective data and criteria. Default weights for each category are 20% (equal), summing to 100%. The overall composite score is calculated by summing the weighted category scores. This composite value is then mapped to a risk level: e.g., ≥4.0 = High Risk, 2.0–3.9 = Medium Risk, <2.0 = Low Risk (on a 1–5 scale).

Beyond numerical scoring, a precautionary principle is applied: if any single category scores 5 (High), particularly relating to conflict or human rights, MSP may escalate the area directly as High-Risk/CAHRA even if the overall average score is diluted. The matrix serves as a consistent guideline, but final decisions also consider qualitative analysis from the due diligence team (e.g., the latest information not reflected in index scores).

The CAHRA risk matrix also assists in supplier categorization: suppliers from high-scoring regions are flagged as Red Flag and require enhanced due diligence, whereas suppliers from low-scoring regions are considered Low Risk and undergo routine checks only. The matrix template can be adjusted in weighting if needed (e.g., a company may assign a higher weight to “Conflict & Security” if deemed most critical). All scoring methodology and weighting are documented for audit and transparency purposes.

4. Documentation, Reporting, and Internal Escalation Mechanism

MSP has a formal mechanism for documenting assessment results, reporting them to management, and escalating actions when high-risk CAHRA issues are identified. This mechanism ensures that all decisions regarding high-risk sources are recorded and reviewed by authorized internal parties, in accordance with OECD Step 3 (Risk Management).Documentation: All evaluations and decisions made during the CAHRA identification process are documented in detail. Risk assessment forms (including index data attachments, source documentation, etc.) are stored in the company’s filing system. MSP applies document control procedures in accordance with ISO standards: each due diligence record is assigned an identification code, securely stored (both physical and digital), and confidentiality is maintained. Records are retained for a minimum of five years or as required by RMAP, ensuring traceability during audits. Transaction and chain-of-custody evidence (delivery orders, invoices, weighing records, etc.) are also fully documented to support the risk assessment conclusions.

Internal Reporting: If a raw material source is identified as High-Risk (e.g., a supplier from a CAHRA country or flagged with serious red flags), the due diligence team immediately reports the findings to the Senior RMAP Manager and executive management. Internal reports include a summary of identified risks, violation categories (e.g., conflict, human rights, etc.), and recommended actions. Senior management reviews the report and provides guidance on follow-up actions. MSP internal procedures require that red flag or high-risk findings be escalated to the Director level promptly, ensuring that company leadership is aware of material risk exposures. In relevant management meetings (ad-hoc if needed), mitigation measures or strategic decisions regarding the source are determined.

Escalation and Follow-Up Actions: In line with company policy, sourcing from confirmed CAHRA areas will be discontinued. However, if high-risk issues are remediable, MSP implements internal risk mitigation plans. For example, management may decide to temporarily suspend cooperation with a supplier while requesting corrective actions (e.g., supplier must demonstrate elimination of conflict sourcing), or continue under strict conditions (e.g., on-site verification, additional source documentation requirements, involvement of third-party local auditors). Mitigation strategies are developed on a case-by-case basis, in accordance with OECD Step 3 guidance. All mitigation measures are documented, and their progress is regularly monitored. For suppliers categorized as High-Risk Sourcing, MSP collects additional information on local conditions (e.g., through field interviews or consultations with local authorities) to assess sustainable sourcing feasibility.

For formal escalation, MSP has a zero-tolerance escalation procedure: if identified risks involve severe Annex II OECD violations (e.g., evidence of funding armed groups or serious human rights abuses), the case is considered zero tolerance and must be immediately reported to the President Director or the company’s ethics committee within 24 hours. Termination decisions with the supplier are executed promptly in zero-tolerance cases. This procedure ensures rapid response to the most severe risks in accordance with RMAP expectations.

In addition to internal reporting, external reporting is conducted as required by regulations: if there is a legal obligation (e.g., indications of criminal activity such as money laundering), MSP cooperates with law enforcement authorities. Furthermore, significant findings and corrective actions are included in MSP’s Annual Due Diligence Report (OECD Step 5), which is published. Through this mechanism, MSP ensures accountability and that all high-risk issues are addressed seriously through documented management decisions.

5. Implementation of CAHRA in MSP’s Internal Supply Structure

MSP operates a closed internal supply structure, meaning that all tin raw materials processed are sourced exclusively from its own mines or affiliated entities within the same corporate group (holders of Mining Business Licenses/IUP). No raw materials are purchased from external parties outside the group, and MSP does not process any recycled (secondary) materials. This arrangement facilitates risk control: the supply chain can be fully traced and directly monitored by the company.Since all mining sources are located within Indonesia (Bangka Belitung Islands), a relatively stable region, the implementation of CAHRA procedures is tailored to this risk profile. Current internal CAHRA assessments indicate that MSP’s operational area is not a CAHRA. Indonesia, as the country of origin, is not listed among conflict-affected regions and has moderate-to-good global indices (e.g., Indonesia’s GPI score reflects a high state of peace, its HDI is in the high category, and there is no armed conflict in Bangka Belitung Province). Consequently, the risk of conflict or human rights violations within MSP’s internal supply chain is assessed as very low. This is reflected in the policy that MSP only sources tin from legitimate own/affiliated IUPs, which are conflict-free and fully traceable. All raw materials are verified to originate from legal sources with complete documentation, minimizing the possibility of funding armed groups or human rights violations.

Nevertheless, MSP continues to conduct internal CAHRA identification as a precautionary measure. Each year, the MSP due diligence team screens internal operations for CAHRA compliance: this includes verifying that mining areas have not experienced situational changes (e.g., emergence of new social conflicts), performing Know Your Supplier (KYS) checks on affiliated entities, and conducting plausibility assessments comparing production against national export data. These steps ensure that no anomalies indicate sourcing from high-risk areas (e.g., MSP’s production volume remains proportional to total national output, avoiding suspicion of mixing with unknown sources). MSP also conducts periodic internal audits of the mine-to-smelter supply chain to verify compliance with CAHRA procedures and RMAP standards.

If in the future MSP needs to engage external suppliers (e.g., due to increased capacity or depletion of its own mine reserves), the full CAHRA procedure will be applied to the potential source before entering the supply chain. External suppliers must undergo a strict selection process, including completing an extended supplier form and signing a declaration confirming that the materials sold are conflict-free and subject to audit. Their data will be assessed against all CAHRA criteria outlined above. Only suppliers from Low-Risk areas may be accepted, and compliance with MSP policies is mandatory. With this approach, MSP’s CAHRA procedures remain effective for both its internal supply structure and potential third-party sourcing.

6. Summary of MSP Due Diligence Findings for All Affiliated IUPs

Based on detailed due diligence conducted on all Mining Business Licenses (IUPs) supplying raw materials to PT Mitra Stania Prima (PT MSP), including PT Aega Prima, PT Mitra Stania Bemban, PT Mitra Stania Kemingking, and MSP’s own Mapur Site, it is concluded that all suppliers comply with the OECD Due Diligence Guidance and RMAP Tin Standard. All IUPs are located in the Bangka–Belitung region, Indonesia, consistently classified as Non-CAHRA based on:

- Global Peace Index (GPI)
- Corruption Perception Index (CPI) & governance indicators
- Human Development Index (HDI) & global human rights reports
- Anti-Money Laundering (AML) indicators
- Local context assessment (security conditions, presence of armed actors, etc.)

In all CAHRA assessments for each IUP, scores across the five risk categories were at the minimum value (1), yielding a composite score of 1.0, classified as LOW risk for each supplier.No Annex II OECD risks or red flags were identified in relation to:

Armed conflict
Armed groups
Human rights violations
Money laundering / terrorist financing
Legal compliance breaches
Social or environmental issues
Traceability manipulation
Production volume anomalies (plausibility)

PT Mitra Stania Prima
Sungailiat, 3 December 2025

Aryo P.S. Djojohadikusumo
Chief Executive Officer

EXTERNAL GRIEVANCE AND REPORTING MECHANISMS

A. Scope of Complaints
The report & complaint team will follow up on actions that can harm the company. The scope of complaints includes the following:

Deviation from the prevailing laws and regulations
Misuse of position for other interests outside the company
Extortion
Cheating
Conflict of interest
Customer complaints (either from buyers or from suppliers/vendors)
Potential risk identified in the company supply chain policy

B. Reporting Mechanism

Reporters
a. Reporters are required to provide personal data such as name, address, mobile number and email.
b. Include supporting documents for reporting.
c. For violation reporting submitted by stakeholder representatives, other additional documents are required:
1) Proof of identity of stakeholders and stakeholder representatives in the form of photocopies,
2) Power of attorney from stakeholders to stakeholder representatives stating that stakeholders grant authority on behalf of stakeholders,
3) A document attachment states that the party filing the violation report has the right to represent the institution or legal entity if the stakeholder is an institution or legal entity.
d. Written violation reports without an identity may be made, but the reporter must include a copy of the documents related to the report to be submitted.

Reporting Supporting Data
a. The time of the violation, which explains when the violation occurred in the form of day, week, month or year.
b. The location of the violation, including the name of the place where the violation occurred.
c. The parties involved who are responsible for the violation.
d. Whether the violation had occurred before and was reported to other parties.

Submission of Complaints by reporters
a. Reporting must be done in good faith, not for personal or retaliatory purposes.
b. Reporting is made for the common interest of both the company and stakeholders.

The reporter makes a complaint and sends it via:
Website : msptin.com
Email : grievance@arsari.co.id
Phone : +62 22 8226 7917
Form : https://docs.google.com/forms/d/1kYKGW_7BMhoGWlyownrGx1-DoLg8qXuu0rTqMLfwQV8/

C. Follow-up Process for Complaints

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

D. Whistle-blower Protection Policy
The company protects whistle-blowers as follows:

The company guarantees the confidentiality of the reporter’s identity.
The company provides full protection for whistle-blowers from all forms of threats, intimidation, or other unpleasant actions from any party.
The company protects parties who help provide information related to the complaint.
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.

PT Mitra Stania Prima
Sungailiat, 31 December 2024

Aryo P.S. Djojohadikusumo
Chief Executive Officer

STEP 5 DUE DILIGENCE REPORT – PT MITRA STANIA PRIMA (MSP)

Executive Summary

This Step 5 Due Diligence Report summarizes the implementation of PT Mitra Stania Prima’s (MSP) responsible minerals due diligence system in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals and the Responsible Minerals Assurance Process (RMAP) Tin Standard. The report covers the 2025 reporting period, with reference to relevant multi-year assessments, and provides an overview of MSP’s policies, governance arrangements, and due diligence practices related to its tin sourcing and processing activities.

MSP operates a closed, internal primary supply chain, sourcing tin ore concentrate exclusively from its own and affiliated mining concessions located in Bangka Belitung Province, Indonesia. In accordance with its documented CAHRA Identification Procedure, MSP applies a structured approach supported by recognized international reference sources to assess conflict and high-risk area indicators. Based on this process, MSP determined that its sourcing locations are classified as Non-Conflict-Affected and Low-Risk Areas (Non-CAHRA) during the reporting period. No indicators of armed conflict or conflict-related human rights risks were identified in relation to MSP’s supply chain.

As part of its upstream due diligence, MSP applies Know Your Supplier (KYS) procedures, risk assessments, and on-the-ground evaluations across all affiliated mining concessions, in line with OECD Step 2 and RMAP upstream requirements. These processes did not identify any OECD Annex II risks, including risks related to conflict financing, serious human rights abuses, corruption, money laundering, or security-related abuses.

At the midstream level, MSP implements traceability, chain of custody, mass balance, and plausibility controls as part of its routine operations. Mass balance reconciliation and plausibility assessments are conducted to support the consistency and reasonableness of material flows within MSP’s internal supply chain. These controls are supported by internal verification and review processes and did not indicate any unexplained discrepancies, material mixing, or unverifiable inputs during the reporting period.MSP also conducted internal reviews and monitoring activities covering key elements of its due diligence system, including CAHRA implementation, traceability and chain of custody, mass balance management, warehouse controls, and documentation practices. No major non-conformities were identified. Minor observations related to documentation consistency and procedural alignment were addressed through corrective actions as part of MSP’s continuous improvement approach.

Transparency and external communication are integral components of MSP’s due diligence framework. MSP publishes its Step 5 Due Diligence Report on an annual basis, and published reports are documented and retained in accordance with internal record-keeping policies. Through these measures, MSP seeks to maintain transparency, support responsible sourcing practices, and ensure ongoing alignment with RMAP requirements.

Overall, this report demonstrates MSP’s continued application of a responsible minerals due diligence system consistent with international expectations. MSP will continue to review and refine its due diligence practices as part of its annual reporting cycle and future assessments.

Company Overview
PT Mitra Stania Prima (MSP) is a fully integrated tin smelter located in the Jelitik Industrial Area, Sungailiat, Bangka, Indonesia. The company specializes in tin smelting, refining, and ingot casting operations. MSP exclusively processes primary tin ore concentrate sourced from its own mining concession (IUP) and affiliated mining concession IUPs located in Bangka Belitung Province, Indonesia. MSP does not source from external suppliers, traders, artisanal miners, scrap, recycled, or secondary materials. Accordingly, MSP operates a closed-loop internal supply chain and applies an internal upstream due diligence mechanism equivalent to RMAP requirements, covering mine-to-smelter traceability, legality verification, CAHRA screening, KYS/KYC, plausibility assessment, mass balance reconciliation, internal audits, and management oversight.All mining operations supplying MSP are located within Indonesia, which based on annual CAHRA screening using internationally recognized indicators and regulatory reference lists is formally classified as a Non-Conflict-Affected and High-Risk Area (Non-CAHRA) under MSP’s CAHRA identification procedure. Through this internal upstream model, MSP maintains full control and visibility over its supply chain, enabling effective implementation of the OECD Due Diligence Guidance and full alignment with the RMAP Tin Standard 2025, including Step 5 public reporting and continuous improvement toward the upcoming audit cycle.

Company RMAP Assessment Summary
PT Mitra Stania Prima (MSP) CID001453 has undergone multiple Responsible Minerals Assurance Process (RMAP) assessments as a tin smelting and refining facility.

Initial RMAP assessment: 30 November – 1 December 2019
Re-assessment: 2 – 3 March 2023
Non-audit year RMI facility review: 19 December 2023 – 8 January 2024
Non-audit year RMI facility review: 27 Februari 2025 – 3 March 2025

The assessment scope covered the period 22 December 2018 to 31 December 2023 and evaluated MSP’s conformance with the OECD Due Diligence Guidance and applicable RMAP Tin Standard requirements. The assessments were conducted by Febryan Muhajid Pantagama (SCS), Arifzal Adrianto (Arche Advisors), Olena Stanislavchuk and Montse Vega Sanchez (RBA Support). The next on-site RMAP audit is scheduled for 2026, and MSP is currently implementing continuous improvement measures to ensure full readiness and alignment with the RMAP Tin Standard 2025.

Responsible Mineral Policy
PT Mitra Stania Prima (MSP) 2025 Responsible Mineral Policy (RMP) defines commitments aligned with the OECD Due Diligence Guidance, OECD Annex II risks, and the RMAP Tin Standard 2025. The policy demonstrates MSP’s commitment to responsible tin sourcing, including the identification, prevention, mitigation, and remediation of risks associated with Conflict-Affected and High-Risk Areas (CAHRA). MSP operates a closed, internal primary supply chain and sources tin ore concentrate exclusively from its own and affiliated IUPs located in Indonesia. Based on its formal CAHRA Identification Procedure, MSP confirms that its sourcing locations are classified as Non-CAHRA during the reporting period. The policy establishes a zero-tolerance approach to all OECD Annex II risks. If any Annex II risk is identified, MSP commits to immediately suspend and terminate sourcing activities. MSP applies an internal upstream due diligence mechanism that is equivalent to RMAP upstream requirements, including CAHRA screening, Know Your Supplier (KYS/KYC), plausibility assessment, mass balance reconciliation, traceability controls, and internal audits.

The Responsible Mineral Policy is publicly available at:
https://msptin.com/mining-principle/#responsible-mineral-policy

Governance & Management System
PT Mitra Stania Prima (MSP) follows through on its commitments to Responsible Mineral Policy and an internal procedure for due diligence as:

MSP Chief Executive Officer Mr. Aryo P.S. Djojohadikusumo is responsible to oversee the due diligence program and risk management design and implementation.
MSP has assigned Senior RMAP Manager and Smelter General Manager, Mr. Sugeng Riyadi, to coordinate the work of the Procurement, Receiving – Warehousing, Production, and Quality Control Departments, respectively, to follow up on their roles and responsibilities to implement the due diligence program, internal upstream mechanism, report any red flag and potential risk identified.
MSP has Documented SOPs for CAHRA, KYS/KYC, traceability, warehouse control & plausibility study. Implement implemented internal due diligence including: risk readiness assessment, upstream due diligence, plausibility study, KYS/KYC, CAHRAs identification procedure, mass balance calculation and public reporting.
MSP 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.
MSP 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.

Supply Chain Mapping
PT Mitra Stania Prima (MSP) operates a closed-loop, internal primary tin supply chain, in which all tin ore concentrate processed by the smelter originates exclusively from MSP-owned and MSP-affiliated Izin Usaha Pertambangan (IUP) located in Bangka Belitung Province, Indonesia.

MSP supply chain consists of the following entities and flows:

Upstream Mining (Internal & Affiliated IUPs)
MSP sources tin ore concentrate solely from: IUP Site Mapur (company-owned); IUP Site Belinyu (affiliated company); IUP Site Bemban (affiliated company); IUP Site Kemingking (affiliated company)

All IUPs hold valid mining licenses (IUP), approved RKAB, and operate under MSP’s Internal Upstream Mechanism Equivalency, including CAHRA screening, KYS/KYC verification, plausibility assessments, on-the-ground assessments, and internal audits.

Supply Chain Components
No	Stage	Ownership	Location	Status
1	Mining	Owned	Mapur, Bangka Belitung	Active
2	Mining	Affiliate	Belinyu, Bangka Belitung	Active
3	Mining	Affiliate	Bemban, Bangka Belitung	Active
4	Mining	Affiliate	Kemingking, Bangka Belitung	Active
5	Transport	MSP-controlled	Internal Logistics	Controlled
6	Smelting	Owned	Sungailiat, Bangka Belitung	Active
7	Warehouse	External (Gov-appointed)	Pangkal Pinang, Bangka Belitung Indonesia	Controlled

Transportation & Logistics
Tin ore concentrate is transported directly from each IUP site to PT Mitra Stania Prima (MSP) smelter using verified internally controlled logistic transports. MSP controls include: Documented surat jalan & weight records; Photo evidence at loading and unloading; Lot number; No transit through third party traders or blending facilities; Midstream smelting & refining. At the MSP smelter (Sungailiat – Jelitik Industrial Area), tin ore concentrate undergoes: Smelting, Refining & Casting into tin ingots. MSP applies: Mass balance reconciliation (input–output–slag); Sn% verification (IUP vs smelter recovery), Annual & multi-year plausibility analysis (2023–2025); Downstream Finished Goods & External Warehouse. Finished tin ingots are transported to: Government-appointed Clearance / Exchange Warehouse.

MSPs’ External warehouse controls include: Lot segregation & labeling, traceability documentation (warehouse receipts, DO, seals), physical security & access control and periodic internal audits & reconciliation. MSP does not source from: External traders, artisanal mining (ASM), scrap or recycled tin & secondary materials.

CAHRA & Risk Context (Link to Supply Chain Mapping):

Country & Sub-national context: Indonesia (Bangka Belitung)
CAHRA Status: Non-CAHRA / Low Risk
Supply Chain Model: Closed, internal, vertically controlled
Annex II Exposure: None identified
Mixing Risk: None (no external suppliers or traders)

CAHRA Identification Procedure
PT Mitra Stania Prima (MSP) applies a formal and documented procedure to identify and assess Conflict-Affected and High-Risk Areas (CAHRA) in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals and the Responsible Minerals Assurance Process (RMAP) Tin Standard. The objective of this procedure is to ensure that all tin ore sourced and processed by MSP does not originate from Conflict-Affected or High-Risk Areas, does not contribute to armed conflict, serious human rights abuses, corruption, or other OECD Annex II risks.

Scope of Application
The CAHRA Identification Procedure applies to:

All internal IUP owned by MSP
All affiliated IUPs supplying tin ore concentrate to MSP
All sourcing locations, including sub-national assessment

Where relevant and all reporting periods covered in the Step 5 Due Diligence Report

Methodology and Risk Categories
PT Mitra Stania Prima (MSP) conducts CAHRA screening using a risk-based, documented assessment methodology covering five core risk categories, consistent with RMAP upstream requirements:

Risk Category	Assessment Focus
Conflict & Security	Presence of armed conflict, armed groups, and national security conditions; supported by Global Peace Index (GPI)
Governance & Corruption	Political stability, corruption risks, and governance indicators; supported by Corruption Perceptions Index (CPI)
Human Rights	Civil and political freedoms, labor rights, and human rights conditions; supported by Freedom House reports and Human Development Index (HDI)
Financial / AML	Risks of money laundering, illicit financial flows, sanctions exposure, and non-payment of taxes and royalties; supported by AML indices and sanctions lists
Local Context	Mine-site security, illegal armed group presence, community conditions, and local conflict dynamics

Each category is assessed using a standardized scoring matrix and is supported by qualitative analysis and documentary evidence.

Data Sources and References
PT Mitra Stania Prima (MSP) uses recognized, independent, and internationally accepted data sources, including but not limited to: Global Peace Index (GPI); Corruption Perceptions Index (CPI–Transparency International); Freedom House – Freedom in the World; UNDP Human Development Index (HDI); EU CAHRA Indicative List (EU Regulation 2017/821); Dodd-Frank Act Section 1502 (DRC and adjoining countries); Basel AML Index / FATF references and Open-source media and government reports (where relevant).

Assessment Outcome
PT Mitra Stania Prima (MSP) formally concludes that Indonesia, including Bangka Belitung Province and all MSP sourcing locations, is classified as a Non-Conflict-Affected and Low-Risk Area (Non-CAHRA) for the reporting period. No armed conflict, non-state armed group involvement, security-related abuses, or systematic human rights violations were identified. All CAHRA assessments are documented using MSP’s standardized CAHRA forms. Assessments are reviewed and approved through a maker-checker-approver mechanism involving the RMAP Manager and senior management. CAHRA status is reviewed at least annually or when material changes in country or local conditions occur. Any escalation to potential CAHRA status triggers immediate risk review in line with OECD Step 3 and MSP’s zero-tolerance policy toward Annex II risks.

KYS/KYC Procedures
PT Mitra Stania Prima (MSP) implements a comprehensive Know Your Supplier (KYS) procedure as part of its internal upstream due diligence system, in alignment with OECD Due Diligence Guidance (Step 1 & Step 2) and the RMAP Tin Standard 2025 upstream requirements. Given that MSP operates a closed, internal primary supply chain, the KYS procedure applies to all MSP-owned and affiliated mining permit holders (IUPs) supplying tin ore concentrate to the smelter. MSP does not source material from external traders, third-party suppliers, scrap, or recycled materials.

Scope of KYS Application
The KYS procedure is mandatory for: MSP-owned IUP; Affiliated IUPs within the corporate group including, but not limited to: IUP (Site Mapur); IUP (Site Bemban); IUP (Site Belinyu) & IUP (Site Kemingking).

Core Elements
The KYS process includes the following verification components:

Legal Ownership & Licensing Verification
PT Mitra Stania Prima (MSP) verifies that each IUP:
- Holds a valid and active Mining Business Permit (IUP) issued by the competent authority.
- Has supporting legal documents (RKAB approval, environmental permits, tax registration).
- Operates within licensed geographic boundaries; Beneficial Ownership Identification.
- Beneficial ownership is identified and verified against corporate records.
- Confirmation that no sanctioned individuals, or restricted entities are involved.
- Alignment with anti-money laundering (AML) and transparency principles.
- Production Capacity & Volume Validation.
Licensed production capacity (RKAB) is compared against: Actual mine production; Delivered quantities to the MSP smelter; Any deviation beyond normal operational variance is flagged for review under plausibility assessment; Tin Grade (Sn%) Verification; Declared Sn% at IUP level is cross-checked against:
Sign a Conflict-Free and Responsible Sourcing Declaration; Formally commit to compliance with: OECD Annex II risk prohibitions; RMAP Tin Standard; Acknowledge MSP’s zero-tolerance policy toward Annex II risks; Traceability & Chain of Custody Controls; Verification of transport routes from mine to smelter; Review of documentation including; delivery orders; weighbridge records; seals and photographic evidence; Controls to prevent material mixing or origin misrepresentation.

Risk Integration & Escalation
KYS results are integrated with:

CAHRA assessment outcomes
Risk assessment scoring
On-the-ground verification

Any red flags identified through KYS trigger escalation in accordance with MSP’s internal risk escalation procedure and No Annex II risks were identified during the reporting period across all MSP IUPs.

Governance & Approval

KYS assessments are prepared by designated analysts (Legal / Commercial / Logistics)
Reviewed by the Senior Manager RMAP

Summary Outcome
Based on KYS implementation during the reporting period:

All MSP and affiliated IUPs were assessed as LOW RISK
Legal status, ownership, production volumes, Sn%, and traceability data were verified and found consistent
No indications of conflict sourcing, human rights abuses, corruption, money laundering, or origin misrepresentation were identified and being maintained as part of MSP’s auditable due diligence records.

Risk Assessment Summary
PT Mitra Stania Prima (MSP) conducts a structured and risk-based assessment of its tin supply chain in accordance with the OECD Due Diligence Guidance Step 2 and the RMAP Tin Standard 2025. The risk assessment process is applied to all upstream sources within MSP’s closed and internal primary supply chain, covering MSP’s own mining concession (IUP) and affiliated IUPs located in Bangka Belitung Province, Indonesia.The objective of the risk assessment is to identify, evaluate, and document any actual or potential risks related to OECD Annex II categories, including conflict, human rights abuses, governance and corruption, financial crime (AML), and local security conditions.

Risk Assessment Methodology
MSP applies a standardized Risk Assessment Matrix integrated with the CAHRA Identification Procedure and KYS process. Each IUP is assessed across five primary risk categories, aligned with RMAP upstream requirements:

Risk Category	Assessment Focus
Conflict & Security	Presence of armed conflict, armed groups, and national security conditions; supported by Global Peace Index (GPI)
Governance & Corruption	Political stability, corruption risks, and governance indicators; supported by Corruption Perceptions Index (CPI)
Human Rights	Civil and political freedoms, labor rights, and human rights conditions; supported by Freedom House reports and Human Development Index (HDI)
Financial / AML	Risks of money laundering, illicit financial flows, sanctions exposure, and non-payment of taxes and royalties; supported by AML indices and sanctions lists
Local Context	Mine-site security, illegal armed group presence, community conditions, and local conflict dynamics

Each category is scored using a weighted scoring methodology (Low/Medium/High), supported by recognized international data sources (GPI, CPI, HDI, Freedom House, EU CAHRA Indicative List, AML indices) and verified through internal documentation review and site-level observations.

Risk Assessment Results
Based on the risk assessment conducted during the reporting period:
All MSP IUPs were assessed as LOW RISK across all five risk categories. Indonesia, including Bangka Belitung Province, is classified as Non-CAHRA and Low-Risk for MSP sourcing locations with the following details:

No actual or potential OECD Annex II risks were identified, including:
No conflict or security incidents
No direct or indirect support to armed groups
No human rights violations
No bribery, corruption, money laundering, or tax evasion
No security-related abuses at mine sites

Integration with Due Diligence Controls
The Risk Assessment outcomes are directly integrated into MSP’s broader due diligence management system, including: KYS verification (legal status, beneficial ownership, production capacity); Plausibility assessments (licensed production vs actual delivery vs national context); Mass balance reconciliation (ore input, WIP, tin output, slag generation); On-the-Ground Assessments, where applicable

Escalation and Zero-Tolerance Policy
MSP applies a zero-tolerance approach to OECD Annex II risks. In accordance with MSP’s Responsible Mineral Policy:

Any identified High-Risk or Annex II indicator would trigger immediate escalation to Senior Manager RMAP and the Chief Executive Officer.
MSP would immediately suspend and terminate sourcing activities pending investigation.
No corrective action plans are permitted for confirmed Annex II violations.
During the reporting period, no escalation or suspension actions were required, as no Annex II risks were identified.

Status
The results of the risk assessment confirm that MSP’s internal primary tin supply chain operates under a low-risk profile, supported by consistent CAHRA screening, KYS controls, plausibility validation, and mass balance integrity. The risk assessment framework demonstrates alignment with OECD DDG Step 2 and fully meets the upstream risk identification and assessment requirements of the RMAP Tin Standard.

Mass Balance
As part of its responsible minerals due diligence program, PT Mitra Stania Prima (MSP) conducted annual and consolidated multi-year mass balance reconciliation covering the period 2023 to 2025, with a reporting cut-off as of 1 November 2025, in accordance with the RMAP Tin Standard. The reconciliation was prepared using the official RMI RMAP Line Item Summary format and covers all relevant material flows from input to output. The mass balance assessment includes tin ore concentrate inputs, work-in-progress, refined tin ingot outputs, and processing by-products, and was reviewed on both single-year and consolidated multi-year bases. Across the reporting period, MSP’s mass balance results remained within industry-accepted tolerance levels, demonstrating consistent operational performance, effective internal controls, and a high level of data integrity. Comparative analysis between declared material characteristics at source and smelter-level processing outcomes indicates technically reasonable and industry-accepted variation, consistent with normal metallurgical processes. No indicators of unexplained losses, material inconsistencies, or irregular movements were identified during the reporting period.

All materials included in the mass balance originate exclusively from MSP’s internal and affiliated sources, and no secondary materials, recycled inputs, or third-party intermediates were processed. Mass balance outcomes are supported by traceability records, production documentation, warehouse controls, and internal verification processes. The use of both annual and consolidated multi-year mass balance reconciliation provides additional assurance against potential time-lag discrepancies and supports MSP’s internal upstream mechanism equivalency under the RMAP framework. Based on these results, MSP confirms that its tin processing activities during the reporting period were technically plausible, internally controlled, and consistent with its closed supply chain model, in alignment with the RMAP Tin Standard.

Plausibility Assessment
PT Mitra Stania Prima conducts plausibility assessments to evaluate the reasonableness of tin ore sourcing and processing volumes across its supply chain. The assessment is performed in line with RMAP Tin Standard 2025 requirements and applies to all tin ore supplied from MSP’s own and affiliated IUPs. The plausibility assessment considers multiple reference points, including approved mining plans and licensed production capacities at IUP level, actual production and delivery records, quantities processed by the smelter, and aggregated mass balance results. This approach enables MSP to assess supply plausibility both at individual mine level and across its integrated operations.

Based on the assessment, all IUPs supplying MSP were determined to be plausible, with production and delivery volumes falling within technically and economically reasonable ranges. No indicators of over-production, unexplained discrepancies, anomalous supply patterns, or unverifiable inputs were identified. The plausibility findings are consistent with MSP’s mass balance results and support the conclusion that MSP’s tin sourcing and processing activities remain controlled and transparent.

External Warehouse Control
PT Mitra Stania Prima (MSP) implements documented and controlled procedures for the transportation and storage of finished tin ingots at external exchange warehouses. The procedure ensures full traceability, material integrity, and compliance with RMAP Tin Standard requirements. Prior to shipment, the Logistics Department coordinates with the Commercial Department to confirm shipment schedules, quantities, and transport readiness. All shipments are documented through official delivery notes, export weight lists, and transport documentation, which are verified and signed prior to dispatch. Security controls are applied throughout the loading and transportation process, including driver identification, vehicle registration, and escorted transport to the exchange warehouse.

Upon arrival, warehouse receipt confirmation is obtained and archived. Inside the external warehouse, tin ingots are segregated by lot, grade, and status, clearly labeled, and stored in designated locations. All movements and location changes are documented to maintain continuous chain of custody. Warehouse records are reconciled with sales, production, and mass balance data, and are subject to internal audit and verification. These controls ensure that no unauthorized material mixing occurs and that all finished products remain fully traceable from smelter to final delivery.

Traceability & Chain of Custody
PT Mitra Stania Prima operates a closed and fully controlled internal supply chain, ensuring full traceability and chain of custody from mine site (IUP) to finished tin ingots stored at the Exchange Warehouse (Gudang Bursa). All tin ore received from MSP’s own and affiliated IUPs is subject to documented receiving procedures, including verification of transport documents, lot-based weighing, sampling, laboratory analysis, and systematic stock recording. Each batch of tin ore and intermediate material is uniquely identified through lot codes, weight records, sampling logs, and internal documentation, enabling end-to-end traceability throughout storage, mixing, production, and refining processes.

MSP implements annual and multi-year mass balance reconciliation in accordance with its Mass Balance Management Policy and the RMAP Tin Standard. The mass balance calculation covers tin ore inputs, work-in-progress, refined tin ingot outputs, and by-products, with defined roles and responsibilities assigned to Logistics, Production, and RMAP Management. Any discrepancies or indicators of inconsistency are escalated, investigated, and resolved through internal coordination. Finished tin ingots are transferred to the Exchange Warehouse under controlled logistics procedures, including verified loading, sealing, documentation, and segregation by lot and grade, ensuring no commingling with third-party materials. These controls collectively demonstrate data integrity, material accountability, and compliance with RMAP traceability, chain of custody, and mass balance requirements.

On-the-Ground Assessment Summary
PT Mitra Stania Prima (MSP) conducts on-the-ground assessments as part of its enhanced due diligence framework to validate documented information and confirm site-level conditions at internal and affiliated mining operations. Site visits and verifications conducted during the reporting period across MSP’s internal and affiliated IUPs confirmed that operations are located in secure and stable environments with no armed group presence, no reported human rights violations, and no significant social or environmental conflicts. Documentation and physical observations were consistent with declared production volumes and transport records. No findings required risk mitigation related to OECD Annex II risks.

Internal audits and management review
Where risk indicators remain at LOW level, sourcing is allowed to continue under routine monitoring. The assessment results are documented, approved through maker-checker controls, and retained for audit purposes. During the reporting period, PT Mitra Stania Prima (MSP) conducted periodic internal audits and management reviews covering key components of the RMAP Due Diligence Management System, including: CAHRA identification, Know Your Supplier (KYS/KYC), traceability and chain of custody, mass balance controls, plausibility assessment, warehouse controls, and documentation integrity across all affiliated IUPs (Mapur, Belinyu, Bemban, & Kemingking).

The internal audits confirmed that MSP’s due diligence system is implemented effectively and consistently aligned with the OECD Due Diligence Guidance and RMAP Tin Standard 2025. Across all audited areas, no significant non-conformities were identified, and no Annex II risks (conflict financing, human rights abuses, corruption, money laundering, security-related abuses) were detected in the internal supply chain.

Grievance Mechanism
PT Mitra Stania Prima (MSP) ensures that our Report & Complaint Team will take follow-up actions upon any harmful complaint to the company. The scope of complaints includes the following:

Deviation from the prevailing laws and regulations
Misuse of position for other interests outside the company
Extortion
Cheating
Conflict of interest
Customer complaints (either from buyers or from suppliers/vendors)
Potential risks identified in the supply chain policy

Reporting mechanism

Reporters
Reporting supporting data
Submission of complaints by reporters
The reporter makes a complaint and sends it via:
Website : msptin.com
Email : grievance@arsari.co.id
Phone : +62 822 8226 7917
Form : https://forms.gle/awKfis3WTJzZ7yeT8

PT Mitra Stania Prima (MSP) carry out a follow-up process for complaints:

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

In order to protects company whistle-blowers company guarantees the confidentiality of the reporter’s identity. The company provides complete protection for whistle-blowers from all forms of threats, intimidation, or other unpleasant actions from any party and protects parties who help provide information related to the complaint. 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.

Stakeholder Engagement
PT Mitra Stania Prima (MSP) conducts stakeholder engagement as part of its responsible minerals due diligence framework, in line with the OECD Due Diligence Guidance and the RMAP Tin Standard 2025. Engagement activities are intended to support transparency, identify potential social and environmental risks, and inform risk management and mitigation measures.

During the reporting period, MSP engaged with relevant stakeholders, including affiliated mining concession holders (IUPs), local communities and government authorities, through structured affiliated mining concessions meeting, consultation processes related to community development and mine closure planning. Stakeholder inputs were documented and considered as part of MSP’s ongoing monitoring and review activities.

Stakeholder engagement outcomes are integrated into MSP’s due diligence processes through internal review and follow-up mechanisms. No conflict-related concerns or Annex II risks were identified through stakeholder engagement activities during the reporting period.

Corrective Actions & Mitigation
PT Mitra Stania Prima (MSP) applies corrective actions and mitigation measures as part of its ongoing due diligence and continuous improvement process, in alignment with the OECD Due Diligence Guidance and the RMAP Tin Standard 2025. Corrective actions are identified through internal monitoring, internal reviews, and management oversight activities and are implemented in a proportionate manner.

During the reporting period, MSP did not identify any OECD Annex II risks within its internal supply chain. Accordingly, no corrective actions related to conflict financing, serious human rights abuses, corruption, money laundering, or security-related abuses were required. Internal reviews identified minor observations primarily related to documentation consistency and procedural alignment.

Follow-up actions focused on improving documentation standardization, reinforcing internal control processes, and enhancing consistency across operational functions. Corrective actions were tracked internally, assigned to responsible functions, and reviewed through management oversight processes. These measures were implemented to strengthen system effectiveness and support continuous improvement.

Implementation Progress (2024–2025)
During the 2024–2025 reporting period, PT Mitra Stania Prima (MSP) continued the implementation and refinement of its responsible minerals due diligence system in alignment with the OECD Due Diligence Guidance and the RMAP Tin Standard 2025. Implementation activities focused on strengthening internal procedures, enhancing consistency across operational functions, and maintaining effective oversight of MSP’s internal supply chain.

MSP continued to apply its documented Responsible Mineral Policy, CAHRA identification process, and supplier due diligence procedures across all affiliated mining concessions. These processes were implemented as part of routine operations and supported by internal coordination and management review to ensure alignment between policy commitments and operational practices.

Throughout the period, MSP maintained the implementation of traceability, chain of custody, mass balance, and plausibility controls as core elements of its midstream due diligence system. These controls were applied on an ongoing basis and supported by internal verification and monitoring activities. Annual and multi-year reviews contributed to the consistency of data management and reinforced confidence in production plausibility and material accountability.

MSP also undertook follow-up actions in response to minor observations identified through internal reviews, focusing on procedural clarity, documentation consistency, and control reinforcement. These actions were implemented as part of MSP’s continuous improvement approach. No significant changes to MSP’s sourcing model occurred during the reporting period, and MSP continued to operate a closed, internal primary supply chain, without the introduction of third-party or secondary materials.

Overall, the implementation progress achieved during the 2024–2025 period reflects MSP’s ongoing commitment to maintaining an effective due diligence system, supporting transparency, and ensuring continued alignment with RMAP requirements.

RMAP Non-conformities & Closures
During the reporting period, PT Mitra Stania Prima (MSP) conducted internal audits, management reviews, and ongoing monitoring activities to evaluate the effectiveness of its Responsible Minerals Due Diligence system in accordance with the OECD Due Diligence Guidance and the RMAP Tin Standard. Based on the results of internal audits, plausibility assessments, mass balance reconciliation, CAHRA screening, and upstream due diligence activities, no major non-conformities related to OECD Annex II risks were identified across MSP’s internal and affiliated IUP supply chain. Specifically, there were no findings related to conflict financing, serious human rights abuses, corruption, money laundering, security-related abuses, or material traceability failures. Several minor observations were identified during internal reviews and prior RMAP assessments. These observations primarily related to documentation standardization, consistency of audit trails, and formalization of certain procedures, including: Harmonization of CAHRA, KYS, and Risk Assessment forms across all affiliated IUPs; Strengthening maker-checker controls for mass balance calculations and production records; Enhanced documentation alignment between logistics, production, and warehouse records.

All identified observations were addressed through corrective actions implemented by MSP, including revision of SOPs, reinforcement of internal controls, additional staff training, and improved document management practices. Corrective actions were tracked internally and reviewed by the RMAP Manager to ensure effective closure. At the close of the reporting period, all identified observations were considered closed, and no outstanding corrective actions related to RMAP requirements remained open. MSP maintains a zero-tolerance policy toward OECD Annex II risks, and any future identification of such risks would trigger immediate escalation, suspension, and termination of sourcing in accordance with MSP’s Responsible Mineral Policy and risk escalation procedures. MSP continues to implement continuous improvement measures across the 2023 – 2025 period, including mass balance reconciliation, strengthened external warehouse controls, and increased integration between upstream due diligence and operational data systems, in preparation for the upcoming RMAP on-site audit cycle.

Secondary Material Screening
PT Mitra Stania Prima (MSP) operates a closed-loop primary tin supply chain and does not source or process any secondary materials, including recycled tin, scrap materials, tailings, or third-party residues. All tin ore inputs processed by MSP are sourced exclusively from its own mining concession (IUP) and affiliated IUPs located in Bangka Belitung Province, Indonesia.

To ensure compliance with RMAP Tin Standard, incoming material screening is conducted at the logistics and receiving stage to verify material origin, physical characteristics, documentation, and conformity with internal sourcing policies. Any material not originating from MSP-owned or affiliated IUPs is automatically rejected. Based on MSP’s sourcing model, operational controls, and verification procedures, secondary material risk is assessed as not applicable (N/A) for the reporting period. This conclusion is supported by internal audits, supplier declarations, traceability documentation, and mass balance reconciliation, which collectively confirm that no secondary materials entered MSP’s production process.

Transparency & External Communication
PT Mitra Stania Prima (MSP) is committed to transparency and responsible external communication as part of its OECD-aligned due diligence framework and compliance with the RMAP Tin Standard. MSP publicly discloses its Step 5 Due Diligence Report on an annual basis, providing stakeholders with an overview of the company’s responsible mineral sourcing practices, risk management approach, and continuous improvement efforts.

The public due diligence report includes information on MSP’s responsible mineral policy, governance and management systems, CAHRA identification, supplier due diligence, traceability and chain of custody controls, mass balance and plausibility assessments, stakeholder engagement, and grievance mechanisms. The report is prepared based on internally verified data and reviewed by designated management prior to publication to ensure accuracy and consistency.

All published due diligence reports are formally documented, archived, and retained in accordance with MSP’s internal documentation and record-keeping policies. This ensures traceability of disclosures, supports audit readiness, and enables continuous improvement through year-to-year comparison. MSP will continue to enhance transparency and external communication as part of its ongoing commitment to responsible tin sourcing and alignment with international due diligence expectations.

Conclusion
This Step 5 Due Diligence Report demonstrates PT Mitra Stania Prima’s (MSP) ongoing implementation of a responsible minerals due diligence system in alignment with the OECD Due Diligence Guidance and the RMAP Tin Standard 2025. Throughout the reporting period, MSP continued to apply its documented policies, procedures, and internal controls across its tin supply chain. MSP operates a closed, internal primary supply chain, sourcing tin ore exclusively from its own and affiliated mining concessions. Based on the application of MSP’s CAHRA identification procedures, supplier due diligence processes, and ongoing monitoring activities, no OECD Annex II risks were identified within MSP’s supply chain during the reporting period. Mass balance reconciliation, plausibility assessments, and traceability controls were applied as part of routine operations and supported by internal verification and review processes. Internal reviews and monitoring activities identified minor opportunities for procedural and documentation improvement, which were addressed through corrective actions consistent with MSP’s continuous improvement approach. No major non-conformities were identified. MSP continues to maintain a zero-tolerance approach toward OECD Annex II risks and has established governance mechanisms to support escalation and decision-making where necessary.

Through the implementation of these measures, MSP aims to maintain transparency, support responsible sourcing practices, and ensure continued alignment with RMAP requirements. MSP will continue to review and refine its due diligence system as part of its annual reporting cycle and future assessments.

PT Mitra Stania Prima
Sungailiat, 23 Desember 2025

Aryo P.S. Djojohadikusumo
Chief Executive Officer

Annexes

1. Responsible Mineral Policy
2. CAHRA Procedure
3. Risk Assessment Forms
4. KYS Forms
5. Mass Balance Spreadsheet 2023-2024
6. Plausibility Matrix
7. Warehouse Audit Photos
8. Internal Audit Reports
9. Transport Route Map
10. On the ground assessment