Eramet: 2020 reporting on financial transparency of the Group

Content

O1 -MEMORANDUM RELATING TO THE 2020 REPORTING ON FINANCIAL TRANSPARENCY

OF ERAMET GROUP

O2 - 2020 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP

MEMORANDUM RELATING TO THE 2020 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP (1/2)

The "accounting" directive 2013/34/EU was adopted in June 2013 and implemented into French law through the Law n° 2014-1662 of

December 30th, 2014 (Article L.225-102-3of the Code du commerce). Those texts require large companies active in the extractive industry or the logging of primary forests to publish a report on payments to governments on an annual basis.

This obligation is directly inspired by the Extractive Industries Transparency Initiative (EITI) which ERAMET voluntarily integrated in 2011. The main goal of the EITI is to fight corruption by encouraging transparency on money transfers between mining, oil and gas companies and countries hosting those economic activities.

The payments to be declared shall include the payments in cash or in kind, made as a single payment or as a series of related payments, for an amount equal to or above 100.000 euros within a financial year. The following subsidiaries of the ERAMET Group are subject to this obligation:

• • SLN - Le Nickel (France - New Caledonia);

• • Comilog SA (Gabon);

• • Maboumine (Gabon);

• • Eramet South Africa (South Africa);

• • Grande Côte Opérations SA (Senegal); and

• • Eramine Sud America SA (Argentina);

• • Eramet Cameroun (Cameroun).

Detailed information on the subsidiaries of the ERAMET Group is available in chapter 2 of the 2019 Universal Registration Document of the ERAMET Group, available on the websitewww.eramet.com.

Payments of the following types shall be taken into account:

• • Production entitlements;

• • Taxes levied on the income, production or profits of the companies, excluding taxes levied on consumption such as value added taxes, personal income taxes or sale taxes;

• • Royalties;

• • Dividends;

• • Signature, discovery and production bonuses;

• • License fees, rental fees, entry fees and other considerations for licenses and/or concessions; and

• • Payments for infrastructure improvements.

2020 Report on the financial transparency of the Group

MEMORANDUM RELATING TO THE 2020 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP (2/2)

In the absence of any precise legal compelling definition, the types of payments have been defined according to the EITI guidance.

For the sake of clarity, the various types of payments have been separated into two general categories: payments imposed on the legal entity as a commercial entity and payments imposed on the legal entity as mining operator.

In 2019, the following subsidiaries did not make payments greater than 100.000 euros : Maboumine, Eramet South Africa, Eramine Sud America, Eramet Cameroun.

This report was approved by the Board of Directors of ERAMET SA on May 26th, 2020.

2020 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP - PAYMENTS PER CATEGORY (1/4)

Payments per category		Definitions	Countries	Legal Entities	Paid Amount (in euros)*	Public authority receiving the payment
Payments imposed on the legal entity as a commercial entity	Taxes levied on the income, production or profits of companies	Taxes levied on the profits of a company's upstream activities, excluding taxes levied on consumption such as value added taxes, personal income taxes or sale taxes.	France (New Caledonia)	Société Le Nickel (SLN)	11 909 075	Public Treasury (Directorate Tax Services New Caledonia)	(a) (b)
			Gabon	Comilog SA	271 277 075	Ministry of Finance of Gabon	(c)
			Sénégal	Grande Cote Opérations SA	-
	Dividends	A payment to a partner or shareholder out of the profit of a company as a return on the investment made.	France (New Caledonia)	Société Le Nickel (SLN)	-
			Gabon	Comilog SA	68 543 854	Société Equatoriale des Mines and Caisse des Dépôts	(d)
			Sénégal	Grande Cote Opérations SA	-
	Payments for infrastructure improvements	Payment required by contract law or tax law (e.g. road building)	France (New Caledonia)	Société Le Nickel (SLN)	-
			Gabon	Comilog SA	145 038	Public Treasury of Gabon	(g)
			Sénégal	Grande Cote Opérations SA	372 269	Thies Region	(h)

(*) The exchange rate used is the 2019 average rate used for the consolidation of the ERAMET Group accounts, i.e. 119.33174 for Pacific Franc in New Caledonia and 655.957 for CFA Franc in Gabon and Senegal. The amounts reported correspond to all of the disbursements made by the various entities and are not prorated according to the percentage of ERAMET Holding. These ownership percentages are indicated in Chapter 2 of the 2019 Universal Registration Document of the ERAMET Group, available on the websitewww.eramet.com.

2020 Report on the financial transparency of the Group