Eramet: 2021 reporting on financial transparency of the Group

2021 reporting on financial transparency of the Group

Content

O1 - MEMORANDUM RELATING TO THE 2020 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP

O2 - 2021 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP

MEMORANDUM RELATING TO THE 2021 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 2020 Universal Registration Document of the ERAMET Group, available on the website www.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.

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MEMORANDUM RELATING TO THE 2021 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 2020, 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 28th, 2021.

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2021 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP

• PAYMENTS PER CATEGORY (1/4)

				Legal	Paid		Public authority receiving the
Payments per category	Definitions	Countries	Amount
Entities		payment
				(in euros)*
			France (New	Société Le Nickel	11 909 075		Public Treasury (Directorate Tax
			Caledonia)	(SLN)		Services New Caledonia)
		Taxes levied on the profits of a company's
		Gabon	Comilog SA	41 274 433		Ministry of Finance of Gabon
	Taxes levied on the income,	upstream activities, excluding taxes levied
	production or profits of	on consumption such as value added		Eramine Sud
	companies	taxes, personal income taxes or sale	Argentina	351 910		Other public authority
	America
		taxes.
			Sénégal	Grande Cote	5 061 165		Ministry of finance and budget of
			Opérations SA		Senegal
			France (New	Société Le Nickel		-
			Caledonia)	(SLN)
		A payment to a partner or shareholder out	Gabon	Comilog SA	6 282 518		Société Equatoriale des Mines and
Payments imposed on the legal entity as a	Dividends		Caisse des Dépôts
of the profit of a company as a return on
commercial entity			Eramine Sud
	the investment made.
		Argentina		-
			America
			Sénégal	Grande Cote		-
			Opérations SA
			France (New	Société Le Nickel		-
			Caledonia)	(SLN)
	Payments for infrastructure	Payment required by contract law or tax	Gabon	Comilog SA	4 623 839		City of Moanda
		Eramine Sud
	improvements	law (e.g. road building)	Argentina
			America
			Sénégal	Grande Cote	337 000		Thies Region
			Opérations SA

1. (b)

(f)

(h)

(i)

1. The exchange rate used is the 2020 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 and 80.43762 for Argentina. 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 2020 Universal Registration Document of the ERAMET Group, available on the website www.eramet.com.

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