Eramet: Reporting on financial transparency of the Group as at 31 December 2021

Reporting on financial transparency of the Group as at 31 December 2021

Content

O1 - MEMORANDUM RELATING TO THE REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP AS AT 31 DECEMBER 2021

O2 - REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP AS AT 31 DECEMBER 2021

MEMORANDUM RELATING TO THE REPORTING ON FINANCIAL - TRANSPARENCY OF ERAMET GROUP AS AT 31 DECEMBER 2021 (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 2021 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 REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP AS AT 31 DECEMBER 2021 (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 2021, the following subsidiaries did not make payments greater than 100.000 euros : Maboumine, Eramet South Africa and Eramet Cameroun.

This report was approved by the Board of Directors of ERAMET SA on 31 May 2022.

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REPORTING ON FINANCIAL TRANSPARENCY OF ERAMET GROUP AS AT 31 DECEMBER 2021 - PAYMENTS PER CATEGORY (1/4)

1. The exchange rate used is the 2021 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 112,23603 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 2021 Universal Registration Document of the ERAMET Group, available on the website www.eramet.com.

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