Human Rights Policy

Impossible Metals is committed to ensuring its operations and supply chains comply with the United Nations Guiding Principles on Business and Human Rights. Impossible Metals acknowledges the importance of the highest levels of transparency in relation to human rights issues, including the opportunity for stakeholders to raise concerns, risks or potential breaches without fear of retribution.

Protecting Human Rights

Impossible Metals is committed to the following principles in relation to human rights:

  • Child labor and modern slavery is eliminated from all operations and supply chains;
  • No forced labor is used, and measures are implemented to ensure employment is freely chosen;
  • All employees have fair wages and employment agreements;
  • Work hours do not exceed the maximum limit set by relevant legislation;
  • All employees are free to exercise their right to form and/or join trade unions and to bargain collectively;
  • Employees experience fair and equal treatment and access to opportunity, and enjoy a work environment that is free of discrimination, harassment, intimidation or coercion;
  • The health and safety of employees, contractors and the community is protected in so far as it relates to any operations, or indirect impacts from operations, undertaken by Impossible Metals;
  • All stakeholders have the right to engage freely, meaningfully and transparently with Impossible Metals, and to raise concerns or complaints with Impossible Metals without fear of retribution;
  • Free, Prior and Informed Consent must be obtained from stakeholders who will be significantly affected by activities of Impossible Metals (noting that it is the objective of Impossible Metals that none of its activities will adversely affect the communities in which it operates).

Positive Duty

Impossible Metals recognizes that it has a positive duty to take reasonable and proportionate measures to eliminate discrimination, vilification, harassment and victimization (together referred to as “unacceptable behavior”) from the workplace. This includes taking action to all reported or observed occurrences of unacceptable behavior, and ensuring employees and contractors are regularly undertaking training to prevent, recognize and address unacceptable behavior.

Approach to Protecting Human Rights

Our approach to protecting human rights is focused on a foundation of transparent communication in relation to expectations, training and development and procedures to govern implementation of practices in relation to employment, community engagement and supply chain management. We undertake the following proactive actions in relation to the protection and monitoring of human rights:

  • Providing awareness of human rights through training of all employees and engagement with contractors and supply chain partners, including auditing of supply chain partners;
  • Communicating our expectations in relation to the protection of human rights through clear discussions and contractual arrangements;
  • Recognizing and responding to the potential for, or occurrence of, inappropriate practices;
  • Providing a clear pathway for employees, contractors, partners and stakeholders to report suspected wrongdoing;
  • Adopting a risk management approach to the engagement of partners and suppliers with particular consideration of human rights;
  • Recognizing where we have the potential to effect positive change, such as through changes in our procurement processes and engagement with stakeholders.
  • Providing adequate and appropriate support to employees and contractors who make a complaint about harassment, discrimination, victimization or vilification, including ensuring that the matter is treated confidentially and that the complainant is not victimized;
  • Managing organizational change in an inclusive and participatory way, consulting with employees and stakeholders who may be affected in a timely and proactive manner;
  • Making reasonable adjustments for employees with a disability, and to ensure inclusivity of cultures, genders and other protected attributes;
  • Reporting on performance against this Human Rights Policy as part of Impossible Metals’s Annual Report; and
  • Taking action (including disciplinary action) if it becomes aware of the occurrence of any behavior which constitutes a breach of this Human Rights Policy.

Reporting

All Impossible Metals employees and contractors are expected to report any known or suspected breach of this Human Rights Policy to the Chief Executive Officer. In the event that the incident relates to the Chief Executive Officer, the incident may be reported to the Chair of the Board. If a complaint is made it will be acted upon immediately and managed in a sensitive and confidential manner, in accordance with the Complaints and Disputes Policy.

Breach of this Policy

Breach of this Policy is considered gross misconduct and will be subject to disciplinary action as outlined in the Employee Handbook, up to and including termination of employment or contractual arrangements.

Changes to this Policy

This policy is reviewed under Impossible Metals’s mandatory annual policy review schedule and is next due for formal review in October 2022.

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