Modern Slavery Statement

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps that Fodere Critical Minerals ("Fodere", "we", "our", or "us") has taken and continues to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chains. Fodere Critical Minerals is a sustainable critical minerals recovery company operating across the United Kingdom, United States, and South Africa. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We have a zero-tolerance approach to modern slavery. We are committed to preventing acts of modern slavery and human trafficking from occurring within both our business and our supply chain, and we expect the same high standards from all of our contractors, suppliers, and business partners.

Fodere Critical Minerals specialises in the recovery of critical minerals from industrial tailings and secondary feedstocks using proprietary zero-waste processing technology. Our primary products include Titanium Dioxide (TiO₂), Vanadium Pentoxide (V₂O₅), Niobium, Alumina, and Rare Earth Elements. Our operations span multiple jurisdictions: United Kingdom: Global headquarters at 5 Approach Road, London SW20 8BA, responsible for corporate governance, strategic direction, and investor relations. United States: Operations office at 1633 Broadway, New York, NY 10019, supporting commercial development and North American partnerships. South Africa: Operations hub at 2nd Floor, West Tower, Nelson Mandela Square, Johannesburg 2196, overseeing mining project development, feedstock sourcing, and pre-commercial plant operations. Given the nature of the extractive industries and the regions in which we operate, we recognise that our sector carries elevated risks relating to modern slavery and human trafficking, particularly in mining supply chains, and we take proactive steps to mitigate these risks.

Our supply chain encompasses: Feedstock Suppliers: Providers of industrial tailings, slag, and secondary mineral feedstocks from mining operations, primarily in Southern Africa. Equipment and Technology Providers: Manufacturers and suppliers of mineral processing equipment, chemical reagents, and laboratory supplies. Construction and Engineering Contractors: Firms engaged in the construction and maintenance of our pre-commercial plant and processing facilities. Professional Services: Legal, financial, consulting, and technical advisory firms. Logistics and Transport: Companies providing transportation, shipping, and warehousing services for feedstocks and mineral products. We acknowledge that certain parts of our supply chain, particularly those involving mining operations and construction in developing regions, present higher risks of modern slavery and exploitation.

We undertake the following measures to assess and mitigate modern slavery risks: Supplier Due Diligence: Before engaging new suppliers, we conduct due diligence assessments that include evaluation of their labour practices, working conditions, and compliance with local employment laws. This is particularly rigorous for suppliers operating in jurisdictions with elevated modern slavery risks. Ongoing Monitoring: We conduct periodic reviews of existing supplier relationships to ensure continued compliance with our standards. This includes site visits to key operational partners and feedstock suppliers in South Africa. Risk Mapping: We have identified the following areas as higher risk within our supply chain: artisanal and small-scale mining operations that may feed into our feedstock supply; construction labour at project sites in Southern Africa; and transportation and logistics services in regions with known exploitation risks. Country Risk Assessment: We assess the modern slavery risk profile of each country in which we operate or source materials, taking into account the Global Slavery Index, government enforcement capacity, and sector-specific risk factors.

We have implemented the following policies and procedures to support our commitment: Anti-Slavery and Human Trafficking Policy: A dedicated policy that sets out our zero-tolerance approach and the responsibilities of all staff in preventing modern slavery. Supplier Code of Conduct: All material suppliers are required to acknowledge and adhere to our Supplier Code of Conduct, which explicitly prohibits forced labour, child labour, debt bondage, human trafficking, and any form of modern slavery. Whistleblowing Policy: We maintain a confidential reporting mechanism through which employees, contractors, and third parties can raise concerns about suspected modern slavery or unethical practices without fear of retaliation. Recruitment Practices: We conduct thorough checks on all employees to verify their right to work and ensure that terms of employment comply with applicable labour laws. We do not engage in any practices that could constitute forced or compulsory labour. Corporate Governance: Our Board of Directors maintains oversight of our anti-slavery measures, with regular reporting on supply chain risks and mitigation efforts.

We are committed to ensuring that our staff understand the risks of modern slavery and human trafficking and their role in preventing it: Key personnel involved in procurement, supply chain management, and project operations receive targeted training on identifying indicators of modern slavery and appropriate response protocols. All employees are made aware of our anti-slavery policy and the confidential reporting mechanisms available to them. We provide additional training for staff operating in or travelling to higher-risk jurisdictions, particularly those involved in feedstock sourcing and project site management in Southern Africa.

We train our staff to be vigilant for potential indicators of modern slavery, including but not limited to: Workers who appear to be under the control of others and are reluctant to interact with outsiders. Workers who are transported to and from the workplace and are never seen outside of work. Workers who appear fearful, withdrawn, or show signs of physical abuse. Evidence that workers are living in overcrowded, unsanitary, or degrading conditions. Workers who have had their identity documents confiscated. Workers who are paid below minimum wage or have unexplained deductions from their pay. Evidence that workers are required to pay recruitment fees or are subject to debt bondage. Children or young persons performing work that is inappropriate for their age.

If we identify or suspect an instance of modern slavery within our business or supply chain, we will: Take immediate steps to protect the welfare of the affected individuals, including liaising with appropriate authorities and support organisations. Investigate the matter thoroughly, engaging independent experts where necessary. Take appropriate action against any supplier or contractor found to be engaged in modern slavery practices, which may include termination of the business relationship. Report confirmed or suspected cases to the relevant law enforcement authorities in the appropriate jurisdiction. Review and strengthen our due diligence processes to prevent recurrence.

We assess the effectiveness of our anti-slavery measures through the following key performance indicators: The number and nature of reports received through our whistleblowing mechanism. The percentage of new suppliers that have undergone modern slavery due diligence assessments. The number of site audits and inspections conducted at key supply chain locations. Completion rates for modern slavery awareness training. The number of supply chain relationships reviewed or terminated due to modern slavery concerns. We review these indicators regularly and report findings to our Board of Directors.

We recognise that combating modern slavery requires collective action. We are committed to: Engaging with industry peers, trade associations, and multi-stakeholder initiatives focused on responsible sourcing in the critical minerals sector. Supporting transparency and traceability in mineral supply chains, consistent with the objectives of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Collaborating with our partners in South Africa, including engagement with government bodies such as the Industrial Development Corporation (IDC), to promote ethical labour practices in the mining sector.

This statement has been approved by the Board of Directors of Fodere Critical Minerals and will be reviewed and updated annually, or more frequently if circumstances require. This statement covers the financial year ending 2026 and is published in accordance with Section 54 of the UK Modern Slavery Act 2015.

If you have any questions about this statement, wish to report a concern, or require further information about our anti-slavery measures, please contact us: Fodere Critical Minerals 5 Approach Road, London SW20 8BA, United Kingdom Email: info@foderegroup.com Phone: +44 (0) 207 859 4161 To report a concern confidentially, please email info@foderegroup.com with the subject line "Modern Slavery Concern".