Contractor Site and Safety Rules

This is a non-binding English translation of the German-language "Fremdfirmenrichtlinie der PPM High Purity Metals GmbH" provided for convenience. In the event of any discrepancy, the German version is controlling.

1. Purpose, Scope and Relationship to the GTCP

These Contractor Site and Safety Rules govern the site-related safety, environmental, access, air cargo security and conduct requirements for contractors and their approved subcontractors, hereinafter jointly "Contractor", who carry out work on premises, at business locations or in administrative buildings of PPM High Purity Metals GmbH, hereinafter "PPM".

The general contractual rights and obligations arise from the order, PPM's General Terms and Conditions of Purchase, hereinafter "GTCP", and the other contract documents. These Rules supplement the GTCP for activities on the premises. In the event of contradictions, the order of precedence of contract documents set out in the GTCP and the precedence of specific safety provisions for activities on the premises apply.

The Contractor shall make these Rules accessible to all personnel deployed and approved subcontractors before work begins, and shall ensure compliance with it.

PPM may remove persons from the premises in the event of serious or repeated violations, immediate danger, or failure to comply with safety-related instructions. Further contractual and statutory rights remain unaffected.

2. Registration, Access and Presence on Site

2.1 Registration and Induction

• The commencement of work shall be announced to PPM's designated contact person in good time.
• Access is only via the designated entrances, following registration and collection.
• A site- and job-specific induction shall be carried out before work begins.
• The Contractor shall designate, before work begins, a supervisor with authority to issue instructions and their deputy. At least one of these persons must be on site or immediately reachable during the work and must be able to ensure safety-related communication with PPM at least in German or English. The Contractor shall ensure that PPM's instructions are conveyed to all deployed personnel promptly and comprehensibly.
• Irrespective of the contractual consent required under the GTCP, every person deployed for a subcontractor requires operational registration and access approval by PPM before first entering the premises. Unregistered persons will be refused access without exception.
• Employees may only remain in the areas approved for the assignment, access and breaks.

2.2 General Rules of Conduct

• Smoking is prohibited in production buildings.
• Eating and drinking are prohibited in production areas.
• Entering the premises under the influence of alcohol, drugs or other intoxicating substances, as well as bringing along or consuming such substances, is prohibited.
• No photographs or videos may be taken anywhere on the premises without the prior approval of PPM's management. This applies regardless of the device used, the purpose of the recording, and whether persons are identifiable. Audio recordings likewise require the prior approval of management. Any approval is limited to the purpose, area, period, group of persons and scope of recording specified therein. Recordings may only be made with approved devices and transmitted only to approved recipients.
• Mobile phones may not be used in areas marked accordingly.
• Escape and rescue routes, emergency exits, fire brigade access routes, traffic routes, switchgear, fittings and safety equipment shall be kept clear at all times.
• Identified hazards, damage, malfunctions or unsafe conditions shall be reported to PPM's contact person without undue delay.

2.3 Traffic on the Premises

• The provisions of the German Road Traffic Regulations (StVO) apply accordingly on the premises.
• The maximum speeds specified by signage shall be observed. Unless a lower speed is prescribed, the maximum speed is 20 km/h. In production, loading, pedestrian, gate and other areas with limited visibility, walking pace (max. 10 km/h) is mandatory.
• Vehicles may only be parked in designated areas and shall be secured against unintended movement.
• Industrial trucks and self-propelled work equipment may only be operated with PPM's consent and by persons who are competent and authorised to do so.
• Work on or affecting traffic routes, as well as transport operations affecting site traffic, shall be coordinated with PPM in advance. The Contractor shall provide any required barriers and traffic signs.
• High-visibility clothing shall be worn when working in traffic areas.

3. Air Cargo Security

3.1 General Requirements

PPM is integrated, at the business location approved for this purpose, as a Known Consignor into the secure supply chain for air cargo.

The Contractor and the personnel it deploys shall comply with all air cargo security-related instructions communicated to them. They may not take any action that could compromise the security status of an air cargo consignment or give rise to doubt as to its integrity.

The details of PPM's air cargo security programme do not form part of these publicly accessible Rules. They are communicated to affected persons only to the extent necessary, as part of the induction or a separate briefing.

PPM decides, based on the activity, area of deployment and possible access to identifiable air cargo, whether a special air cargo security-related briefing, training, vetting or escort is required before work begins. The Contractor may only deploy the person concerned once the requirements specified by PPM have been met and any required evidence has been submitted. Unescorted access to identifiable air cargo requires a valid official reliability check (Zuverlässigkeitsüberprüfung, ZÜP) pursuant to Sec. 7 of the German Aviation Security Act (LuftSiG).

A general external company induction does not replace any special air cargo security training or vetting required for the specific activity.

3.2 Access to Security-Relevant Areas

Security-relevant areas may only be entered if this is necessary for the assigned activity and approved by PPM. Persons without the approval or qualification required for unescorted access may only enter such areas accompanied by a person authorised to do so.

The Contractor shall ensure that its employees and subcontractors:

• use only approved access routes and paths;
• remain exclusively in approved areas;
• observe access restrictions, barriers and markings;
• do not allow other persons to enter with them;
• do not hold open or leave unsecured any doors, gates or other access points; and
• report suspicious persons or unexplained attempts to gain access without undue delay.

3.3 Protection of Identifiable Air Cargo

Goods, packaging, consignments or areas that are recognisable as air cargo, or that have been designated as such by PPM, may not be touched, opened, repacked, labelled, unlabelled, relocated, covered, left unattended and accessible, or otherwise altered without PPM's express approval.

Tools, spare parts, cleaning agents, packaging materials, waste, personal items or other foreign substances may not be placed on, in, or immediately next to identifiable air cargo. Activities in this area shall be carried out in a manner that avoids any manipulation, mix-up, contamination or impairment of product and packaging integrity.

Damage, opened or conspicuous packaging, unknown objects, tampered labelling and other irregularities shall be reported without undue delay. The affected consignment shall be left unaltered pending a decision by PPM, to the extent this does not pose an immediate danger.

The Contractor may not itself assess whether an air cargo consignment is still to be regarded as secure. This decision rests exclusively with the persons authorised to make it at PPM.

3.4 Activities in the Vicinity of Air Cargo

Work in areas where identifiable air cargo is produced, processed, packaged, stored or handed over requires prior coordination with PPM. This applies in particular to cleaning, maintenance, repair, construction, installation, pest control and disposal work, as well as work on doors, gates, windows, fencing, access, alarm, camera or IT systems, and work outside regular operating hours.

PPM may specify additional supervision, escort, control or documentation measures.

3.5 Security-Relevant Events

The following in particular shall be reported without undue delay:

• unauthorised or attempted access;
• loss or misuse of badges, keys or access media;
• damaged fencing, doors, gates, locks or access barriers;
• unattended, unknown or suspicious objects;
• suspicious behaviour;
• signs of tampering with goods, packaging or consignments;
• unintended access to security-relevant information;
• failure or impairment of security-relevant equipment; and
• any other deviation that could compromise the security of air cargo.

Unknown, suspicious or unattended objects may not be touched, opened or moved. The area shall be secured at a reasonable distance and PPM shall be informed without undue delay.

4. Protection of Information and Use of Devices

4.1 Protection of Business Information

PPM's information may only be made accessible to persons who need it to carry out the approved order. The Contractor shall strictly limit access, within its own organisation and among its subcontractors, to this group of persons.

The Contractor may take note of, use or record business information, documents, data or observations only to the extent absolutely necessary for the assigned activity.

Without prior approval from the PPM contact person authorised to grant it, the following in particular are prohibited:

• copying or taking away documents, plans, drawings, labels or shipping documents;
• recording screen contents, user interfaces, nameplates, batch markings or production data;
• documenting production, warehouse, laboratory, shipping or security facilities; or
• disclosing information about products, quantities, customers, shipping routes or security measures to third parties.

The strict management approval requirement under Clause 2.2 applies independently of the foregoing to photographs, videos and audio recordings.

The prohibition on transferring business documents to private or PPM-unapproved cloud, messaging, e-mail, translation or AI services applies in full. This also includes excerpts, screen captures, technical error messages, log files, source code, configurations, and information that is merely purportedly anonymised or pseudonymised.

Information that becomes known incidentally may not be used for other purposes or disclosed to third parties.

4.2 Documents and Data Carriers

PPM's documents and data carriers shall be protected against inspection, loss, damage and unauthorised removal. Printouts, notes or working copies that are no longer needed may not be disposed of with general waste. They shall be returned to PPM or securely destroyed as instructed by PPM.

Removing business documents or data from the premises requires PPM's prior approval.

4.3 IT, OT and Communication Devices

The Contractor's private or business computers, mobile devices, storage media, measuring equipment or other networkable devices may only be used to the extent necessary and approved by PPM.

Without PPM's prior approval, it is prohibited to:

• connect devices to PPM's networks, IT, OT, control or communication systems;
• connect USB sticks or other data carriers to PPM's systems;
• operate own Wi-Fi access points, routers, modems or radio networks;
• install software on PPM's systems;
• alter settings, protective mechanisms or logging;
• share or pass on access credentials; or
• transfer PPM's data to private or unapproved systems.

Access granted may only be used on a personal basis, for the agreed purpose and for the approved duration.

4.4 Information Security Incidents

Loss, misdirected transmission, unauthorised disclosure or unintended access to PPM's information shall be reported without undue delay. This applies in particular to lost or stolen devices and data carriers, accidentally sent files, suspected malware, unusual system messages, unauthorised access, compromised credentials, unintended system changes, and disruptions affecting operational or air cargo security-relevant processes.

The Contractor's own deletion, clean-up or recovery measures may only be carried out after coordination with PPM, unless immediate action is required to avert an immediate danger.

4.5 Marking and Disclosure

Markings relating to information protection and permissible disclosure shall be observed. Documents with a restricted circle of recipients may only be made accessible to expressly authorised persons. In case of doubt, a decision from PPM shall be obtained before use, storage, reproduction or disclosure.

5. Badges, Keys and Access Media

Badges, keys, transponders, cards or other access media issued by PPM:

• shall be used on a personal basis;
• may not be passed on or shared;
• shall be protected against unauthorised access;
• may not be copied or altered;
• may only be used for approved areas and times; and
• shall be returned without undue delay upon completion of the activity or on request.

Loss, damage, malfunction or suspected misuse shall be reported without undue delay. PPM may block or restrict access authorisations at any time for security reasons.

The Contractor shall ensure the return of all access media, documents, devices and other items belonging to PPM when a deployed person leaves or the deployment changes.

For access, security and emergency management purposes, PPM may document in particular name, company, contact person, time on site, work area and access media issued. The Contractor shall provide the required accurate information in good time and shall report changes without undue delay. The processing of personal data in connection with access, security and emergency management is governed by the respective current Privacy Policy of PPM High Purity Metals GmbH.

6. Preparation, Coordination and Approval of Work

6.1 Work Planning

Before work begins, the following in particular shall be submitted to PPM upon request:

• description of the activity, work area and period;
• responsible persons and contact details;
• number and qualification of the personnel deployed;
• work equipment, hazardous substances and particularly energy-intensive equipment;
• activity-related risk assessment;
• evidence of competence, inspection, preventive occupational healthcare and suitability;
• protective measures and personal protective equipment;
• intended subcontractors; and
• required work permits and authorisation certificates.

Changes, disruptions or deviations involving possible additional or mutual hazards shall be reported without undue delay. Affected work shall be safely suspended until coordination has taken place.

6.2 Coordination

PPM will appoint a coordinator where necessary. For construction projects, a health and safety coordinator will additionally be appointed where legally required. Coordination by PPM does not relieve the Contractor of its own responsibility, supervision and coordination duties.

Safety-related instructions from PPM's coordinator shall be followed. The Contractor remains responsible for proper execution and for its employees and subcontractors.

6.3 Work Permits

Prior approval or a permit is required in particular for:

• hot work;
• work in containers, confined spaces or gas-hazard areas;
• work on electrical, mechanical, hydraulic, pneumatic or media-carrying installations;
• interventions in fire detection, extinguishing, gas warning or safety equipment;
• earthworks, drilling, excavation, demolition and roof work;
• work involving risk of falling; and
• activities involving particular hazardous-substance, explosion or water-body risks.

The approval does not replace the risk assessment nor any statutory permits or qualifications.

6.4 Scope, Interruption and Handover

An approval applies exclusively to the designated work area, period, scope of activity and group of persons. Changes require renewed coordination and, where applicable, a new approval.

In the event of work interruptions, shift changes or a change of responsible persons, the work site, plant condition, approvals, residual hazards and protective measures shall be properly handed over. After a longer interruption or a material change, it shall be checked before resumption whether the approval remains valid.

Lone working is not permitted if the risk assessment does not ensure timely assistance, or if PPM requires a second person, a safety watch or supervision.

7. Qualification, Instruction and Preventive Occupational Healthcare

The Contractor may only deploy personnel who are sufficiently qualified, instructed and suitable. It shall:

• instruct its employees and subcontractors, before work begins, on matters specific to the job and the site;
• pass on PPM's instruction content in a comprehensible manner;
• ensure safe communication for personnel who do not speak the local language;
• arrange for required preventive occupational healthcare;
• document suitability, competence, assignment and instruction; and
• submit evidence upon justified request.

This applies in particular to respiratory protection, gas-hazard areas, risk of falling, electrical installations, industrial trucks, and possible exposure to arsenic, lead or other health-hazardous substances.

8. Personal Protective Equipment

The Contractor determines the personal protective equipment required on the basis of its risk assessment and PPM's specifications, provides it, and monitors its use.

In designated production areas, at least the safety footwear prescribed there (at least safety class S3), protective clothing, safety glasses and safety helmets shall be worn. Shorts, bare torsos and unsuitable clothing are not permitted.

Prescribed respiratory protection may only be used in accordance with the induction and by suitable, instructed persons.

9. Work Equipment, Installations and Energy Supply

9.1 Work Equipment

Work equipment, vehicles, scaffolding, ladders, machinery and devices must be suitable, safe, inspected in accordance with regulations, marked where necessary, and technically sound. Defective work equipment may not be used.

9.2 Work on Installations

Work on installations may only begin once all energy and material sources relevant to the activity have been identified, switched off, disconnected, secured against re-energisation or unintended release, marked, and checked for effectiveness.

Stored energy, pressure, vacuum, high or low temperatures, hazardous substances, process gases and product residues shall be eliminated, safely isolated or otherwise controlled by equivalent measures before work begins.

Where PPM has specified a lockout/tagout (LoTo) procedure with personalised locks for the relevant installation or activity, this procedure is mandatory. Personalised lockout devices may only be removed by the person who applied them. Recommissioning may only take place following coordination with, and approval by, PPM.

Faults, damage, leaks or unintended changes of state shall be reported without undue delay.

9.3 Utilities and Energy

The use of electricity, water, compressed air, gases, fuels or other utilities requires coordination with PPM. Energy and utilities shall be used economically and only as required for the job. Unnecessary idling, standby operation and losses shall be avoided. Particularly energy-intensive equipment shall be coordinated in advance. PPM may record consumption.

9.4 Work on Security-Relevant Facilities

Work on, or in the immediate vicinity of, access control systems, locking systems, fencing, doors, gates, alarm and intrusion detection systems, video surveillance systems, fire detection and extinguishing systems, communication and emergency call systems, IT and OT systems with a security function, and facilities for the monitoring or securing of air cargo, requires express prior approval by PPM.

Decommissioning, bypassing, test setups and restrictions must be coordinated and documented before they begin. Security-relevant facilities may not be left out of operation unattended.

Upon completion, proper function shall be verified together with PPM. Temporary access, test accounts, keys, codes and local configurations shall be returned, removed or blocked as instructed by PPM.

10. Utility Lines, Groundworks and Traffic Areas

Before earthworks, drilling, demolition or comparable work, information on existing or suspected utility lines and installations shall be obtained from PPM. Unclear circumstances shall be clarified in advance by suitable investigative measures coordinated with PPM.

If unknown lines or installations are encountered, work shall be stopped immediately, the location secured, and PPM informed.

Lines, fittings, manhole covers, markings and signage must remain accessible and may not be removed, relocated or covered without approval. Damage shall be reported without undue delay and remedied in coordination with PPM.

11. Hazardous Substances, Dangerous Goods and Environmental Protection

11.1 Bringing In and Use

Hazardous substances and dangerous goods may only be brought onto the premises with PPM's prior consent. Before work begins, in particular the product designation, quantity, current German-language safety data sheet, classification, intended use, exposure risks, storage, protective, emergency and disposal measures, and the result of any required substitution assessment shall be provided.

Hazardous substances shall generally be kept in properly labelled original containers. Deviating working containers must be suitable and labelled in compliance with the law. Storage is only permitted in approved, suitable areas. Water-hazardous substances shall be stored and used with a suitable containment facility.

11.2 Releases and Emissions

Releases into soil, groundwater, sewage systems and the environment shall be prevented. Activities shall be carried out with low emissions; avoidable dust, noise, odour and exhaust emissions shall be minimised.

Releases and environmentally relevant disruptions shall, to the extent this can be done safely, be stopped and contained without undue delay, and PPM shall be informed.

11.3 Exposure Register

To the extent a risk assessment does not exclude exposure to carcinogenic or germ-cell mutagenic substances of category 1A or 1B, the Contractor shall fulfil the statutory documentation and retention obligations, in particular with regard to the exposure register for its employees.

11.4 Contamination Control

Work equipment, devices, personal protective equipment, packaging and other items that have been used in areas with possible exposure to hazardous substances may only be removed from the work area or the premises after approval by PPM.

The Contractor shall strictly prevent the carry-over of hazardous substances into clean areas, vehicles, administrative rooms or public areas. Necessary cleaning, decontamination, packaging and disposal measures shall be agreed with PPM before work begins.

Contaminated work clothing or personal protective equipment may not be taken away for private cleaning.

12. Fire and Explosion Protection

Before work begins, the Contractor shall inform itself about alarm procedures, escape and rescue routes, assembly points, fire extinguishing equipment and site-specific fire protection requirements.

Hot work may only be carried out with a valid work permit and the specified protective measures. Required fire watches and suitable extinguishing agents shall be provided.

Fire loads shall be limited. Ignition sources and combustible substances shall be safely separated. Areas at risk of explosion may only be entered in accordance with markings and approval, and worked on using suitable equipment.

Impairment of fire compartments, seals, fire detection or extinguishing systems shall be coordinated in advance and properly remedied upon completion.

13. Risk of Falling, Scaffolding and Work Platforms

For work involving a risk of falling, technical protective measures shall take priority. Floor openings and edges with a risk of falling shall be secured by covers, side protection or barriers. If protective equipment is temporarily removed, the hazard area shall be barriered and secured to an equivalent standard.

Scaffolding may only be erected, inspected, approved, altered and dismantled by competent persons in accordance with regulations. The erector, permissible load and approval status shall be marked. Unapproved areas shall be closed off.

Shared use by PPM or other companies requires coordination. Each user shall inspect the scaffolding for obvious defects before use. Mobile elevating work platforms shall be used in accordance with the manufacturer's instructions; required documentation must be available at the place of use.

14. Containers, Confined Spaces and Gas-Hazard Areas

Work in containers, confined spaces or gas-hazard areas may only be carried out with special approval.

Before work begins, measurements, protective measures, approval conditions and monitoring measures shall be specified. Atmosphere testing may only be carried out by persons competent for this purpose, using suitable, properly inspected measuring equipment. Responsibility, measurement methods, measurement points, assessment criteria, documentation and repeat measurements shall be specified in the approval procedure.

Depending on the hazard, continuous measurement, technical ventilation, respiratory protection, safety watches, rescue equipment and a rescue concept shall in particular be provided. The Contractor shall ensure the required suitability, preventive occupational healthcare, instruction and competence requirements.

15. Construction Sites and Work Areas

Work and construction site areas shall be safely set up, marked, barriered and kept clean. Ongoing operations, traffic routes and the work of other companies may not be impermissibly impaired. Materials, containers, equipment and waste may only be placed in designated areas.

To the extent the German Ordinance on Construction Sites (Baustellenverordnung) applies, its requirements and the health and safety plan shall be complied with. Required planning information shall be submitted in good time.

PPM and appointed occupational safety personnel may enter work areas. Deficiencies shall be remedied without undue delay. In the event of immediate danger, work shall be stopped immediately.

Daily reports shall only be prepared if required by the order, service description or project agreement. Where required, they shall contain at least personnel and equipment deployed, work performed, incidents, hindrances and, for time-and-materials work, the hours worked.

16. Waste, Cleanliness and Completion of Work

Waste shall be avoided or minimised and, in accordance with PPM's specifications, separated and made available safely. Waste arising from the Contractor's own materials or work equipment remains its responsibility, unless otherwise agreed. It shall be suitably collected and properly disposed of. Evidence shall be submitted upon request.

Upon completion, work areas shall be handed over clean and safe, residual materials, waste, tools and equipment shall be removed, protective and safety equipment shall be restored, residual hazards and deviations shall be documented, and any required acceptances and returns shall be carried out.

17. Incidents, Emergencies and Reporting Obligations

Accidents, near misses, fires, releases of hazardous substances, environmental incidents, property damage, safety violations and hazardous conditions shall be reported to PPM without undue delay.

In the event of immediate danger, persons shall be warned, work shall be safely stopped and, to the extent this can be done safely, immediate measures shall be initiated.

In the event of actual or suspected exposure to hazardous substances, contaminated areas shall not be left without approval, to the extent this does not create additional danger. Carry-over shall be avoided. PPM's contact person shall be informed without undue delay, so that decontamination, medical and substance-related measures can be initiated based on the substance concerned.

Every injury, every suspected exposure to a hazardous substance and every instance of first aid administered shall be reported to PPM without undue delay and recorded in PPM's designated first-aid record (e.g. first-aid log book). This also applies to events that initially appear minor. Health-related information shall be treated as confidential and made accessible only to the persons authorised for this purpose.

If medical treatment is required due to the nature or extent of the injury, the operational emergency procedures and the requirements of the statutory accident insurance shall be observed. A referral to an accident insurance consultant physician (Durchgangsarzt/D-Arzt) is mandatory if the injury results in incapacity to work beyond the day of the accident, medical treatment is expected to last longer than one week, therapeutic remedies or assistive devices need to be prescribed, or there is a recurrence of illness due to the consequences of the accident.

17.1 Emergency Call

PPM emergency number: (0)-112

Question	Information
Where?	Exact location
What?	Accident or damage event
How many?	Number of injured or affected persons
What kind?	Type of injury or hazard
Wait	Wait for follow-up questions from the control centre

Nearest hospital / accident insurance consultant physician:

The responsible accident insurance consultant physician's practice or on-call service (Durchgangsarzt/D-Arzt), as well as the nearest hospital, must be obtained from the current operational emergency notice posted on site.

18. Documentation and Evidence

The Contractor shall keep required documents available on site or at short notice. These include, where applicable:

• risk assessments and operating instructions;
• evidence of instruction;
• evidence of competence, inspection, preventive occupational healthcare and suitability;
• safety data sheets;
• work permits and authorisation certificates;
• scaffolding and work equipment approvals;
• disposal records; and
• statutorily required social-security- or occupational-safety-related evidence.

General employment-, social-security-, minimum-wage- and subcontractor-related contractual obligations, including indemnification, are governed by the GTCP. These Rules additionally govern only the operational evidence required before work begins or during deployment.

19. Final Provisions

These Rules supplement the GTCP and the order-specific contract documents. They do not replace the Contractor's statutory obligations, nor its own risk assessment, supervision and responsibility.

Security-relevant details, in particular from the air cargo security programme, are passed on to authorised persons only to the extent necessary and shall be protected in accordance with their classification.