Sims Ltd

###### REGULATIONS AND PUBLIC POLICY

As previously articulated, we recognise the significant shift in our external operating environment and increased stakeholder expectations, including those from government and regulatory authorities. In this regard, we view the efforts of government (and the private sector) to decarbonise and lower emissions as a significant opportunity for Sims.

Particularly relevant to Sims are cap and trade schemes, emission limits, as well as carbon-pricing mechanisms and taxes on GHG emissions. Sims supports the efforts endorsed by the European Council in December 2019 to make the EU climate neutral by 2050 and by the U.S. and Australia to achieve net zero greenhouse gas emissions by no later than 2050, in line with the Paris Agreement. Sims remains committed to curbing its own emissions.

###### Opportunities

As described under 'Climate Change' for Sims, a low-carbon transition is at the heart of our business strategy. As such, we see a significant upside in the current and proposed government policies which aim at transitioning to a low-carbon economy. As a leader in the metals recycling industry, we see ourselves as an indispensable part of the transition, and in furthering the circular-economy agenda, either through strategic industry associations or directly engaging with government where appropriate.

###### Threats

The potential threats arising from these changes or measures range between tactical challenges such as an increased cost of purchased energy, or capital costs needed for the electrification of equipment, or lower emissions equipment to, on a strategic front, potential restrictions to the export of our products which may came through waste management initiatives. Sims has not to date experienced any material negative impact related to these current or potential regulations but we continue to monitor, evaluate and engage with government and through industry associations to ensure we remain current and are able to respond to these changes with sufficient agility.

###### Risk appetite

Sims requires strict compliance with laws and regulations across our organisation including safety, trading, environment, and reporting to the public. While we target compliance, we simultaneously pursue clarity in environmental regulations and strive to ensure all players in the industry are held to the same environmental standards that we pursue.

We encourage regular community and bi-partisan political engagement efforts at a federal, state and local level to support the achievement of our purpose and vision. We discourage complacency in our processes and procedures that put us at risk of regulatory violations and potential litigation.

###### REGULATIONS AND PUBLIC POLICY (continued)

Our management response includes:

- Engaging through industry associations, business chambers, and directly with government where appropriate

- Annual review of industry association lobbying to monitor activity alignment with Sims' policy and position (particularly regarding climate change).

- Monitoring and scanning for changes in the policy and regulatory environment

- Engagement of specialised third-party advisory firms or individuals as required

- Government Engagement & Advocacy Policy to guide activities

- Rotating, regular internal Audit reviews of site compliance with key regulatory obligations

- Internal Controls Questionnaires to regularly assess and report on the status of key controls pertaining to areas of regulatory compliance across all our sites

- Annual Compliance training for all staff

- Whistleblower mechanisms in place to ensure any breaches of laws or regulation can be promptly and anonymously reported and recorded.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Sims commitments are outlined in our Climate & Energy policy. Day-to-day engagements are coordinated via either the Director, Community & Government and/or the Director, Sustainability & CSR. These Directors meet regularly with key stakeholders (such as Operational Executives) to review any advocacy or submissions that may be on the horizon relating to climate matters. These positions have executive reporting lines and report to the Board SHECS Committee and Risk Committee, which assist the board in its responsibilities in assessing risk and effectiveness of climate change engagements. Three is a formal approval process for public statements by Sims including the positions outlined above, the Director of Investor Relations, the Chief Risk & Compliance Officer and the Head of Communication & Marketing, and other executives as required. These executives are familiar with the policy and sustainability strategy.

Sims conducted a review of industry associations in FY22 to assess their alignment with our policy. The scope of the review was limited to industry associations held by entities within the Sims Operational Control boundary where the annual membership fee was AU$20,000 or higher. Where one or more of the below criteria were true, the industry association was deemed to be in scope of the review exercise. The industry association:
1. Engages in or contributes to the climate change discussion
2. Undertakes lobbying or direct climate advocacy of government or organisations
3. Has a public position on climate change OR could reasonably be expected to have one, given its scope of work.
4. A Sims employee has a position on the Board or climate- or environment-related committee of the industry association.

The assessment was carried out by the Sustainability team with input and review from Ethics & Compliance and Government, Stakeholder & Community Engagement functions. The review was carried out assessing sources including government submissions, media and social media commentary against the commitments in Sims Climate & Energy policy. We did not find evidence of material misalignment in any of our industry associations. Our intention is conduct the review every other year or when there is a significant change.