Anglo American PLC

Anglo American's commitment to work with stakeholders, including governments, is included in the Code of Conduct, Government Relations Handbook and the Social Way. [...] Within the Sustainable Mining Plan, the vision of our policy advocacy stretch goal is to take a lead on issues that affect our business in a way that is collaborative and aimed at society's wider goals. [...] In 2018, we launched our accountability forums, which bring together NGOs, government and other stakeholders to engage on topics that they believe are important for us to address and take action upon. [...] As part of our ongoing series of SDG accountability dialogues in the countries where we operate, in November 2022, we held a summit in South Africa focusing on SDG16: Peace, Justice and Strong Institutions. At the event, we consulted with external stakeholders – including local and national governments, NGOs, universities and other groups – about how we measure our contribution to the SDGs and to assess the potential for partnership. The SDG accountability dialogues help build a two-way accountability where we can share our opportunities for learning and collaboration with our stakeholders and hold each other accountable to targets and commitments.

Effective governance and engagement [...] The Board's Sustainability Committee is responsible for addressing the Group's most material sustainability issues – including climate-related topics. The Committee oversees, on behalf of the Board, material policies, processes and strategies designed to manage climate-related risks and opportunities. [...] The Audit Committee reviews the Group's material risks, including those related to climate change, twice a year. [...] The Remuneration Committee addresses climate-related issues when considering environmental and sustainability performance measures in relation to the Group's incentive plans. [...] At executive level, key management decisions are taken by the chief executive and his ELT, in accordance with their delegated authority. [...] Sustainability, including climate change, is fundamental to our ability to deliver on our strategic ambitions. As such, it is now embedded alongside our strategy function, under the leadership of Helena Nonka, strategy & sustainability director. [...] The ELT is held accountable for a range of measures including climate-related performance, which are then cascaded through the Group. In 2023, the ELT was supported by the Climate Change Steering Committee, chaired by the strategy & sustainability director, which draws together all workstreams across the Group related to climate change. [...] For senior leaders, a proportion of their variable pay each year is tied to the delivery of climate-related goals. This is predominantly incorporated into the performance measures through the Group Long Term Incentive Plan (LTIP). [...] Policy and advocacy approach [...] Though we continue to take a cautious approach to proactive lobbying, including on climate-related issues, we are committed to conduct any lobbying activities in line with the goals of the Paris Agreement. [...] In line with this approach, our intention is that the industry associations of which we are a member work on a similar basis and similarly advocate for policies that support the achievement of the goals of the Paris Agreement. [...] To bring greater definition to our approach to any climate-related advocacy to which we might be party, we maintain a list of public policy positions. These define Anglo American's thinking on specific climate-related policy issues and provide a basis against which we can test the alignment of any third-party advocacy. [...] Alignment of advocacy through industry associations [...] To mitigate this risk, we have rigorous internal governance procedures in respect of the management of the relationships with each of the industry associations of which we are a member. This governance is designed, in part, to ensure that misalignments in advocacy do not occur and, if they ever do, that appropriate action is taken. [...] Since 2021, we have also committed, to completing and disclosing an independent review of the alignment of our industry associations with our public policy positions every two years. The most recent review was published in 2023. The review was conducted using our updated public policy positions and demonstrated that, in the vast majority of cases, the industry associations of which we are a member are either aligned with our approach or do not take a position on climate change. [...] In a small number of cases, some potential misalignments were flagged and, in each of these cases, we have taken action with the relevant industry association. [...] The independent review sits alongside our annual disclosure of all associations of which we are a member, which is available on our website. This disclosure includes the rationale for our membership, any leadership positions we hold in each association and our associated financial contributions. [...] Alongside this information, we provide a dedicated email address for anyone wishing to ask questions, seek clarification or raise concerns about any of our memberships. Our aim through this disclosure is to be transparent in respect of our engagement with and through industry associations and to facilitate dialogue with any stakeholders with a particular interest in this subject.

The Board has supervision and direct oversight of the Group's strategy and risk management in relation to climate change and approved this report on 22 February 2023. [...] The Board's Sustainability Committee is responsible for addressing climate change-related topics. The Committee oversees, on behalf of the Board, material policies, processes and strategies designed to manage safety, health, environment, social and climate-related risks and opportunities. Matters relating to climate change are included in quarterly reports to the Committee, and as stand-alone items on the agenda where necessary. The chairman of the Sustainability Committee provides a summary of the Committee's discussions at the Board, which addresses the most material issues raised by the Committee. [...] To mitigate this risk, we have rigorous internal governance procedures in respect of the management of the relationships with each of the industry associations of which we are a member. This governance is designed, in part, to ensure that misalignments in advocacy do not occur and, if they ever do, that action is taken. We have also committed to completing and disclosing an independent review of the alignment of our industry associations with our public policy positions every two years. The most recent review and our response to its findings has been published alongside this report. The latest review was conducted using our updated public policy positions and demonstrated that in the vast majority of cases, the industry associations of which we are a member are either aligned with our approach or do not take a position on climate change. In a small number of cases, some potential misalignments have been flagged and in each of these cases, we have taken action with the relevant industry association.

We recognise that there is interest in our industry association memberships and the policy advocacy role that some play. Therefore, alongside constant monitoring, by each Anglo American employee who manages a relationship with an industry association, we remain committed to: 1) Annual disclosure of active memberships, committee positions and financial contributions on our website. – For more information: [Policy Advocacy | Anglo American.](https://www.angloamerican.com/sustainable-mining-plan/trusted-corporate-leader/policy-advocacy) 2) A biennial independent analysis of the alignment between Anglo American standards and policies and those of the industry associations of which we are a member. This report forms the Anglo American response to that independent analysis. [...] To mitigate this risk, we have rigorous internal governance procedures in respect of the management of the relationships with each of the industry associations of which we are a member. This governance is designed, in part, to ensure that misalignments in advocacy do not occur and, if they ever do, that action is taken. Clear guidance for colleagues on what escalation steps should be taken is included in the internal International Government and Sustainability Relations Policy. [...] In this regard, governance of our industry associations is built on three pillars: transparency, high standards, and clear accountability. [...] Each industry association has a designated Anglo American employee who acts as the relationship owner. The expectations of that relationship owner are set out in the internal Group International Government and Sustainability Relations Policy. These cover: - The expected level of due diligence with respect to the standards, policies and policy positions of the industry association before membership is entered into - Use of influence within the association to ensure that the association acts in a manner consistent with the Anglo American Code of Conduct, Business Integrity Policy and Group Antitrust Policy - Use of influence to seek to ensure that policy positions developed and used as a basis for influencing by the industry association are aligned with Anglo American's policy positions - Where alignment is not possible, to use influence to encourage the industry association to desist from lobbying on that issue. The policy sets out clearly the process for escalation if a misalignment between Anglo American standards or policy positions is identified. [...] The governance that we have in place should enable us to identify any activity by an industry association that might not be aligned with Anglo American's policies or practices. Specifically, each Anglo American employee with responsibility for the relationship with an industry association is reminded of their obligations with respect to monitoring the activities of the association. Formalised monitoring of our associations is represented by the biennial publication of this report and the annual disclosure of memberships. However, we recognise that other interested parties may identify issues of potential concern which the Anglo American relationship owner may not be aware of and, therefore, it is important that we provide others with the opportunity to raise concerns with us. To that end we have provided a channel, through the Anglo American website, for anyone to raise concerns or questions about our memberships, direct to the Anglo American Group International Government and Sustainability Relations team. Any Anglo American employee, contractor, supplier or any other stakeholder who wishes to raise an issue of concern confidentially, is additionally able to do so through the Anglo American "YourVoice" whistleblower service. – For more information: [www.yourvoice.angloamerican.com.](https://app.convercent.com/en-us/LandingPage/891d5ecc-bf20-e911-80e9-000d3ab6ebad/)

### 1. ABOUT THIS REPORT

##### Anglo American appointed ERM to conduct a desk-based Climate Change and Human Rights policy assessment of 131 industry associations that Anglo American is a member of. ERM evaluated the degree of alignment between Anglo American and the industry associations across eight Climate Change and eight Human Rights policy positions (i.e., policy spheres). This report outlines the evaluation findings from the review. This report also highlights the material differences noted between the policy positions of Anglo American and that of the industry associations. [...] ##### e) Is there evidence of Anglo American engaging with the industry association in relation to public advocacy?

The following criteria were utilised to categorise the degree of alignment of Anglo American's policy positions on Climate Change and Human Rights with the positions of the associations:

Classification Definition

1. Aligned Industry association position is aligned with Anglo American's position.

2. Some Industry association position is similar but not fully aligned with Anglo American's position, and/or the difference(s) position is silent on some element of Anglo American's position. Any differences are not considered material.

3. Material Industry association position is significantly different from (i.e., contrary to) Anglo American's position. difference(s) This includes where public statements have been made by senior representatives of the industry association that are significantly different from Anglo American's position.

4. No public position ERM found no public position on this topic.

Anglo American appointed ERM to conduct a desk-based Climate Change and Human Rights policy assessment of forty-four industry associations that Anglo American is a member of. ERM evaluated the degree of alignment between Anglo American and the industry associations across 10 Climate Change policy and 8 Human Rights policy positions. This report outlines the evaluation findings from the 2024 review, highlighting the material differences noted between the policy positions of Anglo American and that of the industry associations. [...] The assessment was guided by the criteria detailed below to evaluate and categorise the degree of alignment of Anglo American's policy positions with the positions of the associations: Classification Definition Aligned Industry association position is aligned with Anglo American's position. Some difference(s) Industry association position is similar but not fully aligned with Anglo American's position, and/or the position is silent on some element of Anglo American's position. Any differences are not considered material. Material difference(s) Industry association position is significantly different from (i.e., contrary to) Anglo American's position. This includes where public statements have been made by senior representatives of the industry association that are significantly different from Anglo American's position. No public position ERM found no public position on this topic.

Contributing our skills and knowledge to the development of responsible public policy

Effective public policy is essential for providing the right framework of drivers and incentives to encourage coordinated, efficient and equitable response measures by all stakeholders. Anglo American is committed to providing our expertise to assist governments and other stakeholders in developing such public policy and regulation. We will:

- Work with industry and regulatory authorities to contribute to the development and implementation of efficient, effective and equitable climate change policies and regulations.

- Advocate policy frameworks which support energy security and encourage research and investments in low carbon technology.

- Encourage co-ordination of a global carbon market and mechanisms which are supportive of low carbon technology and climate adaptation measures in developing nations.

## Monitoring and reporting:

Anglo American will continue to measure and report on our Group-wide direct, indirect and product-related emissions and will regularly update our Board, investors, host governments and other relevant stakeholders on our progress in reducing carbon emissions and energy consumption.

External assurance will be carried out on our Group reporting on our energy and carbon performance.

As a global leader in the mining industry, we are accountable to all of our stakeholders. We aim to be at the forefront of the pressing issues facing society today, ranging from climate change to public health. We are proud to be advocates for what we believe is right and to work as partners to solve complex problems through our public policy engagement. Our dealings with governments and parliaments revolve largely around the practical detail of obtaining and maintaining our licence to operate in line with our Code of Conduct but we will also express our opinion on questions around wider mining policy when called to do so. We will explain our position on ESG (environment, social, governance) issues in response to stakeholder interest and in support of our Sustainable Mining Plan. We believe we have a right and responsibility to speak up as an accountable member of society; at the same time, we are opposed to any system where corrupt business practices can result in unfair advantage. [...] That's why, we have a number of mechanisms in place to ensure that best practice is observed. We have a Government Relations country plan for each country where we operate which charts how we plan to engage the relevant politicians and civil servants. We do not make political donations so any funding request by or for Government is subject to particular scrutiny and the costs have to be strictly proportionate to what is to be delivered. We have a Business Integrity team and an independent Speak-Up system called "Your Voice" to catch and monitor any suspected contraventions. [...] We are careful about being party to lobbying. In 2019, 2021, 2023 and 2025 we reviewed any differences between our policy positions and those of the organisations of which we are a member, concentrating on the areas of climate change and human rights. We have also reported on the sums of money we would attribute as having been spent in support of a certain policy outcome, eg for giving hydrogen fuel-cell technology equal footing with battery electric in low-emission transport schemes. [...] Strong governance around our memberships is crucial to ensure that we maximise the mutual benefits of our engagement and minimise any risks. How Anglo American governs our memberships is outlined in the Code of Conduct, with more detail in the Group International and Government Relations Policy and the Group Business Integrity Policy. We are committed to being transparent about our memberships of industry associations and we publish on this page all relevant details of those memberships, including Anglo American's financial contribution to each association.

Anglo American applies a principled and consistent approach throughout our climate change governance and management systems. We embed our climate change principles in all aspects of our business to ensure that they remain aligned with our commitments and ambitions. [...] Any climate-related advocacy that we undertake or that is undertaken on our behalf through a third party, such as an industry association, should be in line with the letter and the spirit of these policy positions, and supportive of the goals of the Paris Agreement. We have implemented a model of governance over our advocacy based on transparency, high standards and clear accountability, to ensure that such advocacy is conducted in line with our intentions. [...] To this end, we publish on our website (www.angloamerican.com/sustainability/our-sustainable-mining-plan/political-transparency) the details of every industry association of which we are a member. We expect similar standards of behaviour from third parties as from our own workforce. We have clear guidance and escalation procedures in relation to any perceived or reported divergences from this approach, as well as what actions should be taken. In addition, we are committed to disclosing publicly a review of our industry associations every two years to test independently our own internal governance. [...] The latest independent assessment and our detailed response can be found at: www.angloamerican.com/industry-association-audit [...] At Anglo American, the Board's Sustainability Committee is responsible for addressing climate change related topics. The committee oversees, on behalf of the Board, material policies, processes and strategies designed to manage climate-related risks and opportunities. Matters relating to climate change are included in quarterly reports to the committee, and as stand-alone items on the agenda where necessary. The chair of the Sustainability Committee provides a summary of the committee's discussions at the Board, which addresses the most material issues raised by the committee. [...] Following the 2019 Board and committee effectiveness review, the Board agreed that climate change issues and the Group's carbon footprint would be a priority area of focus for the Board for 2020. Building on this, and taking into account discussions held by the Board and the Sustainability Committee in 2020, the Board agreed to direct its climate change focus in 2021 to the workstreams that underpin our carbon neutrality targets and devote more time to circular economy trends and the consequences for the Group's strategy. [...] The Sustainability Committee considers the Group's principal risks that fall within its oversight responsibility. In addition to the discussions at the Sustainability Committee, the Audit Committee reviews the Group's material risks, including those related to climate change, twice a year.

Climate-Related Governance

With delegated authority from the Anglo American plc Board, the Sustainability Committee, alongside the Group Executive Leadership Team (ELT) and Climate Change Committee (CCC) are responsible for the oversight of the Group's approach to climate change, including this Policy and its associated Standards. The Group Sustainability team has responsibility for day-to-day oversight of the implementation of this Policy and its associated Standards.

Climate Advocacy

The Group is committed to conducting any relevant lobbying activities in line with the goals of the Paris Agreement. This relates to direct engagement by those directly covered by this Policy as well as to any lobbying carried out on behalf of the Group by a third party, including industry associations of which the Group, or any of its controlled subsidiaries, is a member.

The Group's controls in respect of any government engagement and lobbying are set out in the **Group Government and International Relations Policy and the associated Government Relations Handbook. The Group's climate-related policy positions are set out in the Approach to Climate Advocacy guidance document. This guidance also includes the monitoring, evaluation and disclosure of the alignment of all industry associations of which the Group is a member to its climate change policy positions every two years.

We have also committed to completing and disclosing an independent review of the alignment of our industry associations with our public policy positions every two years. The 2022 review and our response to its findings have been published alongside this report. The latest review was conducted using our updated public policy positions and demonstrated that in the vast majority of cases, the industry associations of which we are a member are either aligned with our approach or do not take a position on climate change. In a small number of cases, some potential misalignments have been flagged and in each of these cases, we have taken action with the relevant industry association. [...] The independent review sits alongside our annual disclosure of all associations of which we are a member, which is available on our website. This disclosure includes the rationale for our membership, any leadership positions we hold in each association and our associated financial contributions. Alongside this information we provide a dedicated email address for anyone wishing to ask questions, seek clarification or raise concerns about any of our memberships. Our aim through this disclosure is to be transparent in respect of our engagement with and through industry associations and to facilitate dialogue with any stakeholders with a particular interest in this subject.

All Signatories are members of the Sea Cargo Charter Association, the governing body of the Sea Cargo Charter. The Steering Committee, composed of 14 committed Signatories, coordinates the Association and the Sea Cargo Charter on behalf of its members. [...] The Sea Cargo Charter sets a benchmark for what it means to be a responsible charterer. It also serves as an important tool to support decision-making as it establishes a common, global baseline to quantitatively assess and disclose the alignment of chartering activities with climate targets. Guided by four overall principles, Signatories to the Sea Cargo Charter comply with transparency requirements under a robust and industry-appropriate climate alignment assessment methodology and carefully considered accountability and enforcement requirements that support practical and robust data collection and analysis. [...] We will ensure ongoing compliance with the Sea Cargo Charter for new chartering activities through contractual means by using the Sea Cargo Charter Clause in charter parties. We will contribute to the update of the Sea Cargo Charter Clause through the annual review process. [...] On an annual basis, each Signatory will report the vessel category climate alignment scores and total annual activity climate alignment score of its chartering activities and supporting information, as per the Accountability requirements, to the Secretariat no later than April 30. This requirement takes effect for each Signatory in the calendar year after the calendar year in which it became a Signatory.

Industry associations of which we are a member are also required to align with our policy positions, or an equivalent approach [...] The Audit Committee reviews and monitors the effectiveness of the company's arrangement to counter the risk of bribery and corruption. The Audit Committee and executive leadership team is supported by the Group Compliance Committee in overseeing the implementation of an annual compliance management programme that supports building and sustaining a culture of compliance with business-integrity-related policy requirements. [...] Anglo American's commitment to collaborate with stakeholders, including governments, is included in the Code of Conduct, Government Relations Handbook, and the Social Way. Within the Sustainable Mining Plan, the vision of our policy advocacy stretch goal is to take a lead on issues that affect our business in a way that is collaborative and aimed at society's wider goals.

All Signatories are members of the Sea Cargo Charter Association, the governing body of the Sea Cargo Charter. The Steering Committee, composed of 15 committed Signatories, coordinates the Association and the Sea Cargo Charter on behalf of its members.

Anglo American is committed to conducting all lobbying in line with the goals of the Paris Agreement. This commitment has been clear since 2015 when we signed the Paris Pledge for Action. Our aim is to support the efforts of governments in meeting and exceeding their ambition to keep the world on a trajectory that limits global temperature rise to well-below 2°C and ideally to 1.5°C above pre-industrial averages.

Industry association memberships are important for Anglo American. They add real value to the company's understanding of and engagement in a wide range of issues, including in respect of policy advocacy. Many of the industry associations of which we are a member do not advocate and the majority do not have a position on climate-related policy. However, some are relevant when considering climate-related advocacy and we expect those Industry Associations to take the same approach as we do and ensure that their advocacy supports the goals of the Paris Agreement.

We have clear governance in place to ensure that industry associations remain aligned to our own policy positions on climate-related advocacy. In addition, we have committed to completing and disclosing an independent review of the alignment of our industry associations with our policy positions every two years. The independent review sits alongside our annual disclosure of all associations of which we are a member. This disclosure includes the rationale for our membership, any leadership positions we hold in each association and our associated financial contributions.

Climate change thinking is embedded across Anglo American through robust governance, led by the Board, ensuring consistent climate policy and transparent disclosures. We apply a principled and consistent approach throughout our climate change governance and management systems. We embed our climate change principles in all aspects of our business to ensure alignment with our commitments and ambitions: [...] Industry association audit carried out to ensure no misalignment of advocacy on climate change. [...] The Anglo American chairman and chief executive, and the Board's Sustainability Committee have reviewed this report, which has been approved by the Board. [...] At Anglo American, the Board's Sustainability Committee is responsible for addressing climate change related topics. The committee oversees, on behalf of the Board, material policies, processes and strategies designed to manage climate-related risks and opportunities. Matters relating to climate change are included in quarterly reports to the committee, and as stand-alone items on the agenda where necessary. The chair of the Sustainability Committee provides a summary of the committee's discussions at the Board, which addresses the most material issues raised by the committee. [...] The Sustainability Committee considers the Group's principal risks that fall within its oversight responsibility. In addition to the discussions at the Sustainability Committee, the Audit Committee reviews the Group's material risks, including those related to climate change, twice a year. [...] The GMC is supported by a Climate Change Steering Committee, which is chaired by the head of strategy and includes the head of carbon neutrality, the head of sustainable development, the head of international, government and sustainability relations, the executive head of PGMs marketing, and the head of the chief executive's office. The Steering Committee is responsible for driving the multiple workstreams of Anglo American's climate change work and reports regularly to the GMC. [...] We have implemented a model of governance over our advocacy based on transparency, high standards and clear accountability, to ensure that such advocacy is conducted in line with our intentions. To this end, we publish on our website (www.angloamerican.com/sustainability/our-sustainable-mining-plan/political-transparency) the details of every industry association of which we are a member. We expect similar standards of behaviour from third parties as from our own workforce. We have clear guidance and escalation procedures in relation to any perceived or reported divergences from this approach, as well as what actions should be taken. In addition, we are committed to disclosing publicly a review of our industry associations every two years to test independently our own internal governance.

Industry Associations: 2023 Review

Contents

03 Our approach to industry associations 04 Governance 07 Anglo American policy positions/statements 09 Summary findings and actions taken 11 Annex – our memberships

Anglo American Industry Associations 2

Our approach to industry associations

We take up memberships of, or participate in, industry associations where our involvement will bring value to our business or to the interests of our stakeholders, including investors.

Each industry association is different. Whether a thematic, sectoral or geographical mandate, each has its own origin and history, which form the basis on which their specific priorities and approach are built. As such, many industry associations were not established to advocate and have never played that role or, limit their advocacy to a narrow set of issues. As a consequence, those industry associations do not take public positions on key policy topics, such as climate change or human rights.

Other industry associations provide regular input into the policy making process, often representing a sector's specific interest. Bringing together diverse and varied views, as well as the huge expertise from their members, to help policymakers develop more informed policy. Doing so can often mean a position developed through compromise between the members or, advocating the view of the majority which may not always align fully with our own views. Nevertheless, we believe the contribution that industry associations make, co-ordinating, synthesising, and harmonising what would otherwise be a great variety of inputs, then acting as a sounding board for governments, testing ideas and seeking feedback, brings real value to the policymaking process.

We recognise that there is interest in our industry association memberships and the policy advocacy role that some play. Therefore, alongside constant monitoring, by each Anglo American employee who manages a relationship with an industry association, we remain committed to: 1) Annual disclosure of active memberships, committee positions and financial contributions on our website. – For more information:

Policy Advocacy | Anglo American.

2) A biennial independent analysis of the alignment between Anglo American standards and policies and those of the industry associations of which we are a member. This report forms the Anglo American response to that independent analysis.

This review

The independent nature of the underlying biennial analysis aligns with our commitment to governing our industry association memberships with transparency. This report is the third such review - the first having been published in 2019.

We made several changes to the assessment parameters compared with 2021: • Refined and updated our climate change policy positions to reflect the changing nature of the global debate on climate change • Refined positions on human rights • Provided an updated list of industry associations of which we are a member. Most notably, our exit from thermal coal operations has seen us ending our memberships of several organisations associated closely with thermal coal, including the World Coal Association.

Anglo American Industry Associations

The independent review assessed the eight climate policy positions and eight human rights policy positions for all the industry associations of which we are a member. That analysis identified a total of seven differences on climate change which the consultants considered 'material differences'. No such 'material differences' were identified on human rights. This demonstrates clearly that in the vast majority of cases, the industry associations of which we are a member are either aligned with our approach or do not take a position on some or all of the policy positions we have detailed with respect to climate change and human rights.

Following the identification of the material differences, we took the following actions: • Informed the relationship owner for each industry association of the highlighted material difference • Assessed what action should be taken, with the relationship owner • Engaged with the relevant industry associations.

Through this process we concluded that none of the 'material differences' highlighted should result in changes in the status of our membership with any of the organisations this year. Nevertheless, the substance of the analysis is a helpful input into our ongoing engagement with each association. Detail of each identified 'material difference' and our actions, is provided later in this report.

• A full independent analysis has been conducted by ERM. – For more information:

https://www.angloamerican.com industry-association-review-erm-2022.

In line with our commitment to complete this independent audit every two years, we intend to publish the next review of our industry associations in 2025.

3

Governance

We recognise stakeholder interest in advocacy undertaken by third parties on our behalf and the concern that some of that advocacy might not be aligned with our public policy positions on climate change.

At best, any such advocacy might be misaligned with the goals of the Paris Agreement, at worst it might suggest a third party is advocating against those goals. To mitigate this risk, we have rigorous internal governance procedures in respect of the management of the relationships with each of the industry associations of which we are a member. This governance is designed, in part, to ensure that misalignments in advocacy do not occur and, if they ever do, that action is taken. Clear guidance for colleagues on what escalation steps should be taken is included in the internal International Government and Sustainability Relations Policy.

Anglo American works hard to ensure that our voice is heard, and our views are reflected within industry associations, while being careful about being party to any lobbying. Nevertheless, we have, and continue to, strengthen our internal governance procedures including regular refreshment of compliance training for relevant staff across the Anglo American Group.

In this regard, governance of our industry associations is built on three pillars: transparency, high standards, and clear accountability.

Transparency

We are committed to being transparent about our memberships of industry associations and we publish all relevant details of the memberships we have on our website. Each entry explains why we are a member of that industry association, any positions of responsibility that Anglo American employees play in the association, and Anglo American's annual financial contribution. This disclosure allows any interested individual to scrutinise details of our memberships and raise any questions or concerns they might have. We also ensure adherence to all mandatory lobbying registers both directly as Anglo American and ensure any consultants working on our behalf do too.

With respect to financial contributions, in 2022, we made contributions totalling approximately US$21.5 million to all but two of our industry associations. The amount disclosed relates to membership fees and/or other payments to associations, including in respect of programmes run by the associations, apart from where reasons of commercial confidentiality require us to withhold disclosure. In addition, in 2022 our contributions to the marketing of diamonds through the Natural Diamond Council and platinum through the Platinum Guild International, totalled US$83 million.

Anglo American Industry Associations

High standards

We expect all our industry associations, as well as contractors, suppliers and agents, to act in a way which is consistent with the principles contained in Anglo American's Code of Conduct.

Our Business Integrity Policy also sets out the standards of conduct we expect of all our employees to help manage bribery and corruption risk. We expect our industry associations to follow comparable standards of conduct. Our full Business Integrity Policy is available. – For more information:

Group Business Integrity Policy – English (angloamerican.com)

Our intention is to ensure that there can be no scope for any perception that Anglo American is exercising improper influence through its memberships of industry associations.

Anglo American is also committed to being transparent about our political engagement and prohibit the making of donations for political purposes to any politician, political party or related organisation, or to any official of a political party or candidate for political office in any circumstances, either directly or through third parties, including industry associations. In this respect, we do not favour any political party, group or individual and expect the industry associations of which we are a member to act accordingly. This approach is detailed in Anglo American's Code of Conduct.

4

Clear accountability

Each industry association has a designated Anglo American employee who acts as the relationship owner. The expectations of that relationship owner are set out in the internal Group International Government and Sustainability Relations Policy.

These cover: • The expected level of due diligence with respect to the standards, policies and policy positions of the industry association before membership is entered into • Use of influence within the association to ensure that the association acts in a manner consistent with the Anglo American Code of Conduct, Business Integrity Policy and Group Antitrust Policy • Use of influence to seek to ensure that policy positions developed and used as a basis for influencing by the industry association are aligned with Anglo American's policy positions • Where alignment is not possible, to use influence to encourage the industry association to desist from lobbying on that issue.

The policy sets out clearly the process for escalation if a misalignment between Anglo American standards or policy positions is identified.

The process is as follows:

To engage directly with the industry association, up to and including senior leadership, as well as other members of the association to encourage corrective action.

Should no changes be agreed or made after an appropriate time, the misalignment should be escalated first to the Corporate Relations director of the relevant Anglo American Business Unit.

If the misalignment persists, the issue should be escalated to the Anglo American Group head of international government and sustainability relations, who may choose to make the Group Management Committee, including the Group chief executive, aware of the issue.

At each stage, all options for action will be explored, including formerly reviewing, suspending or terminating Anglo American's membership of the industry association.

Anglo American Industry Associations

Case study

Advocating to enhance the just energy transition in South Africa

During 2022, Anglo American senior executives and other leaders met with various stakeholders to support the delivery of our carbon neutrality strategy and our contribution towards supporting the just energy transition.

The centrepiece of this work focused on developing the regional renewable energy ecosystem (RREE) in South Africa. In support of the RREE, we regularly met with senior South African government officials, including the Presidency, the Presidential Climate Commission, the Department of Mineral Resources and Energy, the Department of Treasury and the Department of Public Enterprises.

We also met with institutions, including the Minerals Council of South Africa, the National Business Initiative (NBI), Business Unity South Africa (BUSA), the World Bank, and the African Union, in support of our progress towards our holistic suite of sustainability goals.

Thought leadership targeting key stakeholders at strategic fora, including the launch of our nuGen™ hydrogen haul truck prototype in South Africa, the Investing in African Mining Indaba, the South African Investment Conference, the Joburg Indaba, and COP27, constituted a consistent engagement drumbeat in support of our sustainability and broader strategic objectives.

5

Monitoring of industry association memberships

The governance that we have in place should enable us to identify any activity by an industry association that might not be aligned with Anglo American's policies or practices. Specifically, each Anglo American employee with responsibility for the relationship with an industry association is reminded of their obligations with respect to monitoring the activities of the association. Formalised monitoring of our associations is represented by the biennial publication of this report and the annual disclosure of memberships.

However, we recognise that other interested parties may identify issues of potential concern which the Anglo American relationship owner may not be aware of and, therefore, it is important that we provide others with the opportunity to raise concerns with us. To that end we have provided a channel, through the Anglo American website, for anyone to raise concerns or questions about our memberships, direct to the Anglo American Group International Government and Sustainability Relations team. Any Anglo American employee, contractor, supplier or any other stakeholder who wishes to raise an issue of concern confidentially, is additionally able to do so through the Anglo American "YourVoice" whistleblower service. – For more information:

www.yourvoice.angloamerican.com.

Emerging frameworks and expectations with respect to climate lobbying

In 2015, we demonstrated our commitment to the Paris Agreement through our signature of the Paris Pledge for Action. That pledge demonstrates our willingness to work to support efforts in meeting and exceeding the ambition of governments to keep the world on a trajectory that limits the global warming temperature rise to well below 2°C and where possible, 1.5°C below pre-industrial levels. This pledge continues to guide our position and as such, Anglo American remains committed to conduct lobbying in line with the goals of the Paris Agreement. Aligned with our approach to third party lobbying, our intention is that the industry associations of which are a member, also support this approach and advocate for policies that support the achievement of the Paris Agreement.

We are also mindful of emerging disclosure expectations through the forthcoming implementation of applicable and relevant frameworks such as the UK's Transition Plan and evolving standards, for example the International Sustainability Standards Board (ISSB) climate-related disclosures. Beyond mandatory disclosures alone, we also recognise the role of voluntary frameworks and standards in supporting the evolving interests and expectations of our stakeholders in understanding our thinking on both climate change and climate change lobbying. We have had a regular and constructive dialogue with the Climate Action 100+ group of investors for several years and value its perspectives. In 2020 and 2021, we worked with Climate Action 100+ to support the development of the Net Zero Company Benchmark and its application to the diversified mining sector, including Indicator 7 focused on climate policy engagement. Related to this, as part of our existing commitment to conduct lobbying in line with the goals of the Paris Agreement, we are also considering how more of the recommendations made by the Global Standard on Responsible Lobbying might be incorporated into our existing governance and transparency processes.

Anglo American Industry Associations

Case study

Driving the global hydrogen economy

Anglo American's PGMs business continued its work to encourage the advancement of the hydrogen economy around the world in 2022, working with governments and industry to make this key facilitator of net zero a reality.

In the U.S., we fed into the development of the Inflation Reduction Act and Infrastructure, Investment and Jobs Act through our membership of hydrogen trade associations, contributing to the inclusion of provisions to support hydrogen deployment. The significant momentum behind hydrogen was evidenced through the participation of the CEO of our PGMs business, Natascha Viljoen, in a Hydrogen Forward-Clean Air Task Force panel with Presidential Climate Envoy John Kerry at the Global Clean Energy Action Forum in September 2022.

Meanwhile, in the European Union (EU), we have established ourselves as a key player in the hydrogen ecosystem, building strong relationships within the broader sector and with policymakers. Our advocacy has contributed to the European Commission recognising the crucial role of mining to the low carbon economy, and hydrogen and fuel cell technologies becoming a central part of the EU's climate neutrality plans.

Underpinning our advocacy have been our own efforts to deploy hydrogen solutions, with the launch of our nuGen™ hydrogen mine haul truck, providing a real world example of the power of hydrogen to decarbonise the parts of the global economy that battery electrification will struggle to reach.

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Anglo American policy positions/statements

To bring greater definition to our approach to any climate-related advocacy that we might be party to, we maintain a list of public policy positions.

These define Anglo American's thinking on specific climate-related policy issues and provide a basis against which we can test the alignment of any third-party advocacy.

In 2022, we significantly updated our public policy positions and redefined them across eight issues. These revisions reflected developments in the public discourse, policy environment and societal expectations. The updated policy positions are listed in full below.

Climate change policy statements

The science

We support the mainstream climate science assessed by the Intergovernmental Panel on Climate Change (IPCC), which forms the foundation for our approach to climate change.

Paris Agreement/Scope 1 and 2

We support the Paris Climate Agreement and the subsequent Glasgow Climate Pact, in which governments aimed to limit the global temperature increase to 1.5°C. Achieving this aim requires significant reductions in carbon emissions by all, including businesses.

Scope 3

We recognise the role we have to play in stimulating decarbonisation in our value chain and thereby reducing our Scope 3 emissions, working with our supply chain and, crucially, our customers, to support their own decarbonisation efforts.

Offsetting

We support the principles of the mitigation hierarchy in considering emissions reductions. High-quality or high-integrity offsets should be utilised only after avoidance, reduction and restoration measures.

Carbon pricing/market mechanisms

We believe that carbon pricing has an important role to play in delivering a lower carbon world. We support the development of consistent carbon pricing policies across jurisdictions and the use of fair and well-designed market-based instruments to incentivise investment in low emission technologies.

Anglo American Industry Associations

Transparency/disclosure

We welcome increased transparency on climate reporting and climate advocacy. We support the development of well-designed Climate-Related Financial Disclosures, such as the Task Force on Climate-Related Disclosures (TCFD), and advocate for consistency across standards and metrics.

Adaptation

We recognise the impact of a changing climate. We acknowledge the importance of increased adaptation and resilience for both businesses and wider society.

Just Transition

We support an approach to climate transition which considers the societal impacts, aiming to ensure that that transition is 'just'.

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In addition to a focus on climate policy, our monitoring of industry associations has also focused considered human rights policy, reflecting Anglo American's strong commitment in this area. We have eight specific policy positions relating to human rights and we monitor to ensure no material differences exist in respect to advocacy by the industry associations of which we are a member.

Human rights

United Nations Guiding Principles

We fully commit to implementing the UN Guiding Principles (UNGP) on Business and Human Rights. Where we have caused or contributed to adverse human rights impacts, we believe in contributing to remediation as appropriate.

Labour and employee rights

As signatories to the United Nations Global Compact, we are committed to the labour rights principles set out in the International Labour Organization core conventions, including the right to freedom of association and collective bargaining, non-discrimination, and the eradication of child and forced labour. Observance of these rights is required of all our operations and suppliers, irrespective of location. We recognise our responsibility to ensure that within our collective supply chains the purchasing of goods and services is done without inadvertently exploiting human rights and is free of modern slavery. We are committed to ensuring that every employee earns a 'liveable' wage and want to be certain that this principle is applied to all our of employees in each of our locations. We have been an accredited Living Wage employer in the UK since 2014 through the Living Wage Foundation and have now secured a Living Wage accreditation with the Fair Wage Network.

Vulnerable groups

We pay special attention to the rights of vulnerable groups including indigenous Peoples, women, national or ethnic minorities, religious and linguistic minorities, children, persons with disabilities, and migrant workers and their families. We acknowledge the role of human rights defenders including through safeguarding human rights; the rule of law; and healthy, functioning markets. Underpinned by our Values and our Code of Conduct, we believe in the promotion of an inclusive environment where every colleague is valued and respected for who they are and has the opportunity to fulfil their potential. We support the need to set appropriate global goals for the diversity of gender and culture and ensure continuous improvement.

Community rights

The needs and concerns of all our stakeholders informs and guides our approach to doing business. We aim to make a lasting, positive contribution to the countries and communities in which we operate. We seek to create and maintain mutually beneficial relationships by understanding and maximising the positive influence we can have on local, regional and national development. Specifically in relation to community complaints and grievances, we ensure that our managed operations procedures align with the UNGP effectiveness criteria including communicating that the existence of complaints and grievance mechanisms do not preclude the right of stakeholders to engage in judicial or other legitimate processes.

Voluntary Principles on Security and Human Rights

Anglo American promotes the Voluntary Principles (VPs) on Security and Human Rights (VPSHR) at both international and local level. The company remains strongly committed to implementing the VPs and applies them in all relevant managed operations, recognising that our operations may be located where there are pre-existing, possibly violent, underlying or potential conflicts that can adversely affect local communities, Anglo American's employees' operations, and the relations between them.

Anglo American Industry Associations

Leverage

Anglo American is committed to promoting adherence to human rights within our own operations and encouraging adherence at independently managed joint ventures. Wherever possible we will work to encourage positive change through exercising our influence.

Free Prior and Informed Consent (FPIC)

Anglo American is committed to the International Council of Mining and Metals (ICMM) Position Statement on Indigenous Peoples. As such, our project approval processes require that Indigenous Peoples are: (i) able to freely make decisions without coercion, intimidation or manipulation; (ii) given sufficient time to be involved in project decision making before key decisions are made and impacts occur; and (iii) fully informed about the project and its potential impacts and benefits. The Anglo American Social Way 3.0 reaffirms our commitment and provides practical guidance on how to achieve FPIC.

Binding treaty

Anglo American remains committed to the implementation of the UNGPs (integrating human rights due diligence in our risk processes; training and awareness raising for our employees; and communicating, monitoring and reporting on our progress). In principle, we are supportive of mandatory human rights due diligence and will work to ensure the detail of those measures do not result in unconstructive, unintended consequences for rights holders or our business.

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Summary findings and actions taken

The independent assessment conducted by ERM, published alongside this report is a helpful contribution to our monitoring of the positions and actions of our industry associations.

The desk-based review drew on public information available between July and September 2022 to evaluate whether Anglo American's policy positions on climate change and human rights are aligned with, or contradictory to, the positions held by the associations evaluated.

The following section summarises the 'material differences' identified by ERM, our response to them, and resultant actions.

We also continue to monitor those organisations with which 'some differences' were identified and may choose to escalate engagement with certain groups should we deem it necessary.

Material differences

A significant majority of the industry associations assessed have no public position in relation to some or all of the Anglo American climate change and human rights policy positions (71% - climate change and 79% - human rights). This reaffirms the observation that there are different types of industry associations, many of which do not take public positions on issues, nor advocate with government or others.

As a result of the significant revisions made to our climate policy statements, a slight increase in the number of 'material differences' were identified when compared with the previous 2021 analysis.

The following criteria were used to categorise the degree of alignment:

CLASSIFICATION DEFINITION

1. Aligned 2. Some difference(s) 3. Material difference(s) Industry association position is aligned with Anglo American's position.

Industry association position is similar but not fully aligned with Anglo American's position, and/or the position is silent on some element of Anglo American's position. Any differences are not considered material.

Industry association position is significantly different from (i.e., contrary to) Anglo American's position. This includes where public statements have been made by senior representatives of the industry association that are significantly different from Anglo American's position.

4. No public positions ERM found no public position on this topic.

In seven cases (1%), ERM identified 'material differences' across seven industry associations:

POLICY AREA

Offsetting Carbon pricing/market mechanisms Transparency Just Transition Europe • Eurometaux Long-term position/legacy Australia • Queensland Resources Council (QRC) Policy design/approach South Africa and Europe • Business Leadership South Africa (BLSA) • Business Unity South Africa (BUSA) • Eurometaux Canada • Association for Mineral Exploration (AME) Australia • Queensland Resources Council (QRC)

DIFFERENCE TYPE REGION(S) INDUSTRY ASSOCIATION

Anglo American Industry Associations 9

Response and actions taken

Queensland Resources Council (QRC)

Material difference(s): • Just Transition • Carbon pricing: Long-term position/legacy The QRC represents minerals and oil and gas producing companies in Queensland, Australia.

ERM highlight the QRC's 2020 campaign - "Jobs first, Greens last" – as evidence of a position materially different to our own on a Just Transition. Detail on this campaign and the actions we took as a result, was covered in full in our 2021 Industry Association Review, as the campaign took place in between the conclusion of ERM's 2021 assessment, but before we had finalised our response. We believe that our approach was the correct one, which has led to a revised approach to political engagement by the QRC.

ERM's analysis also suggests a material difference between Anglo American's policy position on carbon pricing and the approach of the QRC. The analysis suggests that current positions held by the QRC on carbon pricing remain aligned to legacy public statements related to the historical introduction of regional carbon pricing mechanisms. The evaluation suggests that opposition statements on carbon pricing date back to early 2010s.

Based on the ERM analysis, we have looked carefully at this issue, and we do not believe that the perceived 'material difference' requires further action. This is based on our own assessment that the QRC's present advocacy is almost exclusively limited to the jurisdiction of Queensland. Although the state government announced a 2050 net zero target in 2021, which the QRC publicly supported, the Queensland government has no policy to place mandatory obligations on companies relating to carbon emissions. The QRC therefore does not play a significant role in, nor does Anglo American look to it for advocacy in, current debates related to market mechanisms that are taking place in the national parliament.

Whilst both the political campaigning and carbon pricing issues raised are legacy issues, which we were already aware of, it is helpful to have them highlighted in this way and to understand how the issues could be perceived. We remain committed to proactive engagement with the QRC to ensure ever closer alignment between our own policy positions and their advocacy activities. In this regard, we welcome the QRC's 2022 Energy and Climate Policy which both supports the Paris Agreement and its emissions reduction goals, and acknowledges the role the resource industry can play in helping meet the ambition.

Anglo American Industry Associations

As part of our ongoing engagement, we shared our revised climate change policy statements with the leadership of the QRC as well as the ERM analysis, highlighting the perceived misalignments.

Association of Mining and Exploration Companies (AME)

Material difference: • Transparency The AME represents the interests of the mineral exploration and development industry in British Columbia, Canada. Through our membership of the AME, Anglo American is able to access resources regarding government mineral exploration policy, advice on aboriginal relations as well as information and advice on health and safety best practice.

ERM's assessment has highlighted that the AME, whilst appreciative of the need for climate-related disclosures, considered the Canadian Securities Administrators (CSA) 51-107 – Disclosure of Climate-related Matters proposals as burdensome to industry. As such, ERM assessed this as being 'materially different' to our support for well-designed disclosure frameworks, and explicit formal support of the Task Force on Climate-Related Financial Disclosures (TCFD).

Through the relevant relationship manager, we engaged with the AME to explain our concerns and understand more fully the position they took in respect of climate-related disclosure. That engagement helped us to understand that the AME aligned itself with the response of the Prospectors and Developers Association of Canada (PDAC) to the consultation. The focus of much of PDAC's work is the support smaller, early-stage mineral exploration companies that may not have access to the same technical capabilities as larger businesses. As a consequence, their comments were not focused on opposing disclosure, but rather to ensure that there was space for reporting methodologies that were appropriate for smaller companies.

As a result of this dialogue, we are confident that no further action is required.

Carbon pricing

Several associations' positions on carbon pricing have been assessed as being 'materially different' to our own. In reviewing the perceived differences, as well as studying similar exercises conducted by other organisations, we recognised a particular challenge in this area - in effect, that it is easy to perceive advocacy against a specific carbon pricing mechanism as being advocacy against the concept of carbon pricing. Drawing a comparison with more general taxation, advocacy against a given tax policy would not be seen by most as advocacy against the concept of taxation. We believe strongly that the same approach must be considered and understood as carbon pricing becomes more common around the world. The challenge we face is understanding whether advocacy is indeed in favour of the concept but arguing against specific measures.

Against this backdrop, we believe that in the cases of Eurometaux, BUSA and BLSA, the perceived 'material difference' highlighted has, in fact, been focused on the way in which a carbon tax is being designed or applied in the respective jurisdictions and does not represent opposition to the application of carbon pricing as a matter of principle. In short, we believe that they are, therefore, aligned with our own policy position.

As such, while we will continue to engage with Eurometaux, BUSA and BLSA, including sharing our updated policy statements and associated expectations, we will not be taking any further action as a result of this review.

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Annex – our memberships

INDUSTRY ASSOCIATION

Natural Diamond Council

Platinum Guild International

World Platinum Investment Council

Minerals Council of South Africa Low Emission Technology Australia International Council on Mining and Metals - ICMM International Copper Association - ICA

Minerals Council of Australia

Nickel Institute

Queensland Resources Council - QRC

IHFCA (Preparatory)

Development Partner Institute Initiative for Responsible Mining Assurance - IRMA Consejo Minero Brazilian Mining Institute - IBRAM

Commercial and Industrial Association of Serro - ACIS

International Platinum Group Metals Association

Anglo American Industry Associations

REGION FEE (USD) WEBSITE

Global 44,376,000 https://www.naturaldiamonds.com/council/ Global 39,000,000 https://platinumguild.com/ Global 7,000,000 https://platinuminvestment.com/ South Africa 4,727,503 https://www.mineralscouncil.org.za/ Australia 1,449,553 www.letaustralia.com.au Global 1,321,481 https://www.icmm.com/ Global 1,000,000 https://copperalliance.org/ Australia 868, 9292 https://minerals.org.au/ Global 757,404 https://www.nickelinstitute.org/ Australia 521,178 https://www.qrc.org.au/ China 480,000 国(ih际fca氢.o能rg燃.cn料)电池协会 Global 250,000 http://www.dpimining.org/ Global 250,000 https://responsiblemining.net/ Chile 195,184 https://consejominero.cl/ Brazil 139,826 http://www.ibram.org.br/ Brazil 116,279 ahtstsposc://iawcwawo-.mcogm.georvc.biarl/instituicao_unidade/ Global 100,000 https://ipa-news.com/

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