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HAYNES® Alloys

Human Rights Policy

Respect for Human Rights

Respect for human rights is a fundamental value of Haynes International, Inc. (“Haynes”). Many of the topics referenced herein are more completely addressed in separate policies.

We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights in our relationships with our employees, suppliers, customers and contractors. Our aim is to expand human rights within the communities in which we operate.

This Policy is guided by international human rights principles encompassed by the Universal Declaration of Human Rights, including those contained within the International Bill of Rights and the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

This policy applies to Haynes, each of its subsidiaries and affiliates and the facilities that we own, use and or manage. Haynes also expects all suppliers to uphold these principles and urges them to adopt similar policies within their own businesses.

We use due diligence as a means to identify and prevent human rights risks to people in our business and supply chain. Where we have identified adverse human rights impacts resulting from or caused by our business activities, we are committed to provide for, or cooperate in, their fair and equitable remediation. We seek to promote access to remediation where we are linked to or involved in those adverse impacts through our relationships with third parties.

As more specifically set forth below, it is our policy to protect minority groups’ rights and women’s rights (under the heading “Diversity and Inclusion”). In addition, we recognize rights to water as a fundamental human right (as more specifically described below under the heading “Land Rights and Water Resources”).

This Human Rights Policy is overseen by the Company’s Board of Directors, including the Chief Executive Officer.

Community and Stakeholder Engagement

We recognize that we are part of the communities in which we operate. We engage with communities on human rights matters that are important to them such as access to water and health. We also engage with people in those communities, including vulnerable and disadvantaged groups. Our aim is to ensure through dialogue that we are listening to, learning from and considering their views regarding policy and implementation as we conduct our business. We believe that local issues are most appropriately addressed at the local level.

We believe in investing time and money to support local not-for-profit organizations and communities where our employees, their families and our neighbors live. We understand that charitable, social service and educational entities count on partnerships with organizations such as ours, and we regularly participate in those partnerships.

We realize the efforts of those who are trying to improve inclusiveness, access to basic needs and educational opportunities improve the quality of life for everyone. In addition to monetary contributions, many of our employees volunteer their time to serve those in the community. Our company and our employees have a long history of being recognized for their support and contribution to community organizations.

Diversity and Inclusion

As demonstrated in our Code of Business Conduct and Ethics, as well as many other policies we have adopted, we value and advance the diversity and inclusion of the people with whom we work.

More specifically, as our policies and actions show, we are committed to equal opportunity and are intolerant of discrimination and harassment. We work to maintain workplaces that are free from discrimination or harassment on the basis of any minority group’s rights, including, without limitation, race, sex, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion or any other status protected by applicable law. The bases for recruitment, hiring, placement, development, training, compensation and advancement at Haynes are qualifications, performance, skills and experience.

We do not tolerate disrespectful or inappropriate behavior, unfair treatment or retaliation of any kind. Harassment is not tolerated in the workplace and in any work-related circumstance outside the workplace.

Freedom of Association and Collective Bargaining

We respect our employees’ right to join, form or not to join a labor union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. Haynes is committed to bargaining in good faith with such representatives.

Safe and Healthy Workplace

The safety and health of our employees is of paramount importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements. We work to provide and maintain a safe, healthy and productive workplace, in consultation with our employees, by addressing and remediating identified risks of accidents, injury and health impacts.

Workplace Security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.

Human Trafficking

In accordance with our Human Trafficking Policy and Disclosure Statement, we prohibit the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, illegal child labor, modern forms of slavery and any form of human trafficking, either by our own entities or anywhere in our supply chain.

Work Hours, Wages and Benefits

We compensate employees competitively relative to the industry and local labor market, and in accordance with terms of applicable collective bargaining agreements. We work to ensure full compliance with applicable wage, work hours, overtime and benefits laws.

Land Rights and Water Resources

We recognize the significant implications regarding respect for human rights that land use and water use across our supply chain may have. We respect the human need for sustainable water supplies, safe drinking water and protection of both ecosystems and communities through proper sanitation. We consult and partner with governments and communities where and when needed to protect water rights, and we have implemented source water protection plans at our facilities.

Guidance and Reporting for Employees

We strive to create workplaces in which open and honest communications among all employees are valued and respected. The Company is committed to comply with applicable labor and employment laws wherever we operate. The Company also ensures employees are aware of the Human Rights Policy through an annual certification process and online training.

Any employee who believes a conflict arises between the language of the policy and the laws, customs and practices of the place where he or she works, or who has questions about this policy or would like to confidentially report a potential violation of this policy, should raise those questions and concerns with local management, Human Resources or the Legal Department. Employees can also report suspected policy violations through EthicsPoint secured internet website at www.ethicspoint.com or by calling the appropriate toll-free number for their location, which can be found on the www.ethicspoint.com website. No reprisal or retaliatory action will be taken against any employee for raising concerns under this policy. The Company will investigate, address and respond to the concerns of employees and will take appropriate corrective action in response to any violation.

The Human Rights Policy is aligned with the Company’s Code of Business Conduct.

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