AN ABS Group Company

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ABS Quality Evaluations AN ABS Group Company QE-OPS-888 Page 1 of 34 Rev 17 Jun 13, 2017 Audit Report No: QE-57220-2 / 12-S - ISO 14001: 2015 Organization: Corporación Aceros Arequipa SA Contact: Ms. Paola Corrales Phone: 51 1 517-1800 Email: [email protected] Rules):ISO 14001: 2015 Duration:6.5auditor day (s) Report date: 2020-Oct-19 Audit dates: 2020-out-12 - 2020-out-16 IAF / NACE code (s): 17 / 27.3 Total number of verified employees on site: approx. 1000 Member (s) of the Audit TeamÁrpád Koszka - (L), Edgar Llamoca - Paula Andrea Alvarez - Roberto Oliva Scope of Certification:Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rod, plates and tubes LAC (hot rolled) / LAF (cold rolled) and zinc plated, dimensioned steel, storage and marketing of steel products. Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rods, plates and tubes (hot rolled) / LAF (cold rolled) and zinc plated, dimensioned steel, storage and sale of steel products. Recommendation of the Audit Team: Surveillance: Keep going Still subject to Corrective Actions Certification Review Audit Results: Total number of Nonconformities: 0 No. of Major N / C's: 0 No. of Minor N / C's: 0 Only for Surveillance and Re-Certification Audits Yes Not Are there any repetitive / repeat non-conformities from previous audit (s)? Are there changes or recommendations for changes that affect the Scope of Certification? (if yes, complete the changes section on page 2) Start date End date Dates for the next audit 13-out-2021 17-out-2021 Acknowledgment of receipt of the audit report Final report Eraser A written audit report (draft or final) with a description of all non-conformities, opportunities for improvement and recommendation from the audit team was delivered to the organization at the closing meeting. Was this report recognized by the Organization? If the Final Report was not delivered to the client at the end of the audit, please indicate the date it was sent to the client: 19-Oct-2020 Attach or include with the Audit Report: Audit plan Audit Planning Form (Required for Surveillance, Renewal, Extension of Scope and Transfers)

Transcript of AN ABS Group Company

ABS Quality

Evaluations AN ABS Group Company

QE-OPS-888 Page 1 of 34 Rev 17 Jun 13, 2017

Audit Report No:

QE-57220-2 / 12-S - ISO 14001: 2015

Organization: Corporación Aceros Arequipa SA Contact: Ms. Paola Corrales Phone: 51 1 517-1800

Email: [email protected] Rules):ISO 14001: 2015 Duration:6.5auditor day (s) Report date: 2020-Oct-19 Audit dates: 2020-out-12 - 2020-out-16 IAF / NACE code (s): 17 / 27.3 Total number of verified employees on site: approx. 1000 Member (s) of the Audit TeamÁrpád Koszka - (L), Edgar Llamoca - Paula Andrea Alvarez - Roberto Oliva

Scope of Certification:Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rod, plates and tubes LAC (hot rolled) / LAF

(cold rolled) and zinc plated, dimensioned steel, storage and marketing of steel products.

Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rods, plates and tubes (hot rolled) / LAF (cold rolled) and zinc

plated, dimensioned steel, storage and sale of steel products.

Recommendation of the Audit Team:

Surveillance: Keep going Still subject to Corrective Actions Certification Review

Audit Results: Total number of Nonconformities:

0 No. of Major N / C's:

0 No. of Minor N / C's:

0

Only for Surveillance and Re-Certification Audits Yes Not

Are there any repetitive / repeat non-conformities from previous audit (s)?

Are there changes or recommendations for changes that affect the Scope of Certification? (if yes, complete the changes section on page 2)

Start date End date

Dates for the next audit 13-out-2021 17-out-2021

Acknowledgment of receipt of the audit report Final

report Eraser

A written audit report (draft or final) with a description of all non-conformities, opportunities for improvement and recommendation from the audit team was delivered to the organization at the closing meeting. Was this report recognized by the Organization?

If the Final Report was not delivered to the client at the end of the audit, please indicate the date it was sent to the client:

19-Oct-2020

Attach or include with the Audit Report:

• Audit plan

• Audit Planning Form (Required for Surveillance, Renewal, Extension of Scope and Transfers)

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Tell us your opinion - Please complete a short evaluation at http://www.abs-qe.com/survey/

Changes that affect the scope of Certification

Instructions: 1. The ABS QE Office should be contacted for approval prior to or during the audit. 2. For Scope Extensions please refer to Procedure QE-OPS-305. 3. Check the “Yes” box in the table on page 1 of this report to indicate identified changes.

Change in scope phrase Changes in the product line

Changing / adding / removing site (s) Increase / decrease in the number of employees

Others:

It is not necessary to contact the office in the following cases:

Increase or decrease in the surveillance interval

Modification of activities If the modification of activities affects other certificates, all the affected certificates must be listed in the Change Details section by Certificate Number.

Increase or decrease in the duration of the audit based on the historical performance of the client

Modification / Addition of NACE code

Change details: There are no changes

Conclusions of the audit team on the effectiveness of the management system:

Based on the results of the audit, the audit team determines that the management system was effectively implemented and maintained in accordance with defined requirements.

Based on the results of the audit, the audit team determines that the management system was effectively implemented and maintained in accordance with defined requirements, except as indicated in non-conformities.

Based on the results of the audit, the audit team determines that the management system was not effectively implemented and maintained in accordance with defined requirements. The audit team's recommendation is for "Certification Review"

Summary of the evidence related to:

• The ability of the management system to meet the applicable requirements and the expected results.

• Internal audit and management review processes

Auditor's conclusion statement: Based on the evidence obtained during this audit by the audit team, it is verified that the organization's management systems are in place and achieve their objectives. The level of maturity of the environmental management and the quality management system are strengths. An important observation is the quality of the organization's reaction to the COVID pandemic, which particularly impacted the countries of South America. Aceros Arequipa's actions and initiatives vis-à-vis its employees, families and society around the Pisco plant and other locations where it operates were examples of a company aware of its role in the social fabric in which it is inserted. Other strengths and areas for improvement are found in the corresponding fields of this report. The audit team recommends ABS-QE to maintain the certification of the audited environmental management system.

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For surveillance and renewal audits (delete for initial audits) Yes Not

The use of the logo (s) of the accrediting body (s) and the ABS trademark was in compliance with the Rules of Use of the Trademark established by ABS, QE, Inc.

(If the answer is "No", see comments in the "General Comments" section.)

Were there significant changes in the executive direction of the organization? (If the answer is "Yes", see comments in the "General Comments" section.)

¿Were there significant changes to the certified management system? (If the answer is "Yes", see comments in the "General Comments" section.)

General comments: 1. Overview

The audited organization has a rolled steel production plant from the recovery of metal scrap with an iron mining complement. The hot and cold rolling process produces wire rods, smooth and corrugated bars, as well as profiles of different natures and alloys, with the basic objective of feeding civil construction. In this area, the organization holds 35% of the market, becoming the most important player in Peru, with significant participation in neighboring markets (Bolivia, Ecuador, etc). As a result of the strategic planning process (which has been developing and improving since 2010), the organization already offers the market integrated solutions in dimensioned steels. Within this strategy, the organization decided to buy a structural tube manufacturing plant, based on coils, located in Callao. In addition to its plant located in the municipality of Pisco, on the South Pan-American Highway and its headquarters in Magdalena del Mar in Lima, the organization has distribution centers and scrap metal collection centers.

2. The environmental issue

The steelmaking and rolling production process is a great consumer of water and this characteristic is a vulnerability:

✓ The plant is implanted in a desert area; ✓ The water table in the region is highly exploited by local agriculture.

Furthermore, the difficulty for the destination of the plant's effluents (including household effluents) is another "handicap", given the plant's high population density. To face this situation, the organization's strategic plan foresees actions on two fronts:

✓ Enable the capture and treatment of seawater by reverse osmosis; ✓ Optimize the use of existing wastewater disposal alternatives and expand treatment capacity, with

the construction of a new treatment and reuse plant for treated water. In the corresponding field of this report you can find more information about the topic of finding solutions for the use of water in the plant. To demonstrate the strategic importance that Senior Management gives to the issue, the goal is to reduce the specific consumption of this input in the plant by 2030 to 1.28m³ / t of finished product (information that appears in the most recent Sustainability Report) , which is ambitious from all points of view. The activity carried out by the organization naturally generates industrial by-products in large quantities. For those, the organization seeks to obtain destinations compatible with the vision of sustainability that its other activities imply. Currently, there are two main options for those by-products: Steel concrete for ecogravel; Treatment for the recovery of zinc contained in steel mill dust.

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Both solutions are under study and tests to find out their technical and economic feasibility. The organization continues to monitor its other environmental impacts according to the guidelines defined in the PAMA (see specific table in this report). 3. The processes

The organization has been improving its approach by processes. All processes and sub-processes were drawn in flowcharts, with detailed information on risks, opportunities and controls necessary for each stage of each process, as applicable, which contributes to the definition of objectives and monitoring of their performance. With this, great progress was made to improve the annually repeated and refined strategic planning process, using the Balanced Scorecard methodology (internally BALSC). Audited Sites: «Callao -Av. Enrique Meiggs, 329 - Parque Internacional de Indústria y Comércio - Callao- -Perú - 24-0-Processes of storage, reception, dispatch, replenishment of finished products, coil cutting line, maintenance. Pisco -Carretera Panamericana Sur - Km 241 - Paracas - Ica - Pisco- -Perú - 841-0-Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rod, LAC (hot rolled) / LAF (cold rolled) and zinc plates, dimensioned steel, storage and distribution. Magdalena -Av. Antonio Miro Quesada, 425 - Floor 17 - Magdalena Del Mar - Lima- -Perú - 263-0-Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rod, LAC (hot rolled) / LAF (cold rolled) and zinc plates, dimensioned steel, storage and marketing of steel products. » IMPORTANT NOTE: This audit was carried out completely remotely, after the risk analysis for the use of ICT tools. The result of the risk assessment is attached to this report.

Turn Shift start time End time of shift

1 07am 03pm

two 03pm 11pm

3 11pm 07am

Audit for all shifts (Required for all standards) Yes Not

Were all shifts audited?

If all shifts were not audited, justify the reason why they were not all audited: This audit was carried out remotely for the reason of the pandemic and therefore the night shift was not audited.

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Audit Objectives Yes Not

Were the objectives defined in the audit plan achieved?

Concerned parties Yes Not

Has the organization determined the relevant stakeholders for the Management System?

Risks Yes Not

Has the organization determined the risks and opportunities that need to be addressed?

Legal and other requirements Yes Not

Has the organization identified the legal and other requirements that apply to it?

Management Review: Yes Not

Do the management reviews meet all the requirements of the Standard and is the management review process effectively implemented and maintained?

Internal audits Yes Not

Were the internal audits implemented effectively and in compliance with the requirements of the standard?

Corrective action Yes Not

Were the corrective actions effectively implemented and in compliance with the requirements of the standard?

Verification of corrective action (s) of the nonconformity (s) of the previous audit: The auditor should record the objective evidence (eg, additional samples taken) verified to demonstrate the effectiveness of the corrective action, as well as record the status of the prior nonconformity.

Audit. Not.

Clause Not.

Item Not.

Evidence of effective implementation (Indicate N / A if there was no N / C)

Not applicable

Corrective action (s) still in process for the Non-Conformity (s) No: zero Corrective action (s) NOT effective (s) for the Non-Conformity (s) No: zero Audited Processes / Functions:

Process (QMS): Strategic Management and System Management Strategic Management 9k / 14k / 45k: 4.1 - 4.2 - 4.3 - 4.4 - 5.1 - 5.3 - 6.1 - 6.2

Local: Magdalena (remote)

Performance Metrics: NA

Tickets: integrated policy, mission and values.

Departures: Identified context, interested parties, defined management system.

Documents / Records: those mentioned below

Interviewed people: Fernando Bustamante - Strategic Management Control Manager Paola Corrales - Head of Quality Management

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Fabrizio Salvatteci Merino - Strategic Planning Assistant Manager

Audit Notes: External and internal context The organization is in its tenth formal Strategic Management Cycle, which has been in place since 2010. Before, it carried out unsystematized exercises to establish its corporate Objectives. This system allows the identification and control of risks based on the characterization and knowledge of the changes in the external and internal contexts. Such a systematic is based on some tools such as:

✓ Balanced Scorecard; ✓ SWOT exercises; ✓ Risk analysis.

The methodology for this strategic planning consists of five stages (in the past there were three): ✓ Analysis of the plan; ✓ Establishment of priorities and goals (Objectives) ✓ Deployment ✓ Approval ✓ Control and follow up.

The cycle begins in May and ends in December. However, in 2020 this cycle is postponed for a few months, due to the pandemic. The main Objectives of the last cycle were (as explained, the new cycle is still in progress):

✓ Generate alignment of efforts; ✓ Strengthen the control of achievement of the Objectives; ✓ Allow performance evaluations (monitoring).

Strengths and weaknesses: ✓ High quality of service ✓ High coverage ✓ Brand preference ✓ Leadership position ✓ Employees' sense of pride ✓ Efficiency in the productive operation ✓ State-of-the-art production technology

Weaknesses: ✓ Ability to attract, retain and motivate staff ✓ Insufficient use of SAP ✓ High cost of sizing steel process ✓ Unused assets ✓ Lay-out of the Pisco plant

Risks evaluated as high and medium: ✓ Lost market share ✓ Unexpected equipment failures ✓ Variations in prices and raw materials ✓ Scrap price increase ✓ High dependence on BACO. ✓ Costs associated with regulatory compliance.

Opportunities ✓ Increase efficiency in the steelmaking and rolling processes ✓ Strengthen the commercial offer ✓ Improve scrap logistics

Guidelines:

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✓ Staff skills and attributes ✓ Increase value ✓ Increase profitability ✓ Greater growth than the market to sustain leadership> 30% participation.

The inputs of the market evaluations, SWOT analysis and other information generate a risk analysis, according to a methodology called GIRO - Risk and Opportunity Management. Currently, the evolution of 14 strategic risks is monitored, related to the four pillars of the BSC: Economical financial Focus on the customer Critical processes Learning and growth. The prioritized actions to meet the Strategic Objectives are broken down for the different managements and are transformed into Sector Objectives. Those are verified in each process owner. The controls of these sectorial plans and Objectives are made with the BALSC, which is an application that allows monitoring all the Objectives, plans and indicators. To ensure complete alignment between the Organization's Objectives with those of the collaborators, the SEVAD mechanism - Performance Evaluation System allows to follow the scope of the individual Objectives with those of the organization. Concerned parties The integrated management system manual Manual CGSG M001 rev 9 presents the seven Stakeholders identified by the organization, along with the main expectations determined, which are shown in the table below. That table had no significant changes since the last audit:

Stakeholders (interest groups)

Expectations

government Compliance with the applicable legal framework, regulations and Peruvian technical standards.

Media Information about improvements, innovations and good quality, environmental and occupational safety practices.

Customers

Fulfillment of your needs and expectations. That the company is recognized as environmentally responsible. Integrity of the collaborators.

Providers

Transparency in purchasing processes and long-term mutually beneficial relationships. Recognition as an environmental company responsable. Safe and healthy work environment to carry out your activities.

Collaborators

Recognition as a competitive company and professional development opportunity Recognition as an environmental company responsable Safe and healthy work environment Consultation and participation in the OSH System.

Shareholders Customer satisfaction Sustainable environmental management Integrity of the collaborators.

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Community

Sustainability of the company to generate employment, and economic benefit in related activities. Control of environmental impacts of operations. Control of the risks generated by the operation that have an external impact.

Management system The processes found in the organization during the last audit are still applicable, therefore, the Certification Cycle Matrix is not changed. The corporate application "Goldenbelt" continues to be the tool that describes the macro-processes, processes and sub-processes identified by the organization, including those dealing with issues such as environment and health / safety. Macro processes are equivalent to management system processes, but not all of those processes are in scope. The processes covered by the management systems follow the following: Strategic Processes

✓ Strategic management ✓ Integral Gestion of projects ✓ Social responsibility and sustainability

Core Processes (Steel Industry) ✓ Steelworks;

o MP classification; o Manufacture of lime; o Processing of Reprocessable Industrial Materials (MIR); o coal cleaning; o recovery of metallic iron;

✓ Lamination; ✓ Transformation of steel;

o Sizing; o Industrialization; o coil cutting; o tube forming;

✓ Sales management ✓ Production planning ✓ Programming and control of production ✓ Purchase management ✓ Scrap metal collection * ✓ Warehouse and distribution center management ✓ Marketing

Support Processes ✓ Human management ✓ Information Technology Management ✓ QA ✓ Maintenance

Control and compliance processes ✓ System management ✓ Environmental monitoring ✓ SSO control ✓ QA

o SSO o MA o Quality

Communication is diffuse among the various other control, support, core and strategic processes.

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The other processes that are not listed above are not part of the management system. The COVID issue affected the company. The reaction plan to this pandemic incorporated a Protocol that was of fundamental importance for the management of the situation, such as:

✓ reduction of 50% of capacity of ALL the points of concentration of people: o Dining rooms; o Transportation o Meeting rooms. o Control rooms.

✓ Rapid and collaborator sorology tests ✓ Review of activities.

As a consequence of these and other different measures, it was possible that only 5 deaths occurred within the universe of more than 1700 own employees (in addition to the contractors). Also as a consequence of the pandemic, it was decided to temporarily close the Trapiche Warehouse, which housed tubes and coils. No detours were found.

Process (QMS): Area / Function / Activity (EHS): Social Responsibility and Sustainability 14k / 45k: 5.1 - 5.2 - 7.4

Local: Pisco, Magdalena, Callao (remote)

Significant Aspects / Important Hazards: risks related to not meeting the Objectives of social responsibility projects; lack of updating of the communication media for different audiences.

Objectives / Goals: maintain a good relationship with stakeholders.

Documents / Records: those mentioned to follow

Interviewed people: José Castañeda - Social responsibility assistant manager Sergio Mija - Project Analyst

Audit Notes (including operational controls and monitoring / measurements - where applicable): The RSGP04 Stakeholder Relations process describes the system adopted by the organization to manage its image with its stakeholders. The organization defined different interest groups as:

✓ Collaborators ✓ Shareholders ✓ Customers ✓ government ✓ Suppliers and contractors ✓ Communities ✓ Society

Regarding communities and society, the organization maintains various support activities. Particularly in that pandemic period, the organization implemented some projects such as:

✓ Disinfection of cluster lanes with sodium hypochlorite solution; ✓ Psychological support for teachers of public schools in the region; ✓ Guidance for children and young people regarding hygiene versus prevention against Coronavirus.

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In addition to these specific projects that are temporary while the pandemic lasts, the organization maintains support programs for the communities, with the participation of its groups of volunteers, known as “Steel Volunteers”. This group of volunteers has been created to reinforce the Values of the organization:

✓ Teamwork ✓ Focus on what is relevant ✓ Passion for the work.

A “Bank of projects” has been defined, based on premises for the Sustainability Program, which are projects based on:

✓ Education; ✓ Environment ✓ Health.

Volunteers propose projects that are selected by an internal committee, using three criteria, that the project: ✓ Bring some idea of innovation; ✓ Use from recycled products ✓ Be in the area of influence of the organization.

Within these criteria, the projects were sampled:

✓ Clean beach (Pisco); ✓ Save the Hummingbirds (Pisco); ✓ Renovation of the soup kitchen of a school in Ventanilla (Callao).

All projects act with the participation of the local government, Civil Defense and some NGO, seeking to have deliverables that are not associated with welfare. The one published in 2019 deals particularly with the environmental issue and presents as a major corporate objective that of reducing greenhouse gas emissions by 3% by 2021, compared to the 2019 baseline. The organization also defined other longer goals term, with goals for 2030, of which the following are mentioned:

✓ lower water consumption to 1.28m³ / t of finished product; ✓ lower electricity consumption to 620 kWh / t of finished product; ✓ achieve 50% use of industrial by-products.

See ahead the strategies to achieve those goals.

Process (QMS): Area / Function / Activity (EHS): Environmental Control 14k6.1 - 6.2 - 8.1 - 9.1 Emergencies: scenarios and plans, reports of drills and real emergencies 14k: 8.2

Local: Pisco (remote)

Significant Aspects / Important Hazards: Emissions from the steel mill, effluents from wastewater treatment, generation of waste from the steel mill and rolling mill.

Objectives / Goals: maintain legal limits for emissions, lower the generation of industrial by-products and improve specific water consumption.

Documents / Records: those mentioned below

Interviewed people: Joshimar Zarate - Environment Supervisor

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Francisco Contreras - Environment Analyst Alexis Luján - Head of Environment Cristian Gomes Borjas - Environment Assistant

Audit Notes (including operational controls and monitoring / measurements - where applicable): Environment The Environment area carries out its SWOT exercise. Were sampled

Strengths

Progressive maturity of the Environmental Management System implemented and certified with ISO 14001: 2015.

Environmental management instruments formalized in all auditable units.

Progressive reduction of waste disposal through waste minimization and recovery alternatives.

Professionals from the environmental team who are responsible and committed to their work.

Have a monitoring program for environmental obligations that allows us to identify possible breaches and sensitize process owners about the applicable regulations for each activity.

Synergy with other areas for the implementation of solutions with an environmental approach related to Industrial Sub Products

Weaknesses

There are environmental risks that do not have 100% implemented controls.

Not having adequate use for the recovery of organic waste, disused wood and sludge from PTARDs.

Insufficient training and dissemination of the Environmental Emergency Response plan.

Little control of the environmental management of contractors and suppliers.

Increase in the volume of SPI's (Waste Material without a 100% recovery form).

The environmental risks have not been identified and evaluated in each of the stages of the product life cycle.

Opportunities

Implementation of strategies to reduce the corporate carbon footprint.

Improve the institutional image as a socially and environmentally responsible company.

Consolidate and expand the scope of the CAE program in all locations.

Develop an Awareness program aimed at Educational Institutions within the area of influence.

Implementation of the Sustainable Purchasing Program.

Threats

New environmental regulations with greater demand and supervision by government entities (new complaint and communication mechanisms, photo through app, inter-institutional agreements).

Delay in the approval of the Environmental Management Instruments for projects associated with environmental controls.

Proposal for the implementation of the carbon price by MINAM ($ 7.17 per T CO2e)

Greater restrictions on the consumption of natural resources that lead to social conflicts in the area of influence.

New environmental requirements by banks to finance projects of the organization.

Source: Record of Analysis of the Strategic Objectives of the Environmental Management System (2020). The main environmental aspects and their respective generated impacts were verified, all registered in the MA MA03MGR Entity V4. This matrix is focused on the major corporate aspects, with each production and support area maintaining its own matrices of environmental aspects.

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The matrices address the aspects from a product life cycle point of view, which for management purposes were identified as:

✓ Raw material ✓ Steel and Logistics ✓ Construction and manufacturing ✓ Use and reuse ✓ Recycling.

Waste The main aspects of the generation of industrial by-products (SPI) and the strategies to control their impacts were verified: Steel mill dust Lamella Ecogravel (slag). The amounts and generations were verified to find out the growth or decrease of liabilities, with the following information (values in kt):

SPI Amount on

Dec / 31/2019

Generation in 2020 (YTD)

Destination in 2020 (YTD)

Steel mill dust 114 1,234 -

Ecogravel 157 42.6 31.4

The lamella is sold. The destination possibilities are: For steel mill dust: recovery of zinc present in the mass, or geotechnical confinement; For ecogravel: use in steel concrete. For both products there are advanced studies. The "Report of the 2nd test of obtaining WAELL oxides from steel mill dust" was evidenced. Emissions to the atmosphere The main aspect of the steelworks is the generation of fumes with particulate material. The organization maintains monitoring of its chimney, with values between 12 and 20 mg / Nm³ of particulates in the emission. These values are well below the Peruvian regulations for PM, which is 100mg / Nm³. PAMA The organization's "8th monitoring and progress report on commitments" was evidenced, dated July 2020. From this document, item 1.7 of the chapter "Scheduling routine activities" was sampled. The Chapter “Environment Indicators - IMA) was also evaluated, with the sampling of environmental noise. All measurements below the limit of 80 dBA and 70 dBA respectively for day and night measurements for industrial zones. No detours were found.

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Process (QMS): Area / Function / Activity (EHS): Maintenance 9/14 / 45k: 6.1 - 6.2 - 7.1.3 - 7.1.4 - 7.1.5 - 8.1 - 9.1

Local: Pisco (remote)

Significant Aspects / Important Hazards: those mentioned

Objectives / Goals: those mentioned

Documents / Records:those mentioned

Interviewed people: Carlos Gomez - Lamination Maintenance Manager Javier Solorzano - Aceria Maintenance Manager Franklin Risco - Workshop Maintenance and Utilities Superintendent Alfredo Tovar - Head of Utilities and Auxiliary services Jorge Vargas - General Supervisor of Substations Eliseo Cancho - General Supervisor of Lamination Maintenance Planning Cesar Jimenez - Aceria and RD Programmer Juan Yeren - Lamination Maintenance Analyst Kenyo Najarro - Water and natural gas plant supervisor

Audit Notes (including operational controls and monitoring / measurements - where applicable): The various sub-processes that make up the Maintenance process were verified. The following were sampled: Maintenance Planning Identification of maintenance needs. Of these, the risks and controls established were evaluated. Ex: Notice not issued in a timely manner That they are created OM not necessary. Modification orders were verified such as: OM 6400009065 - Implementation of command air filters for the PR-3 lubrication center positioners. The risks for the Lamination Maintenance activities were verified in the labor risk matrix MNEM02-SO002 MGIR Mtto Lamination 27192.

✓ falling people - “considerable” risk; ✓ Entrapment by or between objects - “high” risk.

For risks considered high, supplementary controls are established. In the case above, controls such as: ✓ WWTP; ✓ ATS; ✓ PET.

Maintenance indicators were verified. The main ones are:

Indicator Goal

Availability 80%

cost $ 11.5 / t

Backlog 30 days

Backlog Notices Mtto 30 days

Accident rate 0

The numbers for 2020 are atypical, with variations due to the contingency plan to combat the Coronavirus pandemic.

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No detours were found

Process (QMS): Area / Function / Activity (EHS): Waste management Segregation, permits, destinations, temporary collection 14k: 8.1 - 8.2

Local: Pisco (remote)

Significant Aspects / Important Hazards: Soil pollution

Objectives / Goals: correct destination of waste

Documents / Records:the aforementioned.

Interviewed people: Alexis Luján - Head of Environment Francisco Contreras - Environment Analyst

Audit Notes (including operational controls and monitoring / measurements - where applicable): The area is responsible for the comprehensive management of solid waste produced at the plant, except for industrial by-products. In general, there are 110 waste collection points, but there are some that are collected "in situ". The collection process is outsourced. The waste is segregated from the source, and is transported to the central solid waste warehouse. It was verified that the state of this Collection Center is good, with correct segregation, cleanliness and organization. The main types of waste are:

✓ Usable waste (wood, paper, cardboard, plastic) ✓ Not usable (dangerous, not dangerous) ✓ Scrap Sweep ✓ Sludge

Except for usable waste, all waste is destined for a landfill, where hazardous waste is separated from non-hazardous waste. The document “Solid Waste Management and Minimization Plan” was verified, in its April 2020 version. This document controls the generation and intended quantities of waste of all the aforementioned types. Unusable waste is sent to the Tower & Tower supplier, who handles the aforementioned landfills. The dangerous shipments of the year 2020 were verified, as follows (values in t):

JAN FEB SEA APR MAI JUN JUL AUG SET

13.4 8.3 2.2 0 0 0 7.2 11.6 17.8

The Certificate of Treatment / Final Destination of Hazardous Waste 18853-2020 was sampled for waste "rags, land contaminated with HC, paints", issued by Tower & Tower, a company with DIGESA registration. The case of the wood stockpile was sampled, which had a liability of 400 t. A contract was established with a buyer and during 2020 429 tons were sold, significantly reducing liabilities (the generation of wood is usually 30t per month on average). No detours were found.

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Process (QMS): Area / Function / Activity (EHS): Effluent treatment, Oxidation lagoons, Physicochemical treatment 14k: 6.1 - 6.2 - 8.1 - 8.2 - 8.5 - 9.1

Local: Pisco (remote)

Significant Aspects / Important Hazards: soil contamination, contamination of groundwater tables and surface waters

Objectives / Goals: properly allocate effluents and sludge

Documents / Records: the aforementioned

Interviewed people: Alexis Luján - Head of Environment Cristian Gomes Borjas - Environment Assistant Alfredo Tovar - Head of Utilities and Auxiliary services Kenyo Najarro - Water and natural gas supervisor Jeaneth Condori - Head of the GIS

Audit Notes (including operational controls and monitoring / measurements - where applicable): One of the main strategic environmental objectives of the organization is the reduction of specific water consumption to a value of 1.28 m³ / t finished product. For that, the efforts of the organization to benefit the achievement of this objective were verified during that audit. The hydraulic mass flow chart of the Pisco plant was verified, showing the main consumers and destinations of the water flows, from their collection and treatment. Basically, there are two major effluent streams:

✓ Sanitary water (waste water from hygienic and domestic services) ✓ Industrial waters.

The former are treated in facultative lagoons, generating final effluent with a variable volume between 60 and 75 m³ / day. This effluent is used to maintain the living fence that surrounds the plant, which is approximately 6,300 meters long, and is part of an environmental control with several purposes:

✓ Promote biodiversity; ✓ Control the emission of dust; ✓ Control environmental noise.

The parameters that are controlled for this effluent are: ✓ pH ✓ Temperature ✓ BOD ✓ COD ✓ Coliforms ✓ Suspended solids.

All parameters comply with legal limits and are the subject of quarterly reports sent to MINAM. The other effluent flow is made up of the assembly of non-recoverable industrial flows (the flow chart shows two different circuits of reuse, recovery, before the final destination). This final flow, of the order of 50m³ / hour, is used for two main purposes:

✓ Scrap washing (some scrap shipments come with dirt and other dirt that could compromise the performance of the steel furnace);

✓ Control of dust from industrial by-products (in this case, ecogravel)

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The quality of this flow is such that it can be used for these applications, but it no longer meets the requirements for application in production processes, such that:

✓ Make-up of cooling towers; ✓ Refrigeration circuits.

No detours were found.

Process (QMS): Area / Function / Activity (EHS): Quality Management Internal audit and review by Management 9/14 / 45k: 9.2 - 9.3

Local: Magdalena (Remote)

Significant Aspects / Important Hazards: Not applicable

Objectives / Goals: meet the requirements of the standard

Documents / Records:the aforementioned

Interviewed people: Paola Corrales - Head of Quality Management Jeaneth Condori - Head of GIS

Audit Notes (including operational controls and monitoring / measurements - where applicable): Internal audits The organization maintains the description of the process in the flow chart GCGS01 - Audit management. The following documents were verified:

✓ GCGS01 E 004 Corporate Audit Program rev October 2020; ✓ GCGS01 E 005 Lima Audit Plan for 2020 - September 8 to 21 ✓ GCGS01 E 005 Pisco 2020 Audit Plan - September 1 to 15; ✓ GCGS E006 - Lima Audit Report ✓ GCGS E 006 Pisco audit report

In Lima, 17 non-conformities were detected, while in Pisco that number was 12. It should be noted that the Lima audit involves the Callao and Arequipa distribution centers. The audits were originally planned for May 2020, but were postponed to October as a result of the pandemic. The auditors' qualifications were also verified:

✓ Gabriel Matienzo ✓ Cesar Gomez ✓ Alfredo Tovar placeholder image

Who participated in the last audit. Review by Management The GCSG -IS005 rev 1 procedure defines the system for conducting the review by the Management. The model uses current business management meetings to incorporate the requirements of management review of the various standards. Table 4.1 of the procedure determines in which meetings the various topics are discussed. To follow, the various input elements and the forums where they are dealt with, with the frequency of addressing the subject:

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Input element

Management system

Forum Frequency Q MA SST

Associated

record

1. The status of actions from previous management reviews

x x x Defined forums

According to

occurrence and / or Annual

Minutes of meeting of

various forums

The changes in:

2. In external and internal matters that are pertinent to the SIG

Note: External and

internal factors that

are relevant to the

organization's

strategic purpose and

direction, which may

affect its ability to

achieve intended

results.

x x x Corporate Strategic Planning Meeting

Annual Minutes of the Corporate Strategic Planning meeting

3. The needs and expectations of interested parties, including legal and other requirements

x x Stakeholder mapping

Annual Mapping of

actors

4. Its significant environmental aspects;

x Environment Committee

According to

occurrence and / or Annual

Minutes of meeting of the Environment Committee

5. The risks and opportunities

x x Corporate Strategic Planning Meeting

Annual Minutes of the Corporate Strategic Planning meeting

Information on the performance and effectiveness of the quality management system, including trends regarding:

6. Customer satisfaction and feedback from

x Commercial Committee

Annual Minutes of the Commercial Committee

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relevant stakeholders;

7. The degree to which the Objectives have been achieved

x x x PES control and

monitoring meeting

Quarterly Minutes of the PES control and

monitoring meeting

8. The performance of processes and conformity of products and services.

Note: They are

defined in the

Objectives, indicators

and initiatives of

functional models of

each Management.

x x x PES control and

monitoring meeting

Quarterly Minutes of the PES control and

monitoring meeting

9. Nonconformities and corrective actions

x x x Quality Committees

According to the

frequency of each

committee

Quality Committee

Minutes

10. Monitoring and measurement results

Note: They are

defined in the

Objectives, indicators

and initiatives of

functional models of

each Management.

x x x PES control and

monitoring meeting

Quarterly Minutes of the PES control and

monitoring meeting

11. The results of the audits

x x x Quality Committees

According to audit program

Quality Committee

Minutes

12. Compliance with legal requirements

x x Quality Committees

According to audit program

Quality Committee

Minutes

13. External suppliers

Note: Supplier

performance

evaluation.

x Quality Committees: Supply Chain / Production

Annual Quality Committee

Minutes

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14. Results of consultation and participation

x OSH

Committee

Annual OSH Committee Minutes

15. Status of incident investigations

x OSH

committees

Monthly OSH Committee Minutes

16. The adequacy of resources

Note: Planning

and execution of

Management

Budgets.

x x x Meeting of budget

formulation

Annual Budget formulation

meeting minutes

17. The effectiveness of actions taken to address risks and opportunities

x Corporate Strategic Planning Meeting

Annual Minutes of the Corporate Strategic Planning meeting

18. Relevant stakeholder communications, including complaints

x x Quality Committees

According to

occurrence and / or Annual

Quality Committee

Minutes

19. Opportunities for improvement

x x x Forums According to

occurrence and / or Annual

Minutes of meeting of

various forums

The Quality and OSH Committees exist in Pisco and Lima, while the Environment Committee exists only in Pisco and the Commercial Committee exists only in Lima. The Lima Quality Committee includes the Supply Chain; Pisco's Quality Committee includes Production. All Committees are chaired by the different Managers who belong to the Senior Management.

Process (QMS): Area / Function / Activity (EHS): Quality Management 9/14 / 45k: 10.1 - 10.2 - 10.3

Local: Magdalena and Pisco (remote)

Significant Aspects / Important Hazards: does not apply

Objectives / Goals: keep the treatment of non-conformities under control

Documents / Records:the aforementioned

Interviewed people: Paola Corrales - Head of Quality Management Jeaneth Condori - Head of the GIS Cristina Valencia - Continuous improvement analyst Carlos Maicol Ponce - Head of Continuous Improvement

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Jesus Ayllon- Continuous Improvement Supervisor

Audit Notes (including operational controls and monitoring / measurements - where applicable): Corrective action The treatment given to the deviations identified by different sources was verified:

✓ Non-conformities in audits; ✓ Customer complaints; ✓ Goal deviations; ✓ Environmental issues; ✓ Accidents and incidents.

Several examples were sampled as follows:

# Description Correction Causes) Corrective actions Effectiveness

19BS1018 (SSO)

The SSO Objectives did not consider risks and opportunities, considering law 29783

Checklist to develop an action plan

The actions necessary to comply with the requirements of the law were not defined

Review the assignment of SSO Goals; Document the guidelines for setting the OHS Goals

okay

19BS1019 (SSO)

Not all requirements for accident analysis were met

Review and complete the information in the NC

There is a need to deepen knowledge of cause analysis techniques; need to deepen the application of the hierarchy of controls

Reinforce training and SSO management in accident investigation; coordinate development of guidelines for analysis and research; review the sub-process to include the determinations of the Standard

In progress

19IM824 (MA)

Chemical spill in pipe manufacturing plant

Cleaning the affected area

Lack of adequate anti-spill control

Buy anti-spill kit; have chemical products control sheet Training of the people involved.

okay

19AC926 (C)

Lack of evidence of induction of new collaborators

Regularize training log files

Difficulty of monitoring and control of inductions and respective records

Write instruction for induction; define companion CAASA guide for all new collaborators; video for general induction; update Candidate Profile

okay

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Continuous improvement The organization defined a team of 4 people who will be dedicated to formalizing the continuous improvement process, based on tools and programs that already exist, integrating them:

✓ Suggestion program ✓ Projects of the Progress Groups and Quality Circles ✓ 5S ✓ High Performance Teams

An example of the application of this new strategy was the development of a plan to reduce the number of customer complaints, using statistical techniques to identify the most effective focus of action. No detours were found.

Functions / Activities (for QMS / EHS): MANAGEMENT OF LEGAL REQUIREMENTS

Site: Pisco Headquarters (Remote)

Significant Aspects / Important Hazards: N / A

Objectives / Goals: N / A

Tickets: Legal requirements in MA and SST

Departures: Updated matrices and legal devices evaluated

Documents / Records:

Matrix of legal requirements in OSH

Matrix of legal requirements in MA

Legal requirements assessment reports

Monthly reports identifying legal requirements

PAMA compliance report

GIRO matrix

Interviewed:

Alexis Luján - Head of Environment

Joshimar Zárate - Environment Supervisor

Carlos Rodríguez - Deputy Manager of SSO

Paola Corrales - Head of Quality Management

Audit Notes (including operational controls and monitoring and measurements - where applicable).

Identification and evaluation of legal requirements

Process flow diagram OK

Law firm: García Sayán → Identification and monthly report of legal devices.

An internal technical evaluation is then made to see if the legal device is mandatory or informative

The evaluation is done every 2 years. But the update is permanent.

For the evaluation of Req. MA has a contract with the studio: Miranda and Amado.

For the evaluation of Req. SST has a contract with a specialist registered with MINTRA.

García Sayán Study Contract

Since 2013 → Update 2017

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Scope: Identification and Updating of legal matrices, on a monthly basis

Information received in the month of July → Email 24.08.2020

Differentiated matrices and legal regulations of the month are received.

Information received in the month of September → Email 12.10.2020

Scope of environmental evaluation services (Miranda and Amado): Revision and Evaluation of the matrix of

Req. Legal in MA.

- Laws and regulations

- Permissions and licences

- Orders

- Guides

- Treaties

- Protocols

- Environmental commitments

- Agreements with communities and stakeholders

- And other legal regulations applicable to our processes

Report: Executive summary: actions of 24.01 and 08.02.2019 (evaluation of the entire matrix)

95.3% compliance level for Req. Legal of MA.

They also evaluate compliance with the PAMA: 99.6%

Delivery of full report: 15.05.2019

They still have time to comply with the PAMA commitments until 2021.

CIRA: Certificate of Non-Existence of Archaeological Remains

Carbon Footprint Calculation (ISO 14064) →about 350,000 Ton CO2 Eq. (calculated in July 2020)

Initiative: Purchase of 4 electric cranes to replace 4 Diesel cranes in scrap yards.

Delivery of bicycles to people who live 5 km around the Callao warehouse.

GRI reports are made.

Topics of environmental interest: Waste, Effluents and Gases.

They are contemplating the concept of Circular Economy in the comprehensive service provided to the client

SST matrix evaluation → All the latest legal devices of the health emergency COVID 19 have been identified,

OK

They are around 94% compliant and the remaining 6% are still under evaluation.

A previous evaluation has been advanced that has been loaded directly into SUNAFIL

Check list of COVID-19 legal requirements →Directly on the SUNAFIL website. It has been met almost entirely.

It was filled in the month of July (31.07.20)

There was only one point that was considered partially compliant → Implementation of the plan, mental

health measures to maintain the appropriate work environment → Actions have been taken in this regard

and it is in process, OK

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There are no associated indicators to measure the performance of the legal requirements process. It will be

contemplated when you have the complete photograph.

Fines: On the security side, there have been no fines registered. Complaints have been followed, but it has

not reached that level. On the environmental side the same.

IPERC and AAS: The risks of administrative activities are considered.

PAMA: Report submitted to OEFA → July 2020 (semi-annual report)

Compliance with commitments. Until July 2021, all the commitments have to be implemented.

- According to this latest report, the% of implementation is 96.7%

- Dust from the steel smoke plant will be disposed of at the Bellavista farm with 20% progress. / in the

testing process.

- Implementation of a comprehensive system for the treatment of its domestic and industrial effluents

for subsequent reuse: Strengthening of the WWTP → 25% (project in tender) is projected to be

completed in May 2021

- Final disposal of steel mill dust → twenty%

Environmental monitoring

- Made by SGS: Results for the 1st quarter 2020. (Air quality, noise, emissions, effluents).

Process risks

- GIRO methodology: Risk and opportunity matrix management of SSOMA legal requirements

Risks:

1.- That economic losses are generated due to the application of penalties by not identifying or implementing

the requirements applicable to CAASA

2- That cost overruns are generated due to the incorrect implementation of the requirements.

Control: Hiring of law firms and specialist personnel to provide support in the identification and evaluation.

Together with in-house specialists at CAASA

The process was found to be compliant

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Move towards continuous improvement The organization's reaction to COVID, for employees, families and communities. Implementation of the Goldenbelt Continuous improvement team and integration of the different EAD programs, Suggestions, CAASA points. Improvement opportunities The organization could improve the presence of the environmental issue in the risks of product transport, scrap, etc. The organization could improve the system of obtaining data for its mass balance for the hydraulic circuit of the Pisco plant. The focus and determination of plans for the purpose of targeting industrial by-products could be improved.

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Performance Summary (Required for Surveillance and Renewal Audits) Review of historical audit performance: Assess the organization's ongoing compliance using:

• results of previous audits and comments reported

• history of compliance and control of non-conformity of the organization Record the results of your review below. This table is based on the review of the Historical Audit Matrix and previous audits:

The historical performance review and this audit indicate that the organization has:

Yes Not N / A

Action taken to effectively address all non-conformities previously issued by ABS QE? (There should be no repeating N / A trends.)

Effectively handled customer and other complaints? Identified legal and regulatory requirements?

Has the management system been consistently maintained and improved?

For any No - provide support information: There were no "No" answers. Management system effectiveness during the last 3 years: Record the results of the review here. (Detailed Comments Required for Re-Certification Audits

• results of previous audit reports including trends of non-conformities and comments over the last 3 years.

Consistency is verified in the evolution of the Objectives. The organization continues to improve its environmental management in parallel with the consolidated maturity of the quality management system. The organization recently outsourced its tube forming operation and maintains adequate controls of that operation. To face the pandemic, it implemented different prevention initiatives, in addition to foreseeing its Objectives and goals for the year, seeking to review the priority of the tasks, second possibilities due to the capacity cut in all the dependencies of its operating sites.

• the historical performance of the organization including objectives and goals during the last 3 years.

The organization consistently improves its Objectives and results, as a consequence of its consolidated strategic planning system. This audit was carried out completely remotely and was a follow-up, after the previous audit, which was recertification.

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Attendance Record Opening meeting: Date: 2020 Oct 12 Hour: 08:30 am Closing meeting: Date: 2020 Oct 16 Hour: 04:30 pm

NAME POSITION

PAOLA CORRALES HEAD OF QUALITY MANAGEMENT

ALFREDO TOVAR HEAD OF UTILITIES AND AUXILIARY SERVICES

FERNANDO BUSTAMANTE MANAGER OF STRATEGIC CONTROL OF GEST.

JUAN MANUEL OTOYA HUMAN MANAGEMENT MANAGER

IVAN BARRERA WAREHOUSES AND DIST CENTERS MANAGER

JORGE FIESTAS HEAD OF TRANSPORTATION

AUGUSTO CORNEJO CENTRAL PRODUCTION MANAGER

RICARDO FLORES DIRECT REDUCTION MANAGER

ALBERTO RAMOS HEAD OF PRODUCTION SCHEDULING

JEANETH CONDORI SIG PISCO CHIEF

CARLOS MAICOL PONCE REZZIO HEAD OF CONTINUOUS IMPROVEMENT

ALEXIS LUJAN HEAD OF ENVIRONMENT

J. GABRIEL SANDOVAL SOTO LAMINATION PROCESS CONTROL MANAGER

DIEGO ARROSPIDE BENAVIDES STRATEGIC PURCHASING MANAGER

RAFAEL CACERES IT MANAGER

GONZALO ARROSPIDE CORPORATE COMMERCIAL MANAGER

LENIN TAPIA PISCO WAREHOUSE MANAGER

CARLOS TITO HEAD OF PRODUCTION LAM IN TRAINING

RICARDO GUTIERREZ HEAD OF PRODUCT ENGINEERING AND METALOGRAPH

RICARDO GUZMAN ADMINISTRATION AND FINANCE MANAGER

GIOVANNI PALA INDUSTRIAL SALES MANAGER

JOSE CASTILLA REBATTA CHEMICAL LABORATORY CHIEF

ENZO E. ZAMBRANO GARCIA HEAD OF CREDITS AND COLLECTIONS

JORGE TERRONES HEAD OF NATIONAL METALLIC PURCHASES

TULIO SILGADO CONSIGLIERI GENERAL MANAGER

JENNIFER SOTOMAYOR HEAD OF OPERATIONS PLANNING

JORGE TORREBLANCA HEAD OF OPERATIONS WAREHOUSE

MICHAEL LECCA STEEL AND DIRECT REDUCTION MANAGER

MARIANA TALAVERA RUBINA SUPPLY CHAIN MANAGER

JORGE FERNANDEZ SIZED STEEL PLANT MANAGER

CARLOS AHOKI COMMERCIAL PLANNING MANAGER

GEAN FRANCO TORRES HEAD OF PLANT TUBES

OMAR BERROSPI HEAD OF SECURITY AND SO ALL PRESENT AT BOTH OPENING AND CLOSING MEETINGS

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Specific Information - EHS Programs Address and description of the audited site: The organization's production plant is located in the Ica region, near the city of Pisco, in a desert area. The land has space for the implantation of two rolling mills, a steel smelting plant in billets (provision for a second steelworks in progress), finished product warehouses, a dimensioned steel plant. There is also a large area reserved for receiving and storing the main raw materials, consisting of:

✓ Scrap; ✓ Iron ore; ✓ Lime.

The main environmental aspects are described in the table below. From the point of view of occupational safety, the activities offer risks related to accidents and occupational annoyances due to exposure to the following agents:

✓ Noise; ✓ Dust.

The main dangers are described below. Environmental Aspects / Significant Hazards:

Process / Activity / Operation Significant Hazards Environmental aspects

Steelmaking and lamination

Exposure to noise Energy consumption

Exposure to dust Gas consumption

Height Water consumption

Entrapments Soil contamination

Hot surfaces Atmospheric emissions

Slag generation

Effluent generation

Dimensioned Steel (ACEDIM) Entrapments Energy consumption

Sheet metal cutting

Exposure to noise Energy consumption

Entrapments Generation of metallic waste

Cut / contusion wounds

Tube manufacturing

Exposure to noise Energy consumption

Entrapments Generation of metallic waste

Cut / contusion wounds

EHS Complexity (Limited, Low, Medium or High): _HIGH

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Certification Cycle Audit Plan This form represents the plan for the three years of the certification cycle. All requirements of the standard must be covered within the three-year certification cycle. This plan should be updated after each audit based on the results of the audit and changes in the certified organization. All sites of a multi-site certificate must be identified (even if they are not sampled within the 3-year cycle)

Surveillance Clauses

A / R

6 12 18 24 30

R

EHS 2015 4.1 4.2 4.3 4.4 5.1 5.2 5.3 6.1 6.2 7.1 7.2 7.3 7.4 7.5 8.1 8.2 9.1 9.2 9.3

10.1

10.2

10.3

Cert Cycle Audit Plan Function / Process

Place an X to the requirement applicable to the site, department, function or process in the scope of the client

TO

R R R

Lim

a H

ead

qu

arte

rs

Strategic management

X X X X X X

TO

R R R

Integral Gestion of projects

X X

TO

R R

Social responsibility and sustainability

X

TO

R

TO

R

TO

R R R Purchase management

X X X X

TO

R

TO

R R R

CD

s

Warehouse and distribution center management

X X X X

TO

R R R

Pis

co P

lan

t

Scrap metal collection

X X X X

TO

R R

Planning and production control

X X X X

TO

R R R

Steel industry (Programming - Steelworks - Rolling mill - Alternative processes)

X X X X

TO

R R R

Steel transformation (Engineering - dimensioning - industrialization - coil cutting)

X X X X

TO

R R R Maintenance

X X X X

TO

R R Human management

X X X

TO

R

TO

R R R

System management (includes - SSO - MA - Quality Management)

X X X X X X X X X X X

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TO

R R

Cal

lao

Warehouse and distribution center management

X X X X X

TO

R R R Coil cutting

X X X X X X

TO

R R R Tube manufacturing

X X X X X X

X = Clause of the Standard that applies to this Function / Process A = Function / Process Audited in this visit and in this cycle. R = Recommended Function / Process to be audited Historical audit trail Instructions: This is a historical profile of the performance of the management system. For the current audit cycle, indicate in this table the clauses audited in each audit and the total number of non-conformities by clause.

ISO 14001

Shifts

4.1

4.2

4.3

4.4

5.1

5.2

5.3

6.1

6.2

7.1

7.2

7.3

7.4

7.5

8.1

8.2

9.1

9.2

9.3

10

.1

10

.2

10

.3

1 two 3

Phase 2

S6

S12 x x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

S18

S24

S30

RECERT. x x x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Total NC per clause 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Audited Shifts: All shifts must be audited in Phase 2 audits and Re-Certifications, and during the surveillance audit cycle -

Place an “X” in the applicable column to indicate the audited shift (s). Note: When all shifts are audited, emphasis should be placed on the manufacturing and / or service

provision processes.

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AUDIT PLAN QE 57220 2/12 S (14001: 2015)

Company Name: CORPORACIÓN ACEROS AREQUIPA SA Contact Person: Paola Corrales Telephone:51-1- 517-1800

Date of shipment of the plan to the client:

Sep 21 2020

Audit Dates: Oct 12-16, 2020 Duration of the Audit: 20.0 days-auditor

Rules): See above Total number of

Collaborators: To confirm

IAF / NACE code (s): 17-27.3 Auditor team: Árpád Koszka (L) Roberto Oliva Edgar Llamoca Paula A. Alvarez

Certification scopes: Design, development and production of steel billets, construction bars, hot rolled bars and profiles, cold rolled bars, wire rod, LAC (hot rolled) / LAF (cold rolled) and zinc plates, dimensioned steel, storage and marketing of steel products.

Objectives of the Audit: - Evaluate the organization's conformity to the requirements of the cited standards and documented

management systems; - Evaluate whether the organization's management systems comply with the applicable regulatory, legal

and contractual requirements; - Evaluate the capacity of the management systems to continuously meet the specified Objectives; - Identify potential areas for improvement.

Day Date AUDITORS, PROCESSES, SECTORS, REQUIREMENTS

Oct 12 ÁRPÁD KOSZKA EDGAR LLAMOCA ROBERTO OLIVA PAULA ALVAREZ

MAGDALENA (remote) PISCO PLANT (remote) MAGDALENA (remote)

8:00 - 8:30 FIRST CONTACTS TO FIND OUT QUALITY OF CONNECTION

8:30 - 9:00 OPENING MEETING

9:00 - 9:30

Strategic management 9k / 14k / 45k: 4.1 - 4.2 -

4.3 - 4.4 - 6.1 - 6.2

Production planning 9k: 6.1 - 6.2 - 8.1 - 9.1 Projects management

9k: 7.1.3

Marketing 9k: 5.1.2 - 6.1 - 6.2 –7.1.6 - 7.2 –– 9.1 9:30 - 10:00

10:00 - 10:30 Sales and Post-sale

Management 9k: 6.1 - 6.2 - 7.1.3 - 7.1.6 -

7.2 - 8.2

10:30 - 11:00

11:00 - 11:30 Programming and control of production

9k: 6.1 - 6.2 - 8.1 - 9.1 11:30 - 12:00

12:00 - 12:30

12:30 - 13:00 Lunch 13:00 - 13:30

13:30 - 14:00 Social Responsibility and Sustainability

14k / 45k: 5.1 - 5.2 - 7.4

Scrap reception, qualification and industrialization

9k / 14k: 6.1.2 - 8.1 - 8.2 - 9.1

18k: 4.3.1 - 4.4.6 - 4.4.7

Finished product warehouse

9k / 14k / 45k: 6.1 - 6.2 - 8.1 - 9.1

9k: 8.5; 14k / 45k: 8.2

IT management 9k: 7.1.3 - 7.1.4 - 9.1

14:00 - 14:30

14:30 - 15:00

15:00 - 15:30

15:30 - 16:00 Interview with Senior

Management Cap. 5 + 9.3 (*)

Accounting and financial management

9k: 6.1 - 6.2 - 7.1 - 8.1 - 8.5 - 9.1

16:00 - 16:30

16:30 - 17:00

17:00 - 17:30 VOID

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17:30 - 18:00

18:00 - 18:30

18:30 - 19:00

Day Date AUDITORS, PROCESSES, SECTORS, REQUIREMENTS

Oct 13

ÁRPÁD KOSZKA EDGAR LLAMOCA ROBERTO OLIVA PAULA ALVAREZ

PISCO PLANT (remote)

Oquendo / Huachipa (remote) AREQUIPA

(remote)

8:00 - 8:30 Review of the day before. Customer feedback 8:30 - 9:00

9:00 - 9:30 Environmental monitoring 14k6.1 - 6.2 - 8.1 - 9.1

Emergencies: scenarios and plans, reports of drills and

real emergencies 14k: 8.2

Steelworks 9/14 / 45k: 6.1 - 6.2 - 7.1.3 -

7.1.4 - 7.1.5 - 8.1 - 9.1 9k: 8.5; 14 / 45k: 8.2

Occupational health control Strategies, sampling plans,

results, actions 45k: 9.1

OQUENDO / HUACHIPA: Scrap metal collection

9/14 / 45k: 6.1 - 6.2 - 7.1.3 - 7.1.4 - 7.1.5 - 8.1 - 9.1 9k: 8.5; 14 / 45k: 8.2

9:30 - 10:00

10:00 - 10:30

10:30 - 11:00

11:00 - 11:30

11:30 - 12:00

12:00 - 12:30

12:30 - 13:00 Lunch 13:00 - 13:30

13:30 - 14:00

Maintenance 9/14 / 45k: 6.1 - 6.2 - 7.1.3 -

7.1.4 - 7.1.5 - 8.1 - 9.1 9k: 8.5

Hot Rolling 9/14 / 45k: 6.1 - 6.2 - 7.1.3 -

7.1.4 - 7.1.5 - 8.1 - 9.1 9k: 8.5; 14 / 45k: 8.2

Occupational health control Strategies, sampling plans,

results, actions 45k: 9.1

AREQUIPA: Warehouse management,

Transportation and CD 9k / 14k: 6.1 - 6.2 - 8.1 - 9.1

9k: 8.5; 14k: 8.2 18k: 4.3.1 - 4.4.6 - 4.4.7

14:00 - 14:30

14:30 - 15:00

15:00 - 15:30

15:30 - 16:00

16:00 - 16:30

16:30 - 17:00

17:00 - 17:30

VOID 17:30 - 18:00

18:00 - 18:30

18:30 - 19:00

Day Date AUDITORS, PROCESSES, SECTORS, REQUIREMENTS

Oct 14

ÁRPÁD KOSZKA EDGAR LLAMOCA ROBERTO OLIVA PAULA ALVAREZ

PISCO PLANT (remote)

) MAGDALENA - Tomorrow

(remote) CALLAO - Afternoon

(remote)

8:00 - 8:30 Review of the day before. Customer feedback 8:30 - 9:00

9:00 - 9:30

Waste management Segregation, permits,

destinations, temporary collection

14k: 8.1 - 8.2

Steel transformation: Sizing and industrialization

9k / 14k / 45k: 6.1 - 6.2 - 8.1 - 9.1

9k: 8.5; 14k / 45k: 8.2

Spare parts and supplies warehouse

9/14 / 45k: 6.1 - 6.2 - 8.1 - 9.1

9k: 8.5; 14 / 45k: 8.2

Strategic purchasing

9k: 8.4 14 / 45k: 8.1

9:30 - 10:00

10:00 - 10:30

10:30 - 11:00

11:00 - 11:30 Corporate purchases 9k: 8.4

14 / 45k: 8.1 11:30 - 12:00

12:00 - 12:30

12:30 - 13:00 Lunch

13:00 - 13:30

13:30 - 14:00

Effluent treatment Oxidation lagoons,

Physicochemical treatment 14k: 6.1 - 6.2 - 8.1 - 8.2 - 8.5

- 9.1

Kitchen and dining room 14 / 45k: 8.1 - 8.2

MA / SSO - Management of Legal Requirements

14k / 45k: 6.1.3 - 9.1.2 PAMA situation

Tube manufacturing 9/14 / 45k: 6.1 - 6.2 - 8.1 -

9.1 9k: 8.5; 14 / 45k: 8.2

14:00 - 14:30

14:30 - 15:00

15:00 - 15:30

15:30 - 16:00

16:00 - 16:30

16:30 - 17:00

ABS Quality

Evaluations AN ABS GROUP COMPANY

QE-OPS-888 Page 32 of 34 Rev 17 Jun 13, 2017

Day Date AUDITORS, PROCESSES, SECTORS, REQUIREMENTS

15 out ÁRPÁD KOSZKA EDGAR LLAMOCA ROBERTO OLIVA PAULA ALVAREZ

PISCO PLANT (remote) CALLAO (remote)

8:00 - 8:30 Review of the day before. Customer feedback 8:30 - 9:00

9:00 - 9:30

Quality management Internal audit and review

by Management 9/14 / 45k: 6.1 - 6.2 - 8.1 -

9.1- 9.2 - 9.3

QA 9k: 7.1.4 - 7.1.5 - 8.6 - 8.7 -

9.1.3

Human management 9/14 / 45k: 5.3 - 7.2 - 7.3

Coil cutting

9/14 / 45k: 6.1 - 6.2 - 8.1 - 9.1

9k: 8.5; 14 / 45k: 8.2

9:30 - 10:00

10:00 - 10:30

10:30 - 11:00

11:00 - 11:30

11:30 - 12:00

12:00 - 12:30

12:30 - 13:00 Lunch

13:00 - 13:30

13:30 - 14:00

Quality management 9/14 / 45k: 10.1 - 10.2 -

10.3

Health and Safety Control 45k: 9.1 - 10.2

Emergencies: scenarios and plans, reports of drills and real emergencies: 45k: 8.2

Quality management Documented information

9/14 / 45k: 7.5

Warehouse and distribution center

management 9/14 / 45k: 6.1 - 6.2 - 8.1 -

9.1 9k: 8.5; 14 / 45kk: 8.2

14:00 - 14:30

14:30 - 15:00

15:00 - 15:30

15:30 - 16:00

16:00 - 16:30

16:30 - 17:00

Day Date AUDITORS, PROCESSES, SECTORS, REQUIREMENTS

16 out ÁRPÁD KOSZKA EDGAR LLAMOCA ROBERTO OLIVA PAULA ALVAREZ

MAGDALENA (remote)

8:00 - 8:30 Review of the previous day Customer feedback 8:30 - 9:00

9:00 - 9:30

Latest pendencies, brand use verification, initial customer feedback 9:30 - 10:00

10:00 - 10:30

10:30 - 11:00

Individual report preparation 11:00 - 11:30

11:30 - 12:00

12:00 - 12:30

12:30 - 13:00 Lunch

13:00 - 13:30

13:30 - 14:00

Individual report preparation 14:00 - 14:30

14:30 - 15:00

15:00 - 15:30 Closure meeting

15:30 - 16:00

16:00 - 16:30 VOID

16:30 - 17:00

NOTE 1: The requirements of the Standards are indicated as applicable. NOTE 2: Knowledge of the Policy and Objectives and Goals will be verified in all sectors, as applicable. NOTE 3: The audit times consider possible inefficiencies of remote communication. Therefore, if communication is good, interviews can take less time. (*): depending on the availability of the Senior Management agenda, the schedule can be managed.

Remote Audit Utilizing ICT Planning and Risk Evaluation Record

ABS Quality

Evaluations AN ABS GROUP COMPANY

QE-OPS-888 Page 33 of 34 Rev 17 Jun 13, 2017

Certificate and Audit Number (s): QE 57220 2/12 S (14001: 2015)

Organization Name: CORPORACIÓN ACEROS AREQUIPA SA

Standard (s) in which ICT is being used: ISO 9001: 2015 - ISO 14001: 2015, ISO 45001: 2018

Sites and Process in which ICT will be used.

Location Functions / Processes in Which ICT is to be used

Magdalena Headquarters Context of the organization, Management review, internal audits, Non-conformities and corrective actions, Legal requirements, Human resources (competences, awareness, training, communication), occupational health, safety and environmental management

Pisco Plant Steelworks, rolling, drawing occupational health, safety and environmental operational control Monitoring, measurement, analysis and performance evaluation

Callao, Oquendo, Huachipa and Arequipa Distribution centers and Warehouses

Plate coil cutting, material reception, warehousing and distribution occupational health, safety and environmental operational control

Information and Communication Technology (ies) Risk Evaluation

Function and / or Process in Which ICT

Will be Used

ICT to be Utilized

Sites

Virtual (V) or Non-

Virtual (NV) Site

Risks related to ICT in achieving Audit Objective

Risk Level (High,

Medium, Low) *

Opportunities to Mitigate Identified ICT Risk

Context of the organization, Management review, internal audits, Non-conformities and corrective actions.

Microsoft Teams + Emails

and cellphone

V

Risk to authenticity and completeness of audit evidence

Low

Verifying evidence consistency with the provisions of the respective procedure. Checking shared digital records. Verifying records that bear signatures and dates. Checking with previous reports.

Access to previously released documents (audit reports)

Audit team has previously audited this company and all members are familiar with the Integrated Management System of the audited organization.

Risk of ability of technology to

sufficiently cover the scope and boundary of the area to

be audited

Low

The audited area is all in one place (industrial plant), all persons have access to ICT. Planning the audit in detail and in advance with the company verifying schedules of the people to be audited and verifying the operation of the ICT system.

Risk related to effective

functioning of Low

Training and prior tests of communication with the company, and the use of fixed and mobile video capability.

Legal requirements, Human resources (competences,

V

ABS Quality

Evaluations AN ABS GROUP COMPANY

QE-OPS-888 Page 34 of 34 Rev 17 Jun 13, 2017

awareness, training, communication),

the ICT platform (s)

Telephone calls and email exchange, for any connection problems. Monitoring,

measurement, analysis and performance evaluation

V

occupational health, safety and environmental operational control

Microsoft Teams, Emails,

cellphone, Mobile video

NV Medium

Steelworks, rolling, drawing occupational health, safety and environmental operational control

The Risk level is to represent the risk that the ICT represents to meeting the audit objectives for the function or areas being audited. Risk elements to be considered for each Information and Communication Technology to be used include, but are not limited to

✓ Risk to authenticity and completeness of audit evidence ✓ Risk of ability of technology to sufficiently cover the scope and boundary of the area to be audited ✓ Risk related to effective functioning of the ICT platform (s)

Comments: Note: As noted above Non Virtual sites generally require additional information and communication technologies beyond standard meeting telecommunication platforms to effectively achieve audit objectives.

Approval of ICT to be utilized for Non Virtual sites:

ORIGINAL FILE APPROVED BY FERNANDO PIMENTA - TECHNICAL MANAGER OF ABS-QE