1. General Principles of SMM PricingMethodology

Shanghai Nonferrous Metal Network (hereinafter referred to as SMM) is a completely independent third-party service organization that does not participate in any substantive transactions. Instead, it maintains close communication with the buyer or seller of the transaction as a market observer or organizer, and provides the market with Related Services. SMM continuously formulates, reviews and revise its methodology through communication with industry insiders, adopting the most common product specifications, tradeterms and trade conditions in the industry. And pay equal attention to normal transactions that meet specifications and standards. SMM reserves the right to exclude from its price assessment any price data information deemed to be less reliable or non-representative.

SMM publishes metal spot prices (or indexes, etc., including the Chinese market or markets outside China) daily, which are often referred to as SMM prices. SMM has formulated corresponding methodology for the published SMM prices (all will be published on SMM's official website www.smm.cn for inquiry). The methodology stipulates the methods and procedures for the formation and publication of SMM prices, and strictly follows the methodologyprovisions to form and publish SMM prices.

In order tocomply with the actual situation of the spot market, SMM will make necessary revisions to the SMM price methodology and make an announcement on the SMM official website www.smm.cn, unless there are special circumstances, especially force majeure (natural disasters, wars, exchange bankruptcy) etc.) resulting in a shortened notice period. If you have any questions or suggestions about SMM prices and methodology, please contact SMM customer service

personnel (please check the contact information on the SMM official website www.smm.cn). Please read this paragraph in conjunction with the SMM Methodology Review and Change Policy, and the SMM Complaint Policy.

This document stipulates the standards and management methods for setting the spot price of SMM electro-depositednickel. The purpose of SMM in formulating this standard is to establish a transparent and verifiable SMM price setting mechanism and provide an important pricing indicator for market participants.

The SMM Benchmark Management Committee will also regularly review the methodology and its evaluation and release process. The committee maintains supervision of the SMM methodology and compilation process, and ensures that the price or index can reflect the objective conditions of the physical spot market of the relevant commodities as truly as possible. If the Committee believes that there are any problems, it will immediately point them out and propose external consultations and modifications to the methodologies or processes being implemented to improve the quality of prices or indices published by the SMM. The SMM Benchmark Management Committeecan only propose changes to the methodology and procedures used in future price or index assessments; it cannot change published prices or indices.

2. The Generation of SMM Electro-depositedNickelSpot Price

2.1 Definition

The SMM electro-depositednickelspot price is an indicative price generated and published by SMM according to this methodology and can be used by both parties to the transaction as a reference for electro-depositednickelspot trade settlement. This price reflects the indicative range of the warehouse self-pickup spot transaction price that is most likely to be transacted when the SMM electro-depositednickelspot price is released for each full working day. This price is based on the trading conditions in Shanghai on that day. On the basis of this price, other regions can adjust the actual settlement price at the time of transaction based on the market correlation between different regions.

2.2 Introduction to Formation Methods

SMM collects data information used to evaluate the spot price of electro-depositednickelthrough standard collection (that is, collecting raw data information that complies with SMM data standard policy). Including the non-transacted buyer and seller quotations on the day provided by the bidding unit (i.e. the data provider), the actual spot transaction price of the transaction provided by the bidding unit, etc., which can be included in the standard procurement quotation or transaction of electro-depositednickel transactions, etc. The quantity of each transaction is not less than 1 ton. The data collection and evaluation (calculation) of SMM electro-depositednickelspot prices, as well as daily management, are all completed by the SMM nickel business team (set up with three members, post A, post Band pricingmanager). The price of SMM is designed to reflect the true transaction level of a certain commodity at a certain time point or time period throughout the day. Therefore, when transactions, bids and offers based on the same specifications and the same shipping period are announced in the market at the same time, the transaction information is higher than the offer priceand bid information is more important. During the

evaluation process, we will also consider other factors, but the actual transaction (which takes precedence over bids and offers), bids and offers will always take priority.

2.3 Methods of Selecting Bids

Based on the agreement of the purchasing unit, SMM will send price analysts to the bidding unit regularly (between 9:30 and 10:15 a.m. GMT+8on each trading day) via phone, QQ, WeChat, fax and email. The contact person collects relevant data and information on the spot price of electro-depositednickel(price data submitted after 10:15 will not be used as the basis for the day's price assessment. Incomplete data that does not contain the minimum required information details will not be included for use and will be rejected even if it is submitted before the deadline.). The price data information can include the transaction price of the day, the most likely expected transaction price, offer, counter-offer, etc. All instant messages, email communications and records of any face-to-face communications will be archived; details of telephone communications will be summarized and entered into the database. The price data information must be typical and repeatable transactions between unrelated market participants (completely independent financially and legally). SMM Price Analysts are required to abide by the Code of Business Ethics when reporting to their supervisors any forced or threatened communications from market participants, or any inducement offer that attempts to influence the outcome of an assessment. The price data information provided by the bidding unit to SMM should at least include the following content. SMM's price analysts should encourage the bidding unit to submit as much relevant detailed information as possible, not just the minimum requirements specified.

2.4 Evaluation of Published Prices

Before 10:30 GMT+8 on each trading day, it is calculated by adding the corresponding premium and discount range to the real-time market price of the ShanghaiNickel main contractof the SHFEor the corresponding contract held by the purchasing unit for spot hedging. Preliminary spot price range. And because the price reported by SMM is defined as the indicative range of the self-pickup price of the spot warehouse (China Storage Dachang Warehouse) that is most likely to be transacted when the SMM electro-depositednickelspot price is released every full working day. When the spot warehouse's electro-depositednickelquotation sampling is insufficient, other delivery warehouses on the previous exchange (such as SIPG Logistics Warehouse, Shanghai Xinyi Warehouse, etc.) can be used as supplements. However, whether the quotation is adopted requires the approval of at least two bidding units.

SMM electro-depositednickelexists in the form of high and low ranges, which mainly reflects the quotations of electro-depositednickelfrom mainstream brands in Shanghai, including but not limited to HUAYOU brand, nickel plates produced by Zhongwei New Materials Co., Ltd., and GEM Co., Ltd. GEM brand nickel plate. However, due to the complex market quotations, there are large price differences between the same brands during some periods. SMM will comprehensively screen and verify the prices provided by market smelters and traders. SMM reserves the right to make decisions based on market conditions, such as market transactions,the right to make expert judgmentand other factors, the basis and reasons for the judgment will be recorded in writing.

2.5 Price Announcement

SMM will refer to thefollowing standards and regulations to form the SMM electro-depositednickel spot price, and publish it publicly on the SMM official website: www.metal.com;

Release time is 10:15-10:30 GMT+8 a.m.every working day (excluding Chinese statutory holidays and weekends);

The price cut-off point, that is, the 15-20 minutes between 10:15 a.m.GMT+8and the latest release time of 10:30 a.m.GMT+8is used to verify data and evaluate and calculate the final released electro-deposited nickelspot price;

The release time may also be affected by variousemergencies and force majeure factors, such as power outages and natural disasters. If this occurs, SMM will make every effort to publicly inform the market of the delayed price release time as early as possible. For details, please refer to the SMM Disaster Recovery Procedure.

2.6 Modify the Published Price

After the price is published, if an error is found, whether caused by incorrect operation or calculation error, SMM will quickly issue a correction announcement and modify the error. Please see SMM Valuation Correction Policy for details.

2.7 Pricing Unit and Expression Form

SMM electro-depositednickelmining standard product form and specifications: Standard product, SMM electro-depositednickel, complies with the national standard GB/T 6516-2010 Ni9996, in which the total content of nickel and cobalt is not less than 99.96%. Quotation unit: RMB/(physical) ton.

Reference trading volume: SMM defines a typical trading volume that reflects market circulation as greater than or equal to 1,000 kilograms per transaction.

Expression form: Presented in the form of range, tax-included price (including 13% value-added tax).

Delivery method: Same-day delivery, buyer picks up; transportation method is truck transportation;

Payment method: Bank cash transfer, received on the same day;

Delivery location: No. 310, Zhongchu Nanda Road, Shanghai, China. Other warehouses need to consider short-term transportation fee.

More relevant companies in the industry chain are welcome to participate and support SMM to better serve companies related to the nickel industry chain. If you have any questions, please give feedback to Fancy Li at +86-21-51595840 or email to fancyli@smm.cm