RBA 2025 Annual Report

2 0 2 5 ANNUAL R E P O R T

2025 ANNUAL REPORT

TABLE OF CONTENTS Message from the CEO............................................................................... 1 Responsible Minerals Initiative.................................................................. 2 Responsible Labor Initiative ................................................................... 14 Responsible Factory Initiative ................................................................. 18 Responsible Environment Initiative........................................................ 20 Responsible Glove Alliance..................................................................... 26 Public Policy.............................................................................................. 27 Advisory Services .................................................................................... 29 Training and Capability-Building............................................................. 30 RBA Meetings and Events ....................................................................... 31 RBA on the Move ..................................................................................... 38 Supply Chain Mapping and the Responsible Business Transparency Protocol............................................................... 52

Data Analytics in RBA-Online.................................................................. 54 VAP Improvements................................................................................... 55 VAP Assessments – By the Numbers...................................................... 56 Membership Growth................................................................................ 59 FY 2025 Financial Highlights.................................................................... 60

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2025 ANNUAL REPORT

MESSAGE FROM THE CEO

Dear Colleagues, In 2025, the RBA strengthened its position as a leading industry coalition advancing responsible business conduct across global supply chains. Amid a rapidly evolving regulatory environment and continued geopolitical uncertainty, the RBA expanded its tools, standards, partnerships, and digital infrastructure to help members and their suppliers address complex labor, health and safety, environmental, and governance issues worldwide.

The RBA has long been guided by a strategic planning process that helps the organization evolve and continued to implement its long-term strategy in 2025 by preparing a new five-year strategic plan for 2026-2030. To support the process, the RBA undertook an extensive survey of its membership, as well as a listening tour, to identify emerging trends, threats and opportunities affecting sustainability and supply chain efforts and to further assess what member companies need and want from the RBA in the future.

The resulting plan that was approved in 2025 sets a bold course for transformation through 2030. It focuses on simplifying and scaling member services, strengthening the interconnectedness of tools, expanding regional responsiveness, enhancing data capabilities, and driving policy innovation. While implementation details will be further elaborated, implemented and reviewed over the next five years, with additional input from members and the board of directors, much of the work that was done in 2025 laid the foundation for future efforts.

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Across the RBA, we supported members to meet current and emerging due diligence regulations, expanded capacity-building and assurance programs, and advanced interoperability and digital systems to improve supply chain visibility and data sharing. In 2025, the RBA engaged policymakers in Europe and 11 Asian countries on regulatory developments and implementation strategies; made significant improvements to the RBA’s Validated Assessment Program (VAP), making it more streamlined, agile and efficient; piloted the RBA Responsible Business Transparency Protocol (RBTP), based on the UN Transparency Protocol framework, to facilitate secure, interoperable exchange of due diligence and sustainability information; launched the RBA Chemical Platform, to help companies identify, assess, and manage chemical management risks within their supply chains; and grew our membership across the RBA and its Initiatives to 635 companies, increasing our reach and influence to more industry sectors, geographic regions, and tiers of suppliers. In addition, the RBA’s Responsible Minerals Initiative (RMI), with its Responsible Minerals Assurance Process (RMAP), became the first supply chain due diligence scheme to be officially recognized by the European Commission for EU importers’ Conflict Minerals Regulation compliance.

Looking ahead, the RBA will build on this momentum by implementing its new strategic plan, expanding interoperability initiatives, refining standards and assurance programs, developing new tools and services, and further collaborating with stakeholders to achieve meaningful impact.

We greatly appreciate the support of our members as we undertake the next chapter in the evolution of the RBA. Such innovation and progress would not be possible without your efforts.

Sincerely,

”

Rob Lederer CEO, Responsible Business Alliance

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2025 ANNUAL REPORT

RESPONSIBLE MINERALS INITIATIVE

In 2025, the RMI achieved several major milestones, which were the results of significant work in prior years to evolve and improve systems, prepare for and respond to regulatory requirements, and expand scope and support to members and the RMI mission. l

EC Recognition: The RMI was the first supply chain due diligence scheme recognized by the European Commission for Conflict Minerals Regulation Compliance

l

First mover on ESG standards and assessments: published and piloted the Supply Chain Due Diligence Plus Module and Facility Standard for Social, Environmental, Occupational Health and Safety, and Governance Risks

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Operational Improvements: conformance/retention rates, technical assistance, streamlined disposition

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Wayfinding in the regulatory landscape: comprehensive “unified due diligence guidance” for members

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Record training participation: hundreds of suppliers, members, learned about new standards, MRTs

l

Launched and led systems interoperability: transparency protocols, data collection, pilots, MOUs/cooperative agreements

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Visit the RMI website

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With more than

500

MEMBER COMPANIES the RMI is one of the world’s largest industry associations forcused on advancing responsible mineral sourcing across global supply chains

2025 ANNUAL REPORT

Regulatory-Ready Tools and Systems The global policy landscape was highly dynamic in 2025, including dialogue, drafting, and re-examination of mandatory due diligence regulations. Despite this shifting ground, the RMI forged ahead with review and expansion of systems and tools to give its members practical tools to address changing policies as well as company commitments, investor and stakeholder expectations, and overall greater awareness and scrutiny of supply chain due diligence.

Just as the RMI’s scope expanded from its origins in four minerals to a wide spectrum of minerals, our work in 2025 expanded the RMI’s suite of due diligence tools to reflect more comprehensive social, occupational health and safety, governance, and environmental risk assessment. Three key developments demonstrated the RMI’s expanded coverage and support with regulatory-ready, trusted tools and systems: new standards, updated mineral reporting templates, and accountability instruments.

New Standards: Full Risk Scope Coverage with the Facility Standard for Social, Environmental, OHS and Governance Risks and the Supply Chain Due Diligence Module Plus In April 2025, the RMI achieved an important milestone in strengthening its global due diligence ecosystem with the launch of the Supply Chain Due

Diligence Plus Module (SCDDP) and the Facility Standard for Social, Environmental, Occupational Health and Safety, and Governance Risks (Facility Standard). These new standards provide a common framework to assess environmental, social, occupational health and safety, and governance (ESG) performance at facility-level operations and across mineral supply chains, enabling full-risk scope coverage. Available to all supply chain tiers, with the exception of mines, the Facility Standard and SCCDP are designed to support companies navigating an evolving regulatory landscape, including the EU Battery Regulation.

From May through October 2025, the RMI conducted a structured pilot of these standards and assessment tools. Facilities participating in the pilot were nominated and engaged by RMI members through the ESG Collective Action Task Force, reflecting shared responsibility across the supply chain and the RMI’s role as a convener of upstream and downstream actors. The pilots covered a diverse cohort of facilities across Europe, Asia, and Africa representing cobalt, nickel, manganese, lithium, and precursor materials, and enabling testing of both the SCDDP and Facility Standard across real operational contexts.

Throughout the pilot, the RMI gathered feedback from facilities, assessors, and RMI members. This feedback informed targeted refinements to strengthen the 3

2025 ANNUAL REPORT

clarity and auditability of the standards and tools at the end of 2025 in preparation for assessment scaling in 2026. These standards incorporate a progressive scoring methodology that encourages continuous improvement, offering greater transparency into performance levels. To further support shared due diligence responsibility and uptake of the standards, the RMI established the ESG Assessment Fund, which offsets the costs of initial assessments through voluntary contributions by member companies.

Other Risk Assessment Tools for Regulated and Recycled Minerals: Updates to the EMRT, AMRT, and Material Insights The RMI continued to provide updated versions of its Mineral Reporting Templates (MRTs) to allow users to meet regulatory reporting requirements and conduct surveys with flexible mineral scopes. In particular, the Extended Minerals Reporting Template (EMRT) 2.0 added copper, graphite (natural), lithium, and nickel to the reporting scope, so users were able to meet the reporting requirements of the EU Battery Regulation.

EMRT 2.0 also added a Mine List tab, replicated from the Additional Minerals Reporting Template (AMRT), to cover due diligence requirements of the EU Battery Regulation for materials sourced from upstream suppliers. Future MRT updates will continue to be guided by the RMI membership’s needs and consider any new regulatory requirements.

In 2025, the RMI also continued to enhance the Material Insights platform to support evolving due diligence needs for its members. The platform was expanded to host a new section dedicated to 15 recycled materials, including supply chain structure, market developments and available data on association with ESG risks. The profiles of 42 raw materials have also been updated based on newly available research. Data on ESG-risk association has been updated both at material and at country-level.

Expanded Reporting and Transparency The RMI introduced a new template for its public assessment summary reports in 2025. The new format provides a clearer, more graduated representation of assessment outcomes while continuing to safeguard business-confidential information. Key enhancements include expanded assessment details; a breakdown of each assessor conclusion type relative to the total requirements; assessor summaries of facility performance against OECD Steps 1 through 5, and Step 6 where applicable 4

for SCDDP and Facility Standard assessments; and recommended improvement measures to support continuous advancement.

Collaboration for Critical Minerals and Value Chain Coverage The RMI continued its multi-year expansion of critical minerals coverage through member dialogue and work groups, facility outreach and engagement, and ultimately deploying assessments for key minerals and geographies that were a priority for members’ due diligence needs.

The RMI’s expanding focus on critical minerals is guided directly by the priorities of its member companies. Through regular consultations, the RMI engages members to understand which minerals are central to their due diligence activities and where additional support is needed. This collaborative approach helps ensure the RMI’s work remains aligned with industry needs and responsive to evolving supply chain expectations.

In 2025, in addition to ongoing focus on tin, tantalum, tungsten, and gold, the RMI continued its support for members’ critical minerals due diligence efforts across the priority minerals of cobalt, copper, aluminum, nickel, and graphite. Through dedicated mineral teams, the RMI enables members with shared priorities to collaborate, pool expertise, and take industry-wide action that complements their individual company efforts. When launching a mineral team, the RMI begins by mapping the supply chain for the selected material — identifying key actors, analyzing geographical distribution, and locating potential pinch points. This research is then overlaid with an assessment of relevant risks and adverse impacts. Together, these insights form the basis for a joint prioritization exercise in which mineral teams determine where the most significant risks are likely to occur and in which regions they are concentrated.

Member companies can use these insights to inform their internal risk‑scoping processes, guiding their supply chain mapping and helping them identify and engage with key pinch‑point facilities. The RMI also supports members in determining which of the RMI standards and assessments are most appropriate for addressing the prioritized risks associated with specific materials and geographies. In addition, the RMI facilitates alignment across companies by harmonizing supply chain engagement practices and

communications. This joint approach strengthens the effectiveness of individual due diligence efforts while reducing burden, avoiding duplication, and minimizing the risk of conflicting messages to upstream facilities.

industry stakeholders, and participation in regional thought‑leadership initiatives.

In 2025, the RMI supported its member companies in engaging their battery suppliers on regulatory preparedness ahead of the EU Battery Regulation’s entry into force. This included developing a dedicated training session on how to implement the Extended Mineral Reporting Template, preparing a joint letter co‑signed by 15 RMI member companies outlining the Regulation’s requirements and key actions battery producers can take to support compliance, and facilitating regular dialogue between RMI members directly in scope of the EU Battery Regulation and those manufacturing and supplying battery cells and battery packs, particularly in Asia. Similarly, the RMI supported member companies to identify, communicate with, and engage group companies that operate numerous facilities producing significant volumes of battery metals. These efforts helped create a shared understanding of regulatory expectations and strengthened coordination across the supply chain.

Because risk assessment is an iterative process, the RMI engages throughout the year with industry experts, civil society organizations, and international institutions to gather insights on specific supply chains and regional contexts. The RMI connects mineral teams with these sources of expertise, as well as with on‑the‑ground projects that member companies may choose to join or support as part of their risk mitigation strategies. In 2025, the RMI collaborated regularly with the Cobalt Institute to monitor trade policy developments in the Democratic Republic of the Congo and receive country‑level updates. The RMI also participated in the coordination platform established by the Nickel Institute to promote information exchange and alignment among initiatives operating in the Indonesian nickel sector. Regular exchanges also took place with the Aluminum Stewardship Initiative to identify complementarities in each other’s work and to gather industry-specific insights. In addition, civil society representatives were invited to brief mineral teams and share their perspectives on key ESG issues.

Building on pinch‑point (mineral processor) data collected by member companies through the rollout of the RMI Mineral Reporting Templates (MRTs) — and consolidated within the RMI’s members‑only database — the RMI supports mineral teams in engaging directly with identified facilities, either themselves or through their suppliers, with the goal of onboarding these facilities into RMI third‑party assessments. To enable this work, the RMI provides training on the scope, applicability, and requirements of its standards, and facilitates peer‑learning sessions on effective outreach strategies. The RMI also complements individual company efforts with its own engagement activities, including regional communications to facilities listed in the database, collaboration with key

Finally, the RMI worked closely with the RBA Policy team and selected partner organizations to engage government representatives in key producing countries of the prioritized minerals. These engagements aimed to communicate market and regulatory due diligence expectations, highlight the role the RMI can play in supporting local industry to meet these requirements, and contribute to consultations on the development of national frameworks for responsible sourcing and production. RMI members played an important role in this process by sharing information on market needs and priorities that are relevant for government partners, and by participating directly in consultations and meetings to explain the regulatory due diligence requirements that apply to their operations.

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2025 ANNUAL REPORT

Supporting Progressive Due Diligence While many companies and other stakeholders know the RMI for its standards and assessments, a core part of the RMI’s mission and annual work focuses on building the capacity of members and smelters to improve their due diligence, via training, technical assistance, and other initiatives. In 2025, the RMI’s priorities and investments for technical assistance, capacity building, and financial support reflected its expanded tools and standards, with a focus on improving understanding of these tools and facilitating uptake and use.

Technical Assistance: Strengthening Facility Readiness, Conformance, and Retention In 2025, RMI’s Technical Assistance (TA) activities focused on strengthening facility due diligence capacity, supporting timely corrective actions, and reducing disengagement risks across high-impact supply chains. TA delivery prioritized practical implementation support — particularly for facilities navigating corrective action plan (CAP) findings, enhanced due diligence expectations, and expanded standards scope — while reinforcing the RMI’s role as a partner for progressive improvement to complement independent, third-party assessments.

Throughout the year, TA supported facilities at all stages of the assessment cycle, with a strong emphasis on early intervention and CAP closure. This included targeted guidance on Conflict-Affected and High-risk Areas-related requirements, traceability, sourcing from highrisk regions, and interpretation of RMAP and related standards. TA efforts were closely coordinated with facility engagement and escalation processes to stabilize at-risk facilities, improve conformance outcomes, and maintain program participation.

Overall, TA contributed measurably to facility progression and retention in 2025. Most TA-supported facilities either achieved conformance, stabilized following escalation, or remained actively engaged in the program. Continued engagement with facilities that experienced periods of nonconformance also enabled corrective actions and, in several cases, supported re-entry into the program, underscoring the value of tailored, hands-on support in mitigating risk and strengthening due diligence performance.

Training for Members and Suppliers In 2025, the RMI training program significantly extended its reach, delivering 40 training sessions to more than 3,000 participants worldwide — a 400% increase from the previous year. This growth was fueled by the release of the Facility Standard for Social, Environmental, Occupational Health & Safety (OHS), and Governance Risks and the Supply Chain Due Diligence Module Plus. The release of these standards addressed the urgent need to build capacity around evolving frameworks for responsible mineral sourcing, enabling stakeholders to effectively manage complex supply chain risks and adapt to emerging regulatory demands.

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2025 Technical Assistance Highlights • 149 facilities received Technical Assistance support during the year, with engagement spanning CAP1–CAP3, reassessment, re-entry, and new standards readiness.

• More than 1,100 TA hours were delivered, complemented by more than 680 hours of proactive outreach to facilities across priority regions.

• 113 CAP cases were closed with TA support, resulting in 82 facilities achieving Conformant status following assistance.

• TA contributed to the stabilization of more than 100 facilities through removal from Escalation or Preliminary Concern, supporting retention and continued engagement.

• Support was concentrated in high-impact geographies, including China, Indonesia, the DRC, Korea, and India, and across 3TG and battery-related minerals.

• Facility feedback confirmed TA as a high-value support mechanism when accessed, reinforcing the importance of early awareness and activation.

2025 ANNUAL REPORT

The RMI substantially expanded its training portfolio to empower members and suppliers in understanding and implementing the revised RMI Standard Suite for social, environmental, OHS, and governance risks.

Key offerings included comprehensive sessions for members and facilities on the RMI Facility Standard and the Supply Chain Due Diligence Plus Module, as well as specialized environmental deep dives.

These sessions covered essential topics such as risk assessments, greenhouse gas reduction strategies, water stewardship, air emissions management, biodiversity protection, and circular economy principles.

By emphasizing practical, actionable insights, these trainings equipped participants with the knowledge and tools needed to enhance due diligence performance and drive sustainable improvements across mineral supply chains.

To further support compliance with emerging regulations and bolster due diligence capabilities, the RMI broadened its global training reach. Highlights included highly sought-after sessions on mastering the EMRT to meet requirements under the EU Battery Regulation, which attracted nearly 300 participants in the APAC session and more than 270 in the combined Americas/Europe session. The RMI also provided dedicated onboarding trainings to help facilities navigate the RMAP assessment, connecting participants to technical assistance at no cost.

Complementing these efforts, the RMI introduced a new series of instructional videos on the MRT and delivered updated training on the Risk Readiness Assessment (RRA) 3.0 for members and facilities.

Together, these resources delivered clear, practical guidance for conducting robust risk assessments, implementing effective mitigation measures, aligning with key regulations such as the EU Battery Regulation, and advancing responsible sourcing while promoting greater supply chain transparency.

Participation across the training ecosystem was robust, with a record number of smelters and upstream suppliers engaging alongside strong representation from member companies. This widespread involvement highlighted the program’s success in fostering industry-wide collaboration and collective progress. One standout was the RMI Standards Deep Dive: Navigating Due Diligence, Assessments, and Regulatory Alignment member webinar, which drew 457 live viewers and left participants with concrete, actionable steps for implementing the RMI Standard suite throughout their supply chains.

These achievements in 2025 positioned the RMI to deliver even greater impact in 2026 through more focused, high-impact capacity-building initiatives tailored to the evolving needs of the responsible minerals ecosystem.

RMI Member and Facility Outreach in South Korea

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2025 ANNUAL REPORT

2025 Industry Engagement Highlights Active participation in the Tantalum-Niobium International Study Center (T.I.C.) Conference in Cape Town, providing a platform to engage tantalum smelters and stakeholders on due diligence challenges, CAP trends, and practical mitigation approaches.

Focused engagement in Indonesia through active participation in the SMM Critical Minerals Conference in Jakarta, providing a platform to engage stakeholders on due diligence challenges in critical minerals supply chains, regional risk drivers, and facility responsiveness and retention.

Regional engagement across Asia-Pacific, including Korea and China, combining workshops, learning sessions, and direct facility dialogue on standards interpretation and regulatory preparedness.

Ongoing collaboration with industry partners, member companies, and facility representatives through structured forums and working groups to inform guidance development and implementation.

Industry Engagement in Key Sectors and Geographies In 2025, the RMI’s Facility Engagement Team (FET) advanced industry engagement to strengthen shared understanding of due diligence expectations, promote consistent implementation, and support uptake of RMI tools and standards. Engagement activities emphasized collaboration, peer learning, and regional relevance, particularly in jurisdictions and sectors facing heightened regulatory and operational complexity.

Action Plans and $58,774 from the ESG Assessment Fund to support six assessments. The Upstream Due Diligence Fund remained available (up to $10,000 per application) to support upstream due diligence, though no applications were received in 2025. Collectively, these funds expand access to due diligence tools, reduce financial barriers for participating facilities, and support broader uptake of the RMI’s assurance programs.

Through conferences, regional dialogues, and targeted workshops, the FET connected members, facilities, and stakeholders to practical guidance and emerging good practices. These engagements supported alignment across upstream and downstream actors and reinforced the RMI’s role as a convening platform for collective action.

As the RMI expands its coverage of primary and secondary minerals, sectors, geographies, and supply chain nodes, it is deepening its role as a “due diligence bridge” between upstream and downstream supply chains. Central to this role are the RMI’s leadership in systems-to-systems interoperability, expanding the facility database, and building and deploying mineralsrelated digital credentials and other tools for the Responsible Business Transparency Protocol.

Financial Support for Due Diligence The RMI maintains three dedicated financial support mechanisms — the RMAP Assessment Fund, the ESG Assessment Fund, and the Upstream Due Diligence Fund — to help reduce barriers to participation in responsible minerals due diligence. In 2025, the RMI expanded its financial support with the first full year of implementation of the ESG Assessment Fund, which was launched at the end of 2024 and began receiving significant member contributions in 2025.

In 2025, member contributions across all funds totaled $357,000, with the RMI investing an additional $200,000 to further support the RMAP Assessment Fund. The RMI disbursed a total of $429,258 from the RMAP Assessment Fund to support 34 initial assessments, two reassessments, and 49 Corrective 8

Due Diligence and Systems Interoperability

Interoperability Leadership and Systems Partnerships In April 2025, the RMI co-led a session with the OECD Centre for Responsible Business Conduct, initiating discussions on how interoperability between systems can streamline due diligence and promote coherence in a complex standards landscape. The session was also an opportunity for the RMI to explain how the RBA extension of the United Nations Transparency Protocol (UNTP) – the Responsible Business Transparency Protocol (RBTP) – will facilitate due diligence data sharing and access among companies and other entities, including facility records, certifications, and other information.

Beyond the cooperation described in earlier sections, the RMI also deepened and formalized engagement with other individual standards systems and organizations via memoranda of understanding in 2025: l

The RMI-IRMA MOU focuses on supporting the adoption of responsible business practices and effective due diligence practice across supply chains; leveraging data and technology to generate visibility on responsible business conduct and facilitate risk management at scale; and removing barriers to participation for vulnerable or marginalized stakeholders.

l

The RMI-CCCMC MOU supports dialogue and coordination between the initiatives, including participation on advisory and technical committees and hosting joint events; joint capacity building and problem-solving, including training to improve understanding of standards and schemes, and to address specific challenges and issues facing facilities and assessors; and assessment cooperation and observation, including learning about each other’s programs.

l

RMI and CCCMC Sign MOU

The RMI-ASI MOU builds on an earlier 2018 MOU, with renewed emphasis on data sharing to enhance supply chain transparency and systems interoperability; standards and assurance, including auditor training and benchmarking/equivalency processes; and awareness-raising and collective outreach to key supply chain actors and facilities.

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2025 ANNUAL REPORT

RMI and the Responsible Business Transparency Protocol In 2025, the RMI contributed its technical expertise to support the development of the RBTP, the RBA’s initiative to advance interoperable, digital supply chain transparency based on the UN Transparency Protocol.

The RMI supported the creation of a Sustainability Vocabulary Catalog, mapping RMAP requirements to RBTP conformity topics, ensuring the RMI’s responsible minerals due diligence requirements are represented in the RBTP model. The RMI additionally provided input into the scoping and design of the RBTP collaborative pilot, testing how sustainability and due diligence credentials can be securely exchanged across multiple tiers of the supply chain. Through this work, the RMI helped translate RMAP conformity information into standardized digital credentials that can be understood and used across different systems, preparing the RMI to support future interoperability between supply chain actors across tiers.

Expanding the Facility Database and Integrating Third-Party Data The RMI is expanding the Facility Database to become a unified data repository capturing all facilities identified through Mineral Reporting Template submissions, including processors, refiners, and mines. In 2025, the RMI worked with Copper Mark and IRMA, as well as facilities independently identified by the RMI through its ongoing due diligence activities, significantly expanding the scope and utility of the Database. Facilities receive unique identifiers per material, making it clear which minerals they have been assessed for and by what standard. The database provides a standardized way to classify facilities by supply chain position, downstream, pinch point, or mine. These definitions were jointly aligned with other standards, ensuring cross-industry consistency.

The database is a comprehensive visibility tool for members seeking to understand their supply chain and leverage existing assessments. This means RMI members can quickly verify whether their suppliers have been assessed elsewhere, reducing the need to cross-check multiple external lists. By integrating data from multiple standards and harmonizing definitions across the ecosystem, it provides visibility, consistency, and ease of use for RMI members. The RMI will also be working in 2026 to integrate data from additional sources.

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Assessment Operations and Quality Assurance In 2025, the RMI Operations team delivered a productive year with program growth, improvements, and operational excellence. These efforts supported increased scale, operational maturity, and program integrity and positioned the RMI assessment program to deliver higher-quality, more data-driven value to members and stakeholders in 2026 and beyond.

In addition to core assessment activities, RMI Operations completed 51 facility dispositions and conducted 50 off year document reviews for RiskBased Assessment Program (RBAP) participants.

The team also continued to evolve the assessment framework through the introduction of Facility Standard and RMAP+ pilot programs.

Importantly, RMI Operations invested in critical foundations for future scalability. This included improvements to the RMI Public List, enhancements to the Facility Database, and the integration of thirdparty data sources, strengthening transparency, analytical capability, and data-driven insights across the program.

RMI Assessment Program Activity In 2025, RMI Operations completed 222 assessments across RMAP (188 assessments), DAP (15 assessments), RMAP+ (4 assessments) and the Facility Standard (15 assessments).

One hundred ninety-nine facilities became conformant, which includes assessments initiated from the previous year, and 57 (29%) of assessments resulted in a Corrective Action Plan (CAP).

Participation in the RMAP assessment program reflected the geographic diversity of global mineral supply chains. Strong engagement across Asia, alongside sustained participation in the Americas, Europe, Africa, and Oceania, highlighted growing alignment with responsible sourcing expectations across established and emerging markets.

Notably, Indonesia emerged as a key growth market in 2025, driven by the entry of new nickel facilities.

This expansion underscored the increasing relevance of RMI programs within energy transition and battery materials supply chains.

2025 ANNUAL REPORT

Assessment Breakdown

by Metal Cobalt Tin Gold Nickel Tantalum Tungsten Copper Lithium Silver Mica Iridium (Platinum-Group Metals) Palladium (Platinum-Group Metals) Platinum Rhodium (Platinum-Group Metals) Ruthenium (Platinum-Group Metals) Zinc Lead Lime Molybdenum Bentonite (Clay Minerals) Clay Minerals Feldspar Kaolin (Clay Minerals) Manganese Quartz Crystal (Silica) Soda Ash Vanadium

n n n n n n n n n n n n n n n n n n n n n n n n n n n

53 40 37 37 30 25 19 13 7 6 4 4 4 4 4 3 2 2 2 1 1 1 1 1 1 1 1

RMAP 2025

Conformance and Participant Trends In total, 199 RMAP participants achieved conformance in 2025; 32 newly conformant facilities and 167 reassessments.

By material and sector: • 55% of conformant facilities were 3TG operations • 37% were battery materials facilities • The remainder included facilities involved in cobalt, mica, critical minerals, and precious metals Regarding the Corrective Action Plan (CAP) process: • 31% of assessed facilities achieved conformance without entering CAP • 48% achieved conformance following CAP1 • The remaining facilities achieved conformance after CAP2

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2025 ANNUAL REPORT

YOY Trend of RMAP Conformant Smelters 350

NUMBER OF COMPLIANT SMELTERS

300 250 200 150 100 50 0 2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

2025

n Other

0

0

0

0

0

0

0

0

0

0

0

0

2

16

40

67

n Co

0

0

0

0

0

0

0

0

0

2

10

21

33

44

49

58

n Au

0

0

11

31

56

77

89

98

102

105

107

107

99

90

93

90

n W

0

0

0

1

9

29

40

41

40

43

42

40

39

34

34

34

n Sn

0

0

3

9

22

56

66

69

72

45

50

53

56

66

50

50

n Ta

2

10

15

23

43

46

47

42

40

37

37

36

34

32

34

33

2

10

29

64

130

208

242

250

254

232

246

257

263

282

300

332

Totals

Facility Determination, Eligibility and Third-Party Data In 2025, 51 additional facilities were determined eligible for participation in RMI assessment programs. Of these, 30 facilities entered the program, representing an overall conversion rate of 58.8 percent. Pinch point facilities represented the majority of eligible sites, with 37 facilities (72.5%), including 12 3TG facilities. Of these, 25 facilities (67.6%) progressed into the assessment program.

Downstream facilities accounted for 10 eligible sites (19.6%), with four facilities (40%) entering the program. Upstream facilities represented the smallest segment, with four eligible sites (7.8%), of which one facility entered the assessment program.

During the year, the RMI enhanced its Facility Database to integrate data submitted by RMI member

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companies as well as data shared by selected external assessment schemes. In 2025, the database began hosting third-party data from IRMA and The Copper Mark: l

126 Copper Mark–assessed facilities, resulting in 198 metal CIDs

l

12 IRMA-assessed facilities, resulting in 35 metal CIDs

Operational Excellence The RMI Operations made significant progress in 2025, both in the number of participating facilities and the diversity of assessment schemes delivered.

Continued investments in data quality, analytics, and operational processes strengthened program scalability and consistency and reduced cycle times.

2025 ANNUAL REPORT

RMAP and DAP: Average Days from Assessment End to QC Complete 2024 50

2025 51

44 41 37

37

37 30

Q1

Q2

Q3

Q4

Q1

Q2

Q3

Q4

Average Days from Assessment Requested to Initial Determination Letter

156 137 127

‘24 Q1

‘24 Q2

‘24 Q3

135

‘24 Q4

140

‘25 Q1

132

‘25 Q2

124

‘25 Q3

119

‘25 Q4

Looking Ahead In 2026, the RMI will maintain focus on its core programs, including a comprehensive review of the standards suite in preparation for a revisions process, while continuing to build tools and systems to meet the evolving needs of members. Efforts will include a formalized Interoperability Framework, building RBTP digital tools and expanding the Facility Database, and working with members and stakeholders to help advance transparency, stakeholder engagement, and other key areas in which we aim to deepen our work to support the due diligence ecosystem.

For more information on the RMI, visit ResponsibleMineralsInitiative.org 13

2025 ANNUAL REPORT

RESPONSIBLE LABOR INITIATIVE

In 2025, the RBA’s Responsible Labor Initiative (RLI) focused on operationalizing forced labor due diligence across global supply chains by building and reinforcing its tools and programs.

Building Capacity and Operationalizing Forced Labor Due Diligence Helping members operationalize due diligence across industries is a key focus of the RLI’s work and 2025 was a critical year for building on the RLI toolkit to help members identify, address and remediate forced labor. An important driver of forced labor is the payment of recruitment fees and other related costs incurred by workers to obtain work taking on debt that leaves them vulnerable to exploitation and unable to leave their jobs until the debt is repaid. Further complicating this situation is that recruitment fees charged to workers are often legal in many countries. Helping members to work with their suppliers to understand, identify and reimburse recruitment fees and related costs to workers is a critical part of our efforts. Over the past several years, the RBA and RLI have helped return tens of millions of dollars of fees to workers. The RBA’s Fee Standard for the Investigation and Repayment of Fees to Workers and the Specialty Validated Assessment Protocol (SVAP) on Forced Labor were crucial to these efforts.

View the RLI video

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Visit the RLI website

HIGHLIGHTS OF 2025: • Building capacity and operationalizing forced labor due diligence • Scaling programs and tools for impact • Launching the Responsible Recruitment Program (RRP) 2.0 • Increasing public policy advocacy and stakeholder engagement

2025 ANNUAL REPORT

In 2025, the RLI sought to improve these and other resources to increase accessibility, uptake and utilization, and deepen penetration in supply chains.

Increasingly, new members are joining the RLI from across industry sectors to address shared challenges related to recruitment fee remediation.

Throughout 2025, the RLI held discussions with new and potential members organized by industry sectors that are interested in addressing forced labor-related issues in specific regions. Starting with a range of companies in the footwear and apparel sector interested in fee remediation in Chinese Taipei and a group of food and beverage companies seeking support for child and forced labor issues in North America, these efforts help deepen the RLI membership and expand industry footprints to address common issues.

Scaling for Impact Achieving the vision outlined in the RLI Strategic Priorities as well as those outlined in the 2024 Global Summit on Forced Labor required strengthening and revamping of the RLI’s structure and operations. Thus, 2025 was a year that featured significant internal upscaling and efforts. Highlights included: l

Launch of three cross-industry workstreams to drive forced labor due diligence – Forced Labor Due Diligence Practices Working Group to drive effective adoption of RBA and RLI forced labor tools, share best practices and identity emerging issues – Responsible Recruitment Working Group to drive implementation of the RLI’s Responsible Recruitment Program (RRP) – Data Strategy Working Group to operationalize and help develop interoperability of forced labor data

l

Strengthening industry presence by expanding representation in the RLI Steering Committee, creating several new seats and a nonvoting observer category to deepen industry understanding and expertise in RLI work

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2025 ANNUAL REPORT

l

l

Launch of the RRP 2.0 program to help drive demand for ethical recruitment while working with partners to lead assurance and capacity-building activities with Private Recruitment Agencies (PRAs). Since launch, nine PRAs have been certified by third parties, over 1,500 data points from PRAs have been mapped, and seven new PRAs are entering the program with several workshops planned in 2026.

Expanding the RLI toolkit – inclusion of new recruitment corridors in the Labor Migration Corridor Database – a new Simplified Forced Labor Due Diligence and Remediation Toolkit for smaller suppliers beginning their journey on forced labor due diligence – reducing overall costs and streamlining the Specialty Validated Assessment Program (SVAP) to identify the presence of forced labor issues or associated risks

l

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Working with the RBA Public Policy team to deepen understanding of forced labor due diligence and industry practices and to address systemic issues in producing countries

Responsible Recruitment Program (RRP) 2.0 Responsible recruitment has been a pillar of the RLI’s work for many years. From 2018-2023 the Responsible Recruitment Program (RRP) provided a maturity pathway for private recruitment agencies (PRAs), helping to lift them toward ethical recruiter recognition. The RRP was designed to increase the number of recruitment agencies on the pathway toward certification by third-party programs, such as IOM IRIS and On the Level, and help create a market for ethical recruitment.

In 2024 the RLI took stock of the accomplishments and learnings of the RRP program to build RRP 2.0, which will focus on the demand side of ethical recruitment while fostering greater collaboration with partner organizations to help increase capacity building, third-party assessment and certification (aligned with RBA standards) of PRAs at scale across key recruitment corridors. Launched in November 2025, RRP 2.0 will provide a vision for continuous improvement by PRAs while encouraging RBA and RLI members to create a viable marketplace for zero-fees recruitment. This can be a crucial element to help meet increasing regulatory expectations on forced labor due diligence.

2025 ANNUAL REPORT

RLI Public Policy Advocacy and Stakeholder Engagement Addressing forced labor risks requires an approach by all of society as industry, government, and civil society alone cannot solve this issue. Throughout 2025, the RLI participated as an expert resource in global dialogues on forced labor, helping to drive discussions on effective due diligence measures, useful industry tools, meaningful stakeholder engagement, and helpful government policy structure.

The RLI, in partnership with the RBA Public Policy team, maintained regular dialogues with U.S. government agencies including the State Department’s Trafficking in Persons (TIP) office, the Department of Labor and its International Labor Affairs Bureau (ILAB), and the Department of Homeland Security (DHS)’s Customs and Border Protection (CBP) agency, to promote industry best practices during implementation of the U.S. Tariff Act and other U.S. government efforts with trade partners on forced labor.

In May the RBA and RLI organized a briefing with the European Commission’s Director Generals for Growth and Trade; key agencies that will be involved in the implementation of the European Union Forced Labour Regulation.

Additionally, 2025 highlights included participating in the International Labour Organization’s Fair Recruitment Conference in Geneva and various International Organization for Migration Workshops in Nepal and Indonesia. The RLI also helped organize the RBA/ILO/JP-MIRAI Symposium on Forced Labor in Tokyo in April, and participated in global forums such as the Institute for Human Rights and Business Global Forum for Responsible Recruitment, the UN Forum on Business and Human Rights in Geneva, and the UNRBHR Forum in Bangkok.

A critical pillar of the RLI’s work is engagement with stakeholders, and this continued via consistent dialogue in 2025 with local and global civil society on forced labor issues. The aim of the RLI was to promote greater worker engagement in the identification and remediation of forced labor while helping members better understand forced labor issues in specific producing markets such as Malaysia and Chinese Taipei.

Moving Forward The RLI will continue to lead industry efforts related to the practical operationalization and implementation of forced labor due diligence, aligned with international standards, including the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Responsible Business Conduct, to include identification, prevention, mitigation, communication, and appropriate remedy.

RLI priorities in 2026 include: l

Increased uptake of forced labor due diligence

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Revision of the RBA Fee Standard on Identification of Repayment of Recruitment Fees to Workers

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RRP 2.0 implementation

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Forced labor data interoperability

For more information on the RLI, visit ResponsibleLabor.org

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2025 ANNUAL REPORT

RESPONSIBLE FACTORY INITIATIVE

Program Updates In 2025, the RFI program continued to refine its tools, services and trainings for suppliers. To increase agility and meet the diverse needs of RBA members, the RFI introduced additional options such as a desktop approach and a customized onsite assessment. This flexibility helps RBA members determine the best approaches, depending on their supplier risk levels and costs, and makes requirements less burdensome for the suppliers. The new desktop approach leverages the RBA’s Risk-Based SAQ, which includes verification of the SAQ submission.

The RFI program has also been expanded to include indirect spend suppliers, such as service providers in logistics and construction, subcontractors and SMEs. The program continues to provide customized in-house trainings, webinars and other specialized services to tackle common yet challenging issues. Suppliers in the RFI program are also provided with networking opportunities as they are now invited to RBA Outreach meetings for free.

An RFI Advisory Committee comprised of five RBA members continues to actively support the RFI and meets on a quarterly basis to help ensure the program remains relevant to RBA members’ needs in driving supply chain due diligence.

View the RFI video

18

Visit the RFI website

To increase agility and meet the diverse needs of RBA members

the RFI introduced additional options such as a desktop approach and a customized onsite assessment

In 2025, RFI had

71

COMPANIES which is a

15%

INCREASE FROM 2024

2025 ANNUAL REPORT

Program Achievements

Future Enhancements

In 2025, the RFI had 71 companies enrolled in its program, which is a 15 percent increase from 2024.

Its geographical coverage continues to expand beyond China, Malaysia, Vietnam, Thailand, Indonesia, India, Germany, South Korea, and Singapore to other countries including the United States, Mexico and Japan.

Based on annual survey feedback from RBA and RFI members, the program is dedicated to delivering continued improvement, including: l

Identifying criteria for suppliers new to RBA compliance and introducing appropriate recognition to motivate suppliers to implement progressive improvement

While RFI participants have different maturity levels, we continue to see that RFI members typically improve their RBA assessment scores by an average of 18-20 percent since joining in the Initiative.

l

Providing more webinars with best practices and progression to maturity in mandatory Factory Lead training

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Leveraging the Member Portal to provide a platform for greater sharing of useful resources and interaction among suppliers

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Promoting the RFI deeper into RBA members’ supply chains tiers and expanding to additional countries

For more information on the RFI, visit ResponsibleFactory.org

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2025 ANNUAL REPORT

RESPONSIBLE ENVIRONMENT INITIATIVE

REI Roadmap Responsible Environment Initiative (REI) staff actively worked in 2025 to implement the second year of the REI Roadmap, which was developed and approved by the RBA Board of Directors in 2024 and covers Q3 2024-Q2 2026. Central to the Roadmap is the focus on the development of tools and services that help improve environmental performance through value chain alignment and collaboration. The Roadmap guides REI work across its priority focus areas in support of the REI Mission.

It was a productive year for the REI, with numerous new products and services launched as well as continued refinement and deployment of existing REI flagship tools. The REI team actively collaborated with external partners in 2025 to transform the environmental performance of electronics supply chains. The REI team also partnered with the RBA Policy team to hold webinars on environmental policy matters of relevance to RBA members as well as to advance REI tools and services as credible industry solutions for RBA Code conformance, supply chain capacity building, and environmental, health and safety (EHS) leadership.

The Roadmap guides REI work

across its priority focus areas in support of the REI Mission

The

REI

FOCUSES ON ISSUES WHERE THE RBA CAN ADD VALUE through stakeholder engagement, industry collaboration, capacity building, and advocacy: • Decarbonization • Chemical Management • Water Stewardship • Circular Materials

View the REI video

Visit the REI webpage

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2025 ANNUAL REPORT

REI Governance and Member Engagement The REI is guided by a Senior Environmental Advisory Team (SEAT), consisting of environmental sustainability leaders from a cross-section of RBA member companies. The SEAT provides guidance to the REI team to help ensure that RBA members’ greatest needs are met in accordance with the REI mission.

The SEAT met quarterly in 2025 to provide guidance and counsel to REI staff regarding REI workstreams, stakeholder engagements, and tool effectiveness.

Three working groups facilitate RBA member engagement in the REI: the Environmental Sustainability Working Group, the Chemical Management Working Group, and the Circularity and Waste Minimization Working Group. These Working Groups met regularly (typically monthly) and at two different time zones throughout 2025 to accommodate RBA members’ diverse geographic representation.

An Environmental Due Diligence Task Force also met bimonthly to help develop RBA tools to meet new environmental due diligence requirements, including the European Union’s Corporate Sustainability Due Diligence Directive (EUCSDDD). During 2025, the REI remained focused on four member-identified priority issues: decarbonization, water stewardship, circular materials, and chemical management.

2025 Deliverables REI resources, tools, and services that were developed or deployed in 2025 across REI’s priority focus areas included: Decarbonization l

Development of a new and improved Emissions Management Tool (launched Q1 2026)

l

Developed and released the RBA Energy Efficiency and Renewable Energy Guide

l

Developed and released At-A-Glance Documents on GHG Reporting and Climate Mitigation Plans

l

Developed Scope 3 Category 1 GHG Reporting Guidance, in partnership with the Global Electronics Association (released in Q2 2026)

l

Partnered with RBA Policy team on California Greenhouse Gas Reporting Rules webinar

Water Stewardship l

Developed and released the Guide to Water Risk and Stewardship, in partnership with the Alliance for Water Stewardship

l

Held an informational webinar on water risk and stewardship

l

Continued supply chain water stewardship capacity-building efforts, in partnership with the Alliance for Water Stewardship 21

2025 ANNUAL REPORT

Waste Minimization and Circularity l Developed an R2 Recycler Assurance Standard Assessment l Held an REI-RMI Roundtable Series on Due Diligence for Responsibly Sourcing Recycled Minerals l Developed an RBA Learning Academy module on the Regulatory Drivers of Zero Waste l Launched a Zero Waste Task Force l Began development of the RBA Zero Waste Program Chemical Management l Deployed the Specialty Validated Assessment Program on Chemical Management (SVAP-CM) and refinements, including assessor capability building l Launched the RBA Chemical Platform, version 1 l Developed the Process Chemical Reporting Protocol (PCRP) Tool l Launched the RBA Chemical Management Leadership Program (CMLP) l Revised the Industry Focus Process Chemical (IFPC) Policy, including expansion of the IFPC List Environmental Due Diligence l Revised the RBA Self-Assessment Questionnaire (SAQ) that helps RBA members assess supplier risks against the Health & Safety and Environmental sections of the RBA Code of Conduct (deployed Q1 2026) l Partnered with RBA Policy team to assess EU Corporate Sustainability Reporting Directive environmental due diligence requirements versus the RBA Code of Conduct l Partnered with the RBA Policy team to conduct webinars on environmental due diligence

REI Tool Updates Emission Management Tool (EMT) The Emissions Management Tool (EMT) is a data platform that allows RBA members and their suppliers to share GHG data for use in their decarbonization and sustainability efforts. RBA members and their suppliers can use the tool to calculate and report their GHG emissions and share those results with customers, investors, and other stakeholders. The EMT allows RBA member suppliers to complete their GHG inventory once and share those results with multiple RBA member customers, eliminating duplicate requests and reducing supplier burden.

22

In 2025, the REI team deployed the EMT for its third year but also began the process to rebuild a new and improved EMT to address members’ needs for GHG reporting flexibility, emissions allocation and classification, and new upload and download capabilities for data portability. REI staff worked with an EMT Task Force to revise and refine the EMT survey questions and the new EMT data platform was integrated with RBA-Online.

The new EMT is expected to result in increased member usage and supply chain deployment due to alignment with the GHG Protocol and potential use for CDP reporting. REI staff plan to continue refine the EMT question set in 2026 to reflect industry needs and increased standardization. REI staff will also continue to work in partnership with allied trade groups to develop standardized GHG reporting guidance that can be integrated into the EMT and expand its deployment across the supply chain to increase RBA member value.

RBA Chemical Platform and Chemical Management Leadership Program The RBA launched the RBA Chemical Platform, version 1, in June of 2025 to enable members and their suppliers to advance and streamline their collection, analysis, and reporting of supply chain process chemical management risk data. In addition to process chemicals, the Chemical Platform collects usage and control data on all chemicals that are consumed at facilities to better assess occupational safety and worker exposure risks in accordance with the RBA’s new facility risk rating methodology, which is used by all Chemical Platform users for the generation of standardized Facility Risk Scorecards.

RBA members may also use the Chemical Platform to screen their supply chain facilities for conformance with regulatory requirements, voluntary initiatives, ecolabel criteria, and restricted substance lists. The Chemical Platform is fully integrated with RBA-Online, leveraging the secure infrastructure of its ISO 27001 information security-certified system for users to employ their existing company, facility, and trading relationships data as a foundation for collecting chemical management data.

The RBA launched its Chemical Management Leadership Program (CMLP) with four founding Participants in 2025. The CMLP is an industryled, voluntary commitment program in which

2025 ANNUAL REPORT

companies may demonstrate their commitment to responsible business conduct through enhanced transparency, industry collective action, and continuous improvement. REI staff worked with more than a dozen member companies via the Chemical Management Leadership Program (CMLP) Task Force to host a public consultation on the draft CMLP in Q1Q2 2025, select Performance Occupational Exposure Limits (OELs) for IFPC List chemicals in Q3 2025, and develop the Process Chemical Reporting Protocol (PCRP) in Q4 2025.

In establishing and facilitating the CMLP, the RBA seeks to promote the sound management of chemicals toward the United Nations Sustainable Development Goals (UN SDGs) and advance implementation of the new Global Framework on Chemicals (GFC) within the electronics production sector. In accordance with the OECD’s Due Diligence Guidance for Responsible Business Conduct and Guidelines for Multinational Enterprises on Responsible Business Conduct, participation in the CMLP entails implementation of a harmonized, risk-based chemical management due diligence process comprised of eight actions. CMLP Participants may use stakeholder, company-specific,

and RBA supporting resources including the Risk Assessment Platform, RBA-Online, Self-Assessment Questionnaires (SAQs) on Chemical Management, Chemical Platform, PCRP Tool, Specialty Validated Assessment Program on Chemical Management (SVAP-CM), and RBA Voices to satisfy initial and ongoing implementation criteria and be publicly recognized as a CMLP Participant on the RBA’s dedicated CMLP webpage.

In 2026, REI staff will continue to refine, enhance and build recognition of the RBA’s chemical management programs as due diligence tools. In consultation with the newly formed CMLP Advisory Committee and stakeholder partners, REI staff will enhance the Chemical Platform, enabling standardized annual PCRP reporting with customer allocations, enhanced data entry via offline Excel tools, chemical footprint measurement, and streamlined reporting for assurance with ecolabels and material restrictions.

Additionally, the SVAP-CM will be improved through increased assessor capacity, updated informational materials, enablement of combined VAP + SVAP-CM assessments, and enhanced implementation of the recently updated IFPC Policy, version 2.

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2025 ANNUAL REPORT

Circular Materials and Waste Minimization The REI onboarded a new Circular Materials Program Director in 2025 to lead the REI’s waste minimization and circularity work, including leadership of the Circularity and Waste Minimization Working Group (CWMWG). The CWMWG is a members-only working group that has delved into the recommendations of the RBA Circular Materials Landscape Assessment Report, issued in 2024, which contains three primary recommendations for enabling increased circularity: data standardization, supply chain design, and greater recycler assurance.

In 2025, work commenced on data standardization, primarily through a joint effort between the REI and the RBA’s Responsible Minerals Initiative, called the “One-RBA Approach to Due Diligence for Responsibly Sourcing Recycled Minerals.” The REI and RMI held 24

two members-only virtual roundtables in 2025 to share the “One RBA” vision and to introduce members to the Responsible Business Transparency Protocol (RBTP). The RBTP will help enable verifiable, portable, and interoperable supply chain data exchange and is a cross-organizational effort of the RBA. REI staff engaged external partners to explore opportunities to support supply chain design, including participation in exclusive workshops and by providing RBA feedback. These workshops considered systemic challenges in the circular electronics space, including how best to incentivize collection of electronic waste and demand signaling for key recycled minerals and metals. The REI will build on these engagements to further collaborate on supply chain design in 2026.

To support the report’s recommendations regarding greater recycler assurance, the REI led an analysis

2025 ANNUAL REPORT

of recycler assessment protocols against existing recycling standards to better understand where gaps and opportunities exist to improve recycler assurance.

The REI also launched a Zero Waste Task Force for RBA members in 2025. This group participated in multiple discussions to align on how the RBA can support members with their Zero Waste initiatives.

The Task Force provided feedback on a Zero Waste Landscape Assessment, a draft Zero Waste strategy and roadmap, a Zero Waste management system, including participant actions and assurance options, and a new training module titled, “Regulatory Drivers of Zero Waste,” which is available in the RBA’s eLearning Academy in English, Chinese, Spanish, and Vietnamese. The RBA Zero Waste Program is on track to soft launch in late 2026 and fully launch in 2027.

Looking forward, the REI will continue to develop tools and resources to help RBA members and their suppliers to systematically identify, manage, reduce, and responsibly dispose of or recycle solid waste to mitigate environmental impacts and contribute toward a circular economy. Priorities for 2026 include continued work on the Zero Waste Program and its foundational elements, aligning on circularity terms for the electronics industry, working toward a global grading criteria for refurbished products, and refinement of the One-RBA Approach to Due Diligence for Responsibly Sourcing Recycled Minerals.

Looking Ahead The REI Team will continue to refine existing REI resources based on member feedback and will develop new resources to fill any identified gaps.

As REI data platforms are developed, refined, and integrated to measure carbon, chemical and waste impacts, the REI is positioned to offer members a holistic and comprehensive data dashboard for the identification, assessment, mitigation, and reporting of supply chain EHS impacts.

Energy efficiency is a new area for REI tool development, and 2026 plans include a white paper on how RBA members can promote energy efficiency improvements in their supply chains as well as an energy assessment tool that will be integrated with the EMT and allow for facility-level visibility into both carbon emissions and energy efficiency opportunities.

REI staff will also collaborate and partner across the RBA and externally with allied trade groups and organizations to establish supply chain alignment and promote policy recognition, and leverage RBA tools for maximum impact.

For more information on the REI, visit ResponsibleEnvironment.org

Environmental Due Diligence The European Union Battery Regulation and the EU Corporate Sustainability Due Diligence Directive (CSDDD) will require many RBA members to conduct environmental due diligence on their suppliers and certain supply chain partners. The Environmental Due Diligence Task Force will continue its work to discuss potential RBA solutions and the development of an industry approach to supply chain environmental risk assessment and mitigation. The first step was the 2025 revision of the RBA’s Self-Assessment Questionnaire, which includes environmental and health and safety risks at RBA members’ supplier facilities. This revision was deployed in January 2026.

In 2026, additional work will be done for CSDDD preparedness in partnership with internal RBA teams and initiatives.

25

2025 ANNUAL REPORT

RESPONSIBLE GLOVE ALLIANCE The RBA’s Responsible Glove Alliance (RGA) was established in 2022 to address conditions that contribute to forced labor in the rubber glove industry. In 2025, the RGA launched several new campaigns in high-risk tier 2 sectors of rubber glove supply chains. RGA members were also fully integrated into the RBA’s Responsible Labor Initiative (RLI) working groups on forced labor due diligence practices and responsible recruitment. In addition, the RGA worked with members to address and remediate forced labor issues deep in supply chains, stepping in to support workers in challenging situations.

Highlights of 2025 Included: View the RGA video

Visit the RGA website

l

Created and updated tools and training for members

l

Launched the RGA ESG Assessment Criteria and Minimum Standard

l

Deepened the membership compliance process, helping members gauge progress on their journeys toward more responsible sourcing

l

Increased the use of RGA tools and programs for suppliers, particularly the SVAP and RBA Fee Standard

l

Organized dedicated RGA training and capacity-building activities in Malaysia

l

Engaged public buyers in Europe on specific forced labor allegations in the rubber glove industry, providing assurance that due diligence efforts were underway and completed

l

Engaged external stakeholders, including civil society and academics, on due diligence progress

l

Participated in the Malaysian Rubber Council (MRC) Conference to inform on forced labor risks

l

Merged the RGA Annual Conference with the RBA Outreach Meeting in Kuala Lumpur to drive cross-industry cooperation and learnings

l

Discussed collaboration with the Malaysian Rubber Glove Manufacturers Association (MARGMA) including plan to sponsor exhibit and related activities in the 2026 IRGCE, the largest annual glove industry conference in Malaysia

For more information on the RGA, visit ResponsibleGlove.org

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2025 ANNUAL REPORT

2025 ANNUAL REPORT

PUBLIC POLICY In 2025, evolving policies and laws covered a wide range of issues, from forced labor risks to responsible minerals sourcing to environmental stewardship. Ongoing regulatory procedures toward simplification of previously adopted laws, and uncertainty regarding enforcement of existing and upcoming rules created a challenging landscape for companies preparing to implement emerging expectations.

RBA public policy activities aimed to inform and educate members about existing and emerging policies and regulations impacting responsible business conduct efforts, to serve as a technical advisor educating governments on existing industry due diligence approaches and informing policy-making in the area of due diligence, while also fostering collaboration between the RBA and governments worldwide.

Asia Policy Engagement In 2025, the Responsible Business Conduct (RBC) regulatory landscape in Asia was shaped by three converging trends. First, trade and tariff arrangements increasingly incorporated sustainability commitments.

Second, mandatory human rights due diligence (HRDD) legislation gained momentum across the region. Third, governments across Asia adopted more proactive reforms to align national regulatory frameworks with international labor standards. In response to these developments, RBA significantly expanded and deepened its policy engagement across Asia in 2025.

Expanded Geographic Reach The RBA extended its policy engagement to 11 countries across Asia, with the Philippines and Singapore joining the engagement portfolio in 2025. This expansion reflected the RBA’s continued commitment to implementing the RBA Producing Country Engagement Strategy in producing and sourcing markets.

Elevated Levels of Engagement The depth and seniority of engagement increased substantially. In 2025, RBA conducted ministerial-level meetings in India, The Philippines, Chinese Taipei, and many others. In addition, the RBA maintained frequent and structured engagements with senior officials across labor, trade, and human rights ministries and agencies in major producing countries.

Evidence-Based Policy Contributions Under the RBA’s authorization, three high-quality legal gap analysis were completed in India, Indonesia, and Chinese Taipei. These studies were shared with RBA members and policymakers and made tangible contributions to the national regulatory processes. In Indonesia, the research was formally presented to five ministries and recognized as a key input into the development of the country’s mandatory HRDD (mHRDD) legislation. In Chinese Taipei, the service fee research formed the foundation for policy dialogues with the Ministry of Labor and the 27

2025 ANNUAL REPORT

Ministry of Economic Affairs on addressing root causes of forced labor. In India, the research was presented at the National Responsible Business Conduct Conference and will be shared with the National Responsible Business Conduct Taskforce, comprising representatives from 17 ministries.

Leadership in Business Consultation on Emerging Regulations The RBA led business consultations on emerging mHRDD legislation in Thailand and Indonesia. These consultations engaged a broad set of stakeholders, including RBA members, suppliers, national business associations, and employers’ federations, helping to ensure that business perspectives were constructively integrated into legislative discussions.

Policy Dialogues on Root Causes of Non-Conformance The RBA organized and facilitated policy dialogues on systemic root causes of non-conformances with RBA standards in multiple jurisdictions, including Japan, Indonesia, Thailand, Chinese Taipei, and India.

These dialogues provided effective platforms for RBA members and policymakers to jointly examine priority risks, such as recruitment fees for migrant workers in Japan and Chinese Taipei.

Capacity Building for Governments and Industry In 2025, the RBA delivered policy and regulatory training to more than 100 government officials and over 1,000 members and suppliers. These trainings focused on translating evolving regulatory requirements into practical implementation strategies, strengthening both public and private sector readiness.

Other Policy Highlights EU Corporate Sustainability Due Diligence Directive Simplification The RBA Focused significant efforts on the European Union’s first Omnibus simplification package on sustainability, with particular attention to the proposed simplification of the Corporate Sustainability Due Diligence Directive (CSDDD). The RBA’s core objective was to ensure that simplification efforts preserved the core features and outcome levels of the original legislation, in alignment with existing internationally due diligence standards, notably the risk-based approach to due diligence. The RBA advocated maintaining a due diligence mandate applicable across supply chain tiers and grounded in risk, rather than limiting obligations based on narrow interpretations of available or “plausible” information.

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2025 ANNUAL REPORT

The RBA helped shape Omnibus simplification discussions by organizing the conference, “Driving Effective Due Diligence: Omnibus Unpacked,” which was co-hosted with the European Parliament political group European People’s Party (EPP). The event gathered more than 350 participants and served as a bridge across stakeholders, and between policymakers and industry experts.

The RBA led policy engagement throughout the year, including targeted policy dialogues with key decisionmakers across EU institutions, including the European Parliament, the Council of the EU, and continued engagement with the European Commission. This also involved working closely with a broad range of stakeholders in Brussels, including civil society organizations and business associations, which led to the publication of a Joint Statement in November. In doing so, the RBA helped shape the final outcome of the Omnibus process, preserving key elements of a risk-based due diligence approach closely aligned with the RBA’s policy positions.

Engagement in Global Policy Processes and Events The RBA was present at key international for a, including Climate Week NYC, the UN High-Level week, OECD and ILO discussions, and the 2025 UN annual Forum on Business and Human Rights. The RBA co-hosted key sessions and participated as a speaker in prominent discussions to highlight current industry due diligence efforts and help shape policy discussions on emerging responsible business and sustainability topics.

U.S. Bilateral Government Relations and Strategic Outreach The RBA expanded relationships with key U.S. government agencies in 2025, including the U.S. Department of Labor and its Bureau of International Labor Affairs (ILAB), the Office of the U.S. Trade Representative, the U.S. Department of Energy, U.S. Customs and Border Protection, and officials from the California Air Resources Board.

Member Engagement and Community Building The RBA also continued to support members with timely policy intelligence through webinars, strategic convenings, newsletters, and curated discussions with policymakers; positioning the RBA as a central resource on responsible business conduct, sustainability reporting, and regulatory preparedness.

2025 ANNUAL REPORT

2025 ANNUAL REPORT

ADVISORY SERVICES RBA members and their suppliers continue to face an increasingly complex landscape driven by geopolitical pressures and expanding regulatory demands. The RBA’s Advisory Services helps companies mitigate supply chain risks by delivering targeted programs, practical tools, and expert guidance that strengthen the credibility, resilience, and long term effectiveness of their due diligence systems.

Highlights of 2025 Included l

Enhanced visibility across all supplier tiers, extending beyond Tier 1.

l

Ensured the availability of credible data to help substantiate forced labor–related disclosures.

l

Supported member companies in establishing structured and institutionalized due diligence processes

l

Delivered targeted webinars for suppliers at various levels, emphasizing the principle that “workers shall not pay” for their employment.

l

Provided practical guidance on conducting fee investigations and calculating recruitment fees paid by workers.

l

Assisted member companies in aligning with emerging forced labor legislation in both sending and receiving countries.

l

Conducted executive-level and general service provider awareness training sessions

l

Facilitated root cause investigations and supported Corrective Action Plan (CAP) management

l

Performed mock audits to help prepare suppliers for the RBA’s Validated Assessment Program (VAP)

l

Completed nearly 20 fee investigations aligned with the RBA Fees Investigation Standard.

l

More than 2,100 workers benefited from these efforts, with employers collectively reimbursing over 3.3 million U.S. dollar in eligible recruitment fee repayments.

Looking Ahead The RBA will expand its Advisory Services capacity in 2026 to further strengthen support for member companies with new training courses, increased consulting capacity in the Americas and Europe, and partnerships with additional sectors such as footwear and apparel.

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2025 ANNUAL REPORT

2025 ANNUAL REPORT

TRAINING AND CAPABILITY BUILDING RBA Learning Academy

More than

11,000

NEW ACCOUNTS WERE CREATED IN THE LEARNING ACADEMY IN 2025 and there were approximately

60,000

COURSE COMPLETIONS

In 2025, the RBA continued to expand its library of online content for members and their suppliers, adding the following trainings and other resources: l RBA Code of Conduct v8 (English, Chinese, Spanish, Thai, Malay, Japanese) l Regulatory Drivers of Zero Waste (English, Chinese) l Waste Minimization Toolkit (English, Chinese, Vietnamese) l Specialty Validated Assessment Program (SVAP) l Guide to Water Risk and Stewardship l Energy Efficiency and Renewable Energy Guide l Circular Economy Deep Dive Training l Biodiversity Training l RMI Risk Readiness Assessment 3.0 Training l RMI Responsible Minerals Assurance Process 2025 Training l Air Emissions and Noise Training l Guidance for Utilizing External Warehouses l RMI Guidance on the Risk of Misrepresentation of Primary Materials l RMI Standard Suite for Social, Environmental, OHS and Governance Risks l Water Management and Stewardship Training l Decarbonization and GHG Emissions Training l RMI Supply Chain Due Diligence Plus Module Training for Facilities l RMI Facility Standard for Social, Environmental, OHS and Governance Risks Training l RMAP Operations Manual l RMAP Standard Interpretation Guidance l Mastering the EMRT for EU Battery Regulation Compliance l RMI Mineral Reporting Templates Training l RMI Standards Deep Dive: Navigating Due Diligence, Assessments, and Regulatory Alignment for RMI Members Within the Learning Academy in 2025, there were more than 200 completions of the Factory Lead Certification Program, a training and certification program for factory staff. Factory Lead Certification is an important component of the Factory of Choice (FoC) and other Responsible Factory Initiative (RFI) programs. Factories with a Certified Factory Lead have 26 percent to 34 percent higher audit scores on average (varies by industry), fewer priority findings, and fewer overall findings.

Instructor-Led Trainings

Visit the Learning Academy

30 30

In 2025 the RBA held 29 instructor-led virtual Code of Conduct and VAP preparation workshop trainings for 837 participants, four Responsible Supply Chain Initiative (RSCI) trainings for 71 participants, and an RBA Specialty VAP (SVAP) on Forced Labor training for 14 participants. In addition, the RBA held four in-person trainings in Mexico; in Ciudad Juarez, Guanajuato, Guadalajara, and Tijuana.

2025 ANNUAL REPORT

RBA MEETINGS AND EVENTS Outreach Meetings Outreach Meetings are specifically geared toward members of RBA and its initiatives, suppliers and non-member companies and focus on salient global and regional topics as well as updates on the RBA and its Initiatives. In 2025 RBA held in-person Outreach Meetings in Brussels, Kuala Lumpur, and Tokyo.

RBA Outreach Meeting in Kuala Lumpur The RBA, in partnership with the Responsible Glove Alliance (RGA), hosted an Outreach Meeting in Kuala Lumpur, Malaysia on September 25. The event brought together government representatives, RBA members, non-member companies, and key stakeholders to engage in meaningful dialogue on important issues, including strategies for building resilient supply chains amid global uncertainty; addressing emerging labor issues and promoting responsible recruitment; and strengthening shared responsibilities in responsible business conduct. The meeting fostered collaboration, transparency, and actionable solutions to advance ethical practices across the supply chain.

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RBA Outreach Meeting in Brussels The RBA Outreach Meeting on May 13 in Brussels, Belgium provided an in-depth look at the evolving regulatory landscape and its impact on responsible business conduct. Participants examined strategies to address existing and emerging due diligence requirements, including the EU Corporate Sustainability Due Diligence Directive. Discussions also focused on supply chain mapping, responsible recruitment, living wage, and environmental due diligence. Updates on the RBA’s Responsible Minerals, Labor, and Environment Initiatives supported a broader conversation on alignment with rising global expectations.

RBA Outreach Meeting in Tokyo The RBA’s Outreach Meeting in Tokyo, Japan on April 9 focused on key developments shaping responsible business conduct in global supply chains, including current and emerging regulations, collaborations promoting ethical recruitment, best practices for industry to address social and environmental challenges, and real-world examples of forced labor remediation. Attendees also learned the latest on the EU Forced Labor Regulation and Simplification Omnibus, the RBA’s priorities for 2025, and how national policy can support more sustainable approaches to business.

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2025 ANNUAL REPORT

RBA & RMI Annual Conference and Member Meetings Responsible Business 2025 Conference Highlights More than 600 attendees came to the RBA’s annual conference, Responsible Business 2025, in National Harbor, Maryland, just outside of Washington, D.C., November 11-14. Many thanks to all the speakers, panelists and participants who joined us from all over the world to take part in the conference.

Members Day took place on November 11 and the morning featured a Town Hall where RBA staff discussed the next 5-year strategic plan with members.

In the afternoon, staff shared details on the RBA Code of Conduct.

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2025 ANNUAL REPORT

Later, members participated in roundtables on topics of their choosing, to learn more about the RBA’s Initiatives, emerging public policy priorities, Code of Conduct, Zero Waste Program, and supply chain mapping, as well as the RMI’s Responsible Minerals Assurance Process, Facility Standard, tools and platforms, and more.

RBA CEO Rob Lederer and Board Chair Joel Eurich kicked off the first day of the conference portion of Responsible Business 2025, on November 12, with opening remarks.

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2025 ANNUAL REPORT

Gilbert F. Houngbo, Director-General of the International Labour Organization then addressed the conference with an engaging speech.

During the “Responsible is Resilient” session that followed, senior executives explored how supply chain responsibility interacts with business understanding of risk management, and operational or supply chain resilience.

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2025 ANNUAL REPORT

Michael McGrath, EU Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection, addressed the crowd, prior to the next session.

The “Accelerating Responsible Business Conduct: Public Policies to the Rescue?” session focused on the latest macro developments in the regulatory landscape in the area of responsible business conduct.

The second day of the conference began with compelling remarks by Liberia’s Former President and Nobel Laureate Ellen Johnson Sirleaf.

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2025 ANNUAL REPORT

The afternoons of both conference days featured breakout sessions on numerous salient topics, including forced labor prevention, responsible sourcing of materials, critical minerals, human rights due diligence, decarbonization and circularity, global manufacturing trends and sustainability, artificial intelligence for site assessments, renewable energy access, public procurement, supply chain transparency and UNTP, living wage, remedy, double materiality, supplier relationships, and more.

View more photos on Flickr

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RBA ON THE MOVE

Meeting with Ministers, Members and Stakeholders in Taipei City The RBA met with the Labor Minister and Deputy Economy Minister in Taipei City in November, to discuss industry supply chain due diligence programs, responsible business conduct policies, and responsible labor capacity-building efforts. The RBA and its Responsible Labor Initiative (RLI) also met with members to present the RBA’s five-year strategic plan, share updates on regulatory developments, and provide an overview of key programs and tools.

UN Forum on Business and Human Rights in Geneva At the UN Forum on Business and Human Rights 2025, the RBA joined a plenary discussion on the role of assessment and verification systems in access to remedy. The RBA emphasized that assessment and verification are important tools, but only one piece of the broader due diligence landscape. Remedy requires collective action, worker engagement, and collaboration across stakeholders to address root causes and ensure rightscompatible solutions.

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Government and Industry Workshop in Bangkok On October 20, Thailand’s Ministry of Justice and the RBA jointly hosted a key national industry consultation regarding proposed due diligence legislation drafted by the Thai government. The event was a great opportunity for businesses and industry to weigh in on priorities for the design and implementation of due diligence policies. Participants raised concerns and offered solutions relating to ensuring legal certainty and feasibility while effectively aligning with international due diligence standards and existing industry practices and tools.

Stakeholder Roundtable and Member Event in Kuala Lumpur While in Kuala Lumpur, Malaysia for the RBA Outreach Meeting, the RBA hosted a stakeholder roundtable discussion on September 24, bringing together representatives from IOM, IJM, NSI Malaysia, Global Shepherds, Proforest, Earthworm, and Issara. The discussion focused on ongoing challenges and emerging efforts in ethical recruitment and worker protection across supply chains. On September 25, the RBA also hosted a networking lunch for members in the region.

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European Parliament Conference in Brussels On September 23, the RBA joined an event at the European Parliament in Brussels, Belgium organized by the Danish Institute for Human Rights and hosted by key MEPs from different political groups. The discussion focused on the implications of the omnibus legislation on the EUCSDDD proposal, the future of mandatory due diligence in Europe, and the ongoing negotiations shaping the simplified directive.

UN High-Level Week Sessions in New York The RBA took part in a variety of sessions in New York City during the UN High-Level Week, September 22-26, as part of the wider gathering of the United Nations General Assembly. Through these events, the RBA engaged industry members and key policymakers in attendance, such as the Democratic Republic of the Congo’s Minister of Mines, the ILO Director-General, and the U.S. Deputy Secretary of Labor.

Climate Week in New York The RBA’s Responsible Environment Initiative (REI) participated in roundtable discussions and other sessions focused on water stewardship, circularity, critical minerals, and decarbonization, and attended events led by RBA members during Climate Week NYC, September 21-25. The annual event highlighted the actions of climate leaders across the areas of tech, politics, academia, and civil society.

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2025 ANNUAL REPORT

UNRBHR Forum in Bangkok The RBA’s Responsible Labor Initiative (RLI) participated in the UNRBHR Forum in Bangkok, Thailand, September 16-19. The theme of the 2025 forum was Anchoring Progress and Strengthening Regional Leadership on Human Rights through Crisis, and it consisted of 90 sessions with stakeholders from governments, CSOs, trade unions, and businesses.

Chemical Watch Regulatory Summit in Alexandria The RBA presented on Supply Chain Due Diligence on Chemical Management at the Chemical Watch Regulatory Summit North America 2025: Chemicals Management for Electronics event, held September 1516 in Alexandria, Virginia. The RBA highlighted its industry Focus Process Chemicals Policy, Specialty VAP on Chemical Management, and new Chemical Management Leadership Program.

Tantalum-Niobium International Study Center General Assembly in Cape Town The RBA’s Responsible Minerals Initiative (RMI) participated in the 66th General Assembly of the Tantalum-Niobium International Study Center (TIC), held in Cape Town, South Africa, from September 14– 17. The RMI delivered a presentation highlighting the modular approach of the RMI Due Diligence Guidance Ecosystem and emphasized how the framework supports flexible implementation across diverse supply chain contexts, while maintaining alignment with international expectations for responsible sourcing.

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2025 ANNUAL REPORT

Meeting with U.S. Deputy Secretary of Labor in Washington, D.C. U.S. Deputy Secretary of Labor Keith E. Sonderling and RBA CEO Rob Lederer met at the U.S. Department of Labor offices in Washington, D.C. to discuss the RBA’s role as a trusted advisor to governments and introduce the RBA and the work and priorities of its members to the Deputy Secretary.

Samsung Vietnam Synergy Workshop On July 31, the RBA spoke at the Samsung Vietnam Synergy Workshop, where representatives from 13 Samsung subsidiaries gathered to discuss global regulations and stakeholder engagement. The discussions underscored the importance of collaboration in advancing responsible business practices.

Malaysia Rubber Industry ESG Conference in Kuala Lumpur The RBA’s Responsible Glove Alliance (RGA) and the RBA’s Responsible Factory Initiative (RFI) attended the Malaysia Rubber Industry ESG Conference. The event brought together rubber industry players, policymakers, and sustainability experts to address the latest regulations, social compliance, environmental issues, and corporate governance.

The RGA and RFI were featured in the conference exhibition, showcasing each initiative’s programs, tools, and collaborative efforts.

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U.S. Chamber of Commerce Human Trafficking Event in Washington, D.C. The RBA participated in the U.S. Chamber of Commerce’s “Approaches to Combating Human Trafficking” event in Washington, D.C. on July 21, contributing to the session on “Technology for Good.” The discussion focused on how companies are addressing forced labor in global supply chains through best practices, including assessments and remediation.

Ministry of Trade and Investment HRDD Training in Kuala Lumpur The RBA co-hosted a training session for 70 officials from Malaysia’s Ministry of Trade and Investment, focused on Human Rights Due Diligence (HRDD) in global supply chains. The session explored key EU efforts, including its Forced Labor Regulation, Carbon Border Adjustment Mechanism, Batteries Regulation, and Corporate Sustainability Due Diligence Directive, and how other Asian countries have aligned with international standards.

Meeting with Minister of Labor and DGs in Taipei City In Taipei City, the RBA met with the Minister of Labour Hung Sun-han and senior officials from key departments including General Planning, the Workforce Development Agency, and the Occupational Safety and Health Administration. Discussions focused on international forced labor regulations, ethical recruitment, and collaborative solutions to address root causes of supply chain risks.

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2025 ANNUAL REPORT

National Conference on RBC in New Delhi, India The RBA attended India’s third National Conference on Responsible Business Conduct, July 2-3, in New Delhi. The Conference was keynoted by the Minister of State of Corporate Affairs and attended by more than 500 participants from ministries, international organizations, businesses, academia, and NGOs. The RBA contributed to two key panels: one on the EUCSDDD and its implications for Indian industries; and one on building resilient, sustainable supply chains. During the conference, the RBA also met with Shri Harsh Malhotra, Hon’ble Minister of State, Ministry of Corporate Affairs, to discuss shared priorities.

GFC OEWG Conference in Punta del Este At the Global Framework on Chemicals (GFC) Open-Ended Working Group (OEWG) conference in Punta del Este, Uruguay at the end of June, the RBA participated on a panel on Data Transparency and the UNEP/FAO’s session on KnowledgeSharing on Priority Chemicals of Concern. The RBA also spoke at the Electronics Industry Sector Workshop, in which the RBA’s Industry Focus Process Chemical Policy, SVAP on Chemical Management, and Chemical Management Leadership Program were highlighted.

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2025 ANNUAL REPORT

RBA Leadership Circle in San Francisco The RBA convened a two-day Leadership Circle meeting of industry leaders from a diverse cross-section of the RBA to help inform the next 5-year plan (2026–2030). Participants connected with peers, shared perspectives on key trends, challenges, and opportunities impacting due diligence and responsible business conduct in supply chains, and unpacked results from an RBA membership survey.

Critical Minerals Conference in Jakarta The RBA’s Responsible Minerals Initiative (RMI) took part in a series of panels and workshops at the Critical Minerals Conference in Jakarta, Indonesia, engaging key stakeholders in the nickel, cobalt, and tin sectors. Highlights included participation in the APNI Forum, an ICM workshop, the ICM Green Construction panel, a GIZ roundtable, and the Ni & Co & EV Forum.

ILO Fair Recruitment Conference in Geneva The RBA’s Responsible Labor Initiative (RLI) staff participated in the International Labour Organization (ILO) Global Conference on Fair Recruitment, which was held from May 19-20 in Geneva, Switzerland. The RLI provided perspectives on how data interoperability can help foster greater transparency and drive ethical recruitment practices, as well as an update on the Responsible Recruitment Program and RBA supply chain mapping efforts.

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2025 ANNUAL REPORT

Cobalt Congress in Marina Bay At Cobalt Congress 2025 in Marina Bay, Singapore, the RBA’s Responsible Minerals Initiative (RMI) joined the Cobalt Institute and leaders from the Democratic Republic of the Congo and Indonesia in panels on “DRC: Turning Regulation and Strategic Intention into Practical Implementation,” and “Indonesia: Fostering a Sustainable, Responsible and Transparent Cobalt Value Chain.” The RMI discussed responsible minerals value chains, critical minerals producing countries, and the RMI’s standards and assessments.

RBA-BMZ-GIZ Conference in Brussels The RBA, BMZ and GIZ co-hosted a conference in Brussels, Belgium on May 14. The event, “Due Diligence at a Crossroads: Paths to Greater Impact,” convened policymakers, industry leaders, and civil society to address the evolving landscape of Human Rights and Environmental Due Diligence and the implementation of the EU Corporate Sustainability Due Diligence Directive (CSDDD).

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2025 ANNUAL REPORT

Circularity 25 in Denver The RBA’s Responsible Environment Initiative (REI) joined the Circular Electronics Partnership at Circularity 25 in Denver, Colorado, to highlight priorities for advancing circularity in the electronics industry. As part of a panel discussion, the RBA shared key insights from its Circular Materials Landscape Assessment, including recommendations to enable more responsible and effective circular practices across the sector.

OECD Forum in Paris The RBA’s Responsible Minerals Initiative (RMI) led a partner session at the OECD Forum on Responsible Mineral Supply Chains on May 6, focused on interoperability across responsible minerals standards. Discussions covered benchmarking, mutual recognition, data-sharing, and other practical pathways to interoperability. Participants emphasized how aligned systems can support effective upstream-to-downstream due diligence, improve market access for artisanal producers, and enhance the quality and usability of shared data.

Meeting with Government Ministries and Agencies in Jakarta As part of the RBA’s Producing Country Engagement Strategy, on April 17 the RBA presented research on the implications of HRDD regulations on Indonesia during a policy dialogue meeting in Jakarta with six ministries and agencies. Attendees included officials from the Ministries of Human Rights; Manpower; Energy and Mineral Resources; and Law; the Coordinating Ministry of Planning; and the National Human Rights Commission. The DirectorGeneral of Human Rights, Ministry of Human Rights, opened the dialogue.

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2025 ANNUAL REPORT

Ethical Recruitment Symposium in Tokyo The RBA, ILO, and JP-MIRAI jointly held a Symposium on Ethical Recruitment and Challenges for Migrant Workers on April 8. More than 200 people joined, in person and online. Key speakers in addition to the RBA included the Ministry of Justice of Japan, the Chairman of JP-MIRAI, and the ILO.

Japan Electronics Information Technology (JEITA) Meeting in Tokyo The RBA met with the Japan Electronics and Information Technology Industries Association (JEITA) in Tokyo to discuss recent achievements of the RBA’s Responsible Minerals Initiative and the road ahead for responsible minerals sourcing. The conversation highlighted expanded RMI support for smelters and refiners, including investments in technical assistance and 1:1 training to improve conformance, among other issues.

IPC EXPO in Anaheim The RBA’s Responsible Environment Initiative (REI) attended the IPC APEX EXPO 2025 in Anaheim, California, participating in meetings of the 2-18 Supplier Declaration Subcommittee and 2-19E Data Collection and Reporting for Sustainability Compliance Task Group. Alongside several RBA members, the RBA engaged technical experts from a diverse range of industries to advance development of IPC1757, a new process chemical declaration standard.

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2025 ANNUAL REPORT

ATEA Sustainability Focus Forum in Oslo At the ATEA Sustainability Focus Forum in Oslo, Norway, the RBA outlined key priorities for 2025, and the collective action needed to drive responsible business conduct throughout global supply chains. The discussion also highlighted the RBA’s work on living wage, remedy, and supply chain mapping to support more resilient and ethical operations.

BMW-Sustain SC Furnam University Event in Greenville At “Driving a Responsible Future: Navigating the Road Ahead,” hosted by BMW, Sustain SC and Furman University in Greenville, South Carolina, panelists explored the role of business in shaping ethical supply chains, engaging communities, and collaborating across industries. RBA CEO Rob Lederer emphasized that businesses can’t tackle global challenges alone, reinforcing the RBA’s role in working alongside governments, industries, and civil society.

RBA-EPP Conference in Brussels The RBA-EPP joint conference, “Driving Effective Due Diligence: Omnibus Unpacked,” in Brussels, Belgium began with remarks by MEP Axel Voss of the EPP Group in the European Parliament and RBA CEO Rob Lederer, and a keynote address by Nils Behrndt, Deputy Director-General at DG Justice, European Commission. Policymakers, industry, and other stakeholders discussed the proposed EU Simplification Omnibus package on due diligence, with a focus on the EUCSDDD. 49

2025 ANNUAL REPORT

IOM Workshop in Kathmandu The RBA’s Responsible Labor Initiative (RLI) presented findings from its Responsible Recruitment Program and potential next steps during the IOM Ethical Recruitment Workshop in Kathmandu, Nepal from February 25-28. The RLI focused on the need to create a process to drive demand for ethical recruitment via members and their suppliers while working closely with partners to increase supply of private recruitment agencies.

IOMC Workshop in Paris The RBA’s Responsible Environment Initiative (REI) attended a multi-stakeholder workshop hosted by the Inter-Organization Programme for the Sound Management of Chemicals (IOMC) at the OECD in Paris, France from February 24-26 to collaborate with IGOs, policymakers, civil society, and other stakeholders on industry and financial sector actions to implement the internationally adopted Global Framework on Chemicals (GFC).

Ethical Recruitment Workshop in Penang The RBA’s Responsible Labor Initiative (RLI) delivered remarks at an ethical recruitment workshop in Penang, Malaysia, organized by The Fair Hiring Initiative’s on the Level (OTL) program, Feb. 18-19. The event recognized private recruitment agencies nearing completion of the RBA’s Responsible Recruitment Program (RRP) and provided a platform to discuss next steps in advancing a viable market for ethical recruitment.

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2025 ANNUAL REPORT

Mining Indaba Conference in Cape Town During African Mining Indaba in Cape Town, South Africa in February, the RBA’s Responsible Minerals Initiative (RMI) co-hosted a session with the OECD and London Metal Exchange (LME), chaired a panel on remedy, and participated in the Global Investor Commission on Mining 2030 roundtable organized

by Chronos Sustainability, contributing to discussions on corporate responsibility in mineral sourcing.

Meeting with European Commission in Brussels The RBA and its Responsible Labor Initiative (RLI) staff met with representatives from the European Commission’s DG Trade, DG Grow, and the European External Action Service on January 21 to discuss the implementation of various EU legislative efforts, including the EUFLR and the EUCSDDD. Several issues were addressed, including the need to engage industry practitioners early in the process of drafting implementation guidelines and other guidance documents to reflect realworld experience on forced labor due diligence.

CES Conference in Las Vegas The RBA’s Responsible Environment Initiative (REI) participated in a panel at CES 2025 in Las Vegas, Nevada along with members Google, Lenovo and Panasonic. The discussion focused on Circular Economy Innovations, featuring insights into efforts toward plastic-free packaging, deploying refurbished equipment, and ambitious corporate sustainability goals.

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2025 ANNUAL REPORT

SUPPLY CHAIN MAPPING AND THE RESPONSIBLE BUSINESS TRANSPARENCY PROTOCOL Advancing a Global, Interoperable Supply Chain Data Ecosystem In 2025, the RBA advanced its strategy to build a decentralized, interoperable, and verifiable supply chain data ecosystem. Through its Supply Chain Mapping program and the continued development and piloting of the Responsible Business Transparency Protocol (RBTP), the RBA is addressing longstanding challenges that have constrained transparency, due diligence, and sustainability performance across global value chains.

33,000 FACILITY RECORDS CLEANED

22,631

Building the Foundation: Unified Facility Database To lay the foundation for high-integrity data about facilities in supply chains, the RBA has been building a Unified Facility Database, a centralized resource that aggregates, cleans, standardizes, and verifies facility‑level data to support responsible sourcing, risk identification, and due diligence.

Key elements of this work include: l

Data cleaning and deduplication at scale, resulting in more than 33,000 facility records cleaned and 22,631 OS IDs assigned, enabling cross‑platform interoperability and improved accuracy of location and facility attributes

l

Standardization of identifiers and classifications, including broad application of ISIC 4 taxonomy to more than 12,600 locations, enabling consistency in facility characterization across industries and regulatory frameworks

OS IDs ASSIGNED

Broad application of ISIC 4 taxonomy to more than

12,600 LOCATIONS

This improved data foundation strengthens subsequent supply chain visibility and integrity of supply chain facility data. Looking ahead to 2026, the RBA will work to enable the incorporation of value chain companies assessed by other standard schemes and data gathered by members through annual Mineral Reporting Template (CMRT, EMRT, AMRT) rollups.

Launching the Responsible Business Transparency Protocol In 2025, the RBA launched the Responsible Business Transparency Protocol (RBTP), an industry extension of the United Nations Transparency Protocol (UNTP) for the electronics and automotive industries. Built on W3C verifiable credentials, the RBTP is designed to replace static, siloed documents — such as spreadsheets, PDFs, and proprietary portals — with verifiable, portable, and machine‑readable digital credentials that allow supply chain actors to share data securely, selectively, and interoperably

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2025 ANNUAL REPORT

across systems. These credential types include: Digital Product Passports (DPPs), Digital Facility Records (DFRs), Digital Traceability Events (DTEs), and Digital Conformity Credentials (DCCs).

This protocol‑based model helps ensure that organizations retain ownership over their own data, that disclosure is controlled by the originating organization, and that verified sustainability, due diligence, and traceability claims can move more easily across diverse technical ecosystems.

RBTP Collaborative Pilot: Testing Real‑World Complexity Beginning in late 2025, the RBA launched a major multi‑stakeholder pilot to validate the RBTP in real supply chain environments. The pilot involved more than 24 organizations — including upstream producers, downstream buyers, standards bodies, and a government agency — across minerals essential to modern electronics: copper, cobalt, and lithium.

The pilot evaluated how verifiable credentials can address real‑world challenges such as: l

Flow of upstream certifications (e.g., IRMA, Copper Mark) to downstream actors

l

Handling non‑participating or low‑digital‑maturity supply chain nodes

l

Diverse willingness to share data among commercial partners

l

Linking chain‑of‑custody claims across tiers

l

Managing legacy, partial, or inconsistent data formats

Outcomes included: l

Verification of RBTP’s portability, flexibility, and technology neutrality

l

Insights to strengthen vendor tool ecosystems

l

Demonstrated interoperability with other industry frameworks and digital product passport schemes

Scaling the Protocol: Digitizing RBA Tools and Standards The RBA plans to progressively integrate its assessment tools and reporting frameworks into RBTP‑aligned digital credentials, including: l

RMI and RBA standard assessments to be issued as Digital Conformity Credentials

l

Facility‑level data (metadata, emissions, waste, chemicals, worker voice, recruitment agencies) captured in Digital Facility Records

l

Minerals Reporting Templates (CMRT, AMRT) and Self‑Assessment Questionnaires in RBTP‑aligned structures

As the Sustainability Vocabulary Catalogue (SVC) matures, assessment criteria from multiple schemes — not only RBA and RMI tools — can be digitized, mapped, and correlated, supporting mutual recognition and cross‑scheme equivalence.

Member Engagement and Next Steps To support adoption and scale, the RBA has launched broad member and company engagement through a Supply Chain Mapping Work Group and dedicated RBTP technical and supply chain engagement sub‑teams, as well as a Software Implementers’ Network to guide solution providers in enabling RBTP/ UNTP‑aligned data exchange on commercial software.

In 2026, members should be able to access and distribute digital conformity credentials for RMAP and VAP assessments, view cleaned facility data with OS IDs and ISIC classifications, and benefit from increasing interoperability across all RBA tools.

The collaborative pilot concluded in February 2026.

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2025 ANNUAL REPORT

DATA ANALYTICS IN RBA-ONLINE In 2025, the RBA’s Data Analytics team strengthened its role as a trusted partner for members seeking to understand and act on their supply chain data. Beyond developing dashboards and custom datasets, the team worked closely with members to help them navigate RBA’s data resources and uncover useful insights. By guiding members through analysis and benchmarking, the team helps data drive meaningful improvements and amplifies the overall value of RBA membership.

The Data Analytics team increased the number of API endpoints available in 2025, increasing members’ data automation capabilities.

Members now have access to APIs for the new RMI Facility Standard assessments, and the RBA also added the ability to retrieve assessment documents through the existing APIs. The APIs are a benefit of membership for RMI and RBA members, with more than 40 member companies currently taking advantage of RBA and RMI APIs to automatically extract assessment and supply chain data.

View the RBA-Online video

Visit the RBA-Online webpage

Facility data is an ongoing focus of the Data Analytics team. Last year, the RBA partnered with Open Supply Hub to clean, dedupe and validate facility records. This work also maps facility data to a common identifier, the OSID, enabling RBA members to more easily connect their RBA data to other systems to advance traceability and data sharing. The RBA assigned the first OS IDs in December 2025 and will be processing further changes to records throughout 2026.

Each year, the RBA collects, manages and analyzes more data about supply chains. Notably, in 2025, the RBA cataloged 36,000 Worker Voice surveys, up 12 percent over 2024. In 2025, the RBA also collected over 500,000 worker-days’ worth of working hours data, enabling broader visibility into working conditions.

Building on 2025’s momentum, the team remains dedicated to advancing data quality, consistency, and accessibility in the year ahead. By strengthening reporting and analytical capabilities across the RBA’s broad array of initiatives, the team will continue to empower members with trusted information to help drive measurable impact.

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2025 ANNUAL REPORT

2025 ANNUAL REPORT

VAP IMPROVEMENTS With invaluable feedback from members, governments, assessment firms, and stakeholders, we were able to make significant improvement to the RBA’s flagship Validated Assessment Program (VAP) in 2025.

One of the most notable changes was allowing the assessment firm and the company being assessed to connect directly to schedule the assessment. This adjustment has streamlined the scheduling process, making it more efficient and faster for all parties involved. In some cases, this change alone reduced the cost of the assessment.

Another key improvement was enabling all approved assessment firms in the region where the request originated to bid on the assessment. This has fostered a more competitive environment.

Additionally, the RBA took steps to improve data by incorporating drop-down boxes wherever possible, which has greatly enhanced data accuracy and enabled advanced analytics.

Visit the VAP webpage

Perhaps the most impactful change in 2025 was the introduction of a new template that assists assessors in reducing their reportwriting time by 70 percent. This tool not only ensures correct spelling and better grammar, making reports easier to understand, but also provides drop-down boxes for frequently used data such as sample size. As a result, VAP cycle time has improved by more than 40 percent, a benefit to members and those being assessed.

The RBA remains committed to making the VAP easier to use, faster to schedule, and more cost-effective. Efforts to further streamline the program, which will be implemented in 2026, include major process improvements, eliminating waste, reducing time on site, and leveraging secure AI where appropriate.

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2025 ANNUAL REPORT

2025 ANNUAL REPORT

VAP ASSESSMENTS:

BY THE NUMBERS VAP Assessments Performed

Average Assessment Scores

n Closure Assessments n Initial Assessments

n Initial Assessments n Closure Assessments

2,138 1,959

2,217 176

478

562 514

141

174

170

144

145

1,739 1,445

2023

1,576

2024

2025

2023

2025

2024

The total number of VAP and SVAP assessments conducted increased from 2,138 in 2024 to 2,217 in 2025, and average initial assessment scores increased slightly while closure assessment scores decreased slightly year over year.

2025 Assessments by Location In 2025, factories in China continued to represent the plurality (43 percent) of all assessments conducted, with the next highest percentages of assessments conducted in: Vietnam (9 percent); Chinese Taipei (8 percent); Malaysia (6 percent); Japan, Thailand and the United States (5 percent each); Mexico and India (3 percent each); South Korea, Philippines, and Singapore (2 percent each), and others.

VIETNAM

9%

JAPAN

5%

THAILAND

5%

UNITED STATES

5%

CHINA

43% CHINESE TAIPEI

8%

MEXICO

3%

INDIA

3%

MALAYSIA

6%

56

PHILIPPINES

2%

2%

2%

BRAZIL

1%

TURKEY

SOUTH KOREA

SINGAPORE

1%

GERMANY

1%

OTHER

4%

2025 ANNUAL REPORT

VAP ASSESSMENTS:

BY THE NUMBERS 2025 VAP Findings By Section 11.84%

18.32%

Other

2.81%

Control Processes

Energy Consumption and Greenhouse Gas Emissions

3.27%

Prohibition of Forced Labor

5.83%

Wages and Benefits

9.72%

Working Hours

2025 6.50%

Occupational Health and Safety

6.56%

9.58%

Emergency Preparedness

Performance Review and Continuous Improvement

7.69%

Supplier Responsibility

9.57%

Risk Assessment

8.31%

Communication

Other (22 Sections) Industrial Hygiene

1.92%

Freedom of Association and Collective Bargaining

0.31%

Occupational Injury and Illness

1.75%

Company Commitment

0.30%

Food, Sanitation and Housing

1.39%

Materials Restrictions

0.26%

Non-Discrimination / Non-Harassment / Humane Treatment

0.98%

Physically Demanding Work

0.24%

Air Emissions

0.72%

Young Workers

0.21%

Hazardous Substances

0.70%

Business Integrity and No Improper Advantage

0.18%

Machine Safeguarding

0.68%

Disclosure of Information

0.16%

Environmental Permits and Reporting

0.60%

Intellectual Property

0.13%

Responsible Sourcing of Minerals

0.45%

Privacy

0.07%

Solid Waste

0.35%

Protection of Identity and Non-Retaliation

0.05%

Water Management

0.35%

Fair Business, Advertising and Competition

0.04%

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2025 ANNUAL REPORT

VAP ASSESSMENTS:

BY THE NUMBERS Average Weekly Working Hours In 2025

In 2025, Cambodia had the highest number of average working hours per week (56.4), followed by China (55.1), Vietnam (51.4), Thailand (50.8), the Philippines (47.8), and Malaysia (47.7).

Working Hours at Member and Non-Member Facilities On average, workers in RBA member facilities worked 4.9 fewer hours per week than their counterparts in non-member facilities in 2025.

Member

Non-Member

58

45.7 50.6

2025 ANNUAL REPORT

MEMBERSHIP GROWTH The RBA and its initiatives (RMI, RLI, RFI, RGA) ended 2025 with a total of 635 members, up from 614 in 2024.

The total number of core RBA members (not counting the initiatives) was 278 at the end of 2025, up from 256 at the end of 2024.

RBA Membership Growth

n RBA

n RMI n RLI

700

614

587 600

n RGA 635

516 469

500 400 300

n RFI

242

350

307

267

391

200 100 0 2016

2017

2018

2019

2020

2021

2022

2023

2024

2025

Members’ Headquarters in 2025 1.08% each

Canada, Denmark, France

2.16%

Singapore

0.72% each Hong Kong, Norway

0.36% each

Australia, Brazil, Ireland, Turkey

2.52% each Sweden, Switzerland, Malaysia, United Kingdom

3.24% each China, Netherlands

2025

50.36%

United States

3.60% each

Germany, Korea

8.27%

Chinese Taipei

9.35%

View the Membership video

Japan

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2025 ANNUAL REPORT

FY 2025 FINANCIAL HIGHLIGHTS FY 2025 Operating Revenue

$ 39,103,896

13% RMI

15% Other

36%

Membership Dues

36% VAP Assessments

FY 2025 Operating Expenses

6%

$ 36,842,442

Administration

8%

Learning & Capabilities

45%

13%

VAP Compliance/ Assessments

RMI

28%

Issues Management

*The RBA’s fiscal year runs from January 1 through December 31. Percentages have been rounded.

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