Human Rights Policy

Except as noted herein, this Human Rights Policy (“Policy”) applies worldwide to all officers, directors, employees and contractors of Howmet Aerospace Inc. and all of its U.S. and international subsidiaries, affiliates, partnerships, ventures and other business associations that are effectively controlled by Howmet Aerospace Inc., directly or indirectly (collectively, “Howmet Aerospace”, “we” or “us”). Howmet Aerospace also expects all suppliers to adhere to the principles outlined in this Policy.

Howmet Aerospace is committed to promoting human rights in the communities in which we operate. In furtherance of this commitment, Howmet Aerospace has implemented this Policy which establishes its policies and procedures within our business and throughout our supply chain to protect human rights.

This Policy is guided by the international human rights principles encompassed by the United Nations’ Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the principles concerning fundamental rights set out in the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

Guiding Principles

Howmet Aerospace’s Human Rights Policy comprises the following principles:

Children and Young Workers

As a fundamental principle, we do not employ children or support the use of child labor. We do encourage the creation of educational, training or apprenticeship programs tied to formal education for young people.

Freedom of Engagement

We believe that people should work because they want or need to, not because they are forced to do so. We prohibit the use of prison labor, forcibly indentured labor, bonded labor, slavery, or servitude.

Equality of Opportunity

We are an equal opportunity employer that supports diversity and inclusion. We provide equal employment opportunities for all employees and applicants for employment, and prohibit discrimination and harassment of any type without regard to race, color, religion, age, sex (including pregnancy), national origin, disability, genetics, protected veteran status, sexual orientation, gender identity or expression, or any other characteristics protected by law. This Policy applies to all terms and conditions of employment including recruiting, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absences, compensation and training.

Compensation

We ensure that compensation meets or exceeds the legal minimums and is competitive with industry standards. Our compensation philosophy is clearly communicated to employees and is in full compliance with all applicable laws.

Working Hours

We provide employees with regulated hours of work, including but not limited to vacation time, holidays, and any periods of paid time off that are required by applicable law. Rules are in place to approve overtime and reduce safety risks, which includes limiting extended work hours for our US facilities.

Freedom of Association

We recognize and respect the freedom of individual Howmet Aerospace employees to join, or refrain from joining, legally authorized associations or organizations.

Relationships with Indigenous People

Within the framework of our values, we respect the cultures, customs and values of the people in communities in which we operate and take into account their needs, concerns, and aspirations.

Supplier Standards

Howmet Aerospace requires our suppliers to comply with all applicable laws, rules, regulations, orders, conventions, ordinances and standards. In connection with this requirement, all suppliers must adhere to Howmet Aerospace’s Supplier Code of Conduct which sets forth the sustainable ethical and business practices required to do business with us.

Speak-Up Culture

Howmet Aerospace strives to create an environment which empowers employees and stakeholders to ask questions and raise concerns relating to Howmet Aerospace’s policies, procedures and compliance with applicable laws. Employees, stakeholders and any individuals may use Howmet Aerospace’s Integrity Line https://www.howmet.com/integrity-line to report any suspected violations of this Policy.

In addition, employees are encouraged to contact anyone in our Integrity Help Chain to report concerns:

• Supervisors or Team leaders
• Human Resources Department
• Ethics and Compliance
• Legal Department
• Subject matter experts (e.g., Corporate Finance, Audit, Procurement, Security)

Any form of retaliation against employees who raise concerns under this Policy is strictly prohibited.

Penalties for Violation

Violations of this Policy may result in disciplinary action, up to and including termination.