Conflicts Minerals Policy

Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas Policy
Recognising that risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognising that we have the responsibility to respect human rights and not contribute to conflict, we commit to adopt, widely disseminate and incorporate in contracts and/or agreements with suppliers the following policy. We commit to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

I. Serious abuses associated with the extraction, transport or trade of minerals:
We will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:
i) any forms of torture, cruel, inhuman and degrading treatment;
ii) any forms of forced or compulsory labour;
iii) child labour;
iv) other gross human rights violations and abuses;
v) war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

II. Direct or indirect support to non-state armed groups, public or private security forces.
We will not tolerate any “Direct or indirect support” to non-state armed groups or security forces or their affiliates who:
i) illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
ii) illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
iii) illegally tax or extort intermediaries, export companies or international traders.

III. Bribery and fraudulent misrepresentation of the origin of minerals:
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.

IV. Regarding money laundering:
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

V. Payment of taxes, fees and royalties due to governments.
We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI).