Responsible Sourcing Policy

Scope

This policy applies to all material we receive, refine, hold or trade, and to every supplier, agent and counterparty in our supply chain.

Supply-chain due diligence

We apply risk-based due diligence informed by internationally recognised responsible-minerals principles, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Reference to these principles describes our approach; it is not a claim of certification or membership.

Supplier onboarding covers legal identity, licensing, beneficial ownership, origin of material, transport route and payment channel.

Red flags and escalation

Material is declined where origin cannot be evidenced, where documentation is inconsistent, where a counterparty or route carries conflict, sanctions or human-rights risk, or where payment arrangements cannot be traced through regulated channels.

Records and review

Origin documentation, assay and weight records, export permits and transaction files are retained and reviewed. This policy is reviewed periodically and updated as requirements change.