Sustainable Procurement

Responsible Sourcing

◆ Responsible Sourcing of Minerals Policy:
Identify minerals from conflict-affected and high-risk areas, and avoid purchasing minerals that cause conflict or serious human rights violations.

◆ Responsible Sourcing Commitment:
The Company has adopted a policy of conducting due diligence on the source and chain of custody of tantalum, tin, tungsten and gold in its production to provide reasonable assurance that the source is consistent with the Organization for Economic Cooperation and Development (OECD)  Due Diligence Guidance for Mineral Supply Chains in Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework.

◆ Responsible Sourcing of Minerals Objective:
#Direct supplier sourcing of conflict minerals from smelters whose due diligence practices have been validated by independent third-party auditors 

#Implemented due diligence measures for responsible sourcing of minerals 

#Conflict minerals surveys of relevant suppliers are conducted  

#Due diligence information submitted by suppliers is reviewed against company expectations  

#Validation process includes corrective action management

Restrictive measures

◆ EU import and purchase restriction of iron and steel products  originating in Russia (EU) No. 833/2014
Regulation (EU) No. 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.

◆ Declaration of non- use of iron and steel products originating in Russia  (Declaration of Regulation (EU)833_2014 / Test certificate)
We have confirmed with our suppliers that we do not directly or indirectly import Annex XVII steel products originating in or exported from Russia.