Publication Date: October 27, 2023
Last Reviewed: [e.g., October 27, 2025]
Policy Owner: Supply Chain Department / Sustainability Office
1. Policy Statement
[Your Company Name] is committed to conducting business responsibly throughout our global supply chain. We recognize that the trade of certain minerals from Conflict-Affected and High-Risk Areas (CAHRAs) can potentially finance or fuel human rights abuses, environmental degradation, and armed conflict. Therefore, we commit to not sourcing minerals that directly or indirectly contribute to serious human rights violations.
This policy outlines our commitment to responsible mineral sourcing and the due diligence framework we implement to ensure that tin, tantalum, tungsten, gold (3TG), and other critical minerals in our supply chain are sourced ethically.
2. Scope & Applicable Minerals
This policy applies to [Your Company Name], all its subsidiaries, business units, and our global supply chain.
The initial focus of this policy is on Tin (Sn), Tantalum (Ta), Tungsten (W), and Gold (Au), commonly referred to as "Conflict Minerals." We will extend this due diligence process to other critical minerals deemed high-risk (e.g., Cobalt, Mica, Lithium) based on business evolution, industry best practices, and regulatory requirements.
3. Standards & Framework
Our responsible minerals sourcing practices are aligned with the following internationally recognized standards:
The Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
The Responsible Minerals Initiative (RMI) and its related assessment tools.
We encourage supplier participation in industry validation programs such as the Responsible Minerals Assurance Process (RMAP).
4. Due Diligence Management System
We have established a supply chain due diligence management system based on the OECD's five-step framework:
Step 1: Establish Strong Company Management Systems
Develop and publicly communicate this policy.
Establish an internal management structure with clear responsibilities led by the Procurement Department.
Implement a supplier engagement and training mechanism.
Maintain a confidential grievance mechanism for stakeholders to report concerns (e.g., [email protected]).
Step 2: Identify and Assess Risks in the Supply Chain
Request direct suppliers to disclose their smelter/refiner (SOR) information using standardized surveys (e.g., RMI's CMRT).
Cross-reference collected SOR data with independently audited conformant lists such as the RMAP Conformant Smelter & Refiner Lists.
Identify unverified or high-risk sources.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
For suppliers or smelters/refiners identified with risks, we will engage with them to develop a corrective action plan.
If risks cannot be mitigated within a reasonable timeframe, we will consider suspension or termination of the relationship.
We prioritize sourcing from RMAP-conformant or equivalent independently validated smelters and refiners.
Step 4: Carry out Independent Third-Party Audit of Supply Chain Due Diligence
We encourage and expect our direct suppliers to promote participation by their upstream suppliers, particularly smelters/refiners, in independent third-party audit programs like the RMAP.
We will utilize the outcomes of these audits to validate supply chain conformance.
Step 5: Report on Supply Chain Due Diligence
We will annually report on our progress and findings regarding responsible minerals supply chain due diligence, typically through our Sustainability Report or a dedicated Conflict Minerals Report (as required by applicable regulations such as the U.S. Dodd-Frank Act Section 1502).
5. Expectations for Suppliers
We require all suppliers to:
Acknowledge and support the principles of this policy.
Establish their own due diligence systems consistent with the OECD Guidance.
Provide complete and accurate supply chain information, including SOR lists, upon request and in a timely manner.
Cooperate with our due diligence processes and actively encourage their upstream suppliers to participate in industry-recognized audit schemes.
Commit to not sourcing minerals that directly or indirectly finance or benefit armed groups or human rights abuses.
6. Communication & Training
We will communicate this policy to internal personnel and relevant suppliers via our website, supplier portal, and direct engagement.
We will provide necessary training to procurement and supply chain personnel to ensure effective understanding and implementation of this policy.
7. Policy Review
This policy will be reviewed at least annually, or as needed based on changes in legislation, industry standards, or our business operations, to ensure its continued relevance and effectiveness.
8. Contact Information
For questions regarding this policy or our responsible sourcing practices, please contact:
Supply Chain Department / Sustainability Office
Email: buy@Chinaeaststar.com
