Conflict-Free Raw Materials Management
We are committed to sourcing raw materials responsibly and ensuring that our products do not directly or indirectly finance armed conflict, serious human rights abuses, or illegal trade in any region.
This policy applies to our procurement of refractory metals and related raw materials (including, where applicable, minerals defined or treated as “conflict minerals” under relevant regulations).
1. Policy Commitment
- We do not knowingly source raw materials that contribute to armed conflict or human rights abuses.
- We follow the due diligence framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
- We expect all suppliers to respect this policy and to implement equivalent standards within their own supply chains.
2. Supply Chain Transparency & Due Diligence
Objectives
- Establish clear visibility into the origin of raw materials, processing routes, and key upstream actors.
- Identify, assess, and mitigate conflict-related risks in our supply chain.
Measures
- Request and review supplier information on material origin, smelters/refiners, and trade routes (e.g. RMI / OECD-aligned questionnaires and declarations).
- Maintain documented supply chain mapping for key materials, focusing on higher-risk metals or regions identified by international guidance and sanctions lists.
- Require suppliers to disclose changes in sourcing that may affect conflict-free status.
3. Supplier Requirements & Audits
We integrate conflict-free expectations into our supplier management.
- Contractual Expectations
Our purchasing terms require suppliers to:- Avoid sourcing from mines, smelters, or traders associated with armed groups or severe human rights abuses.
- Provide truthful, up-to-date information on origin and processing.
- Risk-Based Assessment
For higher-risk materials or regions:- We may request additional documentation (e.g. smelter certificates, third-party audit results).
- We may conduct remote or on-site assessments directly or via qualified third parties.
- Corrective Actions
Where serious or unresolvable risks are identified, we will work with the supplier on corrective measures, and if necessary, suspend or terminate the business relationship.
4. Regulatory & Standard Alignment
We support and, where applicable, align our due diligence with:
- US Dodd-Frank Act Section 1502 conflict minerals disclosure requirements (for affected customers and 3TG supply chains).
- EU Conflict Minerals Regulation (EU) 2017/821, focusing on responsible sourcing of tin, tantalum, tungsten, and gold (3TG) from conflict-affected and high-risk areas.
- Relevant national guidelines such as China’s policies on responsible mineral sourcing.
- International best practices from initiatives such as the Responsible Minerals Initiative (RMI).
For customers subject to these regulations, we cooperate in providing necessary supply chain data, declarations, and support for their compliance programs.
5. Use of Technology & Data
To enhance reliability and traceability (where practical and proportionate to risk):
- We maintain structured records of supplier declarations, batch data, and key sourcing information.
- We may apply digital tools and databases (e.g. sanctioned-entity and high-risk country screening) to identify red flags in the supply chain.
- We continuously review available industry tools and third-party services that can improve traceability and risk monitoring.
(Any advanced technologies such as blockchain or IoT tracking will be implemented only where they are actually in place and validated within our operations or those of our partners.)
6. Training & Awareness
- Provide training for procurement and quality teams on:
- Conflict minerals concepts and definitions
- OECD due diligence framework
- Identification of high-risk regions and suppliers
- Internal procedures for escalation and documentation
- Communicate our conflict-free expectations to suppliers and, where necessary, offer guidance on meeting documentation and due diligence requirements.
7. Reporting, Escalation & Continuous Improvement
- Suspected violations or concerns related to conflict-affected sourcing can be reported via our compliance / ESG contact channels. Reports are handled confidentially and without retaliation.
- We periodically review this policy in light of:
- Regulatory developments
- Industry best practices
- Feedback from customers, suppliers, and stakeholders
- Where gaps are identified, we update our procedures, supplier requirements, and internal controls accordingly.