We recognise that to create value for our shareholders we must carry out our business fairly and with the intent to benefit the people and communities that are stakeholders in our supply chain, our operations, our customers affairs, and in general. With this in mind we support passed legislation and initiatives that promote safety, fairness, and minimisation of harm: Conflict-Free Minerals Policy: we source our products from persons or entities that produce by their own volition, without coercion, in legitimate ventures. With this in mind we pay fair market prices and reassure ourselves that the nature of the operations of our suppliers is not nefarious. The CFS identifies mineral producing countries by three levels, depending on the perceived risk of minerals exiting the country funding or supporting conflict. We work mainly in countries with the lowest level of risk. We collect documentation, that allows identification of the source of our products as within the country they are declared to be from, and that satisfy the requirement of the CFS; this is important as these documents are passed onto our customers, enabling them to present them to CFS appointed auditors, who will either pass the smelter in the audit or fail them. A CFS passed smelter allows downstream companies to use their materials with knowledge that they are not using products which have financed conflict, and in turn consumers can say the same. If we source from countries that are at higher levels of risk, we extend our documentation requirements and will participate in any of the schemes which aim to trace minerals to particular mine sites that have been independently assessed on the ground to be conflict free. Registration, evaluation, authorisation and restriction of chemicals (REACH): This is the European Unions programme to roll out an industry wide assessment of chemical imports (including ores, intermediates and refined products of metals) to asses their relative impact to the environment. The studies were carried out and collated by the industry. In order to import into the EU, one must be registered for each of the substances they wish to import. We are preregistered for the majority of our products that we import into Europe, and will register fully in 2018 as allowed by the timescale and tonnage bands put in place. Transportation of Naturally occurring radioactive materials (NORM): There exists some amount of uranium and thorium species in the ground, particularly in ore bodies. Mining the materials and processing them physically and/or chemically may increase the percentage by mass of these species. Our intermediate and metal products do not contain any appreciable levels of such species as they are removed during processing. However, our ores and concentrates do sometimes contain appreciable levels. The stoichiometric ratios are preserved as physical processing only has been used here, and indeed the goal is not enhance the percentage by mass of other elements and not uranium or thorium species. There is a requirement to declare shipments with a combined activity of uranium and thorium, measured as oxide species, that exceeds 10 Becquerel’s per gram as class 7 for transport.
Our full supply chain policy document can be read here – Our Supply Chain Policy
Annual Due Diligence Reports: