We promote an ethical and responsible supply chain
Our Group is aware of the human, social and political consequences of trading and sourcing minerals from conflict zones.
We pursue the goal of reducing the risks of human rights violations related to the extraction, tradign and export of conflict minerals, including tin, tungsten, tantalum and gold (3TG) from "conflict-affected and high-risk areas".
Introduction
In 2012, the Securities and Exchange Commission of the United States adopted the final rule implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), which defines the disclosure, reporting, and due diligence obligations for companies that manufacture or contract to manufacture products containing minerals originating from conflict areas, where such minerals are necessary to the functionality or production of a manufactured product.
Furthermore, in 2017, the European Parliament and the Council of the European Union adopted Regulation (EU) 2017/821, which sets out supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected or high-risk areas.
In compliance with applicable legislation, both national and international, we support the fight against violence, human rights violations, and environmental degradation in the extraction and trade of certain minerals originating from the geographical area defined as the Conflict Region. Aware of the social responsibility we are called upon to uphold for sustainable and long-term growth, we are committed to applying and promoting ethics, respect for human rights, and social practices in a transparent and responsible manner, basing our transactions on what is defined by the United Nations Guiding Principles on business and human rights (OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas).
Our commitment and the standards required from our suppliers
Sesa is committed to constantly monitoring its supply chain in order to minimize the risks associated with the purchase of materials containing minerals originating from conflict-affected areas or from mining activities involved in human rights violations.
To this end, on the one hand we require suppliers to adequately monitor their own supply chains, in accordance with the OECD Guidelines (www.oecd.org), and on the other hand we verify that they publish a specific Conflict Minerals Policy on their websites. Furthermore, we expect and verify the adoption of appropriate procedures to monitor the sourcing of raw materials from high-risk areas, also considering that Sesa does not directly purchase raw materials, but uses hardware products that may contain them.
Sesa’s suppliers are required to:
comply with the implementing regulations promulgated by the Securities and Exchange Commission, implementing policies consistent with them and requiring their direct and indirect suppliers to do the same;
implement procedures to trace minerals originating from conflict areas by collaborating with their direct and indirect suppliers, also providing Sesa, upon request, with adequate information on the country of origin and the source of the materials used in the products supplied;
upon request, provide written certifications and other information regarding products and components supplied to Sesa.
In case of non-compliance, the supplier is required to develop, implement and document plans to remedy the situation in a timely manner. If the non-compliance cannot be resolved, Sesa reserves the right to terminate its relationship with the supplier.
Conflict Minerals Policy of Sesa Group
To ensure the responsible sourcing of conflict minerals, Sesa has adopted a Policy in support of this effort. In this Policy, which is unique within the Group, we condemn any activity involving the illegal exploitation of raw materials from which armed groups in conflict zones benefit, either directly or indirectly.
Any questions about this Policy or suspected violations of it may be reported by email to: [email protected]
Reports will be kept confidential to the extent possible and permitted by law. No retaliatory action will be taken against our employees, suppliers, or other parties who report in good faith. We encourage our suppliers to contact [email protected] if they wish to seek advice on the application of this Policy.
