Conflict Minerals (Controversial Sourcing)

Sesa Group is aware of the human, social and political cost caused by illicit trading and procurement of minerals from conflict areas.

We take pride in enforcing social responsibility and we pay continuous attention to any development in and related to US and EU legislation.

In 2012, US Securities and Exchange Commission adopted the final rule of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) setting out disclosure, reporting and due diligence obligations for those issuers that manufacture, or contract to manufacture, products that contain Conflict Minerals that are necessary to the functionality or production of a product manufactured.



Furthermore in 2017, the European Parliament and the Council of the European Union adopted the Regulation (EU) 2017/821 laying down supply chain due diligence obligations for Union Importers of tin, tantalum and tungsten, their ores and gold originating from conflict affected and high-risk areas.



Sesa Group sustains the fight against the violence, the violation of the human rights and the environmental degrade in the extraction and trade of minerals coming from the “Conflict Region”. Conflict minerals include a variety of minerals such as columbo-tantalite (coltan), cassiterite, gold, wolframite and its derivatives, specifically tantalum, tin and tungsten (also known as “3TG”).



Sesa, aware of the social responsibility it must respond to for lasting and sustainable growth, undertakes to apply and promote ethics, respect for human rights and social practices in a transparent and responsible way, basing its 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).



Sesa undertakes to constantly monitor its supply chain to minimize the risks related to the purchase of materials that contain minerals from areas of conflict or from mining activities implicated in the violation of human rights. Sesa also requires its suppliers to adequately monitor their supply chain in accordance with the provisions of the OECD Guidelines (

In furtherance of this commitment, Sesa expects its suppliers to:

  • Familiarize themselves with the SEC’s conflict minerals rule, implement policies that are consistent with this policy, and require their direct and indirect suppliers to do the same;
  • Implement procedures to trace conflict minerals at least to the smelter or refiner level, working with their direct and indirect suppliers as applicable, and to provide Sesa with proper verification of the country of origin and source of the materials used in the products they supply to Sesa;
  • Where reasonably possible, source conflict minerals from smelters and refiners validated as conflict free, and require their direct and indirect suppliers to do the same;

At Sesa’s request, provide Sesa with written certifications and other information concerning the origin of conflict minerals included in products and components supplied to Sesa, and require their direct and indirect suppliers to do the same. Sesa reserves the right to verify any information received from its suppliers, and to request from any supplier at any time such information, certifications and documentation as Sesa shall deem necessary to monitor or assess compliance with this policy.

If a supplier is found to not be in compliance with the objectives of this policy, the supplier is expected to develop, implement and document plans to remedy such non-compliance in a timely manner. If the non-compliance cannot be resolved, Sesa reserves the right to pursue termination of its relationship with the supplier.