Conflict Minerals Policy

Conflict metals and minerals include ores, concentrates and metals containing tin, tantalum, tungsten and gold (3TG). According to Annex I to Regulation (EU) 2017/821, List of minerals and metals covered by Regulation (EU) 2017/821 classified according to the Combined Nomenclature, the quantities of materials we use on an annual basis for the purposes of the production do not exceed the quantitative thresholds of 3TG minerals and metals. Conflict minerals are controversial because their sale can be used to support armed groups and facilitate human rights violations.

Of the listed minerals, we only use tin which we purchase exclusively from certified suppliers within the European Union and regularly check whether their supply chains comply with the EU regulation and accompanying acts.

We collaborate with other industry stakeholders by participating in the Responsible Minerals Initiative (RMI), which aims to develop smelter and refinery monitoring systems with independently verified audits against the RMI Responsible Minerals Assurance Process (RMAP). The RMAP process identifies smelters and refiners that produce conflict-free materials under the RMI initiative. The RMI initiative has developed a standardized Conflict Minerals Reporting Template (CMRT), which enables the collection of conflict mineral data from suppliers across the industry’s supply chains. We use the template in our supply chain monitoring. In addition, we expect from our suppliers to adhere to the Supplier Code, conduct due diligence procedures and, where necessary, plan mitigation actions that support the Conflict Minerals Policy.