Declaration of Compliance To Minterra FZC Supply Chain Policy

The Company declares that it will comply to its Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas which adheres strictly to OECD Guidance on Sourcing Minerals from Conflict-Affected and High-Risk Areas, as well as the UN Security Council’s Resolutions on Conflict Minerals. In following the abovementioned Guidelines, we are continuously improving the Five-Step Due Diligence and Implementation Framework:

  1. Improve Robust Internal Risk Management System.
  2. Improve Supply Chain Risk Identification and Assessment Process.
  3. Improve and Implement a Risk Mitigation Plan to respond to identified risks.
  4. Carry out an Independent Third-Party Audit of Supply Chain Due Diligence.
  5. Report on the Supply Chain Due Diligence.

The Company will maintain and adopt an Internal Risk Management Systems including Policies and Procedures that will be clearly communicated to the Supply Chain. The Company will not tolerate the minerals whose extraction, transport or trade is related to/or contributed to:

  • Any forms of Torture, Cruel, Inhuman and Degrading Treatment;
  • Any forms of Forced or Compulsory Labour;
  • Any forms of Child Labour;
  • Other Gross Human Rights Violations and abuses such as widespread sexual violence;
  • War Crimes or other Serious Violations of International Humanitarian Law, Crimes Against Humanity or Genocide.
  • Direct or Indirect support for Non-State Armed Groups through the Extraction, Transport, Trade, Handling or Export of Minerals.

The Company recognizes the Risks which may be associated with Extracting, Transportation, Trading, Handling and Exporting Minerals from Conflict-Affected and High Risk Areas and recognizes that it has the responsibility to respect Human Rights and not contribute to Conflict. The Company undertakes to incorporate in Legal Contracts and/or Agreements with Suppliers the following Policy on Responsible Sourcing of Minerals from Conflict-Affected and High-Risk Areas.

The Company will ensure to adopt a Common Reference for Conflict Sensitive Sourcing Practices and Suppliers' Risk Awareness from the Point of Extraction and throughout the Upstream Supply Chain until end user. The Company commits to refraining from any action which contributes to the Financing of Conflict and commits to comply with relevant United Nations Sanctions Resolutions or, where applicable, Domestic Laws implementing such resolutions.

Regarding Bribery and Fraudulent Misrepresentation of the Origin of Minerals: The Company will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the Origin of Minerals, to Misrepresent Taxes, Fees and Royalties paid to Governments for the purposes of mineral Extraction, Trading, Handling, Transportation and Exportation.

Regarding Money Laundering: The Company will support efforts, or take steps, to contribute to the effective elimination of Money Laundering where we identify a reasonable Risk of Money-Laundering resulting from, or connected to, the Extraction, Trading, Handling, Transportation or Exportation of minerals derived from the Illegal Taxation or Extortion of Minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

Regarding the Payment of Taxes, Fees and Royalties due to Governments: The Company will ensure that all Taxes, Fees, and Royalties related to Mineral Extraction, Trading and Exportation from Conflict-Affected and High-Risk Areas are paid to governments and, in accordance with the company's position in the Supply Chain, the company commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI).

1. Improving Our Current Internal Risk Management System

Currently implemented Risk Management System

We established Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas as well as our Internal Risk Management System. Minterra is aware that all parties must be subject to screening / a standard background check in order to avoid any potential risks. Minterra uses Refinitiv System to do KYC Risk Intelligence Screening, we check each UBO in the Refinitiv system before engaging in business with any company.

Minterra has read the OECD guidance and guarantees that the business activities fully complies with the iTSCi documentary and tagging requirements, which enable full traceability of minerals from source and conform to the OECD guidance and UN Panel of Experts recommendations. The source of the minerals are legal and do not originate from conflict areas, nor contribute to human rights abuses.

The Company’s Risk-based due diligence refers to the steps that are taken by Minterra. In order to due diligence the Company identifies and address actual or potential risks in order to prevent or mitigate adverse impacts associated with their activities or sourcing decisions. Furthermore, we introduced our employees to highlights of the OECD Guidelines during Compliance trainings.

We commited to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

We developed a strength company’s engagement with the Suppliers. Our Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High Risk Areas and our business principles are incorporated into Contracts and/or Agreements with Suppliers. Where possible, we assist Suppliers in building capacities with a view of improving Due Diligence Performance.

Planned Risk Management Improvements:

Establish a Company-Level, or Industry-Wide, grievance mechanism as an early warning Risk Awareness System.

We are willing to obtain a better Risk Management system to maintain all our internal KYC system. Meaning, that we are about to improve our Policies, improve our data collection, it‘s regularity and record keeping system.

Improve a System of Controls and Transparency over the Mineral Supply Chain. This will include a Chain of Custody or a Traceability System or the Identification of Upstream Actors in the Supply Chain.

This will be implemented through Participation in the Industry Driven Programs. We are wiiling to organise more trainings for our employees regarding Due Diligence requirements as well as most relevant law regulations improvements.

2. Risk Identification & Assessment Within The Supply Chain:

Current Risk Assesment:

As a general rule, we take a holistic approach when determining whether our business partners’ country is high risk, which falls under our broader obligation to take a Risk-Based Approach (“RBA”). As a benchmark, we consider that if a country ranks above 5 on the Basel Institute AML Index, it should be treated as a high-risk jurisdiction, and it is recommended to carry out EDD.

Where a country isn’t listed by Basel, we use contemporaneous sources to identify whether the country is of high risk. These includes the lists and resources published by the Financial Action Task Force (“FATF”) (, the Organisation for Economic Co-operation and Development (“OECD”)Country Risk Classifications, as well as other indicators that may shed light on governance and institutions in place to safeguard against AML, such as the World Bank Governance Indicators (

If we find out that a country is a high risk, we ask our business partners to provide us additional information, which would ensure that a company complies the law regulations of AML, do not support fraud, corruption or any other illegal activity.

Planned Risk Assessment System Improvements:

Improve our internal Risk Assessment system by developing a software which would help to identify high risk suppliers and suggest business solutions in such cases.

3. Improving & Implementing A Risk Response Strategy

Current Risk Response system:

We adopdet Minterra FZC Trading Whistleblowing Policy. This Policy was issued in order to encourage our staff to report malpractice or other wrong-doings to Minterra's Due Diligence Manager or Director. Minterra will investigate each reported case and will take actions accordingly. Our employees were introduced to these policy during Compliance trainings.

Planned Risk Response Strategy Improvements

Improve a strategy for Risk Management by either:

  1. Continuing Trade throughout the course of Measurable Risk Mitigation efforts;
  2. Temporarily suspending Trade while pursuing ongoing Measurable Risk Mitigation,
  3. Disengaging with a Supplier after failed attempts at Mitigation or where the company deems Risk Mitigation not Feasible or Unacceptable

To improve the strategy the company will review Annex II (Model Supply Chain Policy for Responsible Global Supply Chains of Minerals from Conflict-Affected and High-Risk Areas) and consider their ability to influence, and where necessary take steps to build leverage, over suppliers who can most effectively prevent or mitigate the identified risk.

If the Company pursues Risk Mitigation efforts while continuing to trade or temporarily suspending trade, the company will consult with Suppliers and affected Stakeholders, including local and central government authorities, international or civil society organizations and affected third parties, where appropriate, and agree on the strategy for Measurable Risk Mitigation in the Risk Management Plan.

4. Carry Out Independent Third-Party Audit Of Supply Chain Due Diligence

The Company currently has the following Risk Assessment Procedures:

  1. Unannounced Mine Site visits, iTSCi and relationships with other actors in the industry to obtain information about the People and the Mines that our company buys from.
  2. Have 3 levels of Infringements and suitable responses for those differing levels, see examples in the table below:
Ref.No.Risk LevelInfringementImmediate ActionSubsequent Action
1.LowIncorrect Tag or Falsified LogbookDiscuss with iTSCi and ask for VerificationContinue Purchase until the situation is resolved.
2.MediumUnaccounted Weights or Infeasible Mine Production Volumes.Report findings to iTSCi and GMD, compare information with iTSCiInform the Supplier of our doubts and engage them with iTSCi & GMD.
3.High‍Information about Supplier’s Links to Armed Groups or Conducts Human Rights Abuses.Immediate Disengagement and Share Information with iTSCi and GMD.Continued Disengagement until the situation is clarified. If proved untrue, then continue purchasing.

Have 3 levels of Infringements and suitable responses for those differing levels

The Company plans to have Independent Third-Party Audit of Supply Chain Due Diligence at identified risk points along the Supply Chain. Such audits will be independently verified through institutionalised mechanisms.

5. Report On The Supply Chain Due Diligence

The Company will publicly report on its Supply Chain Due Diligence Policy and Practices and will do so by expanding the Scope of its Sustainability, Corporate Social Responsibility, or Annual Report to cover additional information on Mineral Supply Chain Due Diligence.