Duty of Care

Summary

As a supplier of high-quality specialty metals, Concept Metal is committed to conducting its business responsibly and ensuring that none of its activities contribute to human rights violations anywhere in the world.

We have implemented a conflict minerals management system to meet and exceed legal requirements and internationally accepted supply chain due diligence standards to ensure the responsible sourcing of minerals known as the 3TG (tin, tantalum, tungsten, and gold).

In 2020, to comply with the requirements of Section 1502 of the U.S. Dodd-Frank Act and the European Regulation on Conflict Minerals (2017/821), we structured this program in accordance with the OECD guidelines on due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

Based on a clear procurement policy, we require our suppliers to trace their 3TG suppliers and smelters/refiners, as well as their countries of origin.

In particular, we have traced 100% of our tungsten supplies and the relevant smelters and refiners, and have identified no risks in the process, as all smelters and refiners in the conceptual metals supply chain participated and underwent an independent third-party audit program on the responsible sourcing of conflict minerals.

We have updated our communications program so that our company’s new website reflects our commitment to responsible sourcing, and we have established channels for receiving requests, complaints, or inquiries so that we can address them as urgent alerts and respond to any potential risks that may arise.

Our program also ensures that any risk identified during the due diligence process or upon receipt of a grievance will be brought to the attention of the company’s highest levels.

OECD Step 1: Robust corporate governance systems.

In accordance with Step 1 of the OECD Due Diligence Guidance, Concept Metal has established a robust internal management system to ensure the responsible sourcing of 3TG.

Our procurement policy has been updated to specifically address our requirements regarding conflict minerals, and our conflict minerals policy has been communicated to all suppliers involved in the trade of 3TG or derived products.

In 2020, we developed the capability to comply with and exceed regulatory frameworks on conflict minerals (in Europe and the United States). Our staff received training, and all suppliers involved in the trade of 3TG in 2020 were identified and assessed using the RMI-approved conflict minerals reporting template.

As a supplier of high-quality specialty metals, Concept Metal has established a strong commitment to its own suppliers. Starting in 2020, we have once again placed an emphasis on conflict minerals management as part of the qualification process for all new suppliers and the “audits” of existing suppliers.

The CEO of Concept Metal has direct control over all aspects of this management system.

OECD Step 2: Identify and Assess Risks in the Supply Chain.

For European regulations, the thresholds published in Annex I and subsequent amendments have been verified for all relevant CN codes.

Based on these thresholds, Concept Metal was subject to the European regulation on tungsten.

All tungsten suppliers have been identified, and Conflict Minerals Reporting Templates (CMRTs) have been collected accordingly.

For 2020, we have standardized on Revision 6.01 of the CMRT as published by the Responsible Minerals Initiative (RMI).

The reports we collected were evaluated against our internal quality standards to ensure that we received relevant, high-quality responses from our suppliers.

All smelters and refineries reported under the CMRT have been audited to ensure their compliance with the RMI’s PGR process, and the status of the audit has been verified.

In 2020, all reported smelters and refineries were in compliance, with audit validity extending beyond 2021.

Consequently, no risks were identified through our due diligence process, nor were any complaints received regarding this matter.

OECD Step 3: Addressing Identified Risks

No risks were identified in 2020.

However, should a risk be identified, Concept Metal has implemented a corporate management system to provide visibility to senior management, report on progress, track the results of actions taken, and evaluate any required mitigation measures, including:

– Continue trade while closely monitoring an action plan for improvement
– Temporarily suspend trade until the risk is addressed through measurable actions
– Terminate the contract if the supplier does not take sufficient action

OECD Third-Party Audit of Supply Chain Due Diligence

Concept Metal has chosen to follow the RMI’s CMRT framework, which is widely recognized by the industry (http://www.responsiblemineralsinitiative.org/).

We understand that this system has been approved, including with regard to European regulatory requirements, so no additional audit by an independent third party was necessary.

However, we monitor the CMRT status and audit results of all smelters and refiners reported by our suppliers, and we carefully verify them against the latest RMI publications.

OECD Step 5 Report on Supply Chain Due Diligence

This report is our first edition on our due diligence obligation and will be updated annually going forward.

At our clients' request, we can also provide our own conflict minerals report template, in accordance with RMI Template 6.01.

Conclusion

Concept Metal is not involved in the trade or import of minerals; therefore, we are a downstream company in the conflict minerals supply chain.

In 2020, Concept Metal implemented a robust corporate management system for due diligence regarding the sourcing of conflict minerals and conducted a comprehensive analysis of our tungsten supply chain.

This analysis did not identify any risks related to the supply of 3TG, and we did not receive any alerts or complaints regarding this matter throughout the year.

Concept Metal will continue to uphold its commitment to responsible sourcing of conflict minerals and will therefore participate in all industry efforts to improve due diligence in the sourcing of conflict minerals and to mitigate any adverse impact on human rights practices in conflict zones that may indirectly result from our business activities.