Purchasing of Minerals from High-Risk and Conflict Areas Policy

Schlötter Ireland DAC is committed to conducting its business, through its employees, directors, officers, and agents, in compliance with applicable laws and, overall, in an honest and ethical manner. Schlötter Ireland DAC believes that a commitment to honesty, ethics, and integrity is the foundation of trust with clients, business partners, shareholders, and the broader community in which it operates.

While the company has no industrial, mining, or trading operations in conflict-affected and high-risk areas, minerals or metals purchased by Schlötter Ireland DAC in the course of its activities may, in some cases, originate from such areas.

Considering the human rights and other risks that may be associated with the extraction, trading, handling, and exporting of minerals from conflict-affected and high-risk areas, and in line with our commitment to supporting and promoting respect for human rights and ethics in business, Schlötter Ireland DAC has adopted this specific policy on the responsible sourcing of minerals from these areas. This policy is submitted to our suppliers as a common reference for conflict-sensitive sourcing practices and to promote risk awareness. Schlötter Ireland DAC has based this policy on the existing OECD Guidelines on the subject.

Schlötter Ireland DAC does not wish to contribute to the financing of conflict and subscribes to relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

We are not sourcing minerals from conflict-affected and high-risk areas. Schlötter Ireland DAC will, wherever possible, review the following practices, and when identified, will neither tolerate nor profit from, contribute to, assist with, or facilitate the commission by any party of:

  • Any form of torture, cruel, inhuman and degrading treatment;

  • Any form of forced or compulsory labour;

  • Any form of child labour;

  • Other gross human rights violations and abuses such as sexual violence;

  • War crimes or other violations of international humanitarian law, crimes against humanity, or genocide.

We will not give, nor tolerate, any direct or indirect support to non-state armed groups or public or private security forces who illegally control mine sites, transportation routes, and upstream actors in the supply chain; illegally tax or extort money or minerals at points of access to mine sites, along transportation routes, or at points where minerals are traded; or illegally tax or extort intermediaries, export companies, or international traders.

When we identify a reasonable risk that a supplier is sourcing from, or linked to, a party committing serious abuses as set forth above, we will suspend or discontinue our relationship with that supplier. We will not offer, promise, give, or demand any bribes and will resist any solicitation of bribes to conceal or disguise the origin of minerals, or to misrepresent taxes, fees, and royalties paid to governments for mineral extraction, trade, handling, transport, and export.

We will support efforts or take steps to contribute to the effective elimination of money laundering where we identify a reasonable risk of money laundering related to or connected to the extraction, trade, handling, transport, or export of minerals derived from illegal taxation or extortion at points of access to mine sites, along transportation routes, or at points where minerals are traded by upstream suppliers.

We request that our suppliers comply with this policy when extracting, sourcing, transporting, trading, handling, or exporting minerals from conflict-affected and high-risk areas. In accordance with our position in the supply chain, we are willing to engage with suppliers, central or local governmental authorities, international organizations, civil society, and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks. If we have reasonable belief that a supplier is failing to comply with this policy, we will suspend or discontinue the dubious supply.