Conflict Minerals Sourcing Policy

Conflict Minerals Sourcing Policy

Columbite-tantalite (coltan), cassiterite, wolframite and gold, or their derivatives, including tantalum, tin, and tungsten, originating from the Democratic Republic of the Congo (DRC) and adjoining countries (often referred to as “Conflict Minerals”) are sometimes mined and sold by armed groups to finance unfair labor practices or human rights violations. Some of these Conflict Minerals can make their way into the supply chains of the products used around the world. It is the policy of Neo Performance Materials to avoid Conflict Minerals that directly or indirectly finance or benefit armed groups in conflict-affected regions and high-risk areas as defined by OECD Guidance.

As part of Neo Performance Materials commitment to corporate responsibility and respecting human rights in its operations and in its global supply chain, Neo Performance Materials will endeavor to only procure raw materials containing Conflict Minerals that do not support conflict.

In support of this sourcing policy, Neo Performance Materials will:

  • Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
  • Provide, and expect its suppliers to cooperate in providing, due diligence information to confirm that any Conflict Minerals in its supply-chain do not support conflict.
  • Immediately discontinue engagement with suppliers who pose a reasonable risk to be supporting conflict.
  • Commit to transparency in the implementation of this policy by making available reports on its progress to its customers, relevant stakeholders, and the public (as required).

Tantalum Specific Note: Due to naturally occurring radioactivity from thorium and uranium in tantalum ores and their concentrates, this policy covers adherence to international transportation regulations (United Nations Dangerous Goods Class 7).


Last update: August 09, 2019



Mineral Grievance Reporting Mechanism

The Responsible Minerals Initiative (RMI), in collaboration with the London Bullion Market Association (LBMA) and the Responsible Jewelry Council (RJC), has developed an online platform to screen and address grievances linked to smelters and refiners present in global supply chains. The online form developed by RMI can be seen here.

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