Responsible Sourcing Policy

Introduction to the Policy

M&C Logistics and Trading Limited recognizes the significant adverse impacts that may be associated with extracting, trading, handling, and exporting minerals from conflict-affected and high-risk areas. We actively support the Organization for Economic Co-operation and Development (OECD) Framework for Risk-Based Due Diligence in the Mineral Supply Chain and take our responsibilities to respect human rights and not contribute to conflict seriously.

We are committed to refraining from any action that contributes to the financing of conflict, and we commit to comply with international and domestic laws implementing such resolutions. We have adopted the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas.

Scope and Application

This policy outlines the steps we take to comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including addressing:

• Serious abuses associated with the extraction, transport, and trade of minerals.
• Direct or indirect support to non-state armed groups.
• Public or private security forces.
• Bribery and fraudulent misrepresentation of the origin of minerals.
• Money laundering.
• Payment of taxes, fees, and royalties due to governments.

In accordance with the specific position of the company in the supply chain, we commit 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 of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with suppliers after failed attempts at mitigation.

This policy applies to all our staff, including employees, officers, consultants, contractors, and other workers such as agency workers, casual workers, volunteers, interns, and home workers. All staff must be familiar with this policy and comply with its terms.

Serious Abuses Associated with the Extraction, Transport, and Trade of Minerals

While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of any forms of:

• Torture, cruel, inhuman, and degrading treatment.
• Any forms of forced or compulsory labour, which means work or service exacted from any person under the menace of penalty and for which said person has not offered themselves voluntarily.
• 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.

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from or linked to any party committing serious abuses as defined above.

Direct or Indirect Support to Non-State Armed Groups

We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. “Direct or indirect support” to non-state armed groups includes, but is not limited to, procuring minerals from, making payments to, or otherwise providing logistical assistance or equipment to non-state armed groups or their affiliates who:

• Illegally control mine sites or otherwise control transportation routes, points where minerals are traded, 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;
• Illegally tax or extort intermediaries, export companies, or international traders.

We will immediately suspend or discontinue engagement with suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined above.

Public or Private Security Forces

We agree to eliminate direct or indirect support to public or private security forces who:

• Illegally control mine sites, transportation routes, and 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;
• Illegally tax or extort intermediaries, export companies, or international traders.

We recognize that the role of public or private security forces at mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment, and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.

Bribery and Fraudulent Misrepresentation of the Origin of Minerals

We 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, trade, handling, transport, and export. Please see our Anti-Bribery and Corruption Policy for more information.

Money Laundering

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 resulting from, or connected to, the extraction, trade, handling, transport, or export 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.

Payment of Taxes, Fees, and Royalties Due to Governments

Where applicable to our business, we will ensure that all taxes, fees, and royalties related to mineral extraction, trade, and export from conflict-affected and high-risk areas are paid to governments.

Failure to Comply with This Policy

Failure to comply puts both you and the organization at risk. We take compliance with this policy very seriously. Because of the importance of this policy, failure to comply with any requirement may lead to disciplinary action under our procedures, which may result in dismissal.

Training and Awareness

All relevant employees and agents will be trained regularly on how to recognize and deal with adverse impacts that may be associated with extracting, trading, handling, and exporting minerals from conflict-affected and high-risk areas.