POLICY ON A RESPONSIBLE GLOBAL SUPPLY CHAIN OF MINERALS FROM CONFLICT‑AFFECTED AND HIGH‑RISK AREAS (so‑called CONFLICT MINERALS POLICY)
GERMANIA MINT INVEST Sp. z o.o.
Germania Mint Invest Sp. z o.o., a company with many years of experience in the precious metals market, undertakes to comply with the highest standards of ethics and business conduct.
Recognising the risk of significant adverse impacts that may be associated with the extraction, trading, processing and export of minerals from conflict‑affected and high‑risk areas, and recognising that it is our duty to respect human rights and not to contribute to conflicts, we commit to adopt, widely disseminate and include in contracts or agreements with suppliers the following policy on responsible sourcing of minerals from conflict‑affected and high‑risk areas as a common reference point for conflict‑sensitive mineral sourcing practices and supplier knowledge of risks from the mine to the end user.
1. With regard to serious abuses associated with the extraction, transport or trade of minerals, Germania Mint Invest Sp. z o.o. undertakes not to tolerate, benefit from or in any way contribute to the commission of:
- torture or cruel, inhuman and degrading treatment;
- forced or compulsory labour;
- unlawful forms of child labour;
- other serious human rights abuses such as, among others, sexual violence;
- war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
2. With regard to risk management related to serious abuses, Germania Mint Invest Sp. z o.o. will immediately suspend or terminate cooperation with raw‑material suppliers if it finds that there is a reasonable risk that suppliers source from any entity that has committed the serious abuses listed in point 1.
3. Being aware that direct or indirect support for non‑state armed groups includes, among other things, purchasing minerals from them or from entities associated with them and making payments to them, Germania Mint Invest Sp. z o.o. declares that it will not tolerate any direct or indirect support or any provision of logistical assistance or equipment to groups or entities that:
4. unlawfully control mining sites or otherwise control transport routes, points where mineral trade takes place, and entities operating further upstream in the supply chain; or
5. unlawfully impose taxes or extort money or minerals at mine access points, along transport routes or at points where mineral trade takes place; or
6. unlawfully tax intermediaries, exporting or trading companies or international trading companies or extort money from them.
7. With regard to risk management related to direct or indirect support for non‑state armed groups, Germania Mint Invest Sp. z o.o. will immediately suspend or terminate cooperation with raw‑material suppliers if it finds that there is a reasonable risk that they source from any entity that provides non‑state armed groups with direct or indirect support as defined in point 3, or are associated with such an entity.
8. With regard to public or private security forces, Germania Mint Invest Sp. z o.o. agrees to eliminate, in accordance with point 10, direct or indirect support for public or private security forces that unlawfully control mines, transport routes and entities operating further upstream in the supply chain, unlawfully impose taxes or extort money or minerals at mine access points, along transport routes or at points where mineral trade takes place, or unlawfully tax intermediaries, exporting companies or international trading companies or extort money from them.
9. Germania Mint Invest Sp. z o.o. recognises that the role of public or private security forces at mines or in surrounding areas or along transport routes should be limited exclusively to maintaining the rule of law, including protecting human rights, ensuring the security of mine workers, equipment and facilities, and protecting mines or transport routes against interference with lawful extraction and trade.
10. If we or any company in our supply chain enter into an agreement with public or private security forces, we undertake to use, or require the use of, such security forces in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will provide support for or take action towards the adoption of a vetting policy to ensure that individuals or units of security forces known to be responsible for gross human rights violations are not employed.
11. Germania Mint Invest Sp. z o.o. will support efforts to cooperate with central or local government authorities, international organisations and civil society organisations in order to contribute to developing solutions to improve transparency, proportionality and accountability with regard to payments to public security forces for the provision of the rule of law.
12. Germania Mint Invest Sp. z o.o. will support efforts to cooperate with local government authorities, international organisations and civil society organisations to avoid exposing or to minimise the exposure of particularly vulnerable groups, in particular artisanal miners, to negative impacts associated with the presence of public or private security forces at mine sites.
13. With regard to risk management related to public or private security forces, and in line with the company’s position in the supply chain, Germania Mint Invest Sp. z o.o. undertakes to develop, adopt and implement a risk‑management plan together with raw‑material suppliers and other stakeholders in order to prevent or mitigate the risk of direct or indirect support for public or private security forces as referred to in point 5, where we find that such reasonable risk exists. In such cases, Germania Mint Invest Sp. z o.o. will suspend or terminate cooperation with raw‑material suppliers after unsuccessful attempts to mitigate the risk within six months from the adoption of the risk‑management plan.
14. With regard to bribery and misrepresentation of the origin of minerals, Germania Mint Invest Sp. z o.o. will not offer, promise, give or demand any bribes and will not solicit bribes in order to conceal or misrepresent the origin of minerals, or to mislead with regard to taxes and licence fees paid to governments for mineral extraction, trade, processing, transport and export.
15. With regard to money laundering, Germania Mint Invest Sp. z o.o. will support actions aimed at contributing to the effective elimination of money laundering where it identifies a reasonable risk of money laundering arising from the extraction, trade, transport or export of minerals linked to the unlawful imposition of taxes or extortion of minerals at mine access points, along transport routes or at points where mineral trade takes place by raw‑material suppliers, or a risk associated with such activities.
16. With regard to the payment of taxes and licence fees to governments, Germania Mint Invest Sp. z o.o. will ensure that all taxes and licence fees related to mineral extraction, trade and export from conflict‑affected and high‑risk areas are paid to governments in accordance with the company’s position in the supply chain.
17. With regard to risk management related to bribery and misrepresentation of the origin of minerals, money laundering, and the payment of taxes and licence fees to governments, Germania Mint Invest Sp. z o.o. undertakes to cooperate with suppliers, central or local government authorities, international organisations, civil society and, where appropriate, relevant third parties to improve and monitor performance so as to prevent the risk of adverse impacts or to mitigate such risk by taking measurable actions within reasonable timeframes. Germania Mint Invest Sp. z o.o. will suspend or terminate cooperation with raw‑material suppliers after unsuccessful attempts to mitigate the risk.