POLICY ON RESPONSIBLE GLOBAL SUPPLY CHAIN OF MINERALS FROM CONFLICT-AFFECTED AND HIGH-RISK AREAS (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, is committed to adhering to the highest standards of ethics and business practices. Recognizing the risk of significant negative impacts associated with the extraction, trade, processing, and export of minerals from conflict-affected and high-risk areas, and acknowledging our duty to respect human rights and not contribute to conflicts, we commit to adopting, widely disseminating, and incorporating the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas into contracts or agreements with suppliers as a common reference point for mineral sourcing practices that consider conflicts and suppliers' knowledge of risks from the extraction site to the end user.
In relation to serious abuses associated with the extraction, transportation, or trade of minerals, Germania Mint Invest Sp. z o.o. commits not to tolerate, benefit from, or in any way contribute to the commission of:
Torture and cruel, inhuman, or degrading treatment,
Forced or compulsory labor,
Illegal forms of child labor,
Other serious human rights violations such as, but not limited to, sexual violence,
War crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide.
Regarding the management of risks associated with serious abuses, Germania Mint Invest Sp. z o.o. will immediately suspend or terminate cooperation with raw material suppliers if it determines that there is a reasonable risk that suppliers source from any entity that has committed serious abuses listed in point 1.
Aware that direct or indirect support for non-state armed groups includes, among other things, acquiring minerals from them or from entities linked to them, making payments to them, Germania Mint Invest Sp. z o.o. declares that it will not tolerate any direct or indirect support and any provision of logistical assistance or supply of equipment to groups or entities that:
Unlawfully control extraction sites or otherwise control transportation routes, trading points for minerals, and entities operating at higher levels of the supply chain, or
Unlawfully impose taxes or extort money or minerals at access points to mines, along transportation routes, or at trading points for minerals, or
Unlawfully tax intermediaries, exporting or trading companies, or international trading enterprises or extort money from them.
Regarding the management of risks associated with 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 determines that there is a reasonable risk that they source from any entity that provides direct or indirect support to non-state armed groups as defined in point 3, or are linked to such an entity.
Regarding 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, transportation routes, and entities operating at higher levels of the supply chain, unlawfully impose taxes or extort money or minerals at access points to mines, along transportation routes, or at trading points for minerals, or unlawfully tax intermediaries, exporting or international trading enterprises or extort money from them.
Germania Mint Invest Sp. z o.o. recognizes that the role of public or private security forces in mines or surrounding areas or along transportation routes should solely be to maintain the rule of law, including the protection of human rights, ensuring the safety of mine workers, equipment, and facilities, and protecting mines or transportation routes from interference with legal extraction and trade.
In the event that we or any company in our supply chain enters into an agreement with public or private security forces, we commit to utilizing or will require the use of such armed forces' services in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will provide support or take action to adopt a control policy to ensure that individuals or units of security forces known to be responsible for gross human rights violations are not employed.
Germania Mint Invest Sp. z o.o. will support efforts to establish cooperation with central or local government authorities, international organizations, and civil society organizations to contribute to the development of solutions aimed at improving transparency, proportionality, and accountability in payments made to public security forces for maintaining the rule of law.
Germania Mint Invest Sp. z o.o. will support efforts to establish cooperation with local government authorities, international organizations, and civil society organizations to avoid exposing or to minimize the exposure of particularly vulnerable groups, especially artisanal miners, to the negative effects associated with the presence of security forces, whether public or private, in mining areas.
In relation to managing risks associated with public or private security forces, according to the company's position in the supply chain, Germania Mint Invest Sp. z o.o. commits to developing, adopting, and implementing a risk management plan in collaboration with raw material suppliers and other stakeholders to prevent risks related to direct or indirect support for public or private security forces as mentioned in point 5, or to mitigate this risk if we determine that such a 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 of adopting the risk management plan.
Regarding bribery and misrepresentation of the origin of minerals, Germania Mint Invest Sp. z o.o. will not offer, promise, give, or request any bribes, nor will it seek bribes to conceal or alter the origin of minerals to mislead regarding taxes and licensing fees paid to governments for the extraction, trade, processing, transportation, and export of minerals.
In relation to money laundering, Germania Mint Invest Sp. z o.o. will support efforts aimed at effectively eliminating money laundering if it identifies a reasonable risk of money laundering arising from the extraction, trade, transportation, or export of minerals, linked to illegal taxation or extortion of minerals at access points to mines, along transportation routes, or at trading points for minerals by raw material suppliers, or risks associated with such activities.
Regarding the payment of taxes and licensing fees to governments, Germania Mint Invest Sp. z o.o. will ensure that all taxes and licensing fees related to the extraction, trade, and export of minerals from conflict-affected and high-risk areas are paid to governments in accordance with the company's position in the supply chain.
In relation to managing risks associated with bribery, misrepresentation of the origin of minerals, money laundering, and the payment of taxes and licensing fees to governments, Germania Mint Invest Sp. z o.o. commits to cooperating with suppliers, central or local government authorities, international organizations, civil society, and, where appropriate, third parties involved, to improve and monitor outcomes to prevent the risk of negative consequences or to mitigate this risk through 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.