NOVACORE CONFLICT MINERALS POLICY
The trading policy of Novacore FZE is to completely eliminate all conflicts Minerals and metals from the supply chain.
Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act signed by President Obama law1 on July 21, 2010 defines "conflict minerals" as including "cassiterite and its derivatives", along with two other minerals and gold. Novacore supports the objectives of the Act, to progressively reduce the relationship between mining and conflict in the eastern provinces of the Democratic Republic of Congo (DRC) and recognises the disclosure requirements that the law imposes on SEC reporting companies in the United States.
Novacore is concerned about the minerals that are extracted from mining operations to fuel military conflict, related human rights violations and environmental degradation.
Novacore will not trade or mine any such conflict minerals.
Novacore supports the search for sustainable solution to the problem of conflict minerals on the basis of cooperation and monitoring of minerals and transparency of global supply chains.
Novacore strives for the highest standards of ethical conduct and full compliance with all applicable national and international laws.
Novacore seeks to be fully compliant with all relevant United Nations bodies and international sanctions, and the internal laws of the implementation of such decisions. Company policy on conflict minerals monitors and commits to the OECD guidelines.
We will participate in the decisions that are aimed at solving the problems of conflict minerals to ensure that trade will continue in accordance with the requirements of the international community.
We currently going to trade tin, tantalum and tungsten minerals which come mostly from the Rwanda. All tin concentrates purchased by Novacore will be obtained using iTSCi scheme and, therefore, in accordance with internationally recognised due diligence guidance.
The Organisation for Economic Cooperation and Development (OECD) 2, and the United Nations (UN) released three widely similar guidelines for the company due diligence in respect of minerals from conflict-affected and high risk areas, and in the case of the UN, particularly in the DRC . The U.S. State Department has approved the OECD, and encourages companies to draw upon it as they establish their due diligence practices.
Novacore recognises the concerns of the international community with regard to minerals, which can finance the conflict and the need to have a strong organisational structure to deal with such problems. We have provided all relevant information to personnel of our company to know about U.S. law, Frank Dodd, as well as the due diligence guidance of the OECD and the UN.
We will take all reasonable steps to comply with all applicable regulations or guidance.
All of our contracts will have specific paragraph relating to due diligence.
We comply with the registration requirements of the program iTSCi, including adoption and commitment of Annex II model supply chain policy recommended by the OECD. Conflict minerals and metals are the materials for their production, manufacture or supply of either deliberately or accidentally had the benefit of illegal armed groups. All such materials are removed from the Novacore supply chain and, therefore, on all other products, such Novacore can produce itself, or at customer-owned facilities can be classified as a conflict free.
Novacore purchase materials only from reputable suppliers, with whom relations have long been established or for whom adequate due diligence on the supplier known the protocols can be implemented. Deliveries can be either tin ore (concentrate), tin metal, tantalum concentrates or wolframite concentrates.
In all cases, the due diligence will be conducted on suppliers and supply chain to ensure that minerals is authentic, lawful and not in any way contribute to conflict or human rights violations.
Due Diligence will include a written confirmation and assurance from each supplier, confirming that there is no conflict minerals in their supply chain.
Novacore uses supply chain traceability schemes such as the iTSCi tagging scheme to help ensure transparency. Novacore personnel will make selected supplier site visits on a regular basis for audit purposes and to test plausibility.
Novacore conforms to OECD Due Diligence for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This includes the OECD 5-Step Framework as:
-Established strong company management system
-Identified and assessed risk in the supply chain
-Designed and implemented a strategy to respond to identified risks
-Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
-Report on supply chain due diligence
For all materials documentary evidence of due diligence includes the following information for each shipment:
-Certificate of origin - certified by state authorities to the extent possible.
-Local independent surveyor report - checking the source and reliability of products.
-Other export documents - including ocean bills of lading and proof of payment of royalties where it was necessary.
-Full list of iTSCi recommended documents
-Control of tags and weight discrepancy
-Company representatives regularly visit suppliers and their mine sites for additional due diligence of suppliers.
The audit is continuing and the origin of the materials will continue to be tested and verified for each delivered material. We reserved our rights by contract terms with suppliers to conduct unannounced spot-check of suppliers. Our due diligence plan updated yearly.
Novacore policy to differentiate itself by offering its customers and trading partners of the conflict free metals and products, so that the end user in the supply chain can be sure their products are made from metals that are conflict free. We have a risk management strategy as defined by OECD Guidance and track the performance of risk mitigation. This strategy includes suspending or discontinuing supplies in the event that unacceptable practices are identified.
General Manager of Novacore FZE