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Responsible Sourcing of Minerals​

 

1. Purpose

The purpose of this policy is to ensure that Claude Lyons responsibly sources minerals, including tin, tungsten, tantalum, gold, and cobalt, in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This policy aims to promote ethical practices, respect human rights, and avoid contributing to conflict through our mineral sourcing decisions.

2. Scope

This policy applies to all employees, suppliers, and contractors involved in the procurement and use of minerals within Claude Lyons’ supply chain.

3. Commitment

Claude Lyons is committed to:

  • Conducting due diligence on the source and chain of custody of minerals used in our products.
  • Ensuring that our sourcing practices do not contribute to human rights abuses, conflict, or environmental harm.
  • Complying with all applicable laws and regulations related to the sourcing of minerals.

4. Due Diligence Framework

Claude Lyons will implement the following five-step framework as outlined in the

OECD Due Diligence Guidance:

  • Establish Strong Company Management Systems
  • Adopt and clearly communicate a company policy for the supply chain of minerals.
  • Structure internal management to support supply chain due diligence.
  • Establish a system of controls and transparency over the mineral supply chain
  • Strengthen company engagement with suppliers.
  • Establish a grievance mechanism.
  • Identify and Assess Risks in the Supply Chain
  • Identify risks in the supply chain based on the OECD Annex II model supply chain policy.
  • Assess the risks of adverse impacts in the supply chain.
  • Design and Implement a Strategy to Respond to Identified Risks
  • Report findings of the supply chain risk assessment to designated senior management.
  • Devise and adopt a risk management plan.
  • Implement the risk management plan, monitor and track performance of risk mitigation efforts, and report back to senior management.
  • Carry Out Independent Third-Party Audit of Supply Chain Due Diligence
  • Ensure that audits are conducted by independent third parties to verify the due diligence practices.
  • Report Annually on Supply Chain Due Diligence
  • Publicly report on supply chain due diligence policies and practices, including the steps taken to manage risks.

5. Supplier Requirements

Suppliers are required to:

  • Adhere to Claude Lyons’ policy on responsible sourcing of minerals.
  • Provide documentation and evidence of their own due diligence practices.
  • Cooperate with audits and assessments conducted by Claude Lyons or its designated third parties.

6. Continuous Improvement

Claude Lyons is committed to continuous improvement in its due diligence practices and will regularly review and update this policy to ensure its effectiveness and alignment with international standards.

7. Reporting and Grievance Mechanism

Claude Lyons will maintain a grievance mechanism to allow stakeholders to report concerns related to the sourcing of minerals. Reports can be made anonymously and will be addressed promptly and transparently.