Conflict Mineral Policy Statement
Niagara Refining LLC (NR) is committed to the responsible sourcing of Tungsten raw materials. It is antithetical to NR corporate values to use any tungsten raw materials which support or benefit armed conflict groups or involves any serious abuses of human rights. As such, we will take all reasonable efforts to ensure that our supply chain is free of such conflict minerals. Likewise, we will avoid tungsten raw materials where public or private security forces, or non-state armed groups, are illegally used in the supply chain. NR will not use any tungsten material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.
We endorse the Organization for Economic Cooperation and Development (OECD) in their efforts to respect human rights and avoid contributing to conflict. We accept their OECD Due Diligence Guidance for Responsible Supply Chains of Minerals Conflict-Affected and High-Risk Areas as the model for our own due-diligence.
As part of our supply chain due diligence, NR shall take steps to assess and mitigate the various supply chain risks as recommended in the OECD Guidance Annex II Model Supply Chain Policy. These risks include the following:
3. Direct or indirect support to public or private security forces
4. Bribery and fraudulent misrepresentation of the origin of minerals
In order to ensure compliance with our commitment to a "conflict-free" and OECD aligned supply chain, NR has integrated the due-diligence for assessing our tungsten supply chain by establishing strong management and reporting systems to be in accordance with the OECD Guidance Annex II. Our company President has been assigned responsibility for ensuring supply chain compliance. Our process includes a system of ongoing know-your-supplier due diligence and enhanced due diligence for areas in which material would potentially originate from or transit through a conflict affected high-risk area (CAHRA), and methods for mitigating risks that are identified in our supply chain. NR will ensure that training of management and all relevant employees is done at least annually. NR further commits to update supplier due diligence at least every 2 years, or sooner if the situation dictates.
NR is a member of the Tungsten Industry - Conflict Minerals Council (TI-CMC). This requires us our participation in the the Responsible Minerals Assurance Process and also requires us to be regularly audited by an independent third party to ensure compliance. Through these audits, NR displays transparency and our customers gain audit-based assurance that NR's supply chain due diligence policy is verifiable and effective. It also provides NR with additional direction for enhancement and opportunities to provide feedback to the outside auditors for continued improvement. It is NR policy to always maintain RMAP Conformant Tungsten Smelter status.
NR communicates this sourcing policy to our suppliers and make it publicly available on our website. Additionally, NR requires our suppliers to commit to providing information, documentation, and accommodations for site visits as necessary to complete our due diligence as outlined in our basic due diligence and enhanced due diligence policies.
If NR should discover, through its ongoing due-diligence that our customer is engaging in suspect practices or practices do not meet our responsible sourcing requirements, we would immediately suspend sourcing from the identified supplier and develop a plan to mitigate the identified risks. Should the mitigation fail to resolve a matter to our satisfaction or we uncover activities which indicate extreme abuses, dishonesty, or situations where a supplier is unwilling to assist in our due-diligence, NR will immediately discontinue any activity with that entity.
Finally, NR will publish and make publicly available an annual summary due diligence report.
Effective: 1 Oct 2019
Niagara Refining OECD 5 Step Report 2018