Introduction: London Chemicals & Resources Limited is committed to conducting its business operations in an ethical and socially responsible manner. We recognize the importance of addressing the issue of conflict minerals, which are minerals mined in regions that contribute to human rights abuses, environmental degradation, and financial support for armed groups. This Conflict Minerals Policy outlines our commitment to responsible sourcing and our efforts to ensure that our supply chain remains free from conflict minerals.

Policy Statement: Prohibition of Conflict Minerals: London Chemicals & Resources Limited is committed to avoiding the use of conflict minerals in the products we manufacture or distribute. Conflict minerals include tin, tantalum, tungsten, and gold (collectively referred to as “3TG”) sourced from regions associated with human rights abuses, including but not limited to the Democratic Republic of Congo (DRC) and surrounding countries.
Supply Chain Due Diligence: We will exercise due diligence in our supply chain to ensure that the minerals used in our products are sourced responsibly. This includes:

1. Identification and Risk Assessment: We will identify the presence of 3TG in our supply chain and assess the risk of sourcing from regions associated with human rights abuses and conflict. We will use reasonable efforts to determine the country of origin of the minerals used in our products.
2. Supplier Engagement: We will work closely with our suppliers to communicate our expectations regarding conflict minerals. We will request our suppliers to provide information about the origin of the minerals they supply, and we will encourage them to adopt responsible sourcing practices.
3. Supplier Audits and Certifications: We may conduct audits of our suppliers’ facilities to verify the accuracy of the information provided and ensure compliance with this policy. We will also encourage our suppliers to obtain third-party certifications, such as the Responsible Minerals Initiative (RMI) or equivalent, to validate responsible sourcing practices.

Risk Mitigation and Responsible Sourcing: In cases where the minerals in our supply chain are identified as potentially originating from conflict-affected regions, we will take appropriate steps to mitigate the risk, including:

1. Supplier Improvement: We will work with suppliers to address identified risks and support their efforts to improve responsible sourcing practices. We will encourage them to establish robust traceability systems and strengthen their supply chain transparency.
2. Sourcing Alternatives: If we determine that a supplier cannot or will not comply with this policy, we will seek alternative suppliers that demonstrate a commitment to responsible sourcing and provide conflict-free minerals.

Reporting and Transparency: We will provide regular updates on our conflict minerals program and progress towards responsible sourcing. We will strive for transparency by publicly disclosing our efforts to address conflict minerals and promote responsible supply chains.
Employee Awareness and Training: We will educate our employees on the issue of conflict minerals and the importance of responsible sourcing. We will provide training programs to relevant employees involved in the procurement and supply chain management processes to ensure their understanding of this policy and their role in its implementation.

Compliance with Laws and Regulations: We will comply with all applicable laws and regulations regarding conflict minerals, including the reporting requirements of the UK Modern Slavery Act, Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, and any other relevant legislation.

Continuous Improvement: We will regularly review and update this Conflict Minerals Policy to reflect evolving industry best practices and regulatory requirements. We will work towards the continuous improvement of our responsible sourcing efforts and supply chain transparency.

Conclusion: London Chemicals & Resources Limited is committed to responsible sourcing practices and the avoidance of conflict minerals in our supply chain. We recognize that our efforts can contribute to positive change and the promotion of human rights. By adhering to this Conflict Minerals Policy, we aim to foster transparency, accountability, and sustainable practices throughout our supply chain.