中文|English
中文|English

Responsible Minerals Procurement Policy

Global Ethical Sourcing & Human Rights Due Diligence Framework
Document ID:POL‑ESG‑MIN‑001
Effective Date:January 2026
Owner:Global Procurement & Compliance
Applies To:All Global Operations & Direct Suppliers

1. Policy Statement & Commitments

At CoaTech Metal Surface Technologies, we are dedicated to conducting our global business operations with the highest standards of integrity, ethical conduct, and social responsibility. We recognize that the extraction and trading of raw materials can pose significant social and environmental risks, including contributing to armed conflict, forced labor, severe human rights abuses, and environmental degradation in Conflict‑Affected and High‑Risk Areas (CAHRAs).

We are committed to building a transparent, resilient, and ethically responsible supply chain. Our goal is to ensure that all minerals utilized in our products are sourced ethically, legally, and in a manner that respects human rights and protects local communities.

Scope & In‑Scope Materials

This policy applies globally to all operating units, subsidiaries, and direct manufacturing partners. In‑scope materials include 3TG (Tin, Tantalum, Tungsten, and Gold) as well as critical energy transition minerals, specifically Cobalt, Lithium, and Nickel.

2. Alignment with International Standards

Our procurement practices strictly adhere to internationally recognized frameworks, ensuring consistency and regulatory alignment across global markets:

OECD Guidance: The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‑Affected and High‑Risk Areas.

UN Guiding Principles: The United Nations Guiding Principles on Business and Human Rights.

Regulatory Frameworks: Compliance with Section 1502 of the U.S. Dodd‑Frank Act, the EU Conflict Minerals Regulation (Regulation 2017/821), and emerging global due diligence mandates.

3. The 5‑Step Due Diligence Framework

We operationalize our commitments by embedding the OECD 5‑Step Due Diligence Framework into our global procurement systems:

OECD PillarCore Policy Requirement & Implementation Action
Step 1: Strong Management SystemsEstablish internal cross‑functional oversight, integrate responsible sourcing requirements into supplier agreements, and mandate the use of standard industry reporting templates (e.g., RMI CMRT / EMRT).
Step 2: Risk Identification & AssessmentPerform rigorous supply chain mapping back to the mine and smelter/refiner level. Evaluate suppliers against recognized lists of CAHRAs and identify red‑flag operations.
Step 3: Risk Mitigation StrategyDevelop and implement Corrective Action Plans (CAPs) for identified risks. Temporarily suspend or disengage from suppliers involved in unmitigated human rights abuses or non‑cooperative smelters.
Step 4: Independent AuditsRequire direct and sub‑tier suppliers to source exclusively from smelters and refiners validated by third‑party audit mechanisms, such as the Responsible Minerals Initiative (RMI) RMAP.
Step 5: Public ReportingPublish an annual Responsible Minerals Sourcing Report summarizing due diligence activities, smelter validation percentages, and risk mitigation progress.

4. Expectations for Suppliers

We view our suppliers as critical partners in achieving ethical supply chain governance. Direct suppliers are required to:

Adopt and maintain a written responsible sourcing policy aligned with OECD guidelines.

Trace their complete supply chains and disclose processing facilities annually via RMI reporting tools.

Source exclusively from third‑party certified conformant smelters and refiners.

Cascade these ethical procurement standards to their own upstream sub‑tier suppliers.

5. Non‑Compliance & Enforcement

Compliance with this policy is a prerequisite for doing business with CoaTech Metal Surface Technologies. If a supplier fails to comply with data reporting requirements, uses unverified processing facilities, or fails to resolve identified red flags within an agreed Corrective Action Plan timeline, CoaTech Metal Surface Technologies reserves the right to suspend orders or terminate the business relationship.