RESPONSIBLE SOURCING POLICY
Supply Chain Policy for Minerals from Conflict-Affected and High-Risk AreasDillon Gage recognizes there are significant risks which can adversely impact extracting, trading, handling, and exporting minerals from conflict-affected and high-risk areas. Recognizing that Dillon Gage has the responsibility to respect human rights and not contribute to conflict, we commit to adopt and incorporate in contracts and/or agreements with suppliers the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas, as representing a common reference for conflict-sensitive sourcing practices and suppliers’ risk awareness from the point of extraction until end user. Dillon Gage commits to refraining from any action which contributes to the financing of conflict, and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.
Regarding serious abuses associated with the extraction, transport, or trade of minerals:- While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:
- any forms of torture, cruel, inhuman, and degrading treatment.
- any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty, and for which said person has not offered himself voluntarily.
- the worst forms of child labor
- other gross human rights violations and abuses such as widespread sexual violence.
- war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
- Dillon Gage will immediately suspend or discontinue engagement with upstream suppliers where a reasonable risk has been identified that they are sourcing from, or linked to, any party committing serious abuses as defined in paragraph 1.
- Dillon Gage will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling, or export of minerals includes, but is not limited to, procuring minerals from, making payments to, or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
- illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
- illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
- illegally tax or extort intermediaries, export companies or international traders.
- Dillon Gage will immediately suspend or discontinue engagement with upstream suppliers where we identify any reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in paragraph 3.
- Dillon Gage will eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.
- Dillon Gage recognizes that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment, and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
- Where Dillon Gage or any company in our supply chain contracts public or private security forces, we commit to, or will require that such security forces be engaged in accordance with the Voluntary Principles on Security and Human Rights. We will support or take steps, to adopt screening policies to ensure individuals or units of security forces that are known to have been responsible for gross human rights abuses not be hired.
- Dillon Gage will support efforts, or take steps, to engage with central or local authorities, international organizations, and civil society organizations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.
- Dillon Gage will support efforts, or take steps, to engage with local authorities, international organizations, and civil society organizations to avoid or minimize the exposure of vulnerable groups artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
- In accordance with the specific position of Dillon Gage in the supply chain, we will immediately devise, adopt, and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified in paragraph 5, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.8 Where we identify a reasonable risk of activities inconsistent with paragraphs 8 and 9, we will respond in the same manner.
- Dillon Gage will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport, and export.
- Dillon Gage will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport, or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.
- Dillon Gage will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI). Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees, and royalties to governments:
- In accordance with the specific position of the company in the supply chain, Dillon Gage commits to engage with suppliers, central or local governmental authorities, international organizations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue our engagement with upstream suppliers after failed attempts at mitigation.