Ethics and Compliance
Conflict Minerals Policy
Published February 2024
Overview
SNF is committed to conducting its business ethically and responsibly.
As part of this commitment, we recognize the importance of addressing the issue of conflict minerals in our supply chain. Conflict minerals refer to minerals sourced from regions associated with armed conflict, human rights abuses, and environmental degradation. Conflict minerals include metals tantalum, tin, tungsten and gold, which are the extracts of the minerals cassiterite, columbite-tantalite and wolframite.
POLICY STATEMENT
Compliance with Regulations
SNF is committed to complying with all applicable regulations and international standards regarding conflict minerals, including Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Conflict Minerals Rule) issued by the U.S. Securities and Exchange Commission (SEC) as well as the EU Conflict Minerals Regulation.
Supply Chain Due Diligence
SNF will implement a robust due diligence process to ensure that the minerals used in our products are sourced responsibly and do not contribute to environmental degradation, human rights abuses or armed conflict. This process includes:
- Supplier Engagement: We will engage with our suppliers to understand the origin of the minerals in our supply chain and encourage them to source from responsible and conflict-free sources.
- Risk Assessment: We will conduct a risk assessment of our supply chain to identify potential risks associated with conflict minerals.
- Reporting and Documentation: We will maintain records of our due diligence efforts, including supplier responses and any relevant documentation, to demonstrate our commitment to responsible sourcing.
Supplier Expectations
SNF expects suppliers to comply with our Conflict Minerals Policy and cooperate with our due diligence process. We will work collaboratively with our suppliers to address any identified risks and support them in adopting responsible sourcing practices.
Continuous Improvement
SNF will regularly review and update our Conflict Minerals Policy to ensure its effectiveness and alignment with evolving best practices and regulatory requirements.
Transparency and Communication
We will communicate our Conflict Minerals Policy to all relevant stakeholders, including employees, customers, suppliers, and investors. We will also strive to provide accurate and timely information regarding our efforts to address conflict minerals in our supply chain.
CONCLUSION
By adopting this Conflict Minerals Policy, SNF aims to contribute to the responsible sourcing of minerals and support global efforts to eliminate the trade of conflict minerals. We are committed to working towards a conflict-free supply chain, promoting human rights, and minimizing our impact on affected communities and the environment. With the implementation of robust due diligence processes, engagement with suppliers, and continuous improvement of our policy, SNF strives to ensure that the minerals used in our products are sourced responsibly and do not contribute to human rights abuses or armed conflict. Through transparency and effective communication, we will inform and engage our stakeholders in our efforts to address the issue of conflict minerals. We can positively impact and create a more sustainable and ethical supply chain.