Responsible Minerals Policy
1.Purpose
This policy affirms Celtic Chemicals’ commitment to responsible sourcing of minerals and ensures
that our products do not contribute to armed conflict, human rights abuses, or environmental harm.
2. Scope
This policy applies to all operations, products, and suppliers of Celtic Chemicals. It covers the
following minerals:
- 3TG: Tin (Sn), Tungsten (W), Tantalum (Ta), Gold (Au)
- Additional minerals of concern: Cobalt (Co), Nickel (Ni), Lithium (Li), Copper (Cu)
3. Definitaions
Conflict Minerals
Minerals originating from conflict-affected or high-risk areas that may finance
armed groups or contribute to human rights violations.
Due Diligence
Due Diligence process to identify, assess, and mitigate risks in the supply chain
accordance with the OECD Due Diligence Guidance.
4. Responsabilities
Senior Management: approve and oversee the implementation of this policy
Quality Manager: identify products containing conflict minerals / at risk minerals, conduct due
diligence, maintain records, and engage with suppliers.
5. Policy
Celtic Chemicals complies with EU Regulation 2017/821, which establishes supply chain due diligence
obligations for importers of Tin, Tantalum, Tungsten, and Gold (3TG). These minerals have been
linked to armed conflict and human rights abuses, particularly in the Democratic Republic of the
Congo (DRC) and adjoining countries.
Although Cobalt, Nickel, Lithium, and Copper are not classified as conflict minerals under the
regulation, they are considered materials of concern due to extraction practices.
Celtic Chemicals is committed to:
- Avoiding the use of minerals that directly or indirectly fund armed conflict or human rights abuses.
- Conducting due diligence on the source and chain of custody of 3TG, Co, Ni, Li, and Cu.
- Promoting transparency and ethical practices throughout our supply chain.
5.1. Supplier expectations
suppliers.
We seek to keep our supply chain and products free from derivatives or concern, i.e. unethically
sourced materials and we will consider suspending or discontinuing engagement with any supplier
where we identify a reasonable risk in this regard.
We require suppliers to:
- Avoid materials that finance armed groups or violate human rights.
- Implement due diligence processes to identify and verify mineral sources.
- Provide annual reporting using the Responsible Minerals Initiative (RMI) templates, including:
- Conflict Minerals Reporting Template (CMRT)
- Extended Minerals Reporting Template (EMRT)
- or any other Reporting Template that Celtic Chemicals determines as appropriate to
specific materials of concern.
We welcome dialogue from suppliers and customers regarding their compliance in relation to conflict
minerals and materials of concern and seek to raise awareness of these important issues.
5.2. Celtic Chemicals due diligence
Celtic Chemicals will:
- Evaluate our supply chain annually to identify at-risk products.
- Comply with all applicable national and international laws regarding embargoed or banned countries.
- Work toward eliminating the use of 3TG and other minerals of concern that finance armed groups.
