At TUBETECH, we are committed to conducting our business in a manner that respects human rights, supports environmental sustainability, and promotes responsible sourcing practices. As part of this commitment, we recognize the importance of responsible minerals sourcing to avoid contributing to conflict and human rights abuses in the global supply chain. This policy outlines our approach to responsible minerals sourcing, focusing on conflict-free minerals.

 

Scope

This policy applies to all TUBETECH operations, including our suppliers and subcontractors, involved in the sourcing, processing, and use of minerals such as tin, tantalum, tungsten, and gold (3TG) that are sourced from conflict-affected or high-risk areas.

 

Compliance with Regulations and Standards

We are committed to complying with all applicable laws and regulations related to responsible minerals sourcing, including but not limited to the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, the EU Conflict Minerals Regulation, and any other relevant international standards.

 

Supply Chain Due Diligence

We will conduct due diligence to identify and assess risks in our supply chain associated with the sourcing of minerals from conflict-affected or high-risk areas. This includes:

• Establishing robust management systems to support responsible minerals sourcing.
• Communicating our policy and expectations to suppliers and subcontractors.
• Identifying and prioritizing high-risk suppliers and supply chain segments.
• Conducting risk assessments to determine the presence and extent of risks related to conflict minerals.
• Implementing measures to mitigate identified risks, including engaging with suppliers to improve transparency and traceability in the supply chain.

 

Traceability and Transparency

We will work with our suppliers to establish transparent and traceable supply chains for minerals sourced from conflict-affected or high-risk areas. This includes:

• Mapping the supply chain to identify the origin of minerals and any potential risks associated with their extraction and trade.
• Encouraging suppliers to source minerals from responsible and certified mines and smelters.
• Implementing mechanisms to track the movement of minerals throughout the supply chain and verify their compliance with our sourcing standards.

 

Collaboration and Continuous Improvement

We recognize that responsible minerals sourcing is an ongoing process that requires collaboration with stakeholders across the supply chain. Therefore, we are committed to:

• Engaging with industry partners, civil society organizations, and other stakeholders to share best practices and promote responsible sourcing initiatives.
• Providing training and capacity-building support to our employees, suppliers, and subcontractors to enhance awareness and understanding of responsible minerals sourcing issues.
• Regularly reviewing and updating our policies and practices to reflect evolving standards and expectations related to responsible minerals sourcing.

 

Reporting and Transparency

We will publicly disclose information about our responsible minerals sourcing efforts, including our policies, practices, and performance indicators, in accordance with relevant reporting requirements and industry initiatives.

 

Non-Compliance

Non-compliance with this policy may result in corrective actions, including termination of business relationships with suppliers or subcontractors who fail to adhere to our responsible minerals sourcing requirements.

 

Conclusion

TUBETECH is committed to promoting responsible minerals sourcing practices that contribute to the development of conflict-free supply chains and support sustainable development in the communities where we operate. By implementing this policy, we aim to uphold our ethical principles and fulfill our responsibility to respect human rights and protect the environment.