Conflict Minerals Policy

"Conflict minerals" refers to tin, tantalum, tungsten and gold (3TG) and their derivatives where they may originate in the Democratic Republic of the Congo or an adjoining country and finance armed groups. Regulations including Section 1502 of the US Dodd-Frank Act and the EU Conflict Minerals Regulation (EU) 2017/821 require companies to exercise due diligence on these materials.

Our main materials are copper-zinc brasses, stainless and mild steels, aluminium and copper. 3TG can still be present in our supply chain, for example tin in bronze alloys and tin plating, and gold in some electrical platings, so we apply this policy to all of our sourcing.

Follow the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as the framework for our due diligence.

Not knowingly source materials containing 3TG that directly or indirectly finance or benefit armed groups.

Work with suppliers to trace 3TG to the smelter or refiner level and favour smelters and refiners validated as conformant under the Responsible Minerals Assurance Process (RMAP).

Suppliers of materials, platings and components that may contain 3TG are expected to adopt an equivalent policy, perform due diligence on their own supply chains, and provide a completed Conflict Minerals Reporting Template (CMRT) on request.

Where a supplier cannot provide adequate information, or a risk is identified, we will work with them on improvement and, if necessary, seek alternative sources.

On request, we provide customers with a completed CMRT for the parts we supply, based on information from our supply chain, and update it when that information changes.

Customers with questions about conflict minerals or cobalt and mica reporting may contact us through the details on our contact page.

This policy is reviewed annually and whenever relevant regulations or industry guidance change.