As a 21st century global precious metals trader, AGE Global Trading is firmly committed to conducting its business with integrity and transparency and in compliance with best practices and all applicable laws, regulations and guidelines. For minerals and ores known as “Conflict Minerals”, these include:
- The conflict mineral provisions (Section 1502) of the United States Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).
- The due diligence guidance for responsible mineral supply chain activities related to conflict-affected and high-risk areas formulated by the Organization for Economic Cooperation and Development (the OECD Guidance).
- RCM of the ICGLR 2nd Ed.
- DMCC Practical Guidance for Market Participants in the Gold and Precious Metals Industry v.1 released April, 2012 (the DMCC Guidance) & the DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain (the DMCC Rules for RBD-GPM). The Conflict Minerals covered by the Dodd-Frank Act, the OECD Guidance, and ICGLR are known as the “3TGs”, being cassiterite (for tin), wolframite (for tungsten), coltan (for tantalum), and gold ore, minerals and their derivatives that are extracted from and that have been determined to be financing conflict in the Democratic Republic of the Congo or adjoining countries (Great Lakes).
It is AGE Global Trading’s policy to source minerals and metals in a transparent, ethical and responsible manner and, with minerals originating from the Great Lakes, to engage in responsible trade with mineral producers who participate in conflict-free and transparent supply chain initiatives. It is likewise AGE Global Trading’s policy to source minerals and metals that are free of unlawful child or forced labor or other human rights abuses. Consequently, it is also AGE Global Trading’s policy not to engage in the purchase of material that may contain minerals that directly or indirectly finance or benefit armed groups in the Great Lakes or that lend themselves to labor or other human rights abuses. AGE Global Trading’s policy not only extends to the 3TGs within the scope of the Dodd-Frank Act, the OECD Guidance, and ICLGR RCM but also cobalt and other minerals originating from these regions.
AGE Global Trading recognizes the risk that mineral mining and sourcing practices may lend themselves to labor and other human rights abuses and that revenue from mineral trading may be misused to fund armed conflict or corruption. These risks are higher in vulnerable parts of the world with weak or corrupt governments and poor enforcement of the rule of law such as the Great Lakes. AGE Global Trading aims to remain engaged in, and source responsibly from, conflict-affected and high-risk areas while enabling communities to benefit from their mineral resources and contributing to sustainable development in such areas, acknowledging that losing access to markets for artisanal miners can directly translate into lost livelihoods for vulnerable individuals and families.
To identify, manage and mitigate these risks, AGE Global Trading conducts due diligence on its supply chain and works to establish and participate in transparent and responsible mineral supply chain initiatives. Given AGE Global Trading’s position in the supply chain, this due diligence includes know-your-counterparty (KYC) procedures to know proposed suppliers, including determining their good standing with conflict-free supply chain initiatives and, when warranted, on-the-ground visits and meetings. AGE Global Trading also reserves audit rights in their contracts with suppliers and the right to disengage with suppliers whose commitment to conflict-free sourcing and legal and ethical labor practices is questionable or appears to be compromised.
AGE Global Trading’s due diligence for Conflict Minerals follows the OECD Guidance’s five-step framework and seeks to further the Guidance’s objectives, including taking steps to identify and assess risk in the supply chain and make continued efforts to source only traceably conflict-free minerals from the Great Lakes and to refrain from sourcing minerals extracted or produced with unlawful child or forced labor or other human rights abuses. While no member of AGE Global Trading is an SEC-reporting company, we are nevertheless committed to cooperating with our customers and business partners in their compliance with the Dodd-Frank Act.
Sourcing of Minerals from Conflict-Afflicted & High-Risk Areas
AGE Global Trading is firmly committed to conducting its business with integrity and transparency, in accordance with best practices and in compliance with all applicable laws and regulations. In its sourcing of ore and minerals from conflict-affected and high risk areas in the Great Lakes region, AGE Global Trading strives to be inclusive and to influence the supply chain in a positive manner and follows the OECD due diligence guidance for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Guidance) as well as EU regulation 2017/821 of the European Parliament and of the Council of 17 May 2017 on Conflict Minerals supply chain due diligence obligations, itself in line with the OECD Guidance, Regional Certification Mechanism (RCM) of the International Great Lakes Region (ICGLR) 2nd Ed., and the DMCC Practical Guidance for Market Participants in the Gold and Precious Metals Industry v.1 released April, 2012 (the DMCC Guidance) & the DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain (the DMCC Rules for RBD-GPM). The OECD Guidance is a government-backed multi-stakeholder initiative to promote transparent mineral supply chains and avoid contributing to conflict through mineral sourcing practices, while enabling communities to benefit from their mineral resources. Further, and while AGE Global Trading is privately-owned and therefore not directly bound by it, in the United States we follow Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, HR 4173, (the Dodd-Frank Act) and the rules promulgated by the SEC for SEC-reporting companies that use minerals originating in the Democratic Republic of Congo and adjoining countries. AGE Global Trading also self-certifies its supply chain upon request to customers.
This self-certification mechanism follows the OECD Guidance’s five-step framework for due diligence reports and covers sourcing and trading by AGE Global Trading of tin, tantalite, tungsten and gold (Relevant Minerals) from the Great Lakes area in Africa.
Acknowledgement for Responsible Mineral Supply Chain from CAHRAs
AGE Global Trading is at the forefront of efforts to source mineral and metals in an ethical manner by engaging in responsible trade with mineral producers and traders who participate in conflict-free and transparent supply chain initiatives, and with joint efforts to enable such responsible trade.
AGE Global Trading continues to explore and is keen to support additional supply chain due diligence initiatives that can be helpful in establishing a supply chain free of conflict or human rights abuses.
Establish Strong Company Management Systems
AGE Global Trading’s position on conflict minerals is set out in our Conflict Minerals Supply Chain Manual (the Policy) which sets forth our firm commitment to comply with the relevant provisions of the Dodd-Frank Act and to further the objectives of the OECD Guidance and ICGLR RCM. The Policy furthers the objectives and guiding principles laid out in AGE Global Trading’s Code of Conduct to conduct business in an ethical manner and in accordance with best practices and all applicable laws and regulations. AGE Global Trading also has an internal due diligence protocol outlining the due diligence process the company undertakes when sourcing Relevant Minerals.
Supply Chain Risk Assessment
The Great Lakes Area experiences logistics challenges as well as periodic deterioration of the security situations and sourcing from the area remains challenging due to the presence of armed groups, abuses by rogue police and rogue soldiers, bribery and other illegal activity. Risk of smuggling of minerals from surrounding countries into Rwanda and Uganda remains a concern and requires close monitoring. Challenges are sometimes present and incidents can arise in relation to the chain of custody, due diligence, security or human rights concerns.
Security incidents also occur on the roads between the mine sites and the points of export, with attempts at extortion by the mines police or the FARDC (Congolese army). Effective due diligence is critical. AGE Global Trading undertakes due diligence with respect to proposed new suppliers and, if satisfied, approval is granted as per AGE Global Trading’s SCM. Due diligence includes know-your-counterparty (KYC) internal assessment and third-party checks, plausibility checks on the material, including material specifications and production quantities and its purported source. Due diligence has in the past led to AGE Global Trading declining to purchase tagged minerals because material specifications gave rise to doubts as to the real origin of the material being different from that reported. AGE Global Trading sources from a small number of well-known suppliers, all of which are ICGLR traceability compliant.
AGE Global Trading does not undertake any cash purchases and pays all suppliers by international bank transfer. No payments have been made to public or private security forces in relation to purchases of Relevant Minerals.
AGE Global Trading is in regular contact with traceability providers to exchange information, support capacity of suppliers and to discuss issues or concerns. Each import is audited by the compliance department as a way of monitoring good standing of suppliers on an on-going basis.
Response to Risks
AGE Global Trading’s due diligence protocol includes a risk management plan for risks identified. Any identified risk is discussed within the Due Diligence Working Group with a view to determine appropriate measures such as further investigation, suspension or disengagement.
If a red/yellow flag or concern is raised concerning a supplier of Relevant Minerals, depending on the nature and seriousness of the concern, AGE Global Trading will (i) request from the supplier its proposed plan for rectification or significant measurable improvement, (ii) if not satisfactorily resolved, will decide not to enter into or to suspend temporarily the purchase of products of that origin until rectification or significant measurable improvement has been implemented; and (iii) if warranted, terminate the contract with the affected supplier.
Contracts for Relevant Minerals include provisions allowing disengagement with a supplier upon breach by the supplier of undertakings to comply with OECD Guidance as applicable to their operations. If warranted by incidents, alerts or otherwise, AGE Global Trading will exercise such rights.