Advanced Chemical Company - Responsible Sourcing Policy

Advanced Chemical Company is a conformant smelter registered with the Responsible Business Alliance, and conforms to the requirements set forth by the Responsible Minerals Initiative’s (RMI’s) Responsible Minerals Assurance Process (RMAP) Standard, that aligns with the Organization for Economic Co-operation and Development’s (OECD) Due Diligence Guidance for Responsible Supply Chains on Minerals from Conflict-Affected and High-Risk Areas. 

Advanced Chemical Company respect the dignity and importance of human rights and consider any mineral that may pose risks of contributing the harm listed in Annex II of OECD Guidelines to be ‘conflict minerals’ as well as risks related to money laundering and the financing of terrorism. We will only purchase gold-containing materials from sources that have been verified as not involving or contributing to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of the OECD Guidance and listed here: 

• Serious abuses associated with the extraction, transport or trade of minerals:
• Any forms of torture, cruel, inhuman and degrading treatment;
  • Any forms of forced or compulsory labor;
  • The worst forms of child labor;
  • Other gross human rights violations and abuses such as widespread sexual violence;
  • War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
• Direct or indirect support to non-state armed groups.
• Direct or indirect support to public or private security forces.
• Bribery and fraudulent misrepresentation of the origin of minerals.
  • Money laundering.
  • Non-payment of taxes, fees and royalties to governments.

In support of the above, all of our relevant staff members are directed to follow and trained on procedures to implement a conflict minerals due diligence system that aims to:

• • Exercise due diligence with relevant suppliers consistent with the OECD Guidance and the Responsible Business Alliance’s Responsible Minerals Assurance Process (RMAP) and encourage our suppliers to do the same.
  • Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm gold in our supply chain does not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance, as well as an Anti-Money Laundering and Countering Financing Terrorism Policy
  • Aim to establish long-term relationships with our immediate suppliers.
  • Consider ways to support and build capacities of gold supplying counterparties to improve performance and conform to this supply chain policy.
  • Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
  • Immediately discontinue engagement with suppliers who pose a reasonable risk to be causing severe human rights abuses.
  • Undergo an annual RMAP assessment to verify our conflict-free status as well as identify opportunities to continually improve our conflict minerals due diligence management system.
  • Commit to transparency in the implementation of this policy by making available reports on our progress to our customers, relevant stakeholders and the public (as required).
  • Support the implementation of the principles and criteria of the Extractive Industry Transparency Initiative (EITI).

Issue Date: January 1, 2021 

Currently, gold is the only mineral on the list of “Conflict Metals” that is related to our products, chemistries, or services. 

Should any person or party, either internal or external to our organization, have concerns regarding our sourcing practices or our handling of gold, may initiate a grievance with the Responsible Business Alliance by way of visiting their grievance portal at www.responsiblemineralsinitiative.org. 

For additional information regarding our Responsible Minerals Initiative program or our company, please visit www.advchem.com, or email info@advchem.com. 

David Farnum, COO  

Advanced Chemical Company - Step 5 Procedure

The purpose of this procedure is to help make informed decisions about responsibly sourced minerals in our supply chain based on the Responsible Minerals Assurance Process (RMAP) Standard. RMAP uses an independent third-party audit of smelter/refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The RMAP audit validates our company level management processes for responsible mineral procurement. Companies can then use this information to inform their sourcing choices. For more information on the RMAP standard please visit www.responsiblemineralsinitiative.org.

I. Company Information

II. RMAP Assessment Summary

III. Company Supply Chain Policy

IV. Company Management Systems 

V. Risk Identification

VI. Risk Mitigation

Advanced Chemical Company - Grievance Policy

We are aware of and actively supports the international efforts to investigate, monitor and mitigate activities that contribute to illegal armed groups, human rights violations, or financial wrongdoings in gold supply chains as defined in Annex II of the Organization of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas Third Edition (OECD Guidance).

We respect the dignity and importance of human rights and consider any mineral that may pose risks of contributing the harm listed in Annex II of OECD Guidelines to be ‘conflict minerals’. We will only purchase gold-containing materials from sources that have been verified as not involving or contributing to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of the OECD Guidance and listed here:

• Serious abuses associated with the extraction, transport or trade of minerals:
• Any forms of torture, cruel, inhuman and degrading treatment;
  • Any forms of forced or compulsory labor;
  • The worst forms of child labor;
  • Other gross human rights violations and abuses such as widespread sexual violence;
  • War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
• Direct or indirect support to non-state armed groups.
• Direct or indirect support to public or private security forces.
• Bribery and fraudulent misrepresentation of the origin of minerals.
• Money laundering.
• Non-payment of taxes, fees and royalties to governments.

In support of the above, all of our relevant staff members are directed to follow and trained on procedures to implement a conflict minerals due diligence system that aims to:

• Exercise due diligence with relevant suppliers consistent with the OECD Guidance and the Responsible Business Alliance’s Responsible Minerals Assurance Process (RMAP) and encourage our suppliers to do the same.
• Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm gold in our supply chain does not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance.
• Aim to establish long-term relationships with our immediate suppliers.
• Consider ways to support and build capacities of gold supplying counterparties to improve performance and conform to this supply chain policy.
• Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
• Immediately discontinue engagement with suppliers who pose a reasonable risk to be causing severe human rights abuses.
• Undergo an annual RMAP assessment to verify our conflict-free status as well as identify opportunities to continually improve our conflict minerals due diligence management system.
• Commit to transparency in the implementation of this policy by making available reports on our progress to our customers, relevant stakeholders and the public (as required).
• Support the implementation of the principles and criteria of the Extractive Industry Transparency Initiative (EITI).

GRIEVANCE MECHANISM FORM

• Advanced Chemical Company (“ACC”) makes every attempt to ensure that our customers are treated with courtesy and that their concerns are acknowledged and addressed in a timely manner. Our goal is to create a clear and coherent process to respond to any issues, and it is our policy to consider constructive comments as an opportunity for improvement.
• With regard to the Responsible Minerals Initiative (RMI) and the Responsible Minerals Assurance Programs (RMAP), ACC acknowledges the right of any individual or organization relevant to ACC (customers, business partners, service providers, or their representatives) to be able to raise any concerns about our process, and to file a grievance about our decision making protocol.
• This form allows any person or customer to submit a concern or grievance to ACC for review, assessment and response. The issues about ACC policy should be factual and evidence based. Please include all relevant documentation with your submission. All comments about our processes or criteria will be taken seriously and submitted to our compliance officer for investigation and review. All relevant submissions will be “logged” and maintained as a record in our files for a period of five years. If the issue does not concern ACC directly, or you have broader concerns or comments, you may also contact the RBA (Responsible Business Alliance) directly through their grievance page of the Responsible Minerals Initiative
• Our website allows for the anonymous reporting of incidents. In the event a “whistleblower” chooses to disclose information about wrongdoing or human rights related violations about our supplier or their practices, ACC will ensure the confidentiality of the supplier of the information, unless disclosure is required by law. Although providing contact information better allows ACC to further follow up with the information given during the investigation and resolution process, submissions which disclose information in good faith will be investigated in the same manner as other submissions. Anonymous submissions can also be made through the RMI website.