Responsible Supply Chain Policy
At P. Kay Metal, we recognize that risks of adverse impacts may be associated with extracting, trading, handling and exporting minerals, in particular when sourcing from conflict-affected and high-risk areas. We also recognize that we have a responsibility to respect human rights and not contribute to conflict.
To this end, we adopt the following policy for the responsible sourcing of Tin; and expect our suppliers to uphold the same standards and commitments.
Our standards and commitments:
We commit to refraining from any action which contributes to the financing of conflict and we to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.
Serious human rights abuses:
We commit to neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of serious abuses, including:
any forms of torture, cruel, inhuman and degrading treatment;
any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
the worst forms of child labour;
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.
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined in this Policy.
Direct or indirect support to non-state armed groups:
We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. This includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
illegally tax or extort intermediaries, export companies or international traders.
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in this Policy.
Regarding public or private security forces:
We recognise that the role of public or private security forces should be solely to maintain the rule of law, including safeguarding human rights, providing security to workers, equipment and facilities, and protecting sites or transportation routes from interference with legitimate extraction and trade.
We will not tolerate any direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.
Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights.
We will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.
Bribery, fraudulent misrepresentation of the origin of minerals, and money laundering:
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.
We commit to engage with suppliers and other relevant stakeholders, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
Payment of taxes, fees and royalties due to governments:
We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments, in support of the principles set forth under the Extractive Industry Transparency Initiative (EITI).
We commit to engage with suppliers and other relevant stakeholders, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
Our governance framework:
This Policy is endorsed and implemented by P. Kay Metal’s Senior Management / Dan Hall, Operations Manager, in collaboration with all relevant departments.
This Policy is implemented and fully integrated into decision making processes through a riskbased due diligence system aligned with the 5-step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas which includes:
Establishing a strong management system for due diligence;
Identifying and assessing risks in mineral supply chains;
Designing and implementing a strategy to respond to identified risks;
Carrying out independent third-party audits at key stages of transformation in mineral supply chains;
Reporting annually on supply chain due diligence.
This Policy is reviewed for effectiveness and continuous improvement every year and when new circumstances arise.
In the spirit of transparency, this policy is published on our website, and regularly communicated both internally and to our business partners. The results of our due diligence practices will be communicated on our website on a yearly basis.
Should you become aware of any potential associations by P. Kay Metal or our supply chains to any of the risks described in this Policy, we encourage you to get in touch with our team, by submitting any concern or grievance at: grievances@pkaymetal.com.
If you prefer to submit your grievance anonymously, please do so https://www.pkaymetal.com/sustainability
Cindy Flame
Vice President
July 1, 2025