HomeMy WebLinkAboutConflict Minerals - WielandConflict Minerals Policy
Wieland Group
Version 1.0, Valid from 04/09/2021
2 I Conflict Minerals Policy 2021
Introduction and Background
We as Wieland Group take our responsibility on due diligence along the supply chain very seriously. In addition
to our Supplier Code, we have defined expectations on responsible business conduct for the procurement of
conflict minerals.
Already in 2010, US legislators defined “conflict minerals”
as substances that are financing armed conflicts in spe-
cific regions. Since then, various definitions for ”conflict
minerals” have emerged. They usually entail the work-
ing conditions, social and environmental standards, and
high political risks (e.g., corruption) in the affected areas
or countries.
Currently, tantalum, tin, tungsten, their ores (cassiterite,
columbite-tantalite and wolframite) and gold, also known
as “3TG”, are referred to as conflict minerals.
In 2012 the United States Securities and Exchange
Commission (“SEC”) passed the “Conflict Minerals Rule”
to issue a final legislative framework on 3TG. The EU
Conflict Minerals Regulation of the European Commis-
sion came into effect in January 2021. Both legislations
are now relevant for 3TG.
In this context we emphasise that we strictly follow
the EU Conflict Minerals Regulation as well as other
applicable legislations relating to conflict minerals. The
Wieland Group adheres to an integrated managerial
risk-based approach which relies on the five steps of
the OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and
High-Risk Areas (CAHRA).
We expect our business partners to take similar efforts
to comply with the relevant provisions and require-
ments.
In any confirmed case of violation against the expec-
tations outlined in this policy, we will take adequate
measures.
Conflict Minerals Policy 2021 I 3
Expectations
Safeguarding human rights along the supply chain is of essential importance to our business conduct. In this
context we have outlined a set of specific minimum requirements that need to be fulfilled as the very foundation
of our business relationship. Such minimum requirements have been outlined in our Supplier Code already
and are covering principles on human rights and environmental protection.
With respect to 3TG we refer to the CAHRA-list pub-
lished by the EU Commission as a basis for our conflict-
affected and high-risk area classification assessment.
Business partners that are either directly or indirectly
sourcing from, or even have own extraction or pro-
cessing sites within one of the listed areas, are classified
as risky.
In that regard we consider compliance verifications
issued by the Responsible Minerals Initiative (RMI) or
comparable sustainability initiatives as essential tools to
reduce risks in our supply chain.
The RMI is a well-known initiative with special focus on
social and environmental standards in mineral and metal
supply chains. We recognise the standards of this initiative
and accept smelters and refiners that have successfully
completed the RMI assessment.
We strongly prefer working with business partners,
whose (production) sites are either RMI compliant
themselves or mainly source directly or indirectly
from smelters or refiners listed on the RMI´s confor-
mant or active lists. In this case, we consider them
to be “conflict-free”, even if the mining or processing
sites are located in a CAHRA. Therefore, we expect
all business partners to provide the Conflict Minerals
Reporting Template (CMRT), developed by the RMI.
Beyond that, we reserve the right to engage in further
screening of any business partner that is related to 3TG.
Furthermore, we have defined additional No-Go criteria that are in no way acceptable to us. Such No-Go criteria
are defined as confirmed cases in which the following abuses systematically occur:
–Child labour prohibited by ILO Convention 182.
–Forced and compulsory labour.
–Serious abuses and fatal treatment of workers life and limb, including human trafficking and hazardous working
conditions.
We welcome any information regarding violations against the No-Go criteria.
Stefan Thomas Manfred Stadler
VP Global Procurement and Logistics VP Metal Supply
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Wieland-Werke AG I Graf-Arco-Straße 36 I 89079 Ulm I Germany
info@wieland.com I wieland.com