CONFLICT MINERALS POLICY

San Metal has been committed to maintaining a sustainable and transparent supply chain and has adopted the following considerations in relation to providing conflict minerals from Conflict-affected and high risk areas (CAHRA).

According to the generally accepted definition, Tin, Tungsten, Tantalum and Gold (3TG) are considered in this sector as Conflict Minerals. San Metal undertakes to avoid any actions that have been proven to be contributive to the financing of conflicts, to act in adherence to the regulations of the laws and legislation of the Republic of Turkey and to the government decrees of the Republic of Turkey, and to conform when applicable with the relevant United Nations sanctions and to encourage its suppliers and business partners to conform with the same.

As part of our efforts to manage the risks of and the exposure to conflict minerals, our suppliers and business partners are expected to fulfill the following considerations:

  • To work in cooperation with their suppliers that may have potential risks in order to take actions for minimizing and eliminating such risks or to cease cooperating with such suppliers, if necessary, in case of any failed attempt to minimize the risks,
  • To avoid offering, promising, giving and asking for bribes and to stand against the incentives to bribe in order to conceal or change the origin of minerals,
  • In case of the identification of money laundering in connection to the illegal taxation or seizure of minerals along the transportation routes or at the points of trading of minerals by suppliers or at the points of access to the mining sites, and in connection with or arising from the seizure, trading, distribution, transportation and exportation of minerals; to support and duly contribute to the efforts to effectively eliminate such money laundering,

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