Commercial Policy
Version: 05
Validity: 2022-11-24
Our company Operaciones Metalúrgicas S.A., establishes its commercial policy for the purchase of Tin concentrates based on a responsible management in its Supply Chain, with the purpose of respecting Human Rights at all levels and complying with transparent commercial procedures at the moment of supplying the mineral to our company.
The Commercial Management complies with and is committed to disseminate this policy so that it becomes public knowledge, with special emphasis on all its suppliers.
Operaciones Metalúrgicas S.A., in compliance with its Code of Conduct ( point 3- Commitment of Operaciones Metalúrgicas S.A. with our stakeholders, item 4- Bribery and/or Extortion, item 5- Political Activity, item 6- Money Laundering, item 7- Conflicts of Interest and Business Opportunities), establishes the following mandatory compliance criteria in compliance with Bolivian Laws, Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals in Conflict or High Risk Areas Third Edition, and the Dodd Frank Act.
- Operaciones Metalúrgicas S.A. is regulated according to the principles, guidelines and procedures dictated by the Mining and Metallurgy Law of the Plurinational State of Bolivia Law 535 in force since May 28, 2014.
- Operaciones Metalúrgicas S.A. does not do business with tin ore suppliers outside Bolivian territory and therefore does not do business with third party associates in high-risk countries and conflict zones nor with local companies that may import tin ore.
- Operaciones Metalúrgicas S.A. maintains within its Code of Conduct policies of respect for Human Rights and does not tolerate for any reason whatsoever and will never act to contribute, help or facilitate that any actor commits:
* Any form of torture or cruel, inhuman or degrading treatment.
* Any form of forced or compulsory labor
* The worst forms of child labor
* Other serious 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
Extending to customers and suppliers. In case of knowing that these universal principles are being transgressed, consequently our organization will suspend any contract and commercial relationship with its suppliers or customers within the supply chain and will be subjected to an investigation process that will allow to prove or not the transgression.
- Operaciones Metalúrgicas S.A. negotiates under principles of honesty, rectitude and respect with our concentrate suppliers, in order to achieve above all their loyalty and trust towards our company with a fluid, timely and truthful information channel. Our premise is to provide certainty at all times to our suppliers, as well as to ensure sustainable supply in the long term.
- Share Due Diligence information to confirm that the material containing tin in our supply chain does not contribute to illegal armed groups, human rights violations, or financial misappropriations as defined by OECD Annex II.
- Operaciones Metalúrgicas S.A. does not engage in commercial or business practices that violate trade regulations and national laws or that are inconsistent with our philosophy and we are committed to comply with the Extractive Industries Transparency Initiative (EITI).
- Operaciones Metalúrgicas S.A. is committed to collaborate with the national authorities to contribute to the elimination of any type of fraud related to the extraction, trade, handling, transportation or export of any mineral and to guarantee that all taxes and royalties related to extraction, trade and export will be paid to the corresponding Autonomous Departmental Governments.
- Operaciones Metalúrgicas S.A. is compromised with the anti-corruption laws of the Bolivian State, for this reason it does not tolerate and will not tolerate any act of corruption, bribery, money laundering directly or indirectly.
- Operaciones Metalúrgicas S.A., assuming its condition of private industry, does not practice or promote political acts, therefore, it will not have any relationship with political parties.
- Operaciones Metalúrgicas S.A. supports and participates in events that promote legal commerce, protected by Due Diligence, especially if they refer to business conduct that respects Human Rights, honest commercial practices with suppliers and clients and updating of reports and information that have an impact on the business.