Commercial Policy
Version: 06
Validity: 2024-10-24
Our company Metalurgical Operations S.A., establishes its commercial policy for the purchase of Tin concentrates based on responsible management in its Supply Chain, in order to respect human rights above all at all levels and comply with transparent commercial procedures at the time to supply the mineral to our company.
Commercial Management complies and undertakes to disseminate this policy so that it is public knowledge, with special emphasis on all its suppliers.
Metalurgical Operations S.A., in accordance with its Code of Conduct (point 3- Commitment of Operaciones Metalúrgicas S.A. with our stakeholders, point 4- Bribery and/or Extortion, point 5- Political Activity, point 6- Money Laundering 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 respect to 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, European Union Conflict Minerals Regulation, U.S. Treasury Department OFAC Sanctions List, Heidelberg Conflict Barometer.
- Operations Metalúrgicas S.A. It is regulated in accordance with 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.
- Metalurgical Operations S.A. It does not have business or relationship with tin ore suppliers outside Bolivian territory and therefore does not do business with associated third parties in high, medium or low risk countries.
- Operations Metalúrgicas S.A. maintains within its Code of Conduct policies of respect for Human Rights and does not tolerate for any reason or obtain benefits and will never act to contribute, help or facilitate any actor to commit:
- 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
- Metalurgical Operations S.A. negotiates under the principles of honesty, rectitude and respect with our concentrate providers, 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 give certainty at all times to our suppliers, as well as to ensure long-term sustainable supply.
- Metalurgical Operations S.A. does not participate in commercial or business practices that violate commercial regulations and national laws or that disagree with our philosophy and we are committed to complying with the Extractive Industries Transparency Initiative (EITI).
- We define a consistent and transversal Risk Management System, which facilitates the homogeneous measurement of risks, and is also proactive for common understanding. Our risk management is associated with sustainability (environmental, social and governance), considering in the analysis the perspective of the company as its stakeholders. We have adequate action plans to achieve ratings in the Supply Chain Risk and Opportunity Management matrix, thus responding in a timely manner to internal and external changes such as probability of occurrence and conflict-generating impact.
- Metalurgical Operations S.A. undertakes to collaborate with 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 guarantee that all taxes and royalties related to extraction, trade and export will be paid to the Autonomous Departmental Governments and corresponding Municipal Autonomous Governments.
- Metalurgical Operations S.A. is committed to the anti-corruption laws of the Bolivian State, for this reason it does not tolerate or tolerate any act of corruption, bribery, money laundering directly or indirectly.
- Metalurgical Operations S.A. assuming its status as a private industry, it does not practice or promote political acts, therefore, it will not have a relationship with political parties.
- Metalurgical Operations S.A. supports and participates in events that promote legal trade, protected by Due Diligence, especially if they refer to business behaviors that respect Human Rights, honest business practices with suppliers and customers, and updating reports and reports that have an impact on the sector.
Extending to customers and suppliers. In case of knowing that these universal principles are being violated, consequently our organization will suspend any contract and commercial relationship with its suppliers or customers within the supply chain and will be subjected to a research process that allows evidence or not of the transgression.