CDTOP’s Responsibly Sourced Minerals Policy

The trade of minerals in conflict and high-risk areas is often connected to increased violence and human rights abuses, which undermine the efforts towards ethical governance and the rule of law. Increased awareness amongst governments, NGOs, the investment community, and companies worldwide are at the forefront of drawing attention to the exploitative conditions imposed in these conflict and high-risk areas. Working together is critical to establishing peace, development, and stability.

Our Policy

CDTOP’s policy is to ethically source minerals from responsible suppliers to ensure that CDTOP’s supply chain does not contribute to human rights abuses around the globe. If sources are identified that do not follow CDTOP standards, CDTOP will take action to remove them from our supply chain.

Our Approach

CDTOP’s responsibly sourced mineral program is designed in accordance with the Organization for Economic Co- operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas including the related supplements on gold, tin, tantalum and tungsten, as it relates to our position as a “downstream” purchaser. In addition, CDTOP requires our suppliers to adhere to CDTOP’s Supplier Code of Conduct, which compels our suppliers to ensure responsible sourcing of minerals in their supply chains. Suppliers must exercise due diligence on the source and chain of custody of minerals and provide their due diligence policies and measures upon request. To verify compliance with these commitments, CDTOP conducts third- party audits.

CDTOP will continue to responsibly source minerals in our supply chain. We will work together with auditors, governments, other companies, and suppliers to facilitate continuous improvements in industry-wide due diligence approaches and human-rights-focused practices.