Supply Chain Policy

We, Davis Trade & Commodities (DTC), recognize the risks of negative impacts that may be associated with the extraction, trade, handling and export of minerals from conflict zones and high risk areas and understand that we have a responsibility to respect human rights and not contribute to conflict. We also recognize the importance of transparency in mineral supply chains and the positive impact on local development of responsible investment in artisanal and small-scale mining projects.

We are committed to adopting and implementing the responsible procurement policy for the following minerals:

We fully adhere to the standard of traceability as defined and recommended by the OECD, the IGLS and the Congolese Government to reflect the requirements of due diligence among all players up the supply chain.
We are committed to conducting our business in full compliance with all applicable national, regional and international laws and regulations.
We are committed to maximizing transparency in our supply chain and our operations.
We pay all taxes, fees and royalties related to mining, trade and export of minerals from conflict zones and high risk areas. We submit to audits in accordance with the principles set out in the Extractive Industries Transparency Initiative (EITI).

Commitment to the principles of the OECD Guide to the Duty of Care for Responsible Ore Supply Chains from Conflict or High-Risk Areas.

We conduct a permanent and proactive audit of our mineral supply chains from the point of extraction to the point of export in accordance with the OECD Guide to the Duty of Care for Responsible Ore Supply Chains from Conflict or High-Risk Areas.

We entrust authority and responsibility to senior managers with the necessary skills, knowledge, and experience to oversee the supply chain due diligence process.
We have internal responsibility for implementing the supply chain due diligence process.
We share the results of supply chain risk assessments with local mine monitoring committees, the provincial mining committee and other stakeholders.
We recognize that the role of public security forces on mining sites and/or surrounding areas and/or along transport routes should be solely to enforce the law, protect people and their property (including human rights), maintain facilities security and mine site protection, and escape routes (transportation) from extraction to export to avoid interference or illegal trade.
When we or any other company/organization in our supply chain contracts public security forces, we will engage and demand that these security forces be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support measures to adopt screening policies to ensure that individuals or units of the security forces known to be responsible for gross human rights violations are not recruited.
We are committed to avoiding any action that contributes to the financing of conflicts. In particular, we do not tolerate and are committed to eliminating:

Any direct or indirect support to non-state armed groups and public security forces that:

Illegally control mining sites, transport routes, marketing points.
Illegally tax or extort money or minerals at access points to mining sites, along transportation routes or at ore trade points; Or
Illegally tax or extort intermediaries, exporters or international buyers.

We consider "direct or indirect support" to include, but are not limited to, the supply of minerals from, or payment, or the provision of logistical or material assistance to non-state armed groups, public or private security forces.

Commitment to combat money laundering and the fight against the financing of terrorism.

We support efforts and take steps to contribute to the effective elimination of money laundering in situations where we identify a reasonable risk of money laundering resulting from or related to our supply chain and activities.

We will not deal with the following customer segments:

People on official sanctions lists.
Persons indicating possible involvement in criminal activities, based on the information available about them.
Persons with companies in which the legitimacy of the activity or the source of the funds cannot be reasonably verified.
Individuals who refuse to provide the required information or documents.
Entities whose shareholding and control structure cannot be determined.

Commitment to fight corruption.

We will not offer, promise, or grant bribes and will resist solicitations of bribes to hide or conceal the origin of minerals, to make false statements about taxes, duties and royalties paid to governments for the extraction, trade, processing, transportation, and export of minerals.
We prohibit corruption in all business practices and transactions carried out by our company and/or organization and by agents acting on behalf of our company and organization.
We are committed to establishing and implementing systems to manage the risks of corruption in our company and/or organization.

We do not work with suppliers upstream and downstream of the chain when we identify a reasonable risk that they:

Do not have the required licenses, agreements, permits or authorizations that are valid, up-to-date and cover all company or organization operations; Or
Supplies or are linked to a party that commits serious human rights violations; Or
Provide, or are in the process of sourcing from, or related to, any party that directly or indirectly supports non-state armed groups and the public or private security forces engaged in the illegal activities described above; Or
Do not ensure that all ores are fully traceable from the well to the smelter, and/or
Working conditions pose an imminent threat to the lives of employees, subcontractors, or visitors.

In line with our specific position as an upstream player in the supply chain, we are committed to working with relevant suppliers and stakeholders to design, adopt and implement a risk management plan for all risks reasonably identified by OECD standards. We are committed to regularly monitoring and monitoring the performance of suppliers upstream of the chain in order to prevent or mitigate these risks through actions taken in a timely manner. We will suspend or stop working with suppliers after unsuccessful mitigation attempts.