Conflict Minerals Policy
Last updated: March 16, 2022
1. Conflict Minerals Policy Statement
We at EXEO, our legal entities EXEO SAL, EXEO OFFSHORE SAL and SAS EXEO recognise the risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognise that we have the responsibility to respect human rights and not contribute to conflict.
These minerals are defined to be tin, tungsten, tantalum and gold, also referred to as 3TG. By that, we commit to comply with the EU – the Conflict Minerals Regulation.
We at Exeo, conduct due diligence to ensure that throughout our supply chain, human rights are respected and that we do not contribute indirectly to conflict or other related illegal activities..
We commit to:
- Establish a strong management system to identify and assess risk in the supply chain and report findings of the supply chain risk assessment to the Corporate Governance Committee.
- Adopt, widely disseminate and incorporate in contracts and/or agreements with suppliers policies on responsible sourcing of minerals from conflict-affected and high-risk areas.
- Immediately suspend or discontinue engagement with suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses and illicit trade in 3TG minerals.
- Establish a company level grievance mechanism allowing any interested party (affected persons or whistle-blowers) to voice concerns regarding the circumstances of mineral extraction, trade, handling and export in a conflict-affected and high-risk area. This will allow us to be alerted of risks in the supply chain as to the problems in addition to the company fact and risk assessments.
- Engage and actively cooperate with industry members with whom we share suppliers or downstream companies with whom they have a business relationship to identify if there are conflict minerals used in the supply chain.
Exeo is represented by the Corporate Governance Committee with the general responsibility to monitor and improve the established policies and establish processes for handling deviations and exceptions.
3. Review of the policies for information security
This policy is reviewed at planned intervals or if significant changes occur to ensure its continuing suitability, adequacy and effectiveness.
The policy review takes the results of management reviews into account.