Summary of the Blaze Metals Resources supply chain policy

1. Blaze Metals resources, does not tolerate nor profit, assist, facilitate or contribute to any forms of human rights abuse, war crimes, or any form of criminal activity including but not limited to money laundering.
2. We do not tolerate any forms of forced labour, modern slavery, human trafficking the any worst forms of child labour  (as defined by the International Labour Organization Convention No 138 and 182).
3. We do not tolerate any direct or indirect support to non-state armed groups or their affiliates who illegally control or tax mines, or any point in the supply chain.
4. We commit to eliminate however possible direct or indirect support to public or private security forces that illegally control mine sites or any other points in the supply chain.
5. We commit to not offering, promising or demanding any bribes, and resist the solicitation of bribes to conceal the origin of metals or misrepresent taxes paid to the governments. We do not tolerate any forms of bribery or corruption.
6. We will support efforts and contribute to the elimination of money laundering.
7. We commit to uphold high standards of environmental protection and sustainability.
8. We commit to assessing suppliers and transactions on a risk-based approach and commit to a strong management system for identifying and mitigating risks.

Compliance, Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT),
Anti- Bribery and Corruption (ABC), and Supply Chain Management Policy

STATEMENT: The policy of Blaze Metals Resources FZE (“we”) is to (i) engage only in legitimate business abiding by all relevant rules and regulations which apply to our activities and operations, (ii) maintain the highest ethical and moral standards, and (iii) operate always under best practice exercising due-care and all necessary due-diligence. We commit to:

1. ZERO tolerance to profit, assist, facilitate or contribute to any forms of human rights abuse, war crimes, or any form of criminal activity including but not limited to money laundering.
2. We do not tolerate any forms of forced labour, modern slavery, human trafficking the any worst forms of child labour (as defined by the International Labour Organization Convention No 182).
3. We do not tolerate any direct or indirect support to non-state armed groups or their affiliates who illegally control or tax mines, or any point in the supply chain.
4. We commit to eliminate however possible direct or indirect support to public or private security forces that illegally control mine sites or any other points in the supply chain.
5. We commit to not offering, promising or demanding any bribes, and resist the solicitation of bribes to conceal the origin of metals or misrepresent taxes paid to the governments. We do not tolerate any forms of bribery or corruption.
6. We will support efforts and contribute to the elimination of money laundering.
7. We commit to uphold high standards of environmental protection and sustainability.
8. We commit to assessing suppliers and transactions on a risk-based approach and commit to a strong management system for identifying and mitigating risks.

The adoption, implementation, and maintenance of a compliance and risk based supply chain management system to achieve our goals and which will also comply with the responsible supply chain guidance issued by the Organisation for Economic Co-operation and Development (OECD), and relevant industry standards such as that of the London Bullion Market Association (LBMA), the Dubai Multi Commodities Centre (DMCC) and the Responsible Minerals Initiative (RMI).

SPECIFICS:

Due diligence is defined by the Organization for Economic Cooperation and Development (OECD) as an ongoing, proactive and reactive process through which companies ensure that they respect human rights and do not contribute to conflicts in high-risk areas (OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Second Edition, OECD Publishing, 2013, http://www.oecd.org/corporate/mne/guidanceedition2.pdfthus:

1. We do not tolerate nor profit, assist, facilitate or contribute to:
a) Torture, degrading or cruel treatment in any form whatsoever.
b) Any form of forced or compulsory labour, including the worst forms of child labour (as defined by the International Labour Organization Convention No 182* and 138) which includes:

  • All forms of slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage and serfdom and forced or compulsory labour, including forced or compulsory recruitment of children for use in armed conflict;
  • The use, procuring or offering of a child for prostitution, for the production of pornography or for pornographic performances;
  • The use, procuring or offering of a child for illicit activities, in particular for the production and trafficking of drugs as defined in the relevant international treaties;
  • Work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children.

c) Any other forms of human rights violations.

d) War crimes, violations of international humanitarian law, crimes against humanity or genocide.

e) Any form of criminal activity, including but not limited to money laundering, extortion, corruption or lawbreaking activity.

We commit to rejecting or immediately suspending and discontinuing engagement with suppliers or customers where we identify a reasonable risk that they are sourcing (or are linked) to parties committing any of the abuses described above.

2. We will not tolerate any direct or indirect support to non-state armed groups or their affiliates who:
a) Illegally control mine sites, transportation routes or other points in the supply chain.
b) Illegally tax or extort money or minerals at points in the supply chain, such as mining sites, or points where minerals are traded or exported.

We commit to reject or immediately suspend and discontinue engagement with suppliers or customers where we identify a reasonable risk that they are providing direct or indirect support to non-state armed groups as described above.

3. We recognize that the role of public or private security forces is to maintain the rule of law, including safeguarding human rights, providing security to mine workers and their equipment, and protecting the mine sites and transportation routes. We therefore commit to eliminate however possible (for instance through disengagement with the relevant suppliers) direct or indirect support to public or private security forces that illegally control mine sites, transportation routes or actors in the supply chain, or who commit abuse or the actions described in a) and b) of paragraph 2 above.

4. We commit to not offering, promising, giving or demanding any bribes, and we will resist the solicitation of bribes to:

a) conceal or disguise the origin of minerals.
b) misrepresent taxes, fees and royalties paid to governments for the purpose of mineral extraction, trade, handing, transport and export. In fact, we have a zero-tolerance policy towards any type of bribery or corruption. Under no circumstances shall any employee or anyone acting on behalf of an employee give, pay, offer, promise to pay, or authorize the giving or payment of money or any other thing of value to any foreign government official or client, vendor or other business partner for any improper purpose or in violation of applicable laws.
We will however ensure to the extent possible that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments as required.

5. We will support efforts and contribute to the elimination of money laundering and the financing of terrorism, and we commit to reject or disengage from counterparties where we identify a reasonable risk of such activity.

6. We will uphold high standards of environmental protection and sustainability. We commit to minimize the impact of our processes on the environment and to follow all emissions and other regulations that govern our activity. We also commit to investigate the sustainability and environmental impact of our suppliers.

MANAGEMENT SYSTEM

We commit to implement, centralize, communicate, monitor, adapt and improve a robust due-diligence management system, which will include:

  • Clear responsibilities and escalation channels for all relevant employees or external stakeholders.
  • A framework that assesses risk in the supply chain and identifies Conflict-Affected and High-Risk Areas (CAHRA).
  • A robust Know-Your-Customer (KYC) framework for all our suppliers.
  • Monitoring of transactions and risk mitigation steps based on the risk assessment of suppliers.
  • Maintaining records.
  • Mandatory training for all relevant employees.

Identification and risk assessment in our supply chain:

  • We alert relevant central government authority (e.g. Ministry of Mines) of abusive and exploitative practice succouring in the supply chain;
  • In areas in which minerals are illegally taxed or extorted, we take immediate steps to ensure that upstream intermediaries and consolidators disclose downstream or publicize the payments made to public or private security forces for the provision of security.
  • while sourcing from areas of artisanal and small-scale mining (“ASM”), Blaze Metals Resources support the formalization of security arrangements between “ASM” communities, local government, and public or private security forces, in cooperation with civil society and international organizations, as appropriate, to ensure that all payments are freely made and proportionate to the service provided, clarify rules of engagement consistent with the Voluntary Principles on Security and Human Rights, the UN Code of Conduct for Law Enforcement Officials and the UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials;
  • We support the establishment of community forums and build partnership with International Non-Government organizations such as OHENEBA POKU Foundation among others.

Risk responding strategy:

We Preserve the reliability and quality of company fact and risk assessment of a supply chain, by ensuring that company assessors are independent from the activity being assessed and free from conflict of interests.

Our assessors commit to reporting truthfully and accurately and upholding the highest professional ethical standards and exercise “due professional care”

The above is an integral part of our Policy and we require every employee and all our stakeholders in supply chain to fully comply with it. The latest version of this policy will be available on our website https://blazemetalsresources.com/

CONTACT INFORMATION:

If you have any questions regarding the content of this policy or if you have any comments or concerns in relation to responsible sourcing,

please contact:
Email: compliance@blazemetals.org  | Tel: +971 4 2323060 and ask to speak to a member of our compliance team.

ACKOWLEDGMENT:

We wish to Appreciate the “Organization for Economic Co-operation and Development” (OECD) for the guidance provided in Annex II of the “OECD Due Diligence Guidance for the Responsible Supply Chains of Minerals from Conflict.

Policy Adopted :01th July 2019