Advanced Chemical Company - Responsible Sourcing Policy

Advanced Chemical Company is a conformant smelter registered with the Responsible Business Alliance, and conforms to the requirements set forth by the Responsible Minerals Initiative’s (RMI’s) Responsible Minerals Assurance Process (RMAP) Standard, that aligns with the Organization for Economic Co-operation and Development’s (OECD) Due Diligence Guidance for Responsible Supply Chains on Minerals from Conflict-Affected and High-Risk Areas. 

Advanced Chemical Company respects the dignity and importance of human rights and considers any mineral that may pose risks of contributing the harm listed in Annex II of OECD Guidelines to be ‘conflict minerals’ as well as risks related to money laundering and the financing of terrorism. We will only purchase gold-containing materials from sources that have been verified as not involving or contributing to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of the OECD Guidance and listed here: 

• Serious abuses associated with the extraction, transport or trade of minerals:
• Any forms of torture, cruel, inhuman and degrading treatment;
  • Any forms of forced or compulsory labor;
  • The worst forms of child labor;
  • Other gross 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.
• Direct or indirect support to non-state armed groups.
• Direct or indirect support to public or private security forces.
• Bribery and fraudulent misrepresentation of the origin of minerals.
  • Money laundering.
  • Non-payment of taxes, fees and royalties to governments.

In support of the above, all of our relevant staff members are directed to follow and be trained on procedures to implement a conflict minerals due diligence system that aims to:

• • Exercise due diligence with relevant suppliers consistent with the OECD Guidance and the Responsible Business Alliance’s RMAP and encourage our suppliers to do the same.
  • Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm gold in our supply chain does not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance, as well as an Anti-Money Laundering and Countering Financing Terrorism Policy.
  • Aim to establish long-term relationships with our immediate suppliers.
  • Consider ways to support and build capacities of gold supplying counterparties to improve performance and conform to this supply chain policy.
  • Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
  • Immediately discontinue engagement with suppliers who pose a reasonable risk to be causing severe human rights abuses.
  • Undergo an annual RMAP assessment to verify our conflict-free status as well as identify opportunities to continually improve our conflict minerals due diligence management system.
  • Commit to transparency in the implementation of this policy by making available reports on our progress to our customers, relevant stakeholders and the public (as required).
  • Support the implementation of the principles and criteria of the Extractive Industry Transparency Initiative (EITI).

  Currently, gold is the only mineral on the list of “Conflict Metals” that is related to our products, chemistries, or services. 

  In addition, Advanced Chemical Company : 

  1. makes and receives payments for gold through official banking channels where they are reasonably available,
  2. avoids cash transactions where possible and ensures all unavoidable cash transactions are supported by verifiable information,
  3. cooperates fully and transparently with law enforcement agencies regarding gold transactions, when required, and
  4. provide customs officials with access to complete information on all international shipments.

  Should any person or party, either internal or external to our organization, have concerns regarding our sourcing practices or our handling of gold, may initiate a grievance with the Responsible Business Alliance by way of visiting their grievance portal at www.responsiblemineralsinitiative.org. 

  For additional information regarding our Responsible Minerals Initiative program or our company, please visit www.advchem.com, or email info@advchem.com. 

  David Farnum, COO 

  Issue Date: October 31, 2023 

Advanced Chemical Company - Step 5 Procedure

The purpose of this procedure is to help make informed decisions about responsibly sourced minerals in our supply chain based on the Responsible Minerals Assurance Process (RMAP) Standard. RMAP uses an independent third-party audit of smelter/refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The RMAP audit validates our company level management processes for responsible mineral procurement. Companies can then use this information to inform their sourcing choices. For more information on the RMAP standard please visit www.responsiblemineralsinitiative.org.

I. Company Information

II. RMAP Assessment Summary

III. Company Supply Chain Policy

IV. Company Management Systems 

Management Structure

• COO - Oversees due diligence
• Finance Manager – Manages due diligence

Departmental Expectations

• Customer Service – Exercises due diligence regarding KYC procedures, receiving procedures
• Sales – Exercises due diligence regarding KYC procedures, ID Red Flags, ID CAHRA, ID Supply Chain Risks
• Refining – Exercise due diligence regarding receiving procedures, ID Red Flags, CAHRA

Relevant Trainings

• Finance, Customer Service, Sales, Refining annual RMI review will be completed by 6/30/22
• Onboarding training is conducted for any new member or Finance, Customer Service, Sales, Refining

A management review and document will be completed on 6/30/22. Recent improvements to our due diligence program include updating our sourcing policy, CAHRA identification procedure, grievance mechanism and process, and supplier due diligence.

Internal Systems of Control

• Responsible Sourcing Policy states that we uphold RMAP expectations and avoid sourcing from high risk sources
• Enforce supplier expectations and requirements through KYC procedures
• Review material upon receipt through our Lot Receipt Procedures
• Assign a unique lot number to, account for, and reconcile all gold containing material received, processed, and sold
• Conducting inventory controls throughout the refining process
• Continually update and monitor suppliers with annual account review and request updated KYC when applicable
• Ensure our Grievance Mechanism is accessible to all through the company website, utilize our Grievance Response Procedure as needed

Record Keeping System

• KYC information is stored on our internal cloud accessible only by management for review and maintenance
• Refining lot retention kept in storage for 5 years – contains receiving, processing, settlement information

V. Risk Identification

Procedure to Identify CAHRA
The purpose of this procedure is to identify conflict-affected and high-risk areas (CAHRAs) that may exist in our gold supply chains. This procedure will be applied to supply chains (i.e. material, transit routes, suppliers) of all mined gold, recycled gold, and financial or refinery sources that are not conformant with the Responsible Minerals Assurance Process Standard annually or prior to sourcing new material or form new suppliers. The resources and criteria used to define CAHRAs are:

Know Your Supplier (KYC)

• The purpose of this procedure is to complete Know Your Counterparty (KYC) evaluations of each supplier of gold material. We establish and implement basic KYC requirements to determine the identity, type of business relationship and legality of business operations for each supplier of gold material in accordance with Responsible Minerals Assurance Process (RMAP) standard. Our KYC procedure includes an evaluation of beneficiaries against global sanctions lists.

Supply Chain Risk Identification

• We evaluate any posed risks associated with Annex II of the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals in our gold supply chains by leveraging our CAHRA identification and KYC procedures in addition to validating the type and origin of each transaction of gold containing material we source. Advanced Chemical Company has not identified any supply chain risks.

VI. Risk Mitigation

• Advanced Chemical Company has not identified supply chain risks. However, we do have processes in place to respond to future risks should they arise. These include:

Map the Supply Chain:

• Complete RMI Supply Chain Mapping Tool, conduct desktop research, on-site visits, assessment of anti-money laundering and counter-terrorism financing policies and procedures>
• Upon completion of supply chain mapping complete Responsible Minerals Initiative’s Audit High-Risk Workbook details OECD conformance expectations for high-risk sourcing

Lauren Faella 
Finance Manager 

Issue Date: October 5, 2022 

Advanced Chemical Company - Grievance Policy

We are aware of and actively supports the international efforts to investigate, monitor and mitigate activities that contribute to illegal armed groups, human rights violations, or financial wrongdoings in gold supply chains as defined in Annex II of the Organization of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas Third Edition (OECD Guidance).

We respect the dignity and importance of human rights and consider any mineral that may pose risks of contributing the harm listed in Annex II of OECD Guidelines to be ‘conflict minerals’. We will only purchase gold-containing materials from sources that have been verified as not involving or contributing to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of the OECD Guidance and listed here:

• Serious abuses associated with the extraction, transport or trade of minerals:
• Any forms of torture, cruel, inhuman and degrading treatment;
  • Any forms of forced or compulsory labor;
  • The worst forms of child labor;
  • Other gross 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.
• Direct or indirect support to non-state armed groups.
• Direct or indirect support to public or private security forces.
• Bribery and fraudulent misrepresentation of the origin of minerals.
• Money laundering.
• Non-payment of taxes, fees and royalties to governments.

In support of the above, all of our relevant staff members are directed to follow and trained on procedures to implement a conflict minerals due diligence system that aims to:

• Exercise due diligence with relevant suppliers consistent with the OECD Guidance and the Responsible Business Alliance’s Responsible Minerals Assurance Process (RMAP) and encourage our suppliers to do the same.
• Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm gold in our supply chain does not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance.
• Aim to establish long-term relationships with our immediate suppliers.
• Consider ways to support and build capacities of gold supplying counterparties to improve performance and conform to this supply chain policy.
• Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
• Immediately discontinue engagement with suppliers who pose a reasonable risk to be causing severe human rights abuses.
• Undergo an annual RMAP assessment to verify our conflict-free status as well as identify opportunities to continually improve our conflict minerals due diligence management system.
• Commit to transparency in the implementation of this policy by making available reports on our progress to our customers, relevant stakeholders and the public (as required).
• Support the implementation of the principles and criteria of the Extractive Industry Transparency Initiative (EITI).

GRIEVANCE MECHANISM FORM

• Advanced Chemical Company (“ACC”) makes every attempt to ensure that our customers are treated with courtesy and that their concerns are acknowledged and addressed in a timely manner. Our goal is to create a clear and coherent process to respond to any issues, and it is our policy to consider constructive comments as an opportunity for improvement.
• With regard to the Responsible Minerals Initiative (RMI) and the Responsible Minerals Assurance Programs (RMAP), ACC acknowledges the right of any individual or organization relevant to ACC (customers, business partners, service providers, or their representatives) to be able to raise any concerns about our process, and to file a grievance about our decision making protocol.
• This form allows any person or customer to submit a concern or grievance to ACC for review, assessment and response. The issues about ACC policy should be factual and evidence based. Please include all relevant documentation with your submission. All comments about our processes or criteria will be taken seriously and submitted to our compliance officer for investigation and review. All relevant submissions will be “logged” and maintained as a record in our files for a period of five years. If the issue does not concern ACC directly, or you have broader concerns or comments, you may also contact the RBA (Responsible Business Alliance) directly through their grievance page of the Responsible Minerals Initiative website.
• Our website allows for the anonymous reporting of incidents. In the event a “whistleblower” chooses to disclose information about wrongdoing or human rights related violations about our supplier or their practices, ACC will ensure the confidentiality of the supplier of the information, unless disclosure is required by law. Although providing contact information better allows ACC to further follow up with the information given during the investigation and resolution process, submissions which disclose information in good faith will be investigated in the same manner as other submissions. Anonymous submissions can also be made through the RMI website.

To submit to the ACC website directly, please use the form below.

Advanced Chemical Company - RMI RMAP Final Nonconformant Determination

22 May 2023

To Whom it may concern:

This notice confirms the support of ownership and top management to participate in RMI’s extended cap program in order to regain our conformant status.

We recognize the value of the program and are working to ensure the proper due diligence and validation of the origin of gold supplied to Advanced Chemical from all non-RMAP validated sources.

We expect this process to move quickly and look forward to undergoing a full RMAP assessment as soon as the CAP has been implemented.

Sincerely,

David Farnum, President, Advanced Chemical Company

Click here to view: E-Cap Workbook