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Conflict Minerals

At OASST Ltd, we prioritise human rights, fair working conditions, environmental protection, and the fight against corruption throughout our organisation and supply chain. We are committed to the principles of the United Nations Global Compact, integrating responsible practices into our procurement processes. Our contract decisions are based not only on economic and technological criteria but also on sustainability, which plays a crucial role in our supplier management.

We continually strive to enhance our processes, including increasing transparency regarding the origin of raw materials and conflict minerals, allowing us to identify risks early. Compliance with due diligence obligations in our supply chain is essential, especially concerning tin. The extraction of certain minerals in the Democratic Republic of Congo (DRC) and other regions has been linked to severe human rights violations and the funding of violent conflicts.

Within the European Union, importers of conflict minerals face stringent due diligence and inspection obligations to prevent financing violence and human rights abuses in conflict or high-risk areas. Since January 1, 2021, the implementing law for EU regulation 2017/821 has been in effect in Germany, impacting our operations as Union importers of tin. We have established robust procedures to review our supply chains and identify potential risks.

Our supply chains are transparent and regularly audited, ensuring full compliance with legal requirements.

Dodd-Frank Act on Conflict Minerals

Since 2010, OASST Ltd has adhered to the regulations set forth in the Dodd-Frank Act, specifically Section 1502, which mandates that companies disclose whether their products contain “conflict minerals” essential to their functionality or production. These minerals include tantalum, tin, tungsten, and gold, regardless of their source.

While OASST Ltd does not file reports with the SEC and therefore is not subject to the conflict minerals requirements of Section 1502, we acknowledge that our customers are required to perform due diligence across their global supply chains.

We strive to avoid purchasing materials that contain conflict minerals financing or benefiting armed groups. To this end, we have implemented processes to trace the use of these minerals in our products and ascertain their sources within our supply chain, guided by frameworks established by the Organisation for Economic Cooperation and Development (OECD) and other private sector initiatives.

We actively engage with our direct suppliers to enhance transparency regarding the materials they provide. We conduct on-site inspections or hire third parties to ensure compliance and assess supplier conditions regularly. We remain committed to collaborating with customers, suppliers, and other stakeholders to develop effective solutions.

Slavery and Human Trafficking Statement

OASST Ltd is a signatory to the United Nations Global Compact and supports the United Nations Universal Declaration of Human Rights, along with the core labour standards of the International Labour Organisation (ILO). We are dedicated to eradicating slavery and human trafficking within our supply chain and operations. Our commitment is outlined in our “Slavery and Human Trafficking Statement for OASST Ltd,” prepared in accordance with section 54 of the United Kingdom Modern Slavery Act.

Revised September 2024

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Charles AddisonProgramme Director

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