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POLICY STATEMENT - CONFLICT MINERALS

EXOR International supports the humanitarian goal of ending the adverse impacts related to the mining and trade of minerals from conflict-affected and high-risk areas, the following included: serious abuses associated with the extraction, transport or trade of minerals; direct or indirect support to non-state armed groups; public or private security forces; bribery and fraudulent misrepresentation of the origin of minerals; money laundering; payment of taxes, fees and royalties due to governments.

Different laws regulate the responsible sourcing of minerals at a local level, such as the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 and the Regulation (EU) 2017/821. As an European company, EXOR is strongly committed to fulfill the requirements of the European legislative framework and with reference to the aforementioned regulation, EXOR is not identified as “Union importer”. 

However, EXOR recognizes that the direct link between adverse impacts and the supply of minerals or derivatives represents a systemic risk of electronic industry. Thus, on a voluntary basis EXOR decided to work for the responsible supply of 3TG (gold, tin, tantalum and tungsten) and Cobalt, Mica. This commitment recalls the diligence principles described by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This means that EXOR International:

  • has implemented an internal guideline that describes the actions and the responsibilities;
  • requires suppliers to communicate information about the smelters and refiners identified in the supply chain;
  • assesses the risks on the basis of the transmitted information;
  • applies reactive measures when a risk is identified.

Recognizing that due diligence is an ongoing process of gradual improvements, EXOR plans to extend and enhance this commitment over the years.

EXOR strives to be a responsible member of society and encourages all the upstream and downstream companies of the supply chain to cooperate for ethical sourcing.

 

San Giovanni Lupatoto,

Date: 20 January 2025

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