GEIG – CONFLICT MINERALS & COBALT POLICY (v1.1)
Effective from: 30 September 2025

1.0 Purpose and Scope
1.1 This policy sets GeiG’s requirements for responsible sourcing and due diligence on minerals used in our products and components.
1.2 It applies to all GeiG suppliers, contract manufacturers, sub-suppliers, and service providers that supply materials, parts, assemblies, or services containing the covered minerals.
1.3 This policy sits alongside the GeiG Supplier Code of Conduct, Modern Slavery & Human Trafficking Statement, Export & Trade Compliance Policy, and Environmental / WEEE / RoHS Declaration.

2.0 Minerals and Related Policies
2.1 3TG: tin (Sn), tungsten (W), tantalum (Ta), and gold (Au).
2.2 Cobalt (Co), including use in batteries and other components.
2.3 Any derivatives, alloys, solders, plating, cathode materials, or other uses that incorporate the above minerals.
2.4 Alignment with export/sanctions rules: this policy operates alongside our Export & Trade Compliance Policy; minerals, smelters, or refiners implicated in sanctioned activity will be treated as prohibited sources.

3.0 Standards and Frameworks
3.1 Due diligence is aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals (all five steps, scaled to risk and influence).
3.2 We recognise and prefer smelters/refiners validated by the Responsible Minerals Initiative (RMI) under the Responsible Minerals Assurance Process (RMAP) where available.
3.3 Future regulatory readiness: where applicable laws impose additional due-diligence requirements (e.g., EU battery or corporate sustainability rules), suppliers shall cooperate to meet those requirements. (This clause confirms readiness, not current applicability.)

4.0 Supplier Reporting and Onboarding Gates
4.1 Suppliers shall submit, at least annually and upon GeiG request:
a) CMRT (Conflict Minerals Reporting Template) for 3TG; and
b) EMRT (Extended Minerals Reporting Template) for cobalt.
4.2 Templates must be current-version, complete, accurate, and name all known smelters/refiners.
4.3 Suppliers must maintain and provide supporting evidence (policies, procedures, contracts, and smelter/refiner confirmations) upon request.
4.4 Onboarding gate: suppliers must provide current-version CMRT/EMRT with ≥ 95% part-number coverage before first PO and update at least annually or when a material change occurs.
4.5 Template quality: GeiG may reject submissions with unknown (“UNKN”) smelters, missing smelter IDs, or < 90% DIR completeness.
4.6 Where smelter country of origin is unknown, suppliers must evidence the risk assessment performed and planned remediation.

5.0 Smelter/Refiner Expectations and Changes
5.1 Suppliers shall source, where available, from RMI/RMAP-conformant smelters/refiners or those actively pursuing audit with a credible plan and timeline.
5.2 If a smelter/refiner is assessed non-conformant or presents severe risk, the supplier must implement a time-bound risk-mitigation plan or transition to conformant sources.
5.3 Pre-shipment change notifications: suppliers must notify GeiG before shipment if any smelter/refiner changes affect supplied parts and provide updated CMRT/EMRT.

6.0 Recycled and Scrap Material
6.1 Use of recycled/scrap sources for 3TG and cobalt is allowed and preferred where the “recycled” claim is supported in CMRT/EMRT and backed by chain-of-custody or third-party validation acceptable to GeiG.

7.0 High-Risk Areas, ASM, and Labour Safeguards
7.1 We consider the Democratic Republic of the Congo (DRC) and adjoining countries and other conflict-affected or high-risk areas (CAHRAs) as elevated-risk regions.
7.2 Red flags include unknown or unverifiable smelters/refiners, inconsistent supplier disclosures, or material originating from CAHRAs without credible due diligence.
7.3 ASM (Artisanal & Small-Scale Mining): where ASM sources are used, suppliers must demonstrate credible due diligence (cooperatives, traceability, incident response) and avoid child labour and hazardous conditions.
7.4 Cobalt labour safeguards: cobalt sourcing must include explicit controls against child labour, debt bondage, and unsafe working conditions, consistent with our Supplier Code and Modern Slavery Statement.

8.0 Due Diligence, Incident Reporting, and Escalation
8.1 Suppliers must operate an internal minerals due-diligence programme aligned to OECD (policy, risk assessment, control, remediation, and reporting).
8.2 For higher-risk suppliers, GeiG may require independent third-party audits of due diligence and supply-chain claims.
8.3 Where risks are identified, suppliers must implement a Corrective Action Plan (CAP) with clear owners, milestones, and evidence.
8.4 Failure to make timely progress may lead to volume reduction, suspension, or termination in line with the Supplier Code of Conduct.
8.5 Incident reporting SLA: report any credible incident (red flag, NGO report, media coverage, regulator notice) to GeiG within 5 business days, including immediate containment and planned actions.
8.6 CAP timelines: for High/Critical risks, provide initial containment within 10 business days and a transition plan within 30 days.

9.0 Public Transparency
9.1 GeiG will publish an annual summary of our minerals due-diligence results on the GeiG Legal Hub.
9.2 The summary will describe methodology, supplier response rate, % conformant smelters, risk findings by category, and progress on remediation.

10.0 Records, Confidentiality, and Verification
10.1 Suppliers shall retain minerals due-diligence records (CMRT/EMRT, smelter lists, audit letters, CAP evidence) for at least six (6) years or longer if law requires.
10.2 GeiG may review these records and conduct supplier assessments to verify compliance with this policy.
10.3 GeiG will treat submitted templates and supplier identities as confidential business information, disclosed only as required by law or with supplier consent.
10.4 Verification: GeiG may verify claims via document reviews, interviews, and (where proportionate) unannounced assessments or third-party verification.

11.0 Training, Flow-Down, and Whistleblowing
11.1 Suppliers shall train relevant staff (procurement, compliance, quality) on minerals due diligence and reporting templates annually.
11.2 Suppliers must flow down equivalent requirements to all relevant tier-2 and below sub-suppliers and ensure they can provide CMRT/EMRT responses on request.
11.3 Whistleblowing & non-retaliation: suppliers must provide confidential reporting channels and prohibit retaliation. Reports may also be made to GeiG via support@geig.co.uk or 24/7 web chat.

12.0 Non-Compliance and Zero-Tolerance Triggers
12.1 Material misrepresentation, refusal to disclose, or continued sourcing from high-risk non-conformant smelters without credible remediation is a material breach.
12.2 Remedies may include enhanced oversight, third-party audit at supplier cost, re-sourcing, suspension, or termination.
12.3 Zero-tolerance: knowingly sourcing from non-conformant smelters/refiners linked to serious abuses; refusal to disclose CMRT/EMRT; falsification of supply-chain data; or retaliation against whistleblowers.

13.0 Governance and Review
13.1 Operational ownership of this policy and annual reporting sits with GeiG supply-chain due diligence and procurement.
13.2 This policy is reviewed annually and may be updated to reflect standards, laws, or programme improvements. The latest posted version controls.

14.0 Contact
14.1 Questions, disclosures, or concerns regarding this policy or GeiG’s minerals due diligence should be sent to support@geig.co.uk.

15.0 Governing Law
15.1 This policy is governed by the laws of England and Wales.

16.0 Definitions (Quick Reference)
16.1 3TG: tin, tungsten, tantalum, and gold.
16.2 CMRT/EMRT: reporting templates published by the Responsible Minerals Initiative.
16.3 RMI/RMAP: Responsible Minerals Initiative / Responsible Minerals Assurance Process audit programmes.
16.4 CAHRA: conflict-affected and high-risk area as per OECD Guidance and competent-authority lists (where published). Suppliers must document the list(s) used.

End of Conflict Minerals & Cobalt Policy (v1.1)