Responsible Sourcing Policy

This policy applies to every mineral, metal and natural aromatic material ARAM (African Rare Aromatics & Minerals) buys, sells or introduces, to every supplier and buyer we deal with, and to our own staff and agents. It covers tin, tantalum, tungsten and gold (3TG), cobalt, copper, lithium, graphite, rare earths, diamonds and all other minerals we list, and CITES-listed and other regulated botanicals.

In line with Annex II of the OECD Guidance, we will not tolerate, profit from, contribute to, assist with or facilitate:

• Any form of torture, cruel, inhuman or degrading treatment.
• Any form of forced or compulsory labour.
• The worst forms of child labour.
• Other gross human-rights violations and abuses, such as widespread sexual violence.
• War crimes, crimes against humanity or genocide.
• Direct or indirect support to non-state armed groups, or to public or private security forces that illegally control mine sites, transport routes or upstream actors, or illegally tax or extort money or minerals.
• Bribery and fraudulent misrepresentation of the origin of minerals.
• Money laundering, and non-payment of taxes, fees and royalties due to governments for extraction, trade and export.

1. Management systems: this policy, a named compliance officer, supplier contracts that incorporate it, and records kept for at least five years.

2. Risk identification: we identify the mine of origin, transport routes and every intermediary, and assess whether material comes from a conflict-affected or high-risk area.

3. Risk response: where we find a risk, we either suspend or end the relationship or, where the risk can be mitigated and the OECD Guidance allows it, agree a measurable mitigation plan and monitor it.

4. Independent assurance: we rely on independent third-party audits of smelters and refiners (for example the RMI Responsible Minerals Assurance Process or the LBMA Responsible Gold Guidance) and on upstream traceability schemes.

5. Reporting: we publish an annual summary of our due diligence.

We immediately suspend or end engagement with any supplier where we find a reasonable risk that it is sourcing from, or linked to, any party committing the abuses listed above, or providing direct or indirect support to non-state armed groups.

We do not exclude artisanal and small-scale producers by default, because doing so harms the communities the Guidance aims to protect. We work with them where the site is legal, traceable and independently validated, and where the Annex II risks are absent or being mitigated under a monitored plan.

For botanicals we require lawful harvest and export, CITES permits where the species is listed, and no forced or child labour in cultivation, collection or distillation. We decline material whose legal harvest or export position cannot be documented.

Anyone (a worker, a community member, a supplier, a buyer or a member of the public) can raise a concern about our supply chain through our Grievance Mechanism, anonymously if they wish.