Risk-Based Due Diligence Course – SuperAluminium Responsible Sourcing Policy

Example

General:
This policy confirms SuperAluminium’s commitment to respect human rights, avoid contributing to the finance of conflict,
and comply with all relevant UN sanctions, resolutions and laws.
We also commit to use our influence to prevent abuses by others through risk-based supply chain due diligence, by
implementing the OECD five-step framework for responsible supply chains of minerals from conflict-affected and high-risk
areas. Consistent with the OECD Guidance, the design of our due diligence has the following features:
1. Establishment of strong internal company management systems, including
- a responsible minerals policy and other policies such as Human Rights Statement and a Supplier Code of
Conduct;
- a cross-functional team that supports SuperAluminium’s responsible sourcing activities with senior
management approval: SuperAluminium’s Senior Director of Responsible Sourcing sponsors the team. The
team consists of representatives from Responsible Sourcing; Corporate, External and Legal Affairs; Finance;
Information Services; Product Environmental Compliance; Global Trade; and Public Relations.
- a supply chain transparency system: as a standard contractual requirement, we require our suppliers to
annually submit the source and chain of custody information for the products they supply to us. Our
contracts also require our suppliers to require their upstream suppliers to meet these material disclosure
requirements. SuperAluminium evaluates these supply chain disclosures to ensure data integrity and assesses
sourcing risk. SuperAluminium investigates any potential non-conformances and engages with such suppliers
to address any failure to meet SuperAluminium specifications and requirements.
- engagement with our suppliers to communicate and reinforce our expectations and ensure that they share
and extend our responsible sourcing commitment with their upstream suppliers. We train our suppliers to
meet our responsible sourcing requirements through online courses, educational forums, and direct
communications. We also conduct audits of our directly contracted suppliers to assess their conformance to
our requirements.
- and a company level grievance mechanism that is available internally and externally to report concerns,
including those related to conflict-related risk. We investigate and, where appropriate, take remedial action
to address reported concerns.
2. Identification and assessment of risks in the supply chain, including through the supply chain transparency system, the
mechanism by which risks are identified and assessed in the supply chain (generating a list of suppliers, surveying
suppliers, reviewing all responses to identify any contradictions or inconsistencies).
3. Design and implementation of a strategy to respond to such risks as they are identified, including requiring our
suppliers to conduct due diligence to address potential sourcing from CAHRAs and assessing information on the due
diligence practices of those facilities, formulating a risk management plan, and reporting to senior management.
4. Independent third-party audits of supply chain due diligence:
- conduct independent smelters audits to provide assurance that the smelters that were identified in our
supply chain conduct an appropriate level of minerals due diligence,
- and support industry initiatives to carry out independent third-party audits of facilities’ due diligence
practices, including through our membership to the Aluminium Stewardship Initiative that entails a third-
party audit of our due diligence practices for the ASI Performance Standard Certification.
5. Annual reporting through our Due Diligence Report, supplemented with additional information in our annual
Sustainable Impact Report, both available on our website at
http://www.superaluminium.com/v2/GetDocument.aspx?docname=c06596243

ASI RISK-BASED DUE DILIGENCE COURSE • STEP 1 LESSON.

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RESPONSIBLE SOURCING POLICY EXAMPLE • JUNE 2021.
 SuperAluminium is committed to adopting an open and transparent approach in managing stakeholder’s expectations.
Therefore, any concerns regarding impacts that may arise from SuperAluminium’s direct and indirect activities under this
Policy can be raised either:
- Anonymously – by submitting a description of the incident and supporting evidence;
- Non-anonymously – by submitting name, contact details and description of the incident and supporting
evidence.
Reports can be submitted as follows:
- by e-mail: grievances@superaluminium.com
- by post to this address: SuperAluminium - Legal Department – Smelters Road 11, 14186 Citytown
In handling such reports, SuperAluminium will act to safeguard the reporting parties against any form of retaliation also
guaranteeing the identity of the reporting parties, unless otherwise required under the law. Grievance investigation process
will be managed in a timely and efficient manner and non-anonymous grievance submitters will be informed about the
outcomes of the investigation process.
Regarding serious abuses associated with the extraction, transport or trade of bauxite:
We will neither tolerate, nor profit from, contribute to, assist or facilitate by any party the commission of:
i. Torture, cruel, inhuman and degrading treatment
ii. Forced or compulsory labour
iii. The worst forms of child labour
iv. Gross human rights violations and abuses such as widespread sexual violence
v. War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that
they are sourcing from, or linked to, any party committing serious abuses as defined above.
Regarding direct or indirect support to non-state armed groups:
We will not tolerate direct or indirect support to non-state armed groups through the extraction, transport, trade, handling
or export of minerals, including, but not limited to, procuring bauxite from, making payments to, or otherwise assisting or
equipping non-state armed groups or their affiliates, as identified by UN Security Council resolutions, who:
i. Illegally control mine sites, transportation routes, points where bauxite are traded and upstream actors in the
supply chain; or
ii. Illegally tax or extort money or bauxite at mine sites, along transportation routes or at points where bauxite is
traded, or from intermediaries, export companies or international traders.
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that
they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined
above.
Regarding public or private security forces:
We recognise that the role of public or private security forces is to maintain the rule of law, safeguard human rights, provide
security to workers, equipment and facilities, and protect mine sites or transportation routes from interference with
legitimate extraction and trade.
We will not provide direct or indirect support to public or private security forces that commit abuses described in ‘serious
abuses associated with the extraction, transport or trade of bauxite’ paragraph, or that act illegally as described in ‘support
to non-state armed group’ paragraph.
Regarding bribery and fraudulent misrepresentation of the origin of minerals:
We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes to conceal or disguise the origin of
bauxite, or to misrepresent the taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling,
transport and export of bauxite.
Regarding money laundering and payment of taxes, fees and royalties due to governments:
We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk of money
laundering resulting from or connected to the extraction, trade, handling, transport or export of bauxite, derived from illegal
taxation of extortion.
We support the payment and disclosure of all taxes, fees and royalties due to governments related to bauxite extraction,
trade and export from conflict-affected and high-risk areas.

ASI RISK-BASED DUE DILIGENCE COURSE • STEP 1 LESSON.

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RESPONSIBLE SOURCING POLICY EXAMPLE • JUNE 2021.