RESPONSIBLE SOURCING POLICY FOR MINERALS AND METALS
1. Purpose of the Policy
The purpose of this policy is to define the principles of responsible sourcing of minerals and metals by Igopak Rośkowicz Sp. K., in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the requirements of customers in the automotive and industrial sectors.
The policy represents the company’s commitment to avoiding any direct or indirect support for armed conflicts, human rights violations, or environmental degradation through its raw material supply chain.
2. Scope of Application
This policy applies to all purchasing activities of Igopak, especially the sourcing of raw materials, components, and materials that may contain so-called 3TG minerals (tin, tantalum, tungsten, gold) or other metals covered by responsible sourcing requirements, such as copper and its derivatives. Currently, the company does not purchase minerals or metals listed under 3TG regulations; however, it is prepared to meet all the requirements set forth in this policy should the scope of purchasing activities change.
3. Responsible Sourcing Principles
3.1. Policy Establishment
Igopak has developed and implemented this Responsible Minerals and Metals Sourcing Policy as part of its environmental, quality, and customer compliance management system.
3.2. Public Availability
The policy is made available to all employees and business partners in the company’s local network (LAN) and on its website. It may also be electronically provided to contractors upon request.
3.3. Supplier Requirements
When purchasing raw materials or components containing minerals/metals covered by regulations (3TG, copper, etc.), Igopak will require its direct suppliers to:
- source materials only from smelters or refiners whose due diligence practices have been verified through independent external audits (e.g., under the RMI/RMAP program),
- provide reliable data on the origin of minerals within the supply chain.
3.4. Due Diligence
Igopak will implement due diligence practices based on OECD guidelines to ensure that raw materials used in production processes do not originate from conflict-affected or illegal sources. This process includes risk analysis, supplier assessment, and documentation of material origin.
3.5. Surveys and Supply Chain Assessment
If products containing the listed minerals or metals are introduced to the market, Igopak will conduct surveys among relevant suppliers (e.g., based on EMRT/CMRT forms) to collect information regarding the origin of materials.
3.6. Review of Supplier Information
Information received from suppliers regarding due diligence processes is subject to verification and assessment for compliance with company expectations and with the principles of responsible sourcing.
- Corrective Actions
If non-conformities or a lack of transparency related to mineral origin are identified, Igopak will undertake corrective actions, such as:
- renewed requests for source data,
- temporary suspension of cooperation,
- or, as a last resort – termination of cooperation with suppliers who fail to meet responsible sourcing standards.
4. Responsibility and Oversight
Implementation and oversight of this policy are the responsibility of the ISMS Representative, in cooperation with the purchasing department and production management. The policy will be periodically reviewed (at least once per year) and updated in case of regulatory changes or customer requirements.
5. Effective Date
- The policy has been in effect since 10.2025.
Management Board Member
Wojciech Rośkowicz