Conflict Minerals Policy


This Policy refers to EU Regulation 2017/821 (hereinafter also referred to as “the Regulation”).

The Regulation establishes, with application from 1 January 2021, a system on the duty of care in the supply chain within the European Union in order to reduce the possibilities for armed groups and security forces to engage in the trade in tin, tantalum and tungsten, their ores, and gold. It is structured in such a way as to guarantee transparency and security in relation to the procurement practices of European Union importers (therefore for non-EU imports by EU operators), and of smelters and refineries in conflict-affected or high-risk areas .

With regards to the aforementioned metals and their minerals, ITALCHIMICI presents the following types and methods of import:

  • 1) TIN

ITALCHIMICI imports on average 80% of tin (out of the total annual imported volume) from financial intermediaries/brokers on the LME (London Metal Exchange) from smelters that adhere to the RMI (Responsible Minerals Initiative).

LME complies with the duties of care according to the OECD (Organization for Economic Co-operation and Development – OECD) guidelines as evidenced on the website:

Furthermore, ITALCHIMICI requires the financial intermediaries/brokers from which it purchases tin on LME to print the Warrant, containing detailed information on the goods, including the origin of the same for the purposes of controlling the Supply Chain.

Furthermore, the Purchasing Department has established contractual conditions to be applied to all interested suppliers in order to obtain, already at the time of the introduction of new materials, the necessary information through the CMRT (Conflict Minerals Reporting Template), a tool created specifcially for the exchange of information on the supply of 3TG (Tin, Tantalium, Tungsten, Gold) along the supply chain, which has become an international standard.

The CMRT was developed by RMI (Responsible Minerals Initiative), an international organization which provides tools and resources to help companies make better supply decisions globally, in terms of legislative compliance and responsible sourcing support, thus contributing positively in the socio-economic development of mineral supply chains, according to international standards, such as the OECD Due Diligence Guidance.

The RMI, through an independent third-party audit, called the “Responsible Minerals Assurance Process (RMAP)”, identifies refineries and smelters that have active systems to ensure the supply of minerals not benefiting armed groups in high-risk countries .

In ITALCHIMICI a residual part on average equal to 20% of the total volume of annual imports of tin is imported directly from producers/smelters outside the EU, to which the due diligence questionnaire “Conflict metals and minerals” questionnaire is submitted, according to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. ITALCHIMICI therefore requests Tin suppliers to apply reasonable due diligence to ensure the same compliance throughout the supply chain, expecting Tin suppliers to make reasonable efforts to report the status of “conflict metals and minerals” and their policy to regard. In support of this, the Company seeks statements from suppliers from which it sources and manages, in order to ensure transparency in its supply chain. All suppliers must escalate this requirement up the supply chain in order to determine the origin of the specified minerals. Where a source is claimed to be from the Conflict region, the Company will ask those affected suppliers to change their source of supply. In the event that, for various reasons, an immediate alternative is not found, as part of our contract manufacturing responsibility we will work in collaboration with the relevant relevant suppliers to identify, qualify and source alternative parts or solutions.

  • 2) TANTALUM and its minerals

ITALCHIMICI does not import or trade Tantalum.

  • 3) TUNGSTEN and its minerals

ITALCHIMICI does not import or trade Tungsten.

  • 4) GOLD

ITALCHIMICI sources exclusively on the Italian market and never from private individuals. Therefore, to date, the reference legislation applies only to tin.

The Company undertakes to update this Policy if conditions on other metals and minerals change.

The publication of this Policy on the Company’s corporate website fulfills the required communication obligations.

Lumezzane, 01/01/2023