William Rowland Americas plays an important role in the supply-chains of metals driving electrification of the planet. It is vital that these materials are ethically and responsibly sourced if our supply chains are to be sustainable. The responsible sourcing of minerals is an important aspect of our business and integral to our commitment to conducting our business with integrity
Below are key considerations regarding our activities to help our business partners and stakeholders better understand where conflict minerals Tantalum, Tin, Tungsten and Gold are relevant.
William Rowland Americas trades in a variety of physical metals including Tantalum, Tin, and Tungsten. We are a supplier of alloys, concentrates, minerals, metal powders, and refined metals including tin-based and tungsten-based products.
We are focused on growing recycled material flows. Recycling material rather than mining not only has a valuable role to play from an environmental perspective but also in the context of limited funding opportunities for illegal armed groups operating in conflict-affected and high-risk areas (CAHRAs)
William Rowland Americas are not involved in the mining, treatment, or trading of gold or gold-derivative products.
We strongly support industry and government efforts to eliminate Conflict Minerals from Global Supply Chains and are committed to ensuring that we do not use or trade Conflict Minerals.
Our business has adopted the systems and processes, listed here, to achieve this outcome and give confidence to our customers and business partners that Conflict Minerals are not employed by William Rowland Americas.
- Risk-Based Due Diligence: a framework to ensure suppliers and sourcing decisions ensure that Conflict Minerals are not introduced into our supply chains. Our management approach is consistent with the five-step framework for risk-based due diligence in the mineral supply chain set-out in the OECD Guidance.
- Engagement with industry initiatives: Contribute towards and support initiatives looking to eliminate the introduction of Conflict Minerals into supply chains (e.g. traceability systems). Where applicable, we comply with industry–wide mechanisms for addressing Conflict Minerals risk and to encourage other supply chain stakeholders to support them to.
- Engagement with suppliers: Suppliers of our business must have policies in place regarding Conflict Minerals which are compatible with out own and work with us to ensure that Conflict Minerals are not introduced into our supply chains. We require suppliers to be aware of our policies on Conflict Minerals and require them to comply with our policy terms.
- Reporting and record-keeping: we maintain appropriate records of actions taken to address Conflict Mineral risk. This includes records of systems put in place to ensure non-introduction of Conflict Minerals into supply chains and associated due diligence undertaken.
Modern Slavery and Human Trafficking
William Rowland Americas has employed policies and taken actions to prevent the occurrence of modern slavery and human trafficking in our operations and supply chains.
We recognize that combatting modern slavery and human trafficking is a challenge not just within our organization but throughout the supply chain. William Rowland Americas looks to ensure that no party to its business transactions is involved in practices that contravene our policies on modern slavery and human trafficking.
The mining and sale of tantalum, tin, tungsten, and gold pose, in certain jurisdictions, well-publicized risks of benefitting illegal armed groups and leading to the exploitation of local communities. Consequently, supply chains involving these materials are considered at higher risk of giving rise to Slavery Risks than other commodities
A lack of strong governance and/or a robust legal framework within geography can lead to an increased risk of exploitative practices in some countries. Understanding the risks associated with the countries is an important element of our assessment of the Slavery Risks associated with our supply chains
The lengthier / more complex a supply chain, the higher the risk that exploitative practice may go unrecognized and therefore unchallenged; particularly for stages of the supply chain that involve significant physical labour (e.g. Mineral extraction/ processing) are likely to pose greater Slavery Risks