Recognizing that risks of significant adverse impacts which may be associated with extracting, trading, handling, and exporting minerals from conflict-affected and high-risk areas, and that we have the responsibility to respect human rights and not contribute to conflict, SPM Refinery Pte Ltd commit to adopt, widely disseminate, and incorporate in contracts and/or agreements with suppliers the policy of OECD Due Diligence Guidance for Responsible supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as representing a common reference for conflict sensitive sourcing practices and suppliers’ risk awareness from the point of extraction until end user.
We commit not to get involved in any activities which contributes to the financing of conflict, and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.
The types of materials covered by this Policy include gold and silver containing materials. The Policy is applicable for the SPM Refinery Pte Ltd and suppliers of SPM Refinery Pte Ltd supply chain.
Supply Chain Due Diligence
Chapter 1 : Human rights-related risks and risk mitigation measures
Article 1 - Regarding serious abuses associated with the extraction, transport or trade of minerals
While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:
- any forms of torture, cruel, inhuman and degrading treatment;
- any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
- the worst forms of child labour;
- other gross human rights violations and abuses such as widespread sexual violence; war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
Article 2 - Regarding child labour
While sourcing from or operating in conflict-affected and high-risk areas, we will not employ, profit from, assist with, or facilitate, or be linked to, any party employing, profiting from, assisting with, or facilitating the employment of any kind of children under the minimum working age which is legally prescribed by the host country laws and regulations. If there is no relevant host country law or regulation, the minimum working age shall be 16 years.
Article 3 - Risk mitigation measures on human rights related risks
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, hiring of child labour as defined above.
Chapter 2 : Conflicts related risks and risk mitigation measures
Article 1 - Regarding direct or indirect support to non-state armed groups
We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling or export of minerals includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
- illegal control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
- illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where mineral are traded; and/or
- illegally tax or extort intermediaries, export companies or internal traders.
Article 2 - Risk mitigation measures
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.
Article 3 - Regarding public or private security forces
We disagree to provide direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.
We recognize that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the international widely recognized standards. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
We will support efforts, or take steps, to engage with central or local authorities, international organizations and civil society organizations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.
We will support efforts, or take steps, to engage with local authorities, international organizations and civil society organizations to avoid or minimize the exposure of vulnerable groups, in particular, artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
Article 4 - Risk mitigation measures
In accordance with the specific position of the company in the supply chain, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.
Chapter 3 : Governance related risks and risk mitigation measures
Article 1 - Regarding bribery and fraudulent misrepresentation of the origin of mineral
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.
Article 2 - Regarding money laundering
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.
Article 3 - Regarding the payment of taxes, fees and royalties due to governments
We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the requirements of host country on the disclosure of tax information paid to government departments.
Article 4 - Risk mitigation measures
In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organizations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation. Companies should conduct an additional risk assessment on those risks requiring mitigation after the adoption of the risk management plan. If within six months from the adoption of the risk management plan there is no significant measurable improvement to prevent or mitigate the risks of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments, companies should suspend or discontinue engagement with the supplier for a minimum of three months. Suspension may be accompanied by a revised risk management plan, stating the performance objectives for progressive improvement that should be met before resuming the trade relationship.
Chapter 4 : Environment, health and safety related risks and risk mitigation measures
Article 1 - Regarding environment protection
While sourcing from, or operating in high-risk areas, we will not profit from, assist with, or facilitate significant adverse impacts regarding ambient soil, air and water conditions, or source from or be linked to any party with gross violation of local laws and regulations. We will support or take actions to evaluate periodically to minimize the adverse impacts of extraction regarding soil, air and water.
Article 2 - Regarding occupational health and safety
While sourcing from, or operating in high-risk areas, we will not profit from, assist with, or facilitate or source from, or be linked to, any party providing life threatening occupational health and safety conditions to direct and / or indirect employees and / or any person present on the party's operations.
Article 3 - Risk mitigation measures
We will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of environment protection and occupational health and safety, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.
Chapter 5 - Complaint Channel
Any internal or external stakeholders may raise and discuss any comments, suggestions and complaints regarding the human rights, conflicts, governance, environmental protection and occupational health and safety in the process of mining, trading, processing and exporting materials covered by this policy.
Email: feedback@spmrefinery.com.sg
Supply Chain Grievances & Whistleblowing Policy
1. Introductory Scope
This Policy provides framework for receiving, investigating & responding to grievances, promoting mutual confidence & trust with all relevant parties. Its application relates to collective & individual grievances/complaints. Those raised are inclusive of both external & internal allegations. All evidenced grievances/complaints shall be investigated.
2. Incident Report Guidance
Any whistleblower wishing to raise a complaint/grievance must adhere to the following reporting guidance that provides information on how to report an incident to facilitate its resolution.
3. Definition of Malpractice
This Policy encourages the reporting of any abuses, risks and/or behaviour that does not comply with the authorities, or Company Regulations, including but not limited to, the following:
- Corruption/Bribery;
- Fraud;
- Property Damage/Theft;
- Employee Misconduct;
- Health & Safety Violations;
- Inadequate Working Conditions;
- Inadequate Security (People, Metal, Property). Environmental Impacts;
- Child Labour;
- Human Rights Violations
4. On Anonymity
The whistleblower does not need to be named if anonymity is necessary for privacy/protection. However, information & evidence needs to reach a satisfactory level to substantiate any claim.
5. On Evidence
Information provided must include, whenever possible/applicable:
- Name(s) of affected person, community &/or organisation
- Factual description
- Witnesses
- Date
- Time
- Location
- Identity of buyers of minerals from the stated location
Insufficient information may hinder any prevalent investigations, providing as much information as possible is strongly advised.
6. Stakeholder Intelligence
Information as to those informed about the grievance/complaint, other than SPM Refinery Pte Ltd, needs to be relayed. Stating whom was informed, with contact details (e-mail address, phone number, postal address, etc.) & all correspondence had with them. These may include those from the below list:
- Local/Provincial/National Authority Non-Governmental Organisations Lawyers
- Members of Parliament
- Media
- Other (Please specify)
7. NGO Reports
When informing SPM Refinery Pte Ltd of incidents pertaining to the Supply Chain in which we are associated with, include clear research methodology highlighting your educational & professional experiences, precise locations as to where the research was conducted & include those of which who were interviewed. Also ensure accurate referencing to all sources with correct & accurate dates. Sources need to avoid being concentrated, as to avoid weakly supported reports. Should confidentiality of sources be of concern, an appropriate system to mask, but still link them, should be adopted. Victim viewpoints should be included wherever possible, ensuring protection of all vulnerable interviewees in the process. Lastly, it is vital that information generating a link to the actors within the supply chain need to be established to aid in such reports, specifying where the incident took place, or who the trader/exporters were, or if any actors were members of a cooperative (with specifics to which one), & so forth.
8. Internal Reporting
Internal grievances/complaints are to be reported to their relevant manager. Should the individual(s) not find it possible/appropriate, grievances/complaints can be filed through the formal whistleblowing process denoted within Section 9.
9. Formal Reporting
Any whistleblower may make written or electronic disclosures via the following means:
- The dedicated mailbox: feedback@spmrefinery.com.sg
- Postal disclosures may be posted to:
SPM Refinery Pte Ltd
Data Protection Officer
15 Tuas South Street 3, Singapore 638020
10. Assimilation Management
The HR Department is responsible for processing all incoming communications & of keeping Senior Management informed about newly identified risks &/or concerns.
11. Report Process
Once a complaint/grievance has been filed, the following steps shall be taken in respective order:
Step 1: First Contact
Within two weeks, an initial acknowledgement of receipt & an explanation to the proceeding actions will be provided to the relevant parties, also including timeframes within which the relevant parties can expect the complaint/grievance to be reviewed,
Step 2: Analysis
Within the indicated timeframe, an assessment will be made whilst taking into consideration the relevancy to this policy, the type of complaint/grievance, & whether the evidence provided establishes a foundation or not. Consequently, SPM Refinery Pte Ltd will notify the relevant party as to the timeframe governing its resolution.
Step 3: Resolution
Within an acceptable time, any updates pertaining to the timeframe governing its resolution, or closures/resolution of the complaint/grievance, will be provided to all relevant parties.
Data Collection
SPM Refinery Pte Ltd will ensure that all communication is recorded appropriately & tracked through to its closure/resolution. This information will include the:
- Senior Management/department(s);
- Registration date;
- Status – Open (Founded), Rejected (Unfounded) & Closed (Concluded)
12. Definition
Whistleblower - any employee, customer, contractor &/or third-party that raises a complaint/grievance related to the company or its contractor’s activities &/or impacts;
Affected Persons - any individual or group of individuals affected by malpractice;
Relevant Parties - affected persons &/or whistleblowers;
Complaints - as negative feedback raised in regards to the company &/or the activities & impacts of its contractors;
Grievances - formal concerns/allegations brought forward as a result of malpractice, resulting in corrective action &/or a response;
Grievances & Whistleblowing Mechanisms - processes to support implementation of this policy.
Version Date: 1st June 2025