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Conflict Minerals

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Conflict minerals

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In accordance with the policies and regulations to regulate conflict minerals to make our planet more peaceful


LS-Nikko Copper supports worldwide efforts and cooperates actively with various suppliers to ensure that precious metals come from legitimate, ethical sources, and that they have not been associated with crime, armed conflict or human rights abuse. It is our firm conviction and our unalterable policy to refuse any business proposal which might be connected with any illegitimate activity.

Our supply chain policy and practices and our congruent commitment are consistent with the LBMA Responsible Gold Guidance on Gold
(Available at http://www.lbma.org.uk/assets/RGG20130118.pdf) as well with the OECD due diligence guidance
(Available at http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf) on conflict minerals.
We employ this policy by having implemented a program of strict due diligence procedures and our commitment to conduct our activities and business:

With honesty and transparency

  • Do not support fraud, corruption or any other illegal activity.

  • Maintain high moral, ethical and social standards.

  • Cultivate proper business relationships with all counterparts.

  • Seek good and transparent relations with governmental and non-governmental organizations.

  • Have fair and responsible relations with employees and all other stakeholders.

We implemented this policy through an effective and comprehensive management system which is based on strong local and international OECD due diligence practices in order to identify our upstream and downstream partners. In that regard, we are strongly committed

1. Not to tolerate nor profit from, contribute to, assist or facilitate the commission of

  • Torture, cruel, inhuman and degrading treatment.

  • Forced or compulsory labour.

  • The worst forms of child labour.

  • Violations of granting of the freedom of assoc.

  • Human rights violations and abuses.

  • War crimes, violations of international humanitarian law, crimes against humanity or genocide.

2. Not to engage with, and to immediately discontinue engagement with, customers or suppliers where we identify a reasonable risk that they are committing, or are sourcing from or linked to any party committing, abuses described above or any other illegal party.

3. Not to tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring precious metals from, making payments to or otherwise providing assistance or equipment to, non-state armed groups or their affiliates who illegally.

  • Control mine sites, transportation routes, precious metals trade or any other factors in the supply chain; and/or

  • Tax or extort money or precious metals at mine sites, along transportation routes or at points where they are traded, or from intermediaries, export companies or international traders.

4. Not to engage with, respectively immediately to discontinue engagement with any business opportunity or business partner 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 described above.

6. Not to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold. Likewise we will not conceal the origin of precious metals

7. To support efforts and contribute to avoid and disclose money-laundering and financing of terrorism where we identify a reasonable risk of money-laundering and financing of terrorism resulting from, or connected to the supply and distribution chain of precious metals.

8. To perform annual training sessions with relevant employees and partners and encourage them to raise any suspicious relation and/or transactions to management and/or compliance officer. We require our employees, agents, consultants, and business partners to comply with our policy, and will – wherever possible – enforce it with appropriate measures, up to and including termination of employment or contracts