1. Commitment
Ory is committed to sourcing minerals in a manner that respects human rights, avoids contributing to conflict or financial crime, protects the environment, and supports transparent, resilient supply chains.
2.Scope
This Policy applies to Ory’s directors, officers, employees, controlled operations, and mineral suppliers, traders, processors, logistics providers, agents, and other relevant business partners. Risk-based requirements may be incorporated into contracts.
3. Standards
Ory seeks to align its risk-based due-diligence program with applicable law and relevant internationally recognized guidance, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
4. Prohibited and High-Risk Conduct
- Serious human-rights abuses, forced or child labor, torture, cruel treatment, or unlawful displacement.
- Direct or indirect support to non-state armed groups or abusive public/private security forces.
- Bribery, corruption, fraudulent misrepresentation, money laundering, terrorist financing, tax or royalty evasion.
- Material sanctions or export-control violations.
- Knowing sourcing from unlawful mining or trading operations.
- Material environmental harm that is unlawfully caused, concealed, or left unaddressed.
5. Due-Diligence Framework
- Maintain management responsibility, controls, records, and supplier expectations.
- Identify suppliers, beneficial owners, origin and transit information, chain of custody, and relevant licenses on a risk basis.
- Assess country, commodity, counterparty, human-rights, conflict, corruption, sanctions, security, and environmental risks.
- Use enhanced due diligence for conflict-affected or high-risk areas and other elevated risks.
- Design and monitor mitigation plans, exercise leverage, suspend or disengage when appropriate.
- Use independent assessment or audit where proportionate.
- Track performance and communicate results consistent with law, confidentiality, and security.
6. Supplier Expectations
Suppliers must provide accurate information, retain records, flow down appropriate requirements, permit proportionate verification, promptly disclose serious risks, cooperate with remediation, and avoid retaliation against reporters.
7. Grievances and Remediation
Concerns may be reported to ethics@oryminerals.com. Ory will assess credible reports, protect confidentiality where practical, and support or cooperate in remediation where Ory caused or contributed to harm.
8. Governance and Reporting
Executive Management owns and oversees implementation of this Policy and periodically reviews the Policy and Ory’s associated risk-based procedures. Ory will provide role-appropriate training and communicate information about implementation when appropriate, consistent with applicable law, confidentiality, and security considerations.