A.L.M.T. Corp. (hereinafter referred to as "the company") will comply with the Organization for Economic Co-operation and Development "Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict Areas and High Risk Areas, 3rd Edition (OECD Guidance). The company also recognize and actively support international efforts to investigate, monitor and mitigate activities that contribute to illegal armed groups, human rights abuses or financial misconduct in the Tungsten supply chain.
Among the four conflict minerals, the company smelts tungsten alone. Furthermore, all raw tungsten materials are procured by our Procurement Department and then supplied to our factory under the control of the company. Our factory does not procure any raw tungsten material independently.
In order to promote conflict mineral management, the company appoints a compliance officer who is tasked with organizing related sections and departments to establish a management system.
Minerals that may pose a risk of harm listed in Annex II of the OECD Guidance are considered "conflict minerals". Tungsten-containing materials should only be purchased from sources that have been identified as non-conflict minerals.
The company carry out the following due diligence and risk assessment to all of the supplier of tungsten raw materials.
Any raw material purchased by the company is supplied to our smelters. The smelters physically check the material for all accepted lots, compare it with the information presented by the seller which is then provided by the Material Department beforehand and finally report the result of the comparison to the Head Office.
The compliance officer provides opportunities of education and training to the Material Department, our smelters and to other related sections and departments at any point in time and depending on the situation where such education and training are considered to be necessary.
For the purpose of verifying the suitability of the control system and its enforcement, the company undergoes an audit conducted by an independent third-party organization on a periodic basis.
The administrative officer defines the types of documents that need to be retained regarding the conflict mineral management and decides the limit of retention time for the purpose of control.
Established on November 28, 2014
Revised on August 27, 2021