Responsible Supply Chain Policy
EcoPro Group Responsible Minerals Policy
EcoPro Group and its affiliates (‘EcoPro’) are dedicated to the ethical and responsible sourcing of raw materials. We aim to minimize potential environmental and social impacts within our supply chain. To achieve this, we adhere to the principles outlined in the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for responsible supply chains of minerals from conflict-affected (the ‘OECD DDG’), as well as the standards set by the Responsible Minerals Initiative (RMI). Additionally, we are committed to responsible sourcing practices by avoiding the risks identified in AnnexⅩ of the European Union (EU) Regulation Concerning Batteries and Waste Batteries 2023/1542 (the ‘EU Battery Regulation’).
Applicable Minerals
EU Battery Regulation AnnexⅩ Risks
EcoPro Commitment
- Conflict minerals such as 3TG (Tin, Tantalum, Tungsten, Gold) originated from the Democratic Republic of the Congo (DRC) and its nine adjoining countries, which contribute to the ongoing conflict.
- Minerals used in battery Raw materials such as Cobalt, Lithium, Nickel, Manganese, Graphite, Aluminium.
| OECD DDG AnnexⅡ Risks | Examples |
|---|---|
| Serious abuses associated with the extraction, transport, or trade of minerals | Torture, cruel, inhumane, and degrading treatment |
| Forced or compulsory labour | |
| Child labour | |
| Sexual violence | |
| War crimes, violations of international humanitarian law, crimes against humanity, or genocide | |
| Direct or indirect support to non-state armed groups | Illegal control of mine sites or transportation routes, illegal extortion of money along access routes Public or private security forces and to intermediaries |
| Public or private security forces | |
| Bribery and fraudulent misrepresentation of the origin of minerals | Solicitation of bribes to conceal or disguise material origin, misrepresentation, taxes, fees, and royalties |
| Money laundering | - |
| Payment of taxes, fees, and royalties to governments | Non-payment of taxes, fees and royalties to governments |
| Risk Categories | Details |
|---|---|
| Environment, climate and human health, considering direct, induced, indirect and cumulative effects | Air, including air pollution such as greenhouse gas emissions |
| Water, including seabed and marine environment, and including water pollution, water use, water quantities (flooding or droughts) and access to water | |
| Soil, including soil pollution, soil erosion, land use and land degradation | |
| Biodiversity, including damage to habitats, wildlife, flora and ecosystems, including ecosystem services | |
| Hazardous substances | |
| Noise and vibration | |
| Plant safety | |
| Energy use | |
| Waste and residues | |
| Human rights, labour rights and industrial relations | Occupational health and safety |
| Child labour | |
| Forced labour | |
| Discrimination | |
| Trade union freedoms | |
| Community life, including that of indigenous peoples | - |
- Aim to establish long-term relationships with our immediate suppliers.
- Strive to improve immediate suppliers’ capacity and performance to ensure responsible sourcing practices.
- Participate in due diligence audit programs conducted by third-party organizations such as RMI to identify opportunities for continuous improvement in our responsible sourcing due diligence management system.
- Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.
- This policy will be subject to regular review and potential revision in accordance with evolving international standards, regulations, and frameworks to ensure ongoing relevance and compliance.
- Due Diligence : Conduct thorough supply chain due diligence to identify and mitigate risks associated with the sourcing of raw materials. This includes :
- Collect mineral origin information.
- Verify supplier and sub-supply chain information. - Risk Assessment : Assess the risks associated with sourcing raw materials, including those outlined in OECD DDG and EU Battery Regulation.
- Ensure Transparency : Provide the necessary information to ensure the origin and responsible sourcing of raw materials to maintain a transparent and traceable supply chain.
- Drive Engagement : Communicate our policy to suppliers and sub-suppliers to ensure compliance with responsible supply chain policies.
- Third-Party Due Diligence : Encourage suppliers and sub-suppliers to undergo due diligence from third-party due diligence programs such as IRMA and RMI to ensure responsible sourcing.
- Risk Mitigation Measures : Develop mitigation plans and take corrective actions when non-compliance with this policy is identified.
- Must comply with all requirements of this policy and applicable laws and regulations.
- Failure to comply may result in transactions being placed on hold or we reserve the right to search for alternative suppliers.
Grievance Mechanism
Grievances regarding our supply chain policy or due diligence system can be submitted via email to (ecohong23@ecopro.co.kr), or through the Cyber Whistleblower under the Ethical Management page on the EcoPro Group website.