CONFLICT MINERALS POLICY 2024

Date: January 2024

Atlantic Dream RDC is steadfast in its commitment to ethical and responsible mineral sourcing practices. We are dedicated to ensuring that our mineral procurement processes uphold transparency, integrity, and accountability throughout the supply chain. Our policies are designed to mitigate the risk of sourcing minerals that may contribute to conflict, violence, or human rights abuses.

Our Policies Include:

  1. Adherence to Atlantic Dream RDC’s Code of Conduct: We strictly adhere to and understand the principles outlined in our Code of Conduct, which guides our business practices with integrity and ethical standards.

  2. Selective Supplier Engagement: We limit our engagement with upstream suppliers to those with whom we have established strong, long-standing relationships, or those who have undergone satisfactory 'Know Your Customer' (KYC) procedures, including internal audits on supply chain plausibility and facility spot checks.

  3. Documentation Requirements: Each supplier must provide specified origination and traceability-related documentation for every shipment, including tags (where applicable), surveyor’s reports, export documentation, and a Certificate of Origin. This ensures accurate financial declarations and transparency in the supply chain.

  4. Supplier Audits: We conduct regular audits on our suppliers, verifying iTSCi membership (where applicable), valid trading licenses, proprietary conflict mineral policies, and evidence of policy implementation to eradicate illegal activities and human rights violations.

  5. Transparency and Information Sharing: Suppliers are expected to share their due diligence reports promptly, with any findings or concerns communicated immediately. We utilize public and private information sources, including production statistics, to assess production plausibility and actively encourage partners to conduct mine site visits regularly.

  6. Contractual Obligations: We reserve the right to suspend or terminate supply contracts if suppliers fail to collaborate in mitigating or remedying existing or potential risks in their supply chain.

  7. Policy Review and Compliance: We regularly review and update our conflict mineral policies in accordance with international guidelines, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, the US Dodd Frank Act Section 1502, and UN Security Council Resolutions.

  8. Verification of Compliance: We ensure adherence to buyers’ purchase protocols and supply chain procurement practices to meet downstream compliance needs. Additionally, we comply with regulatory requirements regarding the transportation and movement of procured materials.

  9. Stakeholder Engagement: We use the Responsible Minerals Initiative's stakeholder mapping mechanism to evaluate the influence, interest, and value proposition of each actor in our supply chain, identifying applicable risks and mitigation strategies.

  10. Whistleblowing Mechanism: We provide a whistleblowing policy to our upstream suppliers as a grievance mechanism to facilitate ongoing improvement in procurement and traceability practices.

In addition to these policies, Atlantic Dream RDC actively supports and encourages training initiatives for our suppliers, aimed at promoting best practices and resolution methods. Through these efforts, we strive to ensure that our mineral supply chain remains sustainable and free from conflict or human rights abuses, aligning with the principles of 'conflict-free minerals'.