Responsible Minerals

Version 1.0 – Uploaded 24/09/2025

1. Introduction

Purpose
Corintech Ltd is a UK based electronic manufacturer with a worldwide component supply chain that includes raw material minerals. The Company is committed to responsible procurement practices throughout its business operations. This policy aims to prevent the exploitation of local communities by avoiding the
procurement of components that contain minerals that directly or indirectly finance armed conflict or result in human rights abuses, including child labour and forced labour, or environmental degradation.

This Responsible Minerals Policy is also a guide for employees and suppliers in relation to processes and requirements designed to manage risks associated with minerals that originate from conflict-affected, and high-risk areas (CAHRA).

Scope

This policy applies to all employees, suppliers, contractors, and business partners, regardless of separate agreements and location. It covers all products manufactured, or contracted to be manufactured, by Corintech Ltd.

This policy applies to all minerals, but specifically those named by the Responsible Minerals Initiative (RMI) in their reporting templates. These are: tin, tantalum, tungsten, gold, cobalt, mica, copper, graphite (natural), lithium, nickel.

Glossary of terms
3TG: tin, tantalum, tungsten and gold
CAHRAs: Conflict-Affected and High-Risk Areas.

Section 1502 of the Dodd Frank Act names The Democratic Republic of the Congo (DRC) and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia. The list of CAHRAs used for EU Conflict Minerals Regulation 2017/821 includes the above countries, but is updated with additional countries. A current list of affected countries can be found at www.cahraslist.net

CMRT: Conflict Minerals Reporting Template managed and released by the RMI. The minerals reported in this template are 3TG.

EMRT: Extended Minerals Reporting Template managed and released by the RMI. The minerals reported in this template are cobalt, mica, copper, graphite (natural), lithium and nickel.

OECD: Organisation for Economic Co-operation and Development

RMAP: Responsible Minerals Assurance Process

RMI: Responsible Minerals Initiative

2. Responsibilities

Management 
Senior Leaders, Directors and Managers must ensure the Company complies with all laws and regulations directly applicable to Corintech Ltd, but it must also enable its customers to comply with laws and regulations applicable to the customer’s local jurisdiction, including Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, and the EU Conflict Minerals Regulation (EU 2017/821).

Management will also:

  • support our customers by providing them with the information they request
  • inform relevant teams whenever new versions of RMI reporting templates are released
  • engage with suppliers to address and mitigate identified risk(s)
  • reserve the right to terminate trading with suppliers who repeatedly refuse to align with this policy or provide the required information
  • include mineral reporting activities within the Company’s annual sustainability report


Employees

All Company employees should support transparency by accurately documenting supply chain information when requested.

Purchasing and QA should maintain systems to collect, store and collate the required supplier information to enable accurate mineral reporting. Individual customer requests requiring a CMRT, EMRT or other mineral related information, should be actioned by the Company promptly, as supplier response times can be protracted, depending on the length of the supply chain.

3. Supplier Requirements

Corintech’s suppliers are required to:

  • Adopt a policy and management system consistent with this policy
  • Carry out their own due diligence aligned with the OECD guidance
  • Complete the RMI CMRT and EMRT as part of the supplier approval process, or upon request
  • Provide any other mineral information required by our customers upon request e.g. minerals relating to tariffs or sanctions
  • Work toward sourcing components or materials, which have a supply chain of minerals that
    originate only from smelters and refiners that have been audited and validated by industry programs such as RMAP
  • Report any violations of this policy to Corintech Ltd promptly and agree to enact any corrective actions

4. Continuous Improvement 

As with all sustainability, quality and compliance processes, Corintech is committed to a continuous improvement approach in our mineral reporting due diligence processes, and the Company encourages our suppliers to improve their supply chain practices.

5. Accountability & Non-Compliance 

Accurate and reliable information is of crucial importance, particularly in respect to Corintech’s customers who have a legal duty to report on 3TG or other minerals. All Suppliers are accountable for the information they supply Corintech, and they must ensure that submissions made to the Company are correct so that our Company documents, and information supplied to our customers, is complete and accurate.

Suppliers who put Corintech Ltd at risk of non-compliance may be removed from the  Company approved supplier list.

All stakeholders – employees, suppliers and customers, are encouraged to report any non-compliance promptly so that Corintech can investigate and remediate any issues.

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