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​To supply us with ore, mainly gold, Colombian legislation establishes five types of Authorized Mining Operators (EMA), from which the companies that make up the precious metals supply chain can obtain supplies: I. Mining Owners in Exploitation Stage II. Applicants for mining legalization or formalization programs III. Beneficiaries of Special Reserve Areas (ARE) IV. Mining formalization subcontractors V. Subsistence mining (barequeros and scrap dealers) Is my supplier an EMA that can legally sell? The EMA must be registered in the lists of the Single Registry of Mineral Traders (RUCOM) available at: https://tramites.anm.gov.co/Portal/pages/consultaListados/anonimoListados.jsf The EMA must present a certificate of origin for the total amount of mineral to be traded and/or a declaration of production (subsistence mining). The EMA must meet the following requirements, according to their category, to legally market the minerals: I. Mining Owners in the Exploitation Stage: Concession Contract (CC) Exploitation License (LE) Subscription of the CC Approval of the Work Program and Works (PTO) Approval of the LE Approval of the Works and Investments Program (PTI) Granting of the Environmental License Approval of the Environmental Management Permit (PMA) Evidence of payment of the corresponding royalties Approval of the explosives quota by the Trade Control Department of Weapons (DCCA) of the Military Industry (INDUMIL) for vein mining Narcotics Certificate (all those that transport fuels) alluvial mining. II. Applicants for legalization or formalization programs This figure has been provisionally suspended by judicial decision of the Council of State and is awaiting its reactivation. III. Beneficiaries of the Special Reserve Area (ARE) Declaration of ARE by the mining authority. PTO in the event that the ARE has received a Mining Geological Study from the ANM. Instrument duly granted by the environmental authority. Evidence of payment of the corresponding royalties.  Mining formalization subcontractors Registration of the formalization subcontract with the mining authority. Single Registry of Mineral Dealers (RUCOM). PTO approval. Granting of an environmental license, or failing that, proof of filing with the competent Environmental Authority of the commitment to apply the environmental guidelines. Evidence of payment of the corresponding royalties. V. Subsistence Mining Subsistence mining (artisanal mining) is understood to include scoping and collecting river sand and gravel for the construction industry, clay, precious metals, precious and semi-precious stones that are present in the waste from mining operations. Subsistence miner certificate issued by the municipal mayor's office. Submit the mineral production declaration. Not having exceeded production limits greater than 35g per month for precious metals (gold, silver and platinum). More information at https://tramites.anm.gov.co/ Portal/pages/consultaBarequero/ consultaProduccionBarequero.jsf Single Tax Registry (RUT), with economic activity 0722. To supply myself with intermediaries or marketers: Likewise, the authorities have defined the requirements for Authorized Mineral Dealers (CMA); who must understand the following requirement as essential for compliance: Be registered in RUCOM as a marketer at the time of making the sale. In addition to this, they must have: A. Unique Tax Registry (RUT), Mercantile Registry and Billing Resolution (if applicable) in force. B. Commercial invoices or equivalent document of the minerals that are commercialized. C. All the certificates of origin and/or declarations of production of the minerals that it markets. It is important to note that this is the minimum information required to undertake Due Diligence. The exercise needs to be done much more in depth and mineral traceability should also be a focal point of the process.    

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​Our applicable legislation. - Article 863 and 1287 of the Commercial Code, Law 1581 of 2012 and . Decree 1377 of 2013, article 127 of the Substantive Labor Code, Law 685 of 2001, Law 1530 of 2012 art 132, Decree 1886 of 2015, Decree 4134 of 2011 art 4; Decree 2637 of 2012 art 1, Article 9 of Decree 276 of 2015; Decree 276 of 2015 art 4; Consumer Protection Law 1480 of 2011 and Law 1762 of 2015 of the Republic of Colombia and the Dodd-Frank Wall Street Reform of the USA (July of .... 2010), Regulation (EU) 2017/821, Guide of the Due Diligence of the Cooperation Organization and of . Economic Development in its acronym OECD and other applicable standards, whose information requirements help promote legitimate trade and conflict-free purchase of minerals.

METALS AND MINERALS

RESPONSIBLE SOURCING.

 

We establish strong business management systems in support of responsible sourcing;

 

We identify and assess the risk of adverse impacts in the supply chain;

 

We implement a strategy to respond to the risks that are identified;

 

We train relevant employees, contractors and suppliers to ensure they are aligned with our aspiration to maintain a responsible supply chain; and be aware of the risks, acting against them;

 

We carry out independent audits with third parties for the development of a solid management in the due diligence of the supply chain, identifying all its points.

 

Report on the due diligence of the supply chain through a semi-annual or annual Responsibility Report;

 

We periodically review our practices, guiding us to ensure the risks that arise within the supply chain.

 

We purchase and process only raw materials that conform to the Organization for Economic Co-operation and Development (OECD; Due Diligence Guidance for Mineral Supply Chains from Conflict-Affected and High-Risk Areas) guidelines and related regulations of the EU (Regulation (EU) 2017/821) to establish due diligence obligations in the supply chain. Our adherence to this commitment is confirmed by the Responsible Minerals Initiative (RMI).

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