Responsible Sourcing & Compliance
We take social, ethical, and environmental considerations into account across our supply chains and supplier relationships.
Our Commitment
ZG Minerals is committed to responsible mineral sourcing that respects human rights, protects the environment, and contributes to sustainable development in the communities where we operate. We recognize our responsibility to conduct due diligence on our supply chains and to support transparency in the mineral trade.
This commitment is especially important for minerals classified as "conflict minerals" or "3TG" (tin, tantalum, tungsten, and gold), where heightened due diligence is required under international frameworks and national regulations.
Our Due Diligence Framework
Our due diligence approach is aligned to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, which establishes a five-step framework for responsible mineral sourcing.
Establish Strong Management Systems
Adopt and communicate responsible sourcing policies throughout the organization and to suppliers.
Identify & Assess Risks
Map the supply chain and assess risks related to conflict, human rights, and environmental impacts.
Design Risk Mitigation Strategies
Develop and implement plans to prevent or mitigate identified risks in the supply chain.
Independent Third-Party Audit
Engage independent auditors to verify due diligence practices at identified points in the supply chain.
Report Publicly
Provide transparent information on supply chain due diligence policies, practices, and findings.
3TG Minerals Disclosure
Tin and tantalum (two of the minerals we supply) are commonly treated as "conflict minerals" or "3TG" in global supply chain compliance programs, including:
- U.S. SEC Rule (Dodd-Frank Section 1502): Requires publicly traded companies to disclose use of 3TG from the Democratic Republic of Congo (DRC) and adjoining countries.
- EU Conflict Minerals Regulation: Requires EU importers of 3TG to exercise supply chain due diligence.
ZG Minerals applies OECD-aligned due diligence to all tin and tantalum supply chains and supports responsible smelter assurance programs where applicable.
Our Responsible Sourcing Practices
Supplier Due Diligence
All suppliers undergo screening for legal licensing, operating permits, and adherence to local laws. For 3TG minerals, we collect additional information on mine location, chain of custody, and conflict risk indicators.
Chain of Custody Documentation
We maintain records tracing material from mine site through export, including purchase invoices, transport logs, export permits, and assay certificates. For 3TG minerals, enhanced documentation supports downstream customer compliance programs.
Support for RMI RMAP
For tin and tantalum, we support industry assurance mechanisms such as the Responsible Minerals Initiative (RMI) Responsible Minerals Assurance Process (RMAP). We provide information to enable downstream customers to report smelter/refiner identities and conformance status where applicable.
Risk Assessment & Mitigation
We assess risks related to conflict financing, human rights abuses (including child labor and forced labor), environmental damage, and corruption. Where risks are identified, we work with suppliers to implement corrective actions or suspend relationships if risks cannot be mitigated.
Grievance Mechanism
We provide a channel for stakeholders to report concerns related to our supply chains. Reports can be made confidentially through our "Speak Up" mechanism, and all concerns are reviewed and investigated promptly.
Policy Documents
Coming soon - Contact us for copies in the meantime
Report a Concern
If you have information about potential violations of our responsible sourcing standards, human rights concerns, or environmental issues in our supply chains, please report them through our Speak Up channel.
Report a ConcernReports can be made confidentially
Industry Resources
OECD Guidance
The international standard for responsible mineral supply chain due diligence
Visit OECD Website →