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Responsible Minerals Sourcing Policy Statement

MSC is a major global integrated tin producer with exploration, mining, smelting and marketing business divisions. The Company’s custom tin smelter located in Penang, Malaysia sources its feed materials comprising primary tin concentrates, crude tin and secondary tin bearing materials from all over the world. It is the Company’s policy to conduct its custom smelting business in a responsible and ethical manner.

Section 1502 of the US Dodd-Frank Wall Street Reform and Consumer Protection Act signed into law by President Obama on July 21st 2010 defines ‘Conflict Minerals’ as including ‘cassiterite and its derivatives’ along with two other minerals and gold. MSC supports the objectives of this law, to progressively reduce the link between mining and conflict in the eastern Provinces of the Democratic Republic of Congo (DRC) and recognises the disclosure requirements which this law imposes on SEC reporting companies in the US.

MSC purchases tin concentrates from Conflict Affected and High Risk Areas (CAHRA) countries and is fully aware that there are thousands of miners and their dependents in the CAHRA countries and the surrounding region who rely on tin production and its trade, as do thousands more employed in associated services such as transportation. MSC will participate in initiatives that aim to address the CAHRA issues and those defined in the OECD Annex II to ensure that trade will continue and in compliance with requirements of the international community. MSC will suspend or terminate business relationship with suppliers who supply materials from mines which come under the Annex II risk and who do not address known risks.

Currently between 15-20% of the tin MSC produces is sourced from predominantly artisanal miners in Central Africa. The majority of the smelter’s intake from Central Africa comes from Rwanda, or from the southern Katanga Province of the DRC which is not within the recognised conflict areas of Eastern DRC. MSC, as a leading member of the International Tin Association (ITA), has been pro-active in developing the ITRI Tin Supply Chain Initiative (iTSCi) traceability and due diligence system designed to differentiate between conflict and non-conflict sources in high risk areas and promote progressive improvement of the mining areas where the artisanal miners operate. All tin concentrates purchased by MSC from Rwanda and Katanga is obtained through the iTSCi programme and in accordance to internationally recognise due diligence guidance.

MSC has developed and has implemented a due diligence management system that aligns with the Organisation for Economic Co-operation and Development (OECD) and the United Nations (UN) guidelines for company due diligence on minerals from CAHRA countries. The US Department of State has endorsed the OECD guidance and encourages companies to draw upon it, as they establish their due diligence practices. These guidelines outline actions that will allow trade to continue while promoting responsible sourcing and progressive improvement.

MSC conducts due diligence on its suppliers, materials origin and transit routes in accordance with RMAP standard which includes identifying, assessing and addressing OECD Annex II risks.

MSC is also committed to meeting the requirements of Governments of the affected countries and subscribes to a longer term sustainability objective of improving the tin mining industry globally. In this respect the Company will explore opportunities for establishing, either unilaterally and/or on a joint venture basis with private companies as well as Governments in industrial size mining projects in CAHRA countries from where it sources.

MSC is also committed to continuously improve its program and performance which includes addressing any grievances brought forth through RMAP Grievance Mechanism.

Tin Code

Public Due Diligence Report

RMS Policy