Our corporate policies, structures, processes, and all our commercial activities are in tandem with UNGP & UDHR. Source Plus Afrique Group and all its upstream, midstream and downstream suppliers adhere to strict code of responsible business conduct towards Health, Safety, Human Rights and Environmental impact in Communities where we operate throughout the world.
Fair Trade Policy
Our company is fully committed to transparent, fair and responsible trading. We are focused to ensure that our business has a positive impact on the producers at the end of the chain. This is achieved through continuous improvement and innovation of new ways of creating optimum value for our producer communities; together with sound environmental stewardship.
As a group, we believe in secure, long-term partnerships with our customers. We guarantee fair and stable prices to support sustainable production and the creation of opportunities for re-investment into the local communities. We aim to offer our customers across the world superior value, cost effective solutions and unparalleled professional service.
At Source Plus Afrique Group, we are uniquely positioned to oversee all the end-to-end aspects of the commodity transaction cycle, from working on the ground and establishing relationships of mutual trust with local producer partners and communities to confirming and ensuring all legal compliance requirements for international trading in a context where it is essential to guarantee the interests of both producer partner and clients.
CSR Charter
Source Plus Afrique Group is focused on helping communities we work with in elevating quality of life. We are committed to creation and strengthening of education, health and environmental conservation in the communities which we work.
Our company has voluntarily chosen to recognize the importance of Corporate Social Responsibility (CSR) by agreeing to the values outlined in this CSR Charter.
We share commitment to the core principles of CSR and a vision for the way forward.
We agree to:
- Provide leadership
- Integrate CSR into our organizational strategy and operations
We aspire to:
- Engage with our stakeholders
- Communicate CSR
Quality, Health, Safety & Environment
Handling the supply chain of sourcing, marketing, trading, logistics and supply of these commodities is a complex process requiring consummate attention. As part of our company management system, we have comprehensively implemented a specific Quality, Health, Safety and Environment Policy as outlined below:
- This policy has been defined as a reference point for establishing and reviewing our company goals for consistent improvement. Our company is committed to promoting and implementing the policy throughout the corporate structure, and to increasing awareness by involving and consulting all employee and third party stakeholders.
- Our company manages all the operations of sourcing, marketing, trading and supply of all the commodities, in accordance with relevant domestic legislation and laws in all areas where we conduct business and also international standards and ethical principles, whether we are directly or indirectly responsible. We comply with all requests issued by regulatory authorities in our origination and destination markets.
- All our employees receive training, whatever their contractual situation, so as to ensure their awareness, responsibility and involvement in contributing to the quality, health, safety and environmental continuous improvement process.
- Our aim is to reduce to zero all critical deviations, accidents and occupational diseases. We aim to create a safe and healthy workplace and we take preventive care of the health and welfare of our employees.
- We manage all residual risks and their potential impact on our employees, on the environment and on the end-users of our products. We are constantly updating our improvement plans.
- In our Quality, Health, Safety and Environmental System, we define specific standards, procedure and methods aimed at regulating our activities and the ones of all those concerned both internally or externally ( i.e., contractors, suppliers etc)
- We guarantee that the conditions of our Quality, Health, Safety and Environmental Management System are an integral part of our operational processes. We ensure that adequate means and resources are made available to enforce our Policy and achieve our goals.
Global Anti-Corruption Policy
Source Plus Afrique Group’s commitment to doing business with integrity means preventing corruption in any form and complying with both the international and domestic anti-corruption laws of every local communities and countries where we do business.
We avoid all forms of bribery and corruption in all our operations. As a matter of policy, we call for similar ethical requirements from all of our affiliates, associates and third party business partners.
Global Anti-corruption Policy
(Approved by the Source Plus Afrique Compliance Audit Committees on Thursday, 15 June 2017, to be reviewed on 15 July 2018)
1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and in implementing and enforcing effective systems to counter bribery.
1.2 We will uphold domestic laws in area where we conduct business and all international laws and relevant to countering bribery and corruption. However, we remain bound by the laws of the Hong Kong, including the Prevention of Bribery Ordinance (PBO), in respect of our conduct both at home and abroad.
1.3 The purpose of this policy is to:
(a) set out our responsibilities and of those working for us, in observing and upholding our position on bribery and corruption; and
(b) to provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues.
1.4 Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously and we have conducted a risk assessment to identify any key areas which may potentially pose a particular risk to our organization.
1.5 In this policy, third party means any individual or organization you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
Who is covered by the policy?
- This policy applies to all individuals working at all levels and grades, including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers and agency staff, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).
What is bribery?
- A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Gifts and hospitality
4.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.
4.2 The giving or receipt of gifts is not prohibited, if the following requirements are met:
- it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
- it complies with local law;
- it is given in our name, not in your name;
- it is appropriate in the circumstances. For example, in some countries it is customary for small gifts to be given at Christmas time;
- taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
- it is given openly, not secretly; and
- gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the company compliance officer.
4.3 We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
What is not acceptable?
- It is not acceptable for you (or someone on your behalf) to:
- give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
- give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
- accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
- accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
- threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
- engage in any activity that might lead to a breach of this policy.
Facilitation payments and kickbacks
6.1 If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Group Head of Compliance.
6.2 Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
Donations
- We do not make contributions to political parties. We can only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Group Head of Compliance.
Your responsibilities
8.1 You must ensure that you read, understand and comply with this policy.
8.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
8.3 Any employee who breaches this policy will face disciplinary action, which may result in dismissal. We reserve our right to terminate our contractual relationship with other workers and organizations if they breach this policy.
Record-keeping
9.1 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
9.2 You must declare and keep a written record of all hospitality or gifts accepted or offered in accordance with the company’s Regulations and Procedures. You must also ensure that all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with such regulations and the manual.
How to raise a concern
10.1 You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with the Group Head of Compliance. You should raise a concern as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in the Appendix.
10.2 Concerns should be reported by following the procedure set out in our Whistle blowing Policy.
What to do if you are a victim of bribery or corruption
- It is important that you tell the Group Head of Compliance as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
Protection
12.1 Workers who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
12.2 We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
Communication
13.1 Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
Who is responsible for the policy?
14.1 Both the Legal & Compliance Committee and Risk & Audit Committee have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
14.2 The Group Head of Compliance has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels is responsible for ensuring those reporting to them are made aware of and understand this policy.
14.3 The Group Head of Compliance will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and financial procedures will be subject to regular audits to promote best practice in countering bribery and corruption.
14.4 All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
Potential risk scenarios: “red flags”
The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws.
The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them promptly using the procedure set out in the Whistle blowing Policy:
- you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
- you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;
- a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
- a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
- a third party requests that payment is made to a country or geographic location different from where the third party conducts business;
- a third party requests an unexpected additional fee or commission to “facilitate” a service;
- a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
- a third party requests that a payment is made to “overlook” potential legal violations;
- a third party requests that you provide employment or some other advantage to a friend or relative;
- you receive an invoice from a third party that appears to be non-standard or customized;
- a third party insists on the use of side letters or refuses to put terms agreed in writing;
- you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
- a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or
- you are offered an unusually generous gift or offered lavish hospitality by a third party.
Conflict Minerals Policy
By adhering to the guidelines of our Corporate Code of Business Conduct as well as our Global Anti-Corruption Policy, Source Plus Afrique Group is committed to aid in the international efforts to end the violence and human rights abuses associated with the mining and trading of mineral resources in the Designated regions and has therefore integrated Conflict Minerals Policy across its business activities and engagements with all counterparties.
Conflict minerals refer to minerals such as cassiterite(tin), columbite-tantalite, wolframite (tungsten), gold (3TG) and their derivatives which are mined in regions where human rights abuses, armed conflict and environmental harm may exist.
The fundamental purpose of this policy is to promote integrity and sustainability by advancing cogent ways for legitimate minerals from the designated countries to enter the global supply chain, thereby responsibly supporting the economy of the region and the local communities which depend on this trade as their core economic activity.
Source Plus Afrique Group adheres to international policies with benchmark stipulations for transparent, responsible, ethical and sustainable business operations. We are committed to conducting our business in full compliance of all relevant international rules, conventions and regulations relating to supply chain of 3TG minerals. The group will not involve in any activities directly or indirectly which could contribute to financing of conflict.
We will always work with our suppliers to trace material content in the mineral commodities they supply to us down to a conflict free certified smelter and to provide documentation regarding all due diligence efforts. We aim to undertake reasonable due diligence within our supply chain to ensure that specified metals are not being sourced from conflict mines. We will require our suppliers to procure products containing tin, tantalum, tungsten, and/or gold from sources that have been identified to be conflict-free.
In full consideration of the recommendations of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Afflicted and High Risk Areas, Source Plus Afrique Group has adopted the stipulated guidelines to ensure utmost care and due diligence is complied with throughout administration and trading of minerals from the conflict areas. Consistently the following instructions are assimilated in all our trading operations for mineral resources:
- While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:
- i) any forms of torture, cruel, inhuman and degrading treatment;
- ii) any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
iii) the worst forms of child labour;
- iv) other gross human rights violations and abuses such as widespread sexual violence;
- v) war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
- We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined in paragraph 1.
- We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non state armed groups through the extraction, transport, trade, handling or export of minerals includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
- i) illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
- ii) illegally tax or extort6 money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
iii) illegally tax or extort intermediaries, export companies or international traders.
- We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in paragraph 3.
- We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.
- We recognize that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
- Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
- We will support efforts, or take steps, to engage with central or local authorities, international organizations and civil society organizations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.
- Source Plus Afrique Group will support efforts, or take steps, to engage with local authorities, international organizations and civil society organizations to avoid or minimize the exposure of vulnerable groups, in particular, artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
- In accordance with the specific position of the company in the supply chain, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified in paragraph 5, where we identify that such a reasonable risk exists.
In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan. Where we identify a reasonable risk of activities inconsistent with paragraphs 8 and 9, we will respond in the same vein.
- We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.
- We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.
- We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI).
- In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organizations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
Source Plus Afrique Group will seek strategic cooperation like joint ventures with other like minded partners to advance its long term mission of promoting expansive and sustainable development of industries in DRC, Burundi and Rwanda by way of investments in industrial scale exploration, mining, processing and smelting of tin, tungsten, tantalite, gold and associated minerals resources.