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SUPPLY CHAIN
Responsible Sourcing Policy
Scope
This policy applies to selection and retention of Eti Bakır A.Ş. suppliers that provide materials that contain copper, zinc, cobalt etc.
Introduction
Eti Bakır A.Ş. is leading about bringing natural resources into economy and providing
sustainability in its sector. Eti Bakır Mazıdağı Plant request consistently from their suppliers to
conduct their business with the highest-level ethics, to respect labour and human rights and
also expect primarily sensitivity of environment. Eti Bakır Mazıdağı Plant has adopted the
following policy which compliant with Model of Supply Chain Policy in Annex II of
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas.
Products and Operating Processes
Cobalt is especially used in the production of high-capacity batteries, magnets and electromagnets. Zinc is mainly used in galvanizing area for production of construction materials and overhead line poles. Copper is used in the electrical industry and in many other fields.
In the production process of Eti Bakır Mazıdağı plant, pyrite raw material which is concentrated copper production waste of Eti Bakır Küre mine is used. The pyrite raw material is roasted in the sulfuric acid plant, and the resulting calcine ash is transferred to the leaching plant. After the calcine is slurried and leached in an autoclave process, products are obtained by separating cobalt, zinc and copper with selective organics.
Supply Chain Commitment
As Eti Bakır Mazıdağı Plant;
• We will carefully evaluate our suppliers regarding compliance of the OECD Due Diligence
Guidance, National and International Governmental Policies and Eti Bakır A.Ş. Ethical
Policy,
• We commit to follow OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas (“CAHRAs”) when identifying,
mitigating, and reporting risks within our value chain
• We commit to implement the five-step due diligence process defined in the OECD
Guidance Annex I
• We commit to identify and regularly revisit risk for adverse social and environmental
impacts within our value chain.
• We will confirm our suppliers whether they supply minerals from Conflict-Affected and
High-Risk Areas or not,
• We will not make a profit or benefit from the suppliers which are in violation of the OECD
Due Diligence Guidance,
• We will not tolerate any direct or indirect support to non-state armed groups through the
extraction, transport, trade, handling or export of minerals,
And we will support our suppliers and business partners to comply with the decisions in the same way.
Eti Bakır A.Ş. applies a "Zero Tolerance Policy" concerning unethical business behaviour, bribery, corruption and forced or compulsory labour.
Requirements for Our Suppliers
As part of our efforts to identify and manage our risks and exposures associated with conflict minerals, our expectations from our suppliers and business partners are as follows;
• Any forms of torture, cruel, inhuman and degrading treatment should not occur
• Business partners should not participate to any form of forced or compulsory labour
• Absence of worst forms of child labours
• Other gross human rights violations and abuses such as widespread sexual violence
should not be occurred
• War crimes or other serious violations of international humanitarian law, crimes
against humanity or genocide should not be existed
• There must be no non-state armed group which illegally tax or extort money or
minerals in mining sites or transport routes, or in mineral trade areas
• There must be no non-state armed group which illegally tax or extort intermediaries,
export companies or international traders
• Any company in our supply chain makes a contract with public or private security
forces, these security forces do not act against Security and Human Rights
• Transparency, proportionality and accountability in payments made to public security
forces should be provided
• Exposure of vulnerable groups (artisanal or small-scale mining) to adverse impacts
associated with the presence of security forces, public or private should be
minimised
• Any bribes must not be offered, promised, given and demanded to 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
• Money laundering must be effectively eliminated where reasonable risk of moneylaundering
resulting from, or connected to, the extraction, trade, handling, transport
or export of minerals.
Regarding these risks we will not tolerate when we determine that our suppliers are in
violation of the OECD Due Diligence Guidance, and we will immediately suspend and
terminate our relations with the supplier.
Occupational Health and Safety & Environment
Eti Bakır Mazıdağı Plant’s commitment to sustainability includes its commitment to protect the environment and provide healthy and safe workplaces, as well as the efficient use of resources. Eti Bakır Mazıdağı Plant expects its suppliers to make similar commitments to continuously improve their environmental, health and safety performance.
Ensuring Occupational Health and Safety:
Suppliers will provide a safe and healthy workplace
for their direct and indirect employees, including appropriate controls, training, work
procedures and personal protective equipment. Suppliers will comply with all health and
safety laws applicable to the workplace.
Respect for the Environment:
Suppliers shall comply with applicable environmental laws and
have systems in place to ensure the safe management of waste, air emissions and wastewater
discharges. By using recycled materials, suppliers must continually strive to minimize
environmental impact and make continuous improvements in resource efficiency.
Expectations Regarding the Code of Business Ethics for Suppliers
Eti Bakır Mazıdağı Plant expects its suppliers to implement systems and controls that will encourage compliance with applicable national and international laws and principles set forth in this Code, including policies, training, monitoring and inspection mechanisms. Suppliers should apply these or similar principles to the subcontractors and suppliers which they work with while providing goods and services to Eti Bakır Mazıdağı Plant.
Eti Bakır Mazıdağı Plant, reserves the right to evaluate and monitor suppliers' compliance with these Code. Eti Bakır Mazıdağı Plant may request corrective actions from suppliers which do not comply with this Code or these suppliers may not be considered as approved suppliers in future works.
Supply Chain Department
Conflict Minerals Due Diligence Process 2023 Report
Eti Bakır A.Ş. Integrated Fertilizer and Metal Recovery Facility is one of the few facilities in Turkey and in the world where raw materials are produced in the same place.
Eti Bakır A.Ş. Mazıdağı Plant produces approximately 500,000 tons of fertilizer, 2,000 tons of cathode copper, 2,500 tons of zinc carbonate and 5,000 tons of cobalt carbonate annually.
As part of its commitment to maintain ethical, labor and environmental standards, Eti Bakır A.Ş. has adopted Responsible Sourcing Policies regarding the responsible procurement of conflict minerals Cobalt, Copper and Zinc. As Eti Bakır A.Ş. Mazıdağı Plant, we undertake to refrain from any action that will contribute to the financing of the conflict and to comply with the relevant United Nations sanctions decisions or local laws implementing these decisions, if any, and to support our suppliers and business partners to comply with the same issues. Eti Bakır A.Ş Mazıdağı Plant applied to become a member of RMI (Responsible Minerals Initiative) in order to contribute to global responsible purchasing activities and has fulfilled all obligations and become a member of RMI as of 2023.
This report is the second report prepared to explain the due diligence performance of Eti Bakır A.Ş Mazıdağı Plant supply chain for conflict minerals and will continue to be published every year. Eti Bakır A.Ş. does not directly supply conflict minerals from mines and smelters located in conflict-affected and high-risk areas (CAHRA). Eti Bakır A.Ş. complies with the "Responsible Supply Chain OECD Compliance Guide for Mines of Conflict-Affected and High-Risk Regions" to create a responsible supply chain from the mine to the final product.
Eti Bakır Mazıdağı Plant implements the following steps by integrating them into the management system for risk-based due diligence in the supply chains of mines in conflict-affected and high-risk areas.
Step 1.Establishing strong company management systems
Eti Bakır Mazıdağı Plants’ conflict minerals compliance system has been designed to comply in all material respects with the OECD-compliant supply chain management system RBA recommendations. Eti Bakır has established a responsible sourcing policy to prevent the use of conflict minerals in high-risk and conflict-affected areas that directly or indirectly fund or benefit armed groups or are linked to other serious human rights violations. The policy has been widely distributed to interested parties and can be found on Eti Bakır's website ( https://etigubre.com/Responsible-Policiy ). Eti Bakır has established all necessary procedures to fulfill the commitments stated in its responsible supply policy. The company's supply chain manager is responsible for overseeing the design and implementation of the due diligence program and risk management . The supply chain manager works in cooperation with the production and sales departments, reporting to the General Manager. Eti Bakır Mazıdağı plant provides training to all its employees on responsible sourcing processes and makes this training a part of the new recruitment process. When needed, relevant employees receive the necessary training from RBA E-Learning Academy.
Step 2.Identifying and assessing risks in the supply chain
Pyrite material stored as waste after the flotation process at the Eti Bakır Küre facility is brought to Mazıdağı facilities by railway. Pyrite, a by-product of the Küre mine, is not associated with Cahra because it is used in the process from raw material to final product and the sourced region is not included in the Cahra list . As Eti Bakır Mazıdağı factory, periodic on-site inspections are carried out by the production, quality and supply chain departments at the Küre factory, which is our group company, and the risks and opportunities in raw material supply are evaluated and added to the corporate risk analysis table. Additionally, risks in the Supply Chain are evaluated annually and recorded in the risk diary. Although our raw materials are supplied from a single source as the Mazıdağı facility , the CAHRA determination process has been put into effect in order to create a control system for future diversification.
Step 3. Design and implement a strategy that can respond to identified risks
The supplier of the product used as raw material in the process flow is a business within Eti Bakır A.Ş. In this context, the risks identified as a result of the risk assessment are related to natural disasters and logistics processes, and stock management and alternative transportation plans have been made. In order not to negatively affect production, necessary actions regarding stock management and alternative transportation plans were evaluated to reduce the risk identified in the risk analysis. Additionally, according to the supply chain risk analysis table, it was determined that there were no suppliers on the CAHRA list.
Step 4. Independent third-party audit of smelting/refining companies' practices
There is an Internal Audit Procedure at the Eti Bakır Mazıdağı facility and audits are carried out annually within the determined plan. The 2023 Internal Audit Report was published in our QDMS system on 12.03.2024, with action plans and corrective and preventive actions determined. In order to achieve our goal of becoming an approved supplier for our metal products, among our strategic goals for 2023, an external audit was requested by RMI on 13.06.2023-14.06. As a result of the audits carried out in 2023, Eti Bakır became an RMI approved company as of 24.11.2023. Other than thatEti Bakır obtained the ISO 9001, ISO 45001 and ISO 14001 certificates as of 15.06.2023. As part of our ongoing continuous improvement efforts, an interim audit of these documents will be carried out in April 2024 and an ISO 50001 certification audit will also be carried out.
Step 5. Annual reporting of supply chain compliance efforts
Eti Bakır A.Ş. has started to prepare due diligence reports regarding the supply of conflict minerals as of 2022. All raw materials for Eti Bakır's Cobalt , Zinc and Copper products are purchased from Kastamonu Küre facility, which is the company's own subsidiary. In 2022, approximately 460,000 tons of pyrite were supplied from the Küre facility and CoCO3 (Cobalt Carbonate), ZnCO3 (Zinc Carbonate), Cathode Copper and Fertilizer (DAP & NPK) were produced as final products. In 2023 , approximately 540,000 tons of pyrite were supplied from the Küre facility and CoCO3 (cobalt carbonate), ZnCO3 (Zinc Carbonate), Cathode Copper, Iron Cake and Fertilizer (DAP, NPK) were produced. In the raw material supply process, Eti Bakır Küre Enterprise is the only supplier and there are no external suppliers on the Cahra list. Therefore, there are no additional findings to report regarding conflict minerals.
Eti Bakır Mazıdağı Plant Due Diligence Report for Mineral Supplies in 2022
About Mazıdağı Metal Recovery and Integrated Fertilizer Plants
Mazıdağı phosphate mine was acquired by Cengiz Holding in 2011 from the government privatization administration. Investment started in 2014 as the largest private sector investment of 1.2 billion dollars in the region. The plant was commissioned in 2018 started the commercial production. Eti Bakır Mazıdağı plant is one of the unique facilities in Türkiye and in the world, as the plants’ raw materials are produced in the same place.
Integrated Fertilizer and Metal Recovery Facility contributes to the regional and national economy by avoiding 350 million dollars of fertilizer and 270 million dollars of metal imports per year. Eti Bakır Mazıdağı plant produces approximately 500,000 tons of fertilizer, 2,000 tons of cathode copper, 2,500 tons of zinc carbonate and 5,000 tons of cobalt carbonate annually.
As part of its commitment to upholding ethical, labor and environmental standards, Eti Bakır has adopted the Responsible Sourcing, Know Your Supplier and FPIC Policies regarding the responsible sourcing of conflict minerals Cobalt, Copper, Zinc. As Eti Bakır Mazıdağı plant, we are committed to refrain from any action that will contribute to the financing of the conflict, to comply with the relevant United Nations sanctions resolutions or, if any, local laws implementing these decisions, and to support our suppliers and business partners to comply with the same. In this context, Eti Bakır Mazıdağı plant applied to be a RMI (Responsible minerals Initiative) conformant smelter in order to contribute to global responsible purchasing activities.
This is the first supply chain due diligence report prepared of the Eti Bakır Mazıdağı plant and will continue to be published every year. Although Eti Bakır Mazıdağı plant does not directly supply conflict minerals from mines and smelters located in conflict-affected and high-risk areas (CAHRA), our supply chain consists of many stakeholders. For this reason, Eti Bakır complies with the “Responsible Supply Chain OECD Compliance Guide for Minerals from Conflict-Affected and High- Risk Areas” in order to establish a responsible supply chain from the mine to the final product and to do due diligence, and includes the five-stage action plan described in the OECD Principles in its management system.
Eti Bakır Mazıdağı plant integrated following steps into the management system for risk-based due diligence for the supply chains of mines in conflict-affected and high-risk regions.
Step 1. Establishing strong company management systems
Eti Bakır Mazıdağı Plants’ due diligence system have been designed to conform, in all material
respects to the framework in the OECD aligned due diligence supply chain management system, as
well as related RBA recommendations.
Eti Bakır has established a responsible sourcing policy to prevent the use of conflict minerals that
directly or indirectly provided funds or benefits to armed groups in high-risk and conflic-affected
areas ora re related to other serious human right abuses. The policy has been widely disseminated
to relevant interested parties and can be found on Eti Bakır’s website
(https://etigubre.com/Responsible-Policiy) Eti Bakır keeps its promises to the supply chain policy,
and has established required internal procedures for due diligence. The company’s supply chain
manager is responsible for overseeing the design and implementation of its due diligence program
and risk management. He is reporting to general manager and colloborating with production and
the sales departments. Eti Bakır provides training to all employees about responsible sourcing
processes and made this training a part of the new employee onboarding process. Relevant
employees are leveraging e-leaning training from RBA E-Learning Academy when needed.
Step 2. Identification and assessment of risks in the supply chain
After the flotation process in Eti Bakır Küre plant, the pyrite material stored as waste is brought to Mazıdağı facilities by rail. Since pyrite, which is a by-product of Küre mine, is used in the process from raw material to final product, and the supplied region is not on the Cahra list, it has not been associated with Cahra. As Eti Bakır Mazıdağı plant, the production, quality and supply chain departments periodically carry out on-site inspections to the Küre plant, of which we are an internal organization, and evaluate the risks and opportunities in raw material supply and add them to the corporate risk analysis table. In addition, risks in the Supply Chain are evaluated annually and recorded in the risk log. Although, as Mazıdağı plant, our raw material is supplied from a single source, a CAHRA determination process as follows has been put into effect in order to establish a control system for its diversification in the future.
Step 3.Designing and implementing a strategy to respond to the identified risks
The supplier of the raw material in the process is an Eti Bakır company and main risks identified are related to natural disasters and logistics processes. Required actions on stock management and alternative transportation plans have been evaluated to mitigate the risk determined in the risk analysis in order not to adversely affect the production. In addition, according to the supply chain risk analysis table it has been determined that there is no supplier in the CAHRA list.
Step 4. Audit of smelter/refinery practices by independent third parties
Eti Bakir Mazıdağı plant has an internal audit procedure, and audits are carried out within the framework of the annual plan. Besides, in 2022 a 3rd party audit was conducted by an external party in line with customer demand and within the scope of responsible procurement. Minor nonconformities that emerged during this audit were carefully handled and corrective actions were taken. In the coming period, the subject of external audit will be re-evaluated. The 2022 Internal Audit Report was published in our document system on 17.02.2023 by determining action plans and corrective preventive actions.
Step 5.Annual reporting of supply chain compliance studies
Eti Bakır Mazıdağı plant started to prepare a due diligence report on the procurement of conflict minerals as of 2022. Eti Bakır Mazıdağı plant raw materials related with Cobalt , Zinc and Copper products are supplied from Kastamonu Küre mine, which is a subsidiary of the company. In 2022, aprroximately 460,000 tons of pyrite was supplied from the Küre plant and CoCO3 (Cobalt Carbonate), ZnCO3 (Zinc Carbonate), Cathode Copper and Fertilizer (DAP & NPK), were produced as final product. In the raw material supply process, Eti Bakır Küre plant is the only supplier and there is no supplier in the Cahra list. There are no external suppliers. Therefore, there are no additional findings to report regarding the conflict minerals .