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Four E's Industrial Group
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    • Labor & Human Rights
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Responsible Minerals Sourcing

Responsible Minerals Sourcing Policy | Four E' Industiral Group

 

Purpose and scope

Four E's Industrial Group sets the responsible sourcing standard for its operating companies, including Four E's Scientific (laboratory instruments and life science tools) and Four E's Automotive (automotive products). Products across the Group contain metals and electronic components. Some of these can be traced to tin, tantalum, tungsten and gold (the 3TG minerals) and, in certain products, to cobalt and mica. The mining and trade of these minerals in conflict-affected and high-risk areas can fund armed groups and be linked to serious human rights abuses.

This policy sets out how the Group sources these minerals responsibly and what we require of our suppliers. It applies across all Group operating companies, to all products they manufacture and sell, and to every supplier that provides materials or components used in them.

Our commitment

We do not knowingly source 3TG, cobalt or mica that finances or benefits armed groups, or that is linked to human rights abuses, in the Democratic Republic of the Congo, its adjoining countries, or any other conflict-affected or high-risk area.

Our approach follows the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. We support the aims of Section 1502 of the US Dodd-Frank Act and Regulation (EU) 2017/821, and we align our reporting with the Responsible Minerals Initiative (RMI) and its Responsible Minerals Assurance Process (RMAP). We work towards sourcing only from smelters and refiners that RMAP has validated as conformant.

Minerals covered

This policy covers tin, tantalum, tungsten and gold, and their derivatives (the 3TG minerals). We apply the same principles to cobalt and mica where our products contain them, and we report on these using the Responsible Minerals Initiative's Extended Minerals Reporting Template (EMRT) when a customer requires it.

What we expect from suppliers

Suppliers who provide materials or components that contain these minerals must:

  • complete a current Conflict Minerals Reporting Template (CMRT), and an EMRT where cobalt or mica applies, and keep both up to date;
  • identify the smelters and refiners in their supply chain and source, wherever possible, from those validated as conformant under RMAP;
  • carry out their own supply chain due diligence in line with the OECD Guidance, and pass these same requirements on to their own suppliers;
  • respond promptly and accurately to our requests for sourcing declarations and supporting records; and
  • tell us without delay if they identify a smelter or refiner in their chain that is linked to conflict or human rights abuses.

Willingness to meet these expectations forms part of how we select and review suppliers. Where a supplier cannot or will not source responsibly and does not correct the problem within an agreed period, we reserve the right to reduce or end the relationship.

How we conduct due diligence

We follow the five steps set out in the OECD Guidance:

  1. We hold internal management responsible for responsible minerals sourcing and communicate this policy to our suppliers.
  2. We identify the 3TG content of our products, and cobalt and mica where relevant, and collect CMRT and EMRT declarations to map the smelters and refiners in our chain.
  3. We check the declared smelters and refiners against the RMAP conformant list and follow up on any that are not validated or that raise concern.
  4. We rely on RMAP independent third-party audits of smelters and refiners as the assurance mechanism at that point in the chain.
  5. We report to our customers through completed CMRT and EMRT declarations, and we review this policy and our sourcing data at least once a year.

Reporting a concern

Anyone with information about a possible breach of this policy, whether an employee, supplier, customer or member of the public, can contact us at info@4e-s.com . Reports may be made in confidence, and we do not tolerate retaliation against anyone who raises a concern in good faith.

Governance and review

This policy is approved by the management of Four E's Industrial Group and applies to all Group operating companies. We review it at least once a year and update it to reflect changes in regulation, in the Responsible Minerals Initiative's reporting templates, and in our own supply chains.


Approved by the management of Four E's Industrial Group.

Effective date: 31st March 2026

Version: 1.0

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