Conflict-Free Minerals

LOMGroup's Statement on Conflict Minerals

Sustainability in its three dimensions (environmental, social, and economic) is of the highest importance for LOMGroup.

What is 'Conflict Minerals' ?

The term “conflict minerals” is defined as columbite-tantalite, also known as coltan (from which tantalum is derived); cassiterite (tin); gold; wolframite (tungsten); or their derivatives; or any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.

Sustainable conduct forms the basis of our business decisions and dealings with our shareholders. The LOMGroup Business Conduct Guidelines provide the ethical and legal framework in which we strive to conduct successful activities. Adherence to applicable laws and internal policies is an essential part of our integrity, and fundamental to our business.

In order to also ensure Sustainability in our Supply Chain, we have established the Code of Conduct for LOMGroup employees. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization and also reflects our Business Conduct Guidelines. We contractually commit our suppliers to the Code of Conduct for LOMGroup Suppliers and also expect them to promote these standards to their suppliers.

What is our opinion about ?

LOMGroup is not listed on any U.S. stock exchange and thus not under an obligation to respond to the SEC requirements published in August 2012 and to issue a Conflict Minerals Report. Nevertheless, LOMGroup continues to exercise its duty of care within the supply chain. LOMGroup, like many other companies, is aware of the difficult situation that products and components purchased from suppliers may contain minerals originating from conflict-affected countries.

We have rolled out a uniform and enterprise-wide process to determine the use, source and origin of Conflict Minerals in our supply chain. We work closely with our direct suppliers to support us in carrying out these steps. Where necessary, we work with suppliers in order to remediate risks and perform additional due diligence so that we can continue to source responsibly, building on established management processes.

We do not, however, encourage implementing a de facto embargo on the DRC and adjoining countries in the sourcing of Conflict Minerals. This is in line with our requirement to comply with the principles of non discrimination with regard to supplier selection and treatment and follows the call of many internationally active human rights organizations.

LOMGroup actively supported and plans to further support the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as a supporter for the development of the respective Due Diligence processes which expressly recognizes a Risk-Based Due Diligence in the Mineral Supply Chain as well as industry-wide initiatives like the Conflict-Free Sourcing Initiative.