Governance

Accountability

The board of Power Elements, Inc. sets policy, approves strategy and capital, and oversees what the company discloses. It works through three committees: Audit, Remuneration, and Governance, Ethics & Responsible Sourcing.

Day to day, the Chief Executive Officer is accountable for how the company is run. The Head of Traceability runs the responsible-sourcing programme and reports on it to the Governance, Ethics & Responsible Sourcing Committee, and the Head of Risk & Compliance in Rwanda leads risk assessment at upstream sites.

Responsible sourcing

Buyers of tin, tantalum and tungsten originating from Central and East Africa expect due diligence to the OECD standard. We apply the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, with its Supplement on Tin, Tantalum and Tungsten, to our own mine and refinery. Because we own both, we carry the obligations of an upstream producer and of a refiner.

The Guidance sets out five steps. This is how we meet each one.

1. Strong management systems. Our responsible sourcing policy follows the OECD model supply chain policy. We will not tolerate, profit from or contribute to serious human rights abuses, including forced labour, the worst forms of child labour and torture; direct or indirect support to non-state armed groups; or bribery and fraudulent misrepresentation of where minerals come from. The policy also covers public and private security forces, money laundering and payments to governments. The Governance, Ethics & Responsible Sourcing Committee oversees it. The chain of custody is recorded in Original Evidence, our traceability system, operated at arm's length, and concerns can be raised through our grievance mechanism and the Speak up channel.
2. Identify and assess risk. The origin, custody and documents of every lot are recorded in Original Evidence as the material moves, and assessed against the risks named in the policy: at the mine, in transport, at the refinery, and for every counterparty, supplier and service provider, including security providers.
3. Respond to identified risks. Risks are reported to senior management and to the committee, with a plan for each: mitigate while work continues, suspend, or disengage, as the Guidance sets out.
4. Independent audit. Our refinery at Bugesera takes part in the Responsible Minerals Assurance Process (RMAP) of the Responsible Minerals Initiative (RMI). Its due diligence is assessed by an independent, RMI-approved third-party assessment firm against the RMAP Tin and Tantalum Standard, and it is listed as RMAP Conformant on the RMI's public list of facilities. We report that status as it stands, including while any reassessment is in progress.
5. Report every year. We publish an annual supply-chain due diligence report on the Policies & reports page.

The programme is built on the OECD Guidance, the reference point for the frameworks our customers report against, including EU Regulation 2017/821, US conflict-minerals reporting and the CCCMC due diligence guidelines. How we record and share that evidence is set out under Traceability.

Integrity

Our Code of Conduct, and our policies on anti-bribery and anti-corruption, sanctions and export controls, and know-your-counterparty checks, apply to everyone who works for or with the company. We apply the same counterparty checks to our own entities and partners that we ask of our customers. Every policy is published, dated, on the Policies & reports page.

Anyone, inside or outside the company, can raise a concern about conduct, safety, the environment, the treatment of people or the accuracy of anything we publish, in confidence and, where the law permits, anonymously, through Speak up. Retaliation against anyone who raises a concern in good faith is a breach of the Code of Conduct.