NIKIN USA LLC

 Management Procedure Development Process 

 The primary business of Nikin USA is to import tantalite concentrates from mine sources that are not vertically integrated with smelter / refiners providing purified tantalum products into market. In order to meet industry standard sourcing schemes for upstream chain of custody and due diligence verification processes, Nikin has elected to become iTSCI certified.  Nikin’s internal management procedure maintains due diligence and address risk impacting their due diligence program and source of origin verification process. The management of Nikin USA is committed to cultivating transparent mineral supply chains with a view to preventing the extraction and trade of minerals from becoming a source of conflict, human rights abuses, and insecurity.  

Responsible Minerals Management Procedure

The objective of Nikin USA’s management procedure is to support human rights and avoid contributing to conflict through strong mineral sourcing practices. This procedure is also intended to cultivate transparent mineral sourcing practices and sustainable corporate engagement with raw materials suppliers and smelter customers.

Management Systems  

As communicated in its Responsible Minerals sourcing policy Nikin USA takes a strong stance against the sale of materials mined or transported that are believed to be financing or benefiting groups that are responsible for human rights violations. Nikin USA expects its suppliers to adopt similar policies and support Nikin’s efforts to promote transparency of the materials sources of origin. 

As a result of electing to become iTSCI certified Nikin has elected to work with suppliers that are also certified to the schema. This will support their efforts to demonstrate chain of custody and verify their materials sources of origin. The selected supplier is a government run organization in the DRC. A Nikin representative will be onsite within the supplier facility to conduct materials source verification, oversee materials handling procedures and ensure proper payments have been made to all parties involved. If Nikin elects to use sources not certified through iTSCI they will either encourage iTSCI certification or evaluate those sources to ensure they are following proper source verification and chain of custody procedures that align to OECD Guidance on Responsible Minerals sourcing.

The leadership of Nikin USA has established chain of custody expectations to be followed by all its employees and suppliers. This is intended to support Nikin’s supply chain due diligence process and transparency of transaction-based accountability for all purchased and sold materials.

Grievance Mechanism

Nikin USA provides a mechanism to allow any interested party to voice concerns regarding the circumstances or mineral extraction, trade, handling and export. Any concerned party has the opportunity to communicate its concerns regarding accuracy of information, direct knowledge of conflict in sources or additional relevant information that was not uncovered by Nikin processes. Nikin’s open reporting mechanism is specific to Responsible Minerals Sourcing. This is managed through Nikin USA’s operations department which may be contacted by:

Telephone 215-327-9022

Email info@nikinusa.com

Responsible Mineral Sourcing Policy 

In August 2012, the U.S. Securities and Exchange Commission (SEC) adopted final rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule”). "Conflict minerals" refers to columbite-tantalite (coltan), cassiterite, wolframite and gold, and their derivatives tantalum, tin and tungsten, without regard to the location or origin of the minerals or derivative metals.

While not a US publicly-traded company, Nikin USA understands the impact of atrocities being committed in the Democratic Republic of the Congo (DRC) and adjoining countries from the sale of mined materials controlled by armed groups. 

As an exporter of concentrate materials out of the DRC, Nikin USA has taken a stance against revenue from the mining and transport of these conflict minerals believed to be financing or benefiting groups that are responsible for human rights violations.

As a voluntary effort to meet its own ethical sourcing requirements, as well as support the reporting of downstream companies using tantalum concentrate exported by Nikin USA in products. Nikin USA has developed internal programs to ensure proper chain of custody of all materials purchased. These program controls include membership to the industry standard sourcing schema of the ITSCI Programme for Responsible Mineral Supply Chains and alignment with the OECD Guidance. A complete description of the measures taken by Nikin USA, to exercise due diligence on the source and chain of custody of materials purchases is provided within the Nikin USA management procedures and align to the OECD 5 step due diligence guidance.

Nikin USA’s Position Statement:

Nikin USA commits to tracking emerging laws and industry best practices associated with Responsible Minerals Sourcing. As a direct exporter of tantalum concentrates out of the DRC Nikin’s chain of custody process supports industry-wide efforts to identify, reduce and hopefully eliminate the use of conflict minerals originating in the DRC and adjoining countries that are financing or benefiting groups committing human rights violations. In furtherance of this goal, Nikin USA leverages internal controls to support the independent audit of its smelter and refiner customers to verify their materials sources of origin through the delivery of transaction details in accordance with audit standards.

To ensure its smelter and refiner customers meet their requirements to complete the audit process Nikin USA has implemented a due diligence process that aligns with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance).
 

Concentrate suppliers to Nikin USA are expected to establish their own controls process and comply with ITSCI bag and tag standards. Suppliers’ programs to support the bag and tag process should be designed to prevent conflict minerals from being included in the products sold to Nikin USA. In the event Nikin USA determines that a supplier has failed to develop and implement reasonable steps to comply with this policy, Nikin USA reserves the right to take appropriate actions, which may include discontinuing the business relationship with the supplier