Sourcing Policy

SJM Alloys & Metals Limited is a UK company engaged in the recycling and processing of primary metals (including Cobalt metal) , special and super alloys, high speed steels , special steels and refractory metals. We handle secondary raw material (scrap), recycled products made from scrap and pure metals from approved RMI (Responsible Minerals Initiative) and CFSP smelters (Conflict Free Smelter Program).

Our company does not trade in or process minerals or ores and is not involved in materials subject to Class 7 ( Radioactive) Transportation Regulations.

SJM does handle Tungsten and Tantalum in metallic alloyed (scrap) condition as well as primary metal form. We do not handle (currently) Tin or Gold.

We condemn the unlawful exploitation of mineral resources , and support the goal of ending violence , human rights violations and environmental devastation in the Democratic Republic of Congo (DRC).

SJM is committed to supporting a conflict free, not Congo free supply chain. Officially this policy applies to 3TG (Tantalum, Tin, Tungsten and Gold) and does not directly reference Cobalt, however we support responsible sourcing of cobalt metal from suppliers who can demonstrate their sources of materials do not directly or indirectly benefit or finance armed groups, nor are their sources of supply associated with human rights abuses such as forced or child labour. In this regard we select suppliers who demonstrate that the brand (source) of the cobalt metal offered would meet this criteria.

SJM conducts its business in compliance with applicable legislation and is strongly committed to respecting human rights and to combating child labour throughout the supply chain.

The selection of our supplier partners is based heavily upon the approach of the producer (source) in establishing common good practices in sourcing and managing their supply chains responsibly and in the evaluation of feed materials and how and from where they are sourced.

Responsible procurement of cobalt

Once of the most widely recognised international standards for responsible mining is OECD due diligence for supply of minerals in conflict and high risk areas. It puts emphasis on due diligence as a process to ensure a company’s supply chain respects human rights and does not contribute to conflicts/ finance arms purchases. Based on the guidelines of the OECD, SJM suppliers shall specifically:

  • Develop an appropriate management system to conduct due diligence in the supply-chain to determine whether cobalt originates from conflict-affected or high-risk areas.

  • Develop due diligence policies and require tier-one suppliers to (i) adopt corresponding due diligence policies and (ii) request the same from their suppliers down to the level of extraction of cobalt.

  • Identify the risks by mapping the supply-chain and take appropriate steps to mitigate them.

SJM’s due diligence for Conflict Minerals follows the OECD guidelines and seeks to further the Guidance’s objectives, including taking steps to identify and assess risk in the supply chain and make continued efforts to source only traceably conflict-free minerals and to prevent from sourcing minerals extracted or produced with unlawful child or forced labour or other human rights abuses and unethical practices.

SJM acknowledges the “Conflict Minerals Rule” issued by the U.S. Securities and Exchange Commission (S.E.C) issued under section 1502 of the 2012 Dodd Frank Wall Street Reform and Consumer Protection Act and we are committed to assisting our suppliers with their due diligence and disclosure requirements necessary to comply with legislation.