LuNa Responsible Supply Chain of Minerals

Recognising that risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognising that LuNa Smelter Ltd. have the responsibility to respect human rights and not contribute to conflict, commits to the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas. LuNa commits to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

 

LuNa Smelter is the full official member of ITSCI and intends to implement a risk – based audit program for smelters in the Responsible Minerals Assurance Process (RMAP, formerly Conflict – Free Smelter Program, or CFSP).

Go to our supply chain management policy

Please see our annual due diligence report

In accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas regarding Responsible Supply Chain of Minerals LuNa will manage its procurement processes to:

  • eliminate, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain;
  • recognise that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade;
  • commit that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights, in particular, to support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired;
  • support efforts, or take steps, to engage with local authorities, international organisations and civil society organisations to avoid or minimise the exposure of vulnerable groups (artisanal miners) to adverse impacts associated with the presence of security forces on mine sites.

LuNa is encouraging its suppliers to:

  • establish, where practicable, long-term relationships as opposed to short-term or one-off contracts in order to build strong and constructive cooperation;
  • communicate their expectations on responsible supply chains of minerals from conflict-affected and high-risk areas, and incorporating LuNa’s supply chain policy and due diligence measures into commercial contracts and/or written agreements;
  • consider ways to support and build capabilities of suppliers’ to improve performance and conform to company supply chain policy;
  • design measurable improvement plans with suppliers’ involvement, if relevant and where appropriate, of local and central governments, international organizations and civil society when pursuing risk mitigation;
  • cooperate with organizations such as the Organization for Economic Cooperation and Development (OECD), International Tin Research Institute (ITRI), International Conference on the Great Lakes Region (ICGLR), Responsible Minerals Assurance Process (RMAP) and other relevant organizations to put in place credible and effective processes what seeks to ensure that only conflict-free minerals enter the LUNA Smelter mineral supply chain.

LuNa Smelter will work with its suppliers to seek remedies for non-compliance with this policy. These remedies may include suspension or discontinuing engagement with the supplier.

Violations or breaches of this policy should be reported by any interested party through LuNa Grievance Mechanism.

Grievance Policy

LuNa Smelter ltd. is committed to conducting business in accordance with the law and the highest ethical standards. In line with our Code of Business of Conduct, the implementation of Grievance Policy further supports the following principles:

  • We ensure that grievances and complaints will be addressed in a timely, transparent, accessible and equitable manner.
  • We ensure fair and objective investigation of founded grievances and complaints, based on facts or reliable evidence.
  • We will make every effort to ensure that the whistleblower and all interested parties will be protected against any reprisal, discrimination or other adverse employment consequences – excluding compliance to law and disciplinary rules.
  • All interested parties are encouraged to voice concerns to LuNa regarding misconduct, wrongdoing or any identified risk within our supply chain at the earliest opportunity with a view to them being fully investigated by the appropriate authority.
LuNa Grievance Mechanism
1. Website

To register a new concern, please follow the link: Register Concern

2. e-Mail

Please send an email to the following address: 
grievance@lunasmelter.com

3. Telephone Exchange

A professional can be contacted directly from Monday to Friday from 8:30 am to 6:30 pm at the following number: +250 783 445 300

4. Post

Paper disclosures may be posted to LuNa HR Department Manager: 
Karuruma, Jabana, Gasabo
Po. Box. 1011 – Kigali, RWANDA