About Us

Our Commitment to Responsible Commodities Trading

Traxys is committed to the highest internationally recognized principles for responsible business conduct, and to ensuring that our operations are equitable, sustainable, and transparent. Our environmental, social, and governance (ESG) practices enable us to set a leading example for the responsible sourcing and trading of metals and minerals. In 2019, Ecovadis, a responsible business-rating surveyor, awarded Traxys a Silver Medal for overall sustainable business practices.

Environmental Commitments

Environmental protection and sustainability are cornerstones of our ESG policies, and these cornerstones are given careful consideration throughout all aspects of our operations and supply chain. We work with our suppliers and sourcing partners to ensure that the resources we trade are developed in an environmentally sustainable manner.

Traxys recognizes the importance of meeting the United Nations’ Sustainable Development Goals, in particular those that pertain to environmental protection and resource conservation. Traxys also aims to conduct its operations in accordance with the principles for corporate environmental sustainability articulated in the U.N. Global Compact. Additionally, Traxys adheres to all applicable environmental laws and regulations where the company operates.

With respect to our offices and facilities, Traxys participates in on-site recycling; designs its occupied space to minimize waste, energy, and water use; and imposes strict controls on air and water quality. Traxys’ headquarters in Luxembourg is in a High Quality Environment-certified “green” building that functions on an efficient low-energy concept. This includes rainwater recovery, optimizing natural lighting, and photovoltaic panel-covered roofs.

Social & Human Rights Commitments

Traxys adheres to the U.N. Guiding Principles on Business and Human Rights with respect to our projects, supply chain, and partnerships.

In accordance with our Conflict Minerals and Responsible Sourcing Statement, Traxys is dedicated to sourcing metals and minerals in a transparent, ethical, and responsible manner. To establish a baseline for traceability, Traxys follows the Organization for Economic Cooperation and Development’s (OECD) due diligence guidance for responsible supply chains of minerals from conflict-affected and high-risk areas. Following these guidelines allows us to provide assurances to those of our customers and end- users that are publicly-traded companies, and therefore legally required to adhere to the conflict minerals provision in the U.S. Dodd-Frank Act.

Traxys adheres to the guidelines established by various professional trade organizations, including the International Tin Research Institute (ITRI); iTSCi, a responsible supply chain initiative of ITRI; and the

Conflict-Free Tin Initiative. Traxys also subscribes to voluntary protocols in effect for the ethical sourcing of cobalt and other metals and minerals in high-risk regions.

Traxys expects that public and private security forces protecting the assets and facilities from which we source will operate in a manner consistent with the Voluntary Principles on Security and Human Rights.

Traxys has a zero-tolerance policy regarding forced labor of all kinds, including child labor and modern slavery, and uses a variety of mechanisms to eliminate these practices from our supply chains. To this end, Traxys encourages our partners to collaborate with government authorities, civil society, and local communities to formalize the artisanal and small-scale mining sector and prevent practices that contribute to modern slavery.

We respect the fundamental rights of workers who are involved in the extraction of the resources we trade. Traxys recognizes the Conventions of the International Labour Organization (ILO) as well as the ILO Forced Labour Protocol. As part of these commitments, our ESG policies establish the highest standards for employee health and safety, including anti-retaliation, anti-harassment and anti- discrimination protections, as well as equal opportunity employment with a focus on achieving greater diversity, racial equity, and inclusion. We apply these standards to our employees, and expect our suppliers and sourcing partners to apply them as well.

Traxys understands the importance of securing a social license from the local communities in which we operate. We seek to operate our facilities and develop and trade resources in ways that empower and benefit impacted communities. To advance these goals, we collaborate with our partners on a range of social development initiative, such as job skill building, access to fresh water, improved infrastructure in areas where Traxys operates or its supply chain originates, and poverty alleviation. In addition, we recognize the special rights and considerations that must be taken into account when engaging with Indigenous Peoples.

Governance Commitments

Traxys’ Code of Conduct and ESG policies commit us to sourcing and operating with integrity, in line with sound and ethical business practices, while building and maintaining trust relationships with our employees, commercial partners, shareholders, government authorities, and communities. We know that acting with integrity in all aspects of our operations determines our reputation, financial strength, and public confidence in the company’s activities. We also know it is the right thing to do.

Our Code of Conduct requires persons acting on behalf of Traxys to perform their activities ethically and in compliance with all applicable laws and regulations where we operate. The Code of Conduct also protects these personnel from retaliation for reporting violations of company policy and local laws.

In accordance with our Code of Conduct and our Anti-Bribery Policy, Traxys makes every effort to prevent corruption and bribery, in accordance with the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and other applicable anti-corruption laws and regulations. Our policies are designed to promote fair and honest business practices, and require that any actual or potential conflicts of interest be disclosed and properly addressed.

March 2021