Conflict Materials

Reach Policy

ASG Group Conflict Minerals Statement, Human rights, fair working conditions, environmental protection and the battle against corruption – these are values that we hold high within our Group and throughout our supply chain. We at ASG Group are committed to the United Nations Global Compact. Acting responsibly is firmly integrated in our procurement processes. When awarding contracts, our decisions are not only based on economic, technological and process criteria. Sustainability also plays a key role in the supplier management of ASG Group.

Moreover, we continuously develop our processes. This also means, for example, that we want to further increase transparency regarding the origin of raw materials and so-called conflict minerals to detect risks early. Compliance with due diligence obligations in the supply chain of tin The mining of certain minerals in the Democratic Republic of Congo (DRC) and other parts of the world partially contributes to significant human rights violations and to the financing of violent conflicts.

Within the European Union, importers of so-called conflict minerals are now subject to extensive obligations regarding due diligence and inspections across the supply chain in order to curb the financing of violence and human rights violations in areas of conflict or high-risks. The implementing law for EU regulation 2017/821 of 7 May 2020 has been in force in Germany since 1 January 2021. This affects our company because we are Union importers of tin. Already years ago, we established procedures in our company to review supply chains and identify risks.

Our supply chains are transparent and are subject to regular audits, so we fully comply with the legal requirements. Dodd-Frank Act on Conflict Minerals Since 2010, ASG Group Rasselstein has been complying with the regulations of the United States of America that is usually referred to as Dodd-Frank Act (full name: “Dodd[1]Frank Wall Street Reform and Consumer Protection Act”). Section 1502 of the Dodd-Frank Act adopted by the U.S. Securities and Exchange Commission (SEC) requires companies who file reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals” that are “necessary to the functionality or production” of those products. “Conflict minerals” contain tantalum, tin, tungsten (and the ores from which they originate) and gold, regardless of where they are sourced, processed or sold.

ASG Group (including all its subsidiary companies) does not file reports with the SEC and therefore has no legislative obligations to comply with the conflict minerals requirements covered in Section 1502 of the Dodd-Frank Act. At the same time we recognize that the SEC final rule for Section 1502 mandates our direct and indirect customers to undertake due diligence across their global supply chains. Steel Packaging Steel February 2022 Page 1/2 February 2022 Page 2/2 Statement We at ASG Group Rasselstein endeavor not to purchase any material that contains these “conflict minerals” which directly or indirectly finance or benefit armed groups. To this end, we have implemented appropriate processes to understand where “conflict minerals” are being used in our products and to determine the source and the origin within our supply chain. These actions are based on established frameworks of the Organization for Economic Cooperation and Development (OECD) and from other private sector initiatives.

We are contacting our direct suppliers to increase the transparency of the materials they provide to ASG Group. We personally conduct inspections on site, or commission third parties to regularly check the situation at our suppliers. We will continue to work closely with customers, suppliers and other stakeholders to secure good approaches and feasible solutions. Slavery and Human Trafficking Statement ASG Group is a signatory to the United Nations Global Compact and supports the United Nations Universal Declaration of Human Rights and the core labor standards of the International Labor Organisation (ILO).

ASG Group Group is committed to eradicate slavery and human trafficking in its supply chain and own operations. Our efforts to achieve this are described in the “Slavery and Human Trafficking Statement for ASG Group and its Subsidiaries”, which is made pursuant to section 54 of the United Kingdom Modern.

Revised September 2024