Supply Chain Strategy

We strive to maintain a sustainable supply chain that conforms to the highest environmental and social standards and hold ourselves accountable via high ethical expectations and robust compliance. 

Our Supplier Code of Conduct sets out our expectation that SGH suppliers will engage in ethical business practices and remain in compliance with applicable laws and regulations. All suppliers must meet the requirements of our SGH Supplier Code of Conduct before we conduct business with them.

Human Rights In Our Supply Chain

Our commitment to human rights is central to the way we conduct business. We take our responsibility to preserve human rights seriously and do not allow any form of forced labor, child labor, or bonded labor. 

This commitment is highlighted in our Human and Workforce Labor Rights Policy, which was developed in line with the RBA Code of Conduct and several international principles, including the UN Universal Declaration of Human Rights, the ILO Standards and Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, the UN General Comment No. 15 on the right to water, and ISO standards.

Conflict Minerals

We remain committed to the responsible and ethical sourcing of raw materials used in our products and stand in staunch opposition to corruption and human rights violations in every form. Our Conflict Mineral Policy outlines our sourcing strategy for minerals such as tin, tantalum, tungsten, and gold (3TG), and other precious minerals from the Democratic Republic of Congo and neighboring countries. This policy aims to ensure that our products are both safe, made from ethically sourced materials, and that funds from materials purchased by SGH are not used to support instances of bribery, child labor, forced labor, extortion, and/or armed conflict in regions most affected by those risks.

As a member of the RBA’s Responsible Mining Initiative (RMI), we support due diligence and reporting processes that increase supply chain transparency and validate the components of our products as “conflict-free”. Because we do not directly source minerals from smelters and are often several degrees removed from interactions with smelters and refiners, we rely on input from our upstream partners to accurately inform us of risks identified, mitigation activities, and potential concerns related to minerals sourcing.

We encourage our suppliers to become members of the RMI and require that they complete the RMI’s Conflict Minerals Reporting Template each year. We expect both direct and indirect suppliers of 3TG materials to be in compliance with the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. In order to strengthen our due diligence and risk mitigation activities, we also leverage third-party software to screen suppliers for risks related to human rights abuses, ethical violations, and other concerns.

Resources:

Anti-Corruption Policy Code of Business Conduct and Ethics Conflict Mineral Policy Human and Workforce Labor Rights RBA Member Commitment Supplier Code of Conduct UK Modern Anti-Slavery Act Whistleblower Policy