Effective Date: July 8, 2025

 

SAGINT, a Delaware corporation with its principal place of business at 750 North State Street, Suite 148, Chicago, IL 60654, United States ("SAGINT," "we," "us," or "our"), is committed to promoting responsible sourcing of minerals within the economic value chains we support through our digital asset infrastructure. This Responsible Mineral Sourcing Policy (the "Policy") outlines our commitment to ethical, transparent, and sustainable practices in the sourcing, trading, and management of minerals, particularly in conflict-affected and high-risk areas. This Policy applies to all activities related to our services, including the operation of digital exchange platforms.

 

1. Commitment to Responsible Sourcing

SAGINT is dedicated to ensuring that minerals traded or managed through our platforms, including critical minerals such as cobalt, lithium, and others, are sourced responsibly. We align our practices with international standards, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areasand applicable local regulations. Our goal is to prevent contributions to conflict, human rights abuses, or environmental harm while fostering transparency and sustainability in mineral supply chains.

 

2. Due Diligence Framework

We implement a robust due diligence framework to ensure responsible mineral sourcing, which includes the following steps:

2.1 Supply Chain Transparency

• We require participants on our digital platforms to provide verifiable information regarding the origin, chain of custody, and sourcing practices of minerals.

• Our platforms leverage blockchain-based technology to maintain immutable records of mineral provenance, ensuring traceability from mine to market.

2.2 Risk Assessment

• We conduct risk assessments to identify potential adverse impacts associated with mineral sourcing, including risks related to conflict, human rights violations, forced labor, child labor, or environmental degradation.

• Risk assessments are performed in accordance with OECD guidelines and incorporate data from credible third-party sources and our proprietary analytics tools.

2.3 Mitigation Measures

• Where risks are identified, we work with platform participants to implement mitigation strategies, such as enhanced supplier due diligence, contractual commitments to ethical practices, or exclusion of non-compliant sources.

• We reserve the right to suspend or terminate access to our platforms for participants who fail to address identified risks.

2.4 Monitoring and Reporting

• We continuously monitor supply chain activities through our digital platforms to ensure ongoing compliance with responsible sourcing standards.

• We provide regular reports to stakeholders, where required, to demonstrate adherence to this Policy and applicable regulations.

 

3. Compliance with Applicable Laws

SAGINT complies with all relevant laws and regulations governing responsible mineral sourcing, including but not limited to:

• The U.S. Dodd-Frank Act Section 1502, addressing conflict minerals (tin, tantalum, tungsten, and gold).

• Local regulations in jurisdictions where our platforms operate, such as the Democratic Republic of Congo’s Capital Markets Authority.

• International sanctions and export control regimes, including those administered by the U.S. Office of Foreign Assets Control (OFAC).

We prohibit the use of our platforms for sourcing minerals from sanctioned jurisdictions or entities listed on restricted party lists.

 

4. Stakeholder Engagement

We engage with stakeholders, including mining companies, regulators, and civil society organizations, to promote responsible sourcing practices. In regions like the DRC, we collaborate with local authorities and self-regulating organizations to ensure fair and equitable trading practices, as exemplified by our support for the Kinshasa Mercantile Exchange.

 

5. Human Rights and Environmental Standards

SAGINT is committed to upholding human rights and environmental sustainability in mineral supply chains. We:

• Prohibit the use of forced labor, child labor, or any form of human rights abuse in sourcing activities facilitated by our platforms.

• Promote environmentally responsible practices, including minimizing ecological harm and supporting sustainable mining initiatives.

• Encourage platform participants to adopt internationally recognized standards, such as the UN Guiding Principles on Business and Human Rights.

 

6. Grievance Mechanism

We provide a mechanism for stakeholders to report concerns related to mineral sourcing practices on our platforms. Reports may be submitted confidentially to legal@sagint.com. We will investigate and address concerns promptly, in accordance with applicable laws and this Policy.

 

7. Training and Awareness

SAGINT provides training to employees and platform participants on responsible mineral sourcing practices. We raise awareness of this Policy through our Website and direct communications to ensure alignment with our ethical standards.

 

8. Continuous Improvement

We regularly review and update this Policy to reflect evolving international standards, regulatory requirements, and industry best practices. Updates will be posted on the Website, and significant changes may be communicated to stakeholders.

 

9. Contact Information

For inquiries or concerns regarding this Policy, please contact:

• General Inquiries: contact@sagint.com

• Legal and Compliance Matters: legal@sagint.com

• Mail: SAGINT, 750 North State Street, Suite 148, Chicago, IL 60654, United States