CODE OF CONDUCT
RESPONSIBILITY &
ACCOUNTABILITY
Standards
Hambrox Ltd is fully committed to operating with probity in all aspects of its business. The company adheres to the highest ethical standards and complies with all the requisite rules, regulations and laws within all the jurisdictions it operates in and treats all parties with respect and dignity in conducting its business.
Hambrox Ltd carries out all the necessary due diligence in a professional manner on all counterparties to ensure a responsible supply chain management. The company only works with counterparties who agree with its philosophy of transparency, fairness, integrity and mutual respect.
Hambrox Ltd only partners with entities who are committed to maintaining and complying with the highest international standards of employment and safety of their operations to ensure the protection and wellbeing of all their workers and employees. We actively promote good practices among its working partners to minimise the impacts on the environment without affecting the efficient operation of their businesses.
Core Principles
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Honest Communication: Communicate professionally and in good faith, avoiding false urgency or pressure tactics.
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Anti-Corruption: Maintain a strict zero-tolerance policy for bribery, fraud, and kickbacks.
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Conflict Disclosure: Disclose all relationships with buyers, sellers, or government officials that influence transactions.
Compliance & Due Diligence
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Know Your Customer (KYC): Perform continuous, risk-based due diligence on all counterparties.
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Conflict Minerals: Verify that sourced materials (like tin, tantalum, tungsten, or gold) are free from conflict-linked financing or human rights abuses.
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Regulatory Adherence: Comply with local and international trade laws, anti-money laundering (AML) protocols, and market sanctions.
Generally Accepted Industry Norms
Hambrox Ltd ensures that all suppliers adhere to the generally accepted industry norms relating to the responsible supply chain and transparency protocols for the supply of conflict free minerals and adherence to international labour standards as stipulated by the OECD and the United Nations.
Conflict Affected & High Risk Areas (CAHRA)
Hambrox Ltd exercises extreme caution with regards to the provenance of minerals, such as the 3TG and Cobalt, that are sourced predominantly from high risk areas affected by conflicts (CAHRA). Hambrox Ltd ensures that all entities engaged in the supply chain are fully vetted, properly regulated and licensed and are subject to regular independent third party international audit compliance such as ITSCI and the Responsible Minerals Initiative (RMI).
Responsible Minerals Initiative (RMI)
The Responsible Minerals Initiative (RMI) is one of the world’s largest industry associations focused on advancing responsible mineral sourcing across global supply chains. The RMI supports comprehensive due diligence ecosystem through leading standards for smelters, refiners and recyclers, data, and collaborative actions across minerals supply chains. The RMI serves as a bridge between upstream and downstream companies, facilitating accountability and transparency through third-party assessments, facility data, and reporting on minerals due diligence.
ITSCI
The ITSCI Programme is a traceability and due diligence initiative for the tin, tantalum, and tungsten (3T) minerals. As a facilitation initiative fully aligned with the OECD Guidance, they support companies with their due diligence responsibilities. ITSCI implements a bagging and tagging system at mining sites to track mineral origin from mine to export, and includes an incident reporting system to identify and address human rights and security incidents. ITSCI membership is widely used by smelters as evidence of responsible upstream sourcing for RMAP audits.
Sustainability & the Environment
Sustainability is the process of maintaining change in a balanced environment in which the exploitation of resources is managed so as not to hinder progress and development.
The natural increase in demands for commodities all around the world is putting serious strain on the ecological balance of our planet. Improved resource efficiency together with business model innovation are needed to achieve sustainable economic development. All stakeholders face new challenges in the face of increased global awareness about climate change and sustainability.
Hambrox Ltd is a strong proponent of ethical business practices to redress the balance between the big multinational corporations and the SMEs all around the world to create a more level playing field for all. We encourage the adoption of fairer trading rules amongst all parties to empower a wider community of producers, buyers, traders and consumers to contribute towards a more sustainable circular global economy.
Hambrox Ltd promotes the UN and OECD Sustainable Development Goals (SDGs) 2030 programme and the Environmental, Social and Governance (ESG) initiative.
Sustainable Development Goals (SDGs) 2030
The 2030 Agenda for Sustainable Development is a UN initiative supported by the OECD. It is a universal blueprint adopted by UN member states in 2015 featuring 17 goals and 169 targets to end poverty, fight inequality and protect the planet by 2030.
This is a very ambitious programme with specific targets and objectives. The Organisation for Economic Co-operation and Development (OECD) acts as a supporting partner to help countries implement the agenda, using unique data methodologies to track how close advanced economies are to reaching these global targets
Environmental, Social & Governance (ESG)
The OECD Environmental, Social and Governance (ESG) initiative consists of policy guidance and analytical assessments designed to improve the consistency, comparability and transparency of environmental, social and governance metrics and ratings globally.
The initiative encompasses a suite of policy frameworks, guidance reports and alignment tools designed to transition ESG from niche investing into mainstream, reliable corporate and financial practices.