Responsible Sourcing of Raw Materials Policy

1. Purpose and scope

ADOZ, s.r.o. (“the Company”) is committed to the sustainable and ethical procurement of the raw materials contained in its products. This policy applies to the purchase of materials, components and goods for all products the Company manufactures or supplies – in particular CNC machined and welded parts, bearings and other distributed components. It supplements section 7 of the Company's Code of Conduct and is binding for all employees involved in purchasing and for the Company's suppliers.

2. Raw materials covered

  • Raw materials contained in our products: steel/iron, aluminium/bauxite, copper, zinc, nickel and chromium.
  • Conflict minerals and other high-risk raw materials, wherever contained in purchased goods: tin, tantalum, tungsten and gold (3TG), cobalt and mica.

3. Our commitments

  • We do not tolerate, and do not knowingly contribute to, human rights abuses (including child labour, forced labour and human trafficking), bribery and ethics violations, or serious negative impacts on the environment and local communities in raw material supply chains.
  • We carry out due diligence in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the OECD Due Diligence Guidance for Responsible Business Conduct.
  • For goods containing tin, tantalum, tungsten or gold, we request from the relevant suppliers a Conflict Minerals Reporting Template (CMRT) or an equivalent conflict minerals statement; for cobalt and mica, an Extended Minerals Reporting Template (EMRT). We expect our suppliers to source these minerals from smelters and refiners validated as conformant (e.g. under the RMI Responsible Minerals Assurance Process).
  • We give preference to suppliers that can demonstrate responsible sourcing, certified management systems and, where available, recycled content.

4. Requirements for suppliers

  • comply with the ADOZ Code of Conduct and this policy and pass these requirements on to their own suppliers as binding requirements;
  • on request, disclose the origin of raw materials (country, smelter/refiner or producer) and provide material declarations (e.g. CMRT/EMRT, REACH/RoHS);
  • inform the Company without delay of any known risk or violation in their raw material supply chain.

5. Due diligence process

  • Identify: map our main suppliers and the raw materials contained in the goods we buy (supply chain mapping).
  • Assess: evaluate risks annually by country of origin, commodity and supplier, using the supplier self-assessment questionnaire and supplier declarations.
  • Respond: agree corrective actions with suppliers where risks or violations are identified; in case of serious violations that are not remedied, the Company may terminate the cooperation.
  • Review: review the results and this policy at least once a year as part of the management review of the integrated management system.

6. Responsibilities

The Managing Director has overall responsibility for this policy. Purchasing implements it in supplier selection and communication. The Human Rights Officer monitors human rights risks and reports to the Managing Director at least once a year; the EHS Manager is responsible for environmental aspects.

7. Grievance mechanism

Concerns related to raw material sourcing can be reported by employees, suppliers and any other affected persons, also anonymously, via the Company's whistleblowing channel (adoz.wb@adoz.cz, +420 771 161 589) in accordance with section 8 of the Code of Conduct. Retaliation is prohibited.