SUSTAINABLE SUPPLY CHAIN

In an era where environmental stewardship and social responsibility are paramount, Bulk Trading recognizes the critical importance of a sustainable supply chain. Our commitment to sustainability is not just a business strategy; it is a core value that guides our operations and relationships with our suppliers.
We believe that a sustainable supply chain is essential for long-term success and for contributing positively to the world around us.

Our Supplier Code of Conduct

Building on our “Code of Business Conduct,” our Supplier Code of Conduct is a testament to our alignment with internationally recognized standards and principles related to human rights, labor rights, anti-corruption, and environmental responsibility. This Code is a foundational element of our contractual relationships with suppliers, and we expect all suppliers to adopt practices consistent with it.

We require all our suppliers to sign and adhere to this Code, ensuring it also applies throughout their supply chains. Our business activities are subject to national laws and regulations on environmental protection, product safety, and social welfare. Beyond legal compliance, we formally request that all our suppliers respect the principles of our Supplier Code of Conduct, our group policies/regulations, and all applicable laws and regulations. Commercial transactions can only be entered into with approved counterparties.

Expectations from Suppliers

Bulk Trading expects its suppliers to adhere to the principles of the following internationally recognized standards:

• The eight core conventions of the International Labour Organization (ILO)
• The Ten Principles of the United Nations Global Compact
• The OECD Guidelines for Multinational Enterprises
• The UN Guiding Principles on Business and Human Rights

More specifically, Bulk Trading expects its suppliers to comply with the following obligations:

Working Conditions / Labor

• Child Labor: Suppliers must not use child labor and should follow ILO conventions on the minimum age for employment.
• Compensation and Benefits: Fair wages, working hours, and benefits must be provided, ensuring equal pay for equal work.
• Forced Labor: Any form of forced labor is prohibited; employees must be free to leave employment.
• Freedom of Association: The right to freedom of association and collective bargaining must be respected.
• Safe Working Conditions: Safe and healthy working conditions must be maintained.

Environmental Standards

Suppliers must comply with environmental laws and manage their environmental impacts.

Business Ethics

• Business must be conducted with integrity, avoiding undue advantages.
• Relationships must be impartial, and conflicts of interest must be handled appropriately.
• Financial Transactions must comply with laws, avoiding money laundering or terrorism financing.
• Suppliers must comply with sanctions and export control legislation.
• Fair and free competition must be promoted, avoiding anti-competitive practices.
• Human rights must be respected, ensuring non-discrimination and equal opportunity.
• Reporting Channels: Suppliers must have internal reporting channels to address compliance risks and misconduct.

Supply chain due diligence

Bulk Trading applies a risk-based approach to supplier management. Suppliers must be qualified before they can be approved and added to the Bulk Trading supplier portfolio. During the qualification process, potential risks and opportunities are identified and evaluated. This ensures that suppliers comply with Bulk Trading Supplier Requirements and can consistently provide conforming raw materials, products, or services.

Supply chain complaints

The Bulk Trading Misconduct Reporting Mechanism allows its employees and external stakeholders to report misconduct in our operations or those of our suppliers. Reports can be made confidentially and anonymously, where permitted by local laws and regulations.

Due Diligence and Transparency Report

In compliance with Swiss law, Bulk Trading is proud to present its comprehensive report on due diligence and transparency in relation to minerals and metals from conflict-affected areas and child labor. This report is a testament to our commitment to ethical sourcing and responsible business practices.