1. Company information

The company is called WEEECycling SAS.
The company was established in 2019 with subsidiaries WEEERefining established in 2019 respectively. The company’s CID number is 848 958 591 registered in Le Havre, France. The company has one smelting and refining facility called WEEERefining, located at 13 Route des Ifs, 76400 Tourville les Ifs, France. The smelting/Refining facility is processing precious metals products (Gold, Silver, Copper, Platinoids). 0% of the precious metals processed by WEEECycling originate from mining, 100% originate from WEEE (Waste from Electrical and Electronic Equipment).

2. RMAP Assessment Summary (ALL SOURCES) 

In line with our commitment to responsible sourcing, WEEECycling is currently in the process of preparing for the RMI’s RMAP assessment for gold. This assessment had been delayed but we are expecting to be added to the RMI’s RMAP conformant smelter list in early 2022, following the assessment of our operations scheduled for June, 2022. The assessment period would cover June 28-30.

3. Company Supply Chain Policy

To avoid the use of conflict minerals, which directly or indirectly finance or benefit armed groups and/or involve other serious human right abuses in high-risk and conflict-affected regions, the company has developed a supply chain policy. 0% of the precious metals processed by WEEECycling originate from mining, 100% originate from WEEE (Waste from Electrical and Electronic Equipment). The supply chain policy is fully aligned with the third edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). The company is committed to addressing any Annex II risks if identified. The policy was reviewed and approved by senior management, which committed to support its implementation. The policy is available on the company website www.weeecycling.com.

4. Company Management Systems

An internal management system is implemented to establish the requirements needed to support supply chain due diligence at WEEECycling. The management system includes guidelines, processes and standardised forms for risk identification, client acceptance, monitoring of suppliers and controlling of incoming materials. In addition, the internal management system defines governance roles and responsibilities, internal audit, trainings, communications and annual group internal compliance report for WEEECycling. The Compliance officer has been assigned to manage and monitor supply chain due diligence at WEEECycling. The Compliance officer reports directly to the managing partner. WEEECycling aims to achieve continuous improvement through the management system and its processes.
WEEECycling has a precious metal receiving process. Precious metals bearing materials delivered for refining, must be accompanied by a completed form called “Annex 7” or “Bordereau de suivi des déchets” or the FID/ Waste Identification Form. The form is filled out by the supplier, the form requires the supplier to include the supplier’s name, address, date of delivery, weight of material delivered, the type of material, the material composition (expected) and the material’s origin. The information provided is reviewed for consistency. The specific lot is given a unique reference number and the information is entered in the ERP-System. The supplier receives confirmation of receipt, which shows the unique reference number for the specific lot. This number is used for any communication concerning the lot.
The Compliance Officer provides KYC to staff members who are involved in supply chain matters. 0% of the precious metals processed by WEEECycling originate from mining, 100% originate from WEEE (Waste from Electrical and Electronic Equipment).
The WEEECycling Supply Chain Policy names a functional E-mail-Address (Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.) of the Compliance Officer for internal and external stakeholders to contact for any reason related to supply chain due diligence. During the annual trainings, employees are encouraged and trained to participate in the risk identification and management systems as well as communicating potential and actual risks internally to the Compliance Officer.

5. Risk identification

Recycled precious metals material and precious metal by-products coming from WEEE (Waste from Electrical and Electronic Equipment) are our key business. Since WEEECycling only recycle precious metals, material coming from WEEE, the company is not subject to the usual risks smelters and refiners face while recycling precious metals material coming from mining (CAHRAs…). The other potential risks are identified by WEEECycling during client on-boarding and during the monitoring of suppliers and material.
WEEECycling monitors incoming transactions as well as the precious metals suppliers. WEEECycling uses a specific form as explained in Step 4 for the delivery of precious metals containing material.
WEEECycling has implemented a Grievance Mechanism. The purpose of this process is to encourage members, stakeholders, public or any other person to raise concerns or to provide information regarding any part of the supply chain.

SERGE KIMBEL
WEEECYCLING - CEO

Revision 1 - 05/10/2021

WEEECycling is a French recycling precious metals and production company. The Group is certified ISO 9001, ISO 14001 and WEEELABEX.

Our fully-owned subsidiary WEEERefining is specialized in refining Gold, Silver, Palladium, Platinum, Ruthenium and Copper and produce by-products containing those metals. WEEECycling has adopted a guideline which is consistent with the OECD Due Diligence Guidance.

Our objective is to ensure that all the precious metals we process come from waste resources and not mines, in order that we do source from legal, ethical sources and are not associated with crime, armed conflict or human right abuses.

Our main objective is to provide Industries with ethical and ecological metals and to offer circular economy loops for precious metals, in their production.

We implement our Supply Chain Due Diligence Policy for the responsible sourcing of precious metals to demonstrate that appropriate and ongoing due diligence has been followed.

We do not source our materials from mines and from conflict-affected or high-risk areas. We define “conflict-affected” and “high risk” areas according to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risks Areas.

We are aware that the control and monitoring of suppliers is a key activity to ensure sustainability, especially in the refining and trading business.

We undertake to conduct business in an honest manner to maintain high moral, ethical and social standards;

We will never tolerate or assist in:

• Torture or cruel, inhuman and degrading treatment
• Corruption or any other illegal activities
• Human rights violations and abuses
• War crimes or the violation of international humanitarian law
• Child labour or any other form of forced labour

We will not engage with-and will immediately stop any potential or upcoming engagement with-customers, suppliers or public or private security forces whenever we identify a link to or participation in any of the forms of abuse defined above.

We will not conceal or disguise the origin of our precious metals, or misrepresent taxes, fees and royalties paid for the purpose of the mining, trade, handling, transport and export of precious metals.

We will support efforts for-and contribute to-the prevention of money laundering and the financing of terrorism whenever we identify a reasonable risk of money laundering and the financing of terrorism resulting from or connected to the extraction, trade, handling, transport and export of precious metals.

The compliance is integrated in the management systems and thus serve to reduce the entrepreneurial risk. The management systems ensure that processes are documented and regularly trained and evaluated in internal and external audits.

Serge Kimbel

WEEECycling - CEO