我们重点关注能源技术，确定了整个非洲最具吸引力的项目。我们的重点是可持续和环保的采矿活动，深深植根于社区的发展，确保世界一流的劳工实践以及健康和安全活动。
Mezzarion 致力于成为非洲各国经济增长和工业化的前沿。
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Human rights: zero tolerance for forced, child, or compulsory labor; no inhumane treatment.
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Anti-corruption: strict compliance with anti-bribery laws; no facilitation payments.
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Conflict-free: proactive identification and mitigation of risks in conflict-affected and high-risk areas (CAHRAs).
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Environment & safety: baseline HSE standards; responsible water, tailings, emissions, and biodiversity practices.
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Traceability: increasing transparency from mine (or asset) to market through documentation and audits.
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Remediation over exit: where safe and feasible, we favor corrective action plans before disengagement.
Our commitments
The 5-step framework we follow (OECD-aligned)
1. Strong management systems
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Responsible Sourcing Policy & Supplier Code of Conduct (issued at onboarding).
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Roles & oversight: ESG Lead (owner), Compliance (KYC/sanctions), Legal (contracts), Ops (site & logistics).
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Secure grievance channels and data handling (GDPR baseline).
2. Identify & assess risks
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Jurisdiction, CAHRA status, UBO & sanctions screening, adverse media, environmental and social red flags.
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Product/asset risks (mine site conditions, tailings, mercury use, ASM conditions, transport routes).
3. Mitigate & manage
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Risk rating (Green / Amber with conditions / Red).
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Corrective Action Plans (CAPs) with clear owners and timelines; increased monitoring where needed.
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Suspend or terminate where risks cannot be mitigated.
4. Independent assurance
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Third-party audits where material (site, warehouse, or documentation).
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Acceptance of credible certifications or recognised schemes where applicable.
5. Report & improve
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Annual program summary (aggregated metrics below).
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Lessons learned feed into contract riders and on-the-ground controls.
Suppliers / Producers
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Legal & ethical: comply with our Supplier Code; no forced/child labor; non-discrimination; freedom of association.
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Traceability: provide mine/asset of origin (where available), chain-of-custody records, transport documents, and inspection/assay history.
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Environment & safety: basic HSE plan; incident log; tailings and waste managed to recognized standards (e.g., GISTM where applicable); mercury phase-out plans for ASM where relevant.
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Disclosure: permits/licenses; community engagement summary; any security provider arrangements (respecting the Voluntary Principles on Security & Human Rights).
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Continuous improvement: agree corrective actions with time-bound milestones.
Buyers
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Compliance: import licenses where required; end-use/end-user declarations on request; adherence to sanctions/export-controls.
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Integrity of payment: use approved instruments or regulated escrow; no side payments; documented fee structures.
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Transparency: allow reasonable verification of final consignee and route, subject to confidentiality.
Intermediaries / Mandates
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Registration: NCNDA + Fee Letter; full payee disclosure.
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Mandate chain: verifiable authority from principals.
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KYC & conduct: pass KYC; no facilitation payments; comply with anti-bribery rules.
Investors / Capital Partners
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Source of funds: SOF/SOW transparency.
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ESG undertakings: accept minimum ESG covenants and incident notification duties.
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Use of proceeds: no funding of prohibited or high-risk activities without agreed mitigations.
What we expect from counterparties
ASM
(Artisanal & Small-scale Mining): our approach
We support responsible ASM participation where lawful:
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Minimum entry bar: no child/forced labor; basic PPE and safety; no protected-area infringement.
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Progressive plan: simple, time-bound CAP covering safety, environmental controls (incl. mercury), legal formalisation, and traceability steps.
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Market access: we use smaller pilot lots with enhanced monitoring, escrowed payments, and independent inspection to de-risk early engagement.
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Identity & ownership: company registry, UBO declaration (≥10–25%), IDs for controllers.
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Licenses & permits: mining/processing/export permits; environmental approvals where applicable.
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Operations: site coordinates, production capacity, tailings/waste management summary, HSE plan.
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Traceability & quality: chain-of-custody (transport docs, warehouse receipts), assays/CoA, lab details.
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Community & security: summary of social engagement; use of public/private security and incident logs.
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Assurance: recent audits or certifications (if any) and CAP status.
(We collect the minimum necessary and store it securely; see Privacy below.)
Due diligence & documentation
(what we collect)
Red flags (examples)
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CAHRA exposure with missing or falsified permits; security abuses.
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Refusal to disclose UBOs or site origin; unverifiable warehouse or lab.
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Child labor indicators; forced labor; severe OHS violations.
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Bribery requests; side-payment demands; undisclosed intermediaries.
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Tailings instability, toxic discharges, or banned substances (e.g., mercury where prohibited).
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Sanctions hits or export-control circumvention.
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If a red flag is identified: we open a case, apply the risk matrix, and either (a) implement a CAP with timelines and extra monitoring, or (b) suspend/exit where mitigation is not credible.
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Mandatory clauses: human rights, ABC, sanctions & export-controls, modern slavery, ESG, data privacy, audit rights, and termination for cause.
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Quality & inspection: independent labs; chain-of-custody; documented re-test & dispute process.
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Fees & commissions: disclosed waterfall via regulated escrow only.
Contracts & enforcement
Grievance & whistleblowing (open to all)
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If you see or experience misconduct linked to our value chain, tell us. We accept anonymous reports where lawful.
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Email: [info@mezzarion.com]
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Subject: “Responsible Sourcing Concern — [optional reference]”
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What to include: who/what/where/when; any evidence; your safety considerations.
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We acknowledge within 5 business days, triage within 10, and keep you updated where it’s safe and lawful to do so. Retaliation against good-faith reporters is prohibited.
We operate a GDPR-grade baseline globally:
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Lawful basis: contract and legitimate interests for due diligence.
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Minimum-necessary collection; encrypted storage; role-based access.
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Typical retention: KYC (10y), contracts (10y), compliance logs (5y) unless law requires longer.
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Contact our DPO: [info@mezzarion.com], subject: Privacy concern.
Data privacy & security
Program metrics (what we track and publish annually)
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% of active suppliers with completed KYC & sanctions screen
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% traceable to mine/asset of origin (or to recognized choke points)
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material red-flag cases opened / closed; median time-to-closure
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audits completed and CAPs verified
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% ASM engagements with active improvement plans
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Material incidents and remedial actions (aggregated)
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Customer Engagement: see our 12-step journey and SLAs (Welcome → KYC → Terming → Execution).
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Payment Instruments: instruments we accept (UCP/URDG/ISBP) and how we validate drafts.
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Policies: Privacy, ABC, Sanctions, Modern Slavery, and Terms.
How this connects to the rest of our process
*Legal Notice
This page summarises our responsible sourcing program. It is not legal advice. Binding obligations are defined in executed agreements and incorporated policy riders.