Conflict minerals and child labour

For Phoenix Mecano, social commitment is an integral part of sustainable and responsible business.

Phoenix Mecano’s Code of Conduct explicitly requires compliance with human rights. This includes, in particular, the core labour standards of the International Labour Organization (ILO) and the United Nations Conventions on the Rights of the Child and on Human Rights.

Phoenix Mecano is subject to the reporting obligation on non-financial matters under Article 964bis of the Swiss Code of Obligations. It already implemented these requirements for the 2021 financial year and communicated on non-financial matters in its sustainability report.

In addition to non-financial reporting, the regulation introduces a due diligence and reporting obligation in the areas of “conflict minerals” and “child labour”.

The scope of application includes companies that either import minerals (ores and concentrates) or metals containing tin, tantalum, tungsten or gold (3TG) from conflict-affected or high-risk areas or process them in Switzerland, or offer products/services – including worldwide – in relation to which there is a reasonable suspicion that they have been manufactured or provided using child labour.

The scope of application includes companies that

• import minerals (ores and concentrates) or
• metals containing tin, tantalum, tungsten or gold (3TG)

from conflict-affected or high-risk areas, or

• process them in Switzerland, or

offer products/services – including worldwide – in relation to which there is a reasonable suspicion that they have been manufactured or provided using child labour.

Phoenix Mecano complies with the legal requirements and is exempt from the due diligence obligations due to the low quantities of 3TG imported and processed in Switzerland. Nevertheless, Phoenix Mecano requests information on smelters/refiners from its 3TG suppliers worldwide. Suppliers complete the Conflict Minerals Reporting Template provided by the Responsible Minerals Initiative (RMI) and Phoenix Mecano checks whether the smelters are RMI-compliant. This was the case for all reported smelters in the reporting year.

With regard to child labour, an annual review is carried out to determine whether there is any evidence of child labour in the companies themselves or at their suppliers. No cases of actual or suspected child labour were reported for the reporting year.

A digital whistleblower system has been set up to provide a point of contact for reporting suspicions during the year.