No conflict minerals policy found, but this section is in the company's sustainability report p.24 "Polyus recognises that revenue transparency is important in order to ensuring countries and communities have well-functioning economies, good governance, and develop sustainably. As an ICMM member, Polyus is committed to the transparent disclosure of mineral revenues in our sustainability report and on the Company’s website (for details see http://polyus.com/en/investors/ disclosure/) and supports the Extractive Industries Transparency Initiative (EITI) (for details see https://eiti.org/supporter/polyus). The EITI is a coalition of governments, companies, civil society groups, institutional investors, and international investors that seek to improve governance and establish a global standard for monitoring and reconciling tax revenues paid by oil, gas, and mining companies. The ICMM supports the EITI and the EITI Principles (established in 2003), which form the cornerstone of the initiative (https://eiti.org/standard/principles). As a supporting company, Polyus takes steps to disclose all pertinent information relating to payments and taxes to the government, engages in rigorous procurement processes, and ensures that the Company’s processes are sufficient to provide the level of information required to deliver high standards of accountability."