Question: Has the company established a system to accurately review the information they gathered in Step 1?
Answer:
Yes
7974393
2018
Unverified - Added by Steward
"a. Identification of CAHRAs: Refer to www.knowyourcountry.com as well as countryspecific government and industry websites i. Absence of Government controls / formalized laws and regulatory structure for the Tantalum mining industry in the Country ii. Absence of Government Controls / formalized laws and regulatory structure for Corporate Governance in the Country iii. Presence of illegal armed conflicts / human rights abuses having ties to the Tantalum mining industry in the Country iv. Control/ influence of any illegal, armed militia or selfproclaimed authoritarian group on any part of the Tantalum mining industry in that Country which challenges the authority of the Government / Judiciary of that Country b. Know Your Counterpart: Supplier corporate information and business permissions reviewed and EU Sanction / OFAC Lists referred as per our Know Your Supplier Policy d. Identification of Red Flags No Red Flags were identified during this reporting period. The following points were taken into consideration: i. Plausibility ii. Common border with a CAHRA iii. Transportation via a CAHRA iv. Third Party / Cash payments" p. 3