Direct sourcing · NDPE compliance · KYC · Sanctions screening. Minimum standards of conduct for all producers, processors, carriers and business partners supplying Ahmia Co.
AHMIA CO. connects Brazilian production of agricultural commodities, industrial metals and natural stone to global demand, under a direct B2B business model guided by complete documentation and regulatory compliance. We only achieve this by working closely and responsibly with our Supplier Partners.
This Supplier Code of Conduct ("Code") establishes how we expect rural producers, mining companies, natural stone processors, customs brokers, port agents, carriers, consultants and other third parties supplying goods or services to AHMIA CO. (each, a "Supplier Partner") to act ethically, legally, and in alignment with our institutional values.
This Code sets minimum acceptable conduct standards. We encourage our Supplier Partners to exceed these minimums and adopt international best practices for their activity. Where local legislation imposes less restrictive obligations than this Code, we expect the Supplier Partner to observe this Code when doing business with or on behalf of AHMIA CO. This Code is incorporated by reference into all contracts and commercial instruments executed with Supplier Partners, and compliance with it constitutes a contractual obligation.
Supplier Partners must prohibit all forms of forced or compulsory labor, including labor analogous to slavery, debt bondage and human trafficking, as well as child labor, respecting the minimum age set by Brazilian legislation and International Labour Organization (ILO) conventions. AHMIA CO. will not tolerate any Supplier Partner that, knowingly or negligently, employs forced labor or exploits children, directly or indirectly, within its supply chain.
Supplier Partners must respect their employees' right to organize and bargain collectively, free from interference, intimidation or retaliation.
Supplier Partners must maintain safe and healthy working conditions, complying with applicable health and safety legislation, and must promote a professional, diverse work environment free from discrimination, harassment or intimidation, regardless of race, color, origin, sex, sexual orientation, gender identity, age, religion, disability or political conviction.
Supplier Partners must comply with or exceed applicable labor legislation regarding working hours, overtime, rest and compensation, including minimum wage and other rights provided by law or collective bargaining agreement.
Supplier Partners must respect access to safe drinking water and adequate sanitation services, both for their own employees and for communities affected by their operations.
Given the geographic origin of its supply chain — Brazil's Central-West region, Cerrado biome — AHMIA CO. requires agricultural commodity Supplier Partners to commit to the principles of No Deforestation, No Peat, No Exploitation ("NDPE"), comprising:
Supplier Partners must respect land use, tenure rights and the demarcation of indigenous lands and traditional community territories, in compliance with Brazilian legislation and the United Nations Declaration on the Rights of Indigenous Peoples.
For Supplier Partners in the industrial metals chain (including tantalite and copper), AHMIA CO. requires the adoption of due diligence practices regarding ore origin, aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, even where extraction occurs in Brazilian territory outside any internationally recognized conflict zone, so as to meet the standards required by international buyers and regulators.
Supplier Partners must maintain regular applicable environmental and mining licensing, adopt efficient use practices for water, energy and natural resources, and mitigate impacts on climate, soil, air and biodiversity.
Supplier Partners must comply with applicable anti-corruption legislation, notably Law No. 12,846/2013, and are prohibited from offering, promising, authorizing or accepting, directly or indirectly, any improper advantage to a public official, domestic or foreign, or to an employee or representative of AHMIA CO., with the purpose of obtaining or retaining business or an improper advantage.
Supplier Partners must observe all trade restrictions applicable to their operations, including economic and trade sanctions imposed by Brazilian authorities and, where applicable, by the United Nations, the United States (OFAC), the European Union and the United Kingdom, as well as export, re-export and import control laws and, where applicable, anti-boycott legislation. The Supplier Partner is prohibited from maintaining a commercial relationship, direct or indirect, with any individual or entity listed on applicable restrictive lists.
Supplier Partners must observe anti-money laundering and counter-terrorism financing legislation, adopting measures to identify, prevent and report atypical transactions related to the commercial relationship with AHMIA CO.
Supplier Partners must avoid conflicts of interest and promptly disclose to AHMIA CO. any financial, family or personal relationship with partners, officers or employees of AHMIA CO. that could represent, even in theory, a conflict of interest.
Supplier Partners must conduct their commercial activities ethically and independently; conduct constituting cartel behavior, price fixing, market allocation or improper exchange of sensitive information with competitors is prohibited.
Supplier Partners must protect confidential AHMIA CO. information to which they have access, including intellectual property, trade secrets, commercial terms and financial information, as well as personal data of employees, clients and business partners, in compliance with Law No. 13,709/2018 (LGPD) and, where applicable, the European Union General Data Protection Regulation (GDPR).
Supplier Partners must supply safe products and services, in accordance with agreed technical and commercial specifications, and must make available to AHMIA CO., upon request, information on the location of their facilities and the known origin of supplied materials, for supply chain traceability purposes.
Supplier Partners must maintain books and records that accurately reflect their transactions and must respond to reasonable requests from AHMIA CO. regarding the origin of goods and services and supply chain traceability.
AHMIA CO. reserves the right to request information, certifications and evidence of compliance with this Code, and to conduct or commission audits, directly or through designated third parties, to verify observance of these guidelines.
Supplier Partners, their employees and subcontractors who identify or suspect conduct that violates this Code may report the situation, confidentially and without the need for identification, through the following channels:
AHMIA CO. will treat all communications with confidentiality, impartiality and a prohibition on retaliation against good-faith whistleblowers.
When a reasonable concern is identified regarding a Supplier Partner's compliance with this Code, AHMIA CO. will, as a first measure, seek dialogue with the Supplier Partner to identify the root cause of the non-compliance and jointly develop a corrective action plan with a reasonable implementation deadline. AHMIA CO. reserves the right to suspend commercial operations during the investigation of a concern. Should the Supplier Partner fail to cooperate with the process or fail to correct the non-compliance within the agreed deadline, AHMIA CO. reserves the right to terminate the commercial relationship, without prejudice to other applicable contractual or legal measures.
Supplier Partners are expected to promote the principles of this Code among their own suppliers, subcontractors and other partners involved in carrying out activities related to AHMIA CO.