TELF AG Responsible
Sourcing Policy

TELF AG Due Diligence
Report

Raise
a Concern

Sustainability
Report

TELF AG RMAP
Certificate

Our Sustainability Approach

TELF Insights

Environment

Social

Governance

TELF Insights

Environment

Social

Governance

For TELF AG, sustainability is about ensuring that we source and deliver our commodities safely, responsibly and reliably.

Beyond this, it is also about:

  • Continuing to comply with all applicable regulations, whilst proactively aligning to industry best practice
  • Ensuring that our business is resilient and fit for the future, and can continue to deliver value to our stakeholders – including our employees, customers and business partners
  • Playing our role as a trusted intermediary to promote harmonized and efficient responsible value chain assurance – as well as resilient and transparent value chains
  • Meeting the evolving ESG requirements of our customers and finance providers
  • Continuing to increase our focus on “transition metals” such as cobalt to help meet growing demand driven by the global energy transition
  • Helping to support regional economic development by supplying scarce commodities to countries where they are needed most.

The nature of our business means that we take a holistic focus to sustainability, that includes our own operations, our material suppliers, logistical partners and the broader value chain.

 

For further information about our sustainability journey, please contact us at sustainability@telf.ch

Our ESG Focus Areas

TELF Insights

Environment

Product sustainability, operational environmental impact, climate risks/opportunities

Our independent sourcing partners implement a range of measures to help minimise negative environmental impacts associated with the extraction and processing of the commodities that we source from them.

Such measures are increasingly important in the context of broadening stakeholder scrutiny of ESG impacts taking place at all stages of the value chain. This includes a growing focus on the cross-lifecycle impacts of commodities themselves.

In line with our Code of Conduct, we seek to protect the environment. We are aware that the activities of our logistics partners, including those involved in transportation and warehousing, have the potential to cause negative impacts in this regard.

In this context, we select our partners based not only on commercial factors, but also on their ability to handle our commodities (as well as associated processes like loading/unloading, handling, packaging and waste disposal) in a responsible way.

The small size of our offices and workforce means that our own direct emissions (i.e. Scope 1 and Scope 2) are very limited.

Nonetheless, we are aware, given we arrange the delivery of the commodities we trade, that our Scope 3 emissions are much more substantial. This reflects our extensive use of heavy transportation services, including shipping, railway and road transportation – as well as the significant environmental impacts associated with some of the commodities we trade.

Similarly, the nature of the commodities that we trade means that we, our suppliers and our customers are exposed to a range of climate-related risks and opportunities. These require careful, forward-looking planning and management to ensure that our business – and those of our partners – remain sustainable in the medium- to long-term.

Social

Operational Health and Safety, value chain traceability, responsible sourcing, diversity and inclusion

Telf strives to comply with all applicable official norms and regulations relating to health protection, industrial safety and environmental protection.

Our commitments in this regard are set out in our Code of Conduct. We have also established internal Health, Safety & Environmental Compliance (HSEC) expectations, which outline the standards that we apply to the commodities that we trade in. We encourage our business partners to adopt such standards in accordance with local and international laws.

We work with a network of warehouse providers and port operators that have long operational track records and mature management systems, offering a high-level of assurance regarding the safety standards applied during the handling and storage of our commodities.

The fact that we purchase our commodities directly from a relatively small number of producers, and that we do not mix cargos, supports our capacity to offer the highest standards of transparency in terms of the ultimate source – and journey – of what we sell.

In addition, it means we can offer insight into the conditions of extraction and processing (in terms of potential ESG impacts) and can work constructively and collaboratively with our long-term partners to ensure that they – and thus we – are able to satisfy customer demand for ESG assurance.

Our Cobalt Due Diligence Policy sets requirements for our suppliers based on internationally recognised standards for responsible minerals sourcing, with a focus on addressing:

  • Serious human rights abuses
  • Direct or indirect support to non-state armed groups
  • Public or private security forces
  • Bribery and misrepresentation of the origin of cobalt
  • Money laundering
  • The payment of taxes, fees and royalties to governments.

It is aligned with:

  • The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Due Diligence Guidance)
  • The Chinese Chamber of Commerce of Metals, Minerals and Chemicals Importers & Exporters Due Diligence Guidelines for Responsible Mineral Supply Chains (CCCMC Due Diligence Guidance)
  • Cobalt Due Diligence Standard (RMI and RCI).

Governance

Compliance & Business Ethics

We comply with all applicable laws and regulations and apply strong ethical standards in all that we do.

Any failure in this regard would not only have serious legal implications, but could harm our reputation, impact our commercial relationships and undermine the achievement of our business objectives.

In this context, we apply a robust Compliance Framework, which supports the implementation of our compliance commitments, including those relating to sanctions compliance, anti-bribery and corruption, counterparty due diligence, and other applicable legal and regulatory requirements.

Our Code of Conduct underpins our Compliance Framework.
The Code, which is approved by the Management Board, establishes the ethical standards to be applied in our business practices.

It also defines the minimum requirements for directors and employees (as well as expectations applicable to third parties acting on behalf of the company) and provides direction and guidance on the application of our Values and Principles in practice.

The nature of our business, as well as the geographical breadth of our activity, means we must ensure, on an ongoing basis, that we are in full compliance with all relevant sanctions and export controls.

Our Global Sanctions and Export Controls Policy (Sanctions Policy) establishes a comprehensive and coordinated approach towards Sanctions and Export Controls compliance.

We are committed to conducting its activities free from the influence of bribery and corruption, as well as money laundering.

We only conduct business with reputable agents, advisors, contractors, representatives and other business partners who are involved in legitimate business activities and whose funds are derived from legitimate sources.

Telf’s commitments in this regard, are set out in our ABC Policy. The ABC Policy was developed with support from a leading US-based law firm, and is aligned to the requirements of a range of global anti-bribery and corruption laws, including the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA).

Our CPDD Policy helps us determine if counterparties (or their ultimate beneficial owners, UBOs) appear on any political or economic sanctions or terrorist financing lists, or are involved in criminal activity, including bribery and corruption and/or money laundering.

We undertake CPDD checks on:

  • Those we sell commodities or provide services to
  • Those from whom we buy commodities
  • Our intermediaries, including agents and distributors
  • Our service providers
  • The financial institutions through which we receive and send funds.

The Telf Employee Handbook sets out the basic principles and policies applied by the company and provides employees with information about the work environment, compensation/benefits and relevant rights/obligations. Topics covered range from working hours through to conflicts, grievances and complaints.

Our Corporate Disclosure and Media Policy sets out our employees’ obligations with respect to the management of confidential company information (with all employees under a general duty to keep company information confidential under Swiss Law) and the circumstances under which company information can be disclosed.

In addition, it defines the procedures that employees must follow when asked for information by third parties, including governmental authorities, suppliers, customers and financial institutions, or when engaging with the media.

In addition, our IT Policy Book is designed to ensure (amongst other things) high levels of IT security and the effective management of IT-related risks. This includes:

  • Data protection, including the management of risks relating to data loss, leakage or corruption (e.g. back-up practices, access controls, confidentiality levels and security testing)
  • Anti-virus approach, including the protection of our IT assets from computer viruses, network worms, spyware, malware and trojan viruses
  • Data encryption, including the protection of the confidentiality, authenticity and integrity of electronic information used within TELF AG.
  • Third-party access, including relevant contractual clauses, approval processes and external data storage
  • IT disaster recovery, including disaster recovery planning and testing
  • Incident management, including the process for managing unplanned interruptions to IT services.

We are committed to enhancing the levels of ESG assurance that we provide to our finance providers, customers and other stakeholders.

Over the long-term, this will help support our competitiveness, improve our access to finance and ensure we meet evolving stakeholder ESG expectations and reporting requirements.

Our role within the market, means we take a broad approach that looks beyond our own business to incorporate our outsourced operations and contracted logistics activities, as well as our wider value chain.

Sustainability Partners and Initiatives

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