This statement is made on behalf of HUTKA SA and its affiliated corporate entities. It sets out the uncompromising actions we have taken, and continue to take, to ensure that modern slavery, forced labor, and human trafficking are entirely eradicated from our global physical operations and trans-hemispheric supply chains.

HUTKA SA recognizes that the global trade of physical commodities—particularly the extraction, processing, and transportation of critical minerals—carries inherent human rights risks. We do not tolerate human exploitation in any form and view the defense of human rights as a fundamental mandate of our corporate governance.

1. Our Organizational Structure

HUTKA SA operates an integrated network of physical commodity sourcing, refining, and global trade logistics. Our operations span the Americas, connecting upstream extraction zones and secondary processing hubs to international industrial markets. Our supply chain relies on a complex network of maritime charterers, heavy-haul logistics providers, terminal operators, and raw material vendors.

2. Supply Chain Policies & Due Diligence

Our commitment to ethical operations is embedded directly into our corporate DNA and enforced through our rigorous compliance architecture. We align our internal policies with the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.

• Supplier Code of Conduct: All vendors, contractors, and upstream suppliers must formally commit to our Code of Conduct, which explicitly prohibits the use of forced, bonded, or child labor, and guarantees workers’ rights to freedom of association and fair compensation.
• Enhanced Due Diligence in CAHRAs: When sourcing from or operating near Conflict-Affected and High-Risk Areas (CAHRAs), we escalate our due diligence protocols to maximum severity, requiring continuous, on-the-ground verification of labor conditions.

4. Training & Whistleblower Protection

A policy is only effective if the workforce is equipped to enforce it. Our Executive Board mandates that all employees—from global port operators to senior commercial traders—undergo targeted training on identifying the indicators of modern slavery and human trafficking within the logistics and commodity sectors.

We operate secure, encrypted, multi-lingual grievance channels. We provide total anonymity and strict anti-retaliation protections for any employee, contractor, or community member who reports suspected human rights abuses or compliance violations within our operational footprint.

5. Executive Approval

HUTKA SA is committed to the continuous improvement of our ethical sourcing protocols. We regularly review our procurement strategies, audit methodologies, and risk matrices to ensure we are applying industry-leading defenses against human exploitation.

This statement has been formally approved by the HUTKA SA Executive Board of Directors and is reviewed annually to reflect our ongoing commitments.