OECD Compliance
Supply Chain
Transparency Report
OECD Due Diligence Framework for Responsible Mineral Sourcing and Ethical Supply Chains
Our Commitment
Responsible Sourcing
NDB is committed to implementing responsible sourcing practices aligned with OECD Due Diligence Guidance for Responsible Supply Chains.
Developing nuclear-powered battery technology requires transparent, ethical, and responsible supply chains from the outset. This inaugural report establishes our framework, policies, and commitments.
We are proactively building the infrastructure, policies, and partnerships that will ensure responsible sourcing as we scale operations toward production (targeted 2030 launch).
Scope: This report covers our current supplier relationships and outlines our planned approach for production-scale supply chain management.
Framework
OECD Five-Step Due Diligence
Our supply chain due diligence follows the OECD framework for responsible mineral sourcing and ethical procurement.
Step 01
Establish Strong Management Systems
Implemented- Adopted Responsible Sourcing Policy (RSP) and Supplier Code of Conduct
- Designated Chief Compliance Officer with supply chain oversight
- Established Sustainability Committee with quarterly reviews
- Integrated RSP into all new supplier agreements (template created)
Step 02
Identify and Assess Risks
In Progress- Mapping current R&D supplier base (12 active suppliers in 2024)
- Developing comprehensive risk assessment framework
- Identifying high-risk materials: radioactive isotopes, synthetic diamonds, rare earths
- Planning supplier audits and country-of-origin verification (to launch 2025)
Step 03
Design Risk Mitigation Strategy
Framework Established- Zero-tolerance policy for conflict minerals and human rights abuses
- Supplier engagement plan for continuous improvement
- Escalation protocols for non-compliance (warning → improvement plan → termination)
- Whistleblower mechanism for supply chain concerns
Step 04
Independent Third-Party Audit
Planned (2027+)- Commit to third-party audits for Tier 1 suppliers by 2027
- Target: 100% of high-risk suppliers audited within 2 years of production launch
- Audit criteria: labor practices, environmental compliance, conflict minerals
- Annual audit reports to be published starting 2028
Step 05
Report on Due Diligence
Initiated (This Report)- This inaugural transparency report establishes baseline
- Annual reporting commitment starting 2024
- Public disclosure of supplier engagement progress
- Transparent reporting on non-compliance and remediation
Risk Management
Supply Chain Risk Categories
We have identified the following risk categories in alignment with OECD guidance and international human rights standards.
Serious Human Rights Abuses
NDB will not tolerate or profit from torture, forced labor, child labor, human rights violations, war crimes, crimes against humanity, or genocide associated with material extraction, transport, or trade. Zero-tolerance policy with immediate supplier termination.
Conflict-Affected Areas
We will not knowingly source materials from conflict-affected or high-risk areas that directly or indirectly support non-state armed groups. Country-of-origin verification required for all high-risk materials.
Labor Rights & Safety
All suppliers must comply with ILO conventions: no forced labor, no child labor, freedom of association, safe working conditions, fair wages above minimum wage, and no excessive overtime. Annual supplier self-assessment and third-party audits.
Bribery & Corruption
We will not offer, promise, give, or demand bribes. Suppliers must comply with anti-corruption laws (FCPA, UKBA) and maintain transparent transaction procedures. Whistleblower protections in place.
Environmental Compliance
Suppliers must comply with all environmental regulations, minimize ecological impact, and align with our sustainability commitments. Preference for suppliers with ISO 14001 certification or equivalent.
Money Laundering & Fraud
NDB supports efforts to eliminate money laundering throughout our supply chain. Suppliers must maintain accurate records, transparent financial practices, and compliance with AML regulations.
2024 Status
Current Supplier Profile
Our current supplier base supports R&D equipment, laboratory services, and professional services as we prepare for scaled operations.
2024 Supplier Profile
Supplier Categories:
- • R&D equipment and laboratory services
- • IT/software and technology infrastructure
- • Legal and compliance services
- • Professional consulting and advisory
Geographic Reach:
Our suppliers span multiple continents including North America, Europe, and Australia.
Code of Conduct:
All new suppliers required to sign Supplier Code of Conduct
High-Risk Materials (Future Sourcing)
As we prepare for production (2030 target), we have identified high-risk materials that will require enhanced due diligence:
Critical Materials:
- • Radioactive isotopes (Carbon-14, Nickel-63)
- • Synthetic diamond substrates
- • Rare earth elements (semiconductor doping)
- • Precious metals (electrical contacts)
Due Diligence Approach:
- • Source only from licensed nuclear facilities
- • Chain of custody documentation required
- • Country-of-origin certification
- • Annual supplier audits (third-party)
Standards
Supplier Code of Conduct
All NDB suppliers must comply with our Supplier Code of Conduct, which establishes minimum standards for labor, ethics, and environmental practices.
Labor & Human Rights
- Prohibition of forced labor and child labor
- Freedom of association and collective bargaining
- Non-discrimination (race, gender, religion, age, etc.)
- Fair wages and benefits above statutory minimum
- Safe working conditions and health & safety protocols
Ethics & Compliance
- Anti-corruption and anti-bribery (FCPA, UKBA compliance)
- Conflict minerals disclosure and certification
- Intellectual property protection and confidentiality
- Accurate recordkeeping and financial transparency
Environmental Responsibility
- Compliance with all environmental laws and regulations
- Waste minimization and responsible disposal practices
- Energy efficiency and greenhouse gas reduction efforts
- ISO 14001 certification or equivalent (preferred)
Supplier Cascade Requirement
All suppliers must deliver this Code of Conduct to their own suppliers (sub-tier suppliers) and monitor compliance throughout the supply chain. This ensures responsible practices extend beyond our direct relationships.
2025-2030 Roadmap
Supply Chain Development Plan
Comprehensive Mapping
- Complete full supplier mapping for planned production (Tier 1, 2, 3)
- Launch supplier self-assessment questionnaires
- Develop supplier scorecard and performance metrics
Risk Assessment & Audits
- Complete risk assessment for all Tier 1 suppliers
- Launch third-party audit program for high-risk suppliers
- Implement supplier improvement plans for non-conformances
Production Launch
- 100% of Tier 1 suppliers signed to Code of Conduct
- All high-risk materials sourced with full traceability
- Third-party audits completed for critical material suppliers
Accountability
Grievance & Whistleblower Mechanism
We have established confidential channels for reporting supply chain concerns, with protections against retaliation.
How to Report Concerns
Contact Form:
Submit confidential inquiry →Whistleblower Hotline:
Anonymous reporting available (Details provided to suppliers)
Investigations & Remediation:
All reports investigated within 30 days. Corrective action plans developed for confirmed issues. Transparent reporting on outcomes.
Non-Retaliation Policy
NDB prohibits retaliation against any individual who reports supply chain concerns in good faith. This protection extends to employees, suppliers, and third parties. Retaliation is grounds for termination of employment or supplier contracts.
"Responsible sourcing is not optional—it is a fundamental requirement for building a business that creates value for all stakeholders, respects human rights, and protects our planet."
— NDB Compliance Team, December 2024
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