Imaginarium/Compliance/Responsible Sourcing Provenance, proven

Responsible Sourcing

know where every gram comes from

Our parts fly, get implanted and race. That means the powder, billet, resin and hardware we buy must be as accountable as the parts we ship. This page sets out the standards we source against, what we expect of every supplier, and how anyone can raise a concern. It applies to all Imaginarium sites, all suppliers and all sub-tier suppliers.

The rulebook

The standards we source against

01 / Quality flow-down

Aerospace & medical quality

Our AS9100D and ISO 13485 obligations do not stop at our door. Purchase orders flow the applicable quality, traceability and record-keeping requirements down to every supplier, and through them to their sub-tiers.

AS9100D · ISO 9001:2015 · ISO 13485:2016
02 / Conflict minerals

3TG due diligence

We work to exclude tin, tantalum, tungsten and gold that finances armed conflict. Suppliers of covered materials complete conflict minerals reporting, and we support customer CMRT requests with smelter-level data where available.

OECD Due Diligence Guidance · RMI / CMRT · Dodd-Frank §1502 · EU 2017/821
03 / Substances

Chemical compliance

Materials and consumables must comply with applicable substance regulations. Suppliers declare REACH substances of very high concern and RoHS-restricted substances, and notify us when declarations change.

REACH (EC 1907/2006) · RoHS · Safety data sheets on file
04 / Labour & human rights

People in the chain

No forced labour, no child labour, no debt bondage, anywhere in our supply chain. Suppliers must respect freedom of association, pay legal wages, keep working hours lawful and provide safe conditions.

ILO Core Conventions · UK Modern Slavery Act · UN Global Compact
05 / Ethics

Anti-bribery & fair dealing

Zero tolerance for bribery, facilitation payments, kickbacks and undisclosed conflicts of interest, on both sides of the purchase order. Gifts and hospitality stay modest, transparent and recorded.

FCPA · UK Bribery Act 2010 · Prevention of Corruption Act (India)
06 / Counterfeit prevention

No grey market

Metal powders, alloys and hardware are bought only from original manufacturers or their authorised distributors. Unverifiable stock is quarantined, reported and never enters production.

AS5553 · AS6174 · Authorised-source purchasing only
The supplier code

What we expect of every supplier

Accepting an Imaginarium purchase order means accepting these terms. They are conditions of doing business with us, not aspirations.

  1. Prove provenance.

    Supply material with certificates that trace back to the original heat, lot or batch. If the paperwork cannot be verified, the material does not ship to us.

  2. Act with integrity.

    Compete fairly, invoice honestly, declare conflicts of interest and never offer or accept improper payments in any form.

  3. Treat people lawfully and fairly.

    Employ only voluntary, legally aged workers. Pay at least the legal wage, respect working-hour limits and never retain identity documents or charge recruitment fees.

  4. Keep workers safe.

    Provide safe equipment, training and protective gear, and report serious incidents connected to our orders.

  5. Protect the environment.

    Hold the required environmental permits, handle process waste and effluent responsibly, and work to reduce energy, water and material waste.

  6. Guard what we share.

    Customer drawings, CAD and data are confidential. Protect them, use them only for our orders, and return or destroy them when the work ends.

  7. Flow it down.

    Hold your own suppliers to these same standards. Sub-tier sourcing is disclosed to us on request, and undisclosed subcontracting of our orders is not permitted.

  8. Tell us early.

    Escapes, substitutions, ownership changes, or anything that could affect conformity or continuity of supply: we hear it from you first, not from an audit.

Transparency in practice

Every part carries its history

Lot to part
Material traceability

Every metal powder lot, resin batch and billet heat is logged at goods-in and linked to the build, the machine and the shipped part number.

Certs on file
Documented conformity

Mill and material certificates, including EN 10204 Type 3.1 where specified, are retained and issued with the inspection report on every aerospace and medical order.

Open books
Customer & authority access

Customers, their customers and regulatory authorities have right of access to the applicable records and, where agreed, to the supply chain behind them.

Chapter and verse

The regulations, and where we stand

United States
Dodd-Frank Act, Section 1502
What it requires

US law obliging companies to determine whether the tin, tantalum, tungsten or gold in their products originated in the Democratic Republic of the Congo or adjoining countries, whether it financed armed groups, and to report on the due diligence performed.

Where we stand

We do not knowingly purchase 3TG that benefits armed groups. Suppliers of 3TG-bearing materials declare origin, we collect smelter and refiner data using the industry-standard Conflict Minerals Reporting Template, and we pass that data up the chain so our customers can complete their own Section 1502 filings.

European Union
Conflict Minerals Regulation (EU 2017/821)
What it requires

EU regulation placing supply-chain due diligence obligations on importers of 3TG from conflict-affected and high-risk areas, built directly on the OECD framework: management systems, risk assessment, third-party audits and disclosure.

Where we stand

We apply the same due diligence expectations to every 3TG source regardless of geography, not only EU imports. We give preference to smelters and refiners validated under the Responsible Minerals Assurance Process, and unverifiable sources are removed from our approved list.

International
OECD Due Diligence Guidance
What it requires

The international five-step framework for responsible mineral supply chains: establish strong management systems, identify and assess risk, design and implement a response to identified risks, carry out or rely on independent audits, and report publicly on due diligence.

Where we stand

Our minerals due diligence is modelled on the five steps. This policy and its ownership form the management system, supplier declarations and CMRT data map the chain, quarantine and disengagement are our risk responses, we rely on RMAP audits at smelter level, and we disclose our approach here and to customers on request.

European Union
REACH & RoHS
What it requires

REACH (EC 1907/2006) governs the registration, evaluation and authorisation of chemical substances and the communication of substances of very high concern. RoHS restricts hazardous substances such as lead, mercury, cadmium and certain phthalates in electrical and electronic equipment.

Where we stand

Suppliers declare any SVHC content above 0.1% by weight and any RoHS-restricted substances in the materials they supply, and must notify us when the candidate list changes their declaration. Safety data sheets are held on file for every material in the building, and we support customer REACH and RoHS material declarations on request.

Due diligence

How a supplier earns the order

01

Qualify

New suppliers are assessed before the first order: certifications, financial standing, ethics declarations and, for critical materials, source and smelter information.

02

Flow down

Quality, traceability, substance and ethics requirements are written into the purchase order, so expectations are contractual from day one.

03

Verify

Incoming material is checked against its certificates. Critical suppliers are audited on a risk-based cycle, on site or by document review.

04

Review

Performance is scored on quality, delivery and responsiveness. Findings get corrective actions with deadlines. Repeat failures end the relationship.

trust, then verify. then keep verifying.

Speak up

See something off?

Suppliers, employees, customers and members of the public can raise a sourcing or ethics concern with us directly. Reports can be made in confidence, they are investigated, and we do not tolerate retaliation against anyone who raises a concern in good faith.

hello@imaginarium.io