Volex: Conflict Minerals Engagement
As part of our ongoing efforts to improve performance across key environmental, social, transparency and governance (E.S.T.) metrics, we recently engaged with Volex, held in our Thoughtful UK Smaller Companies Fund, to discuss its approach to conflict minerals due diligence.
Tin, tungsten, tantalum and gold (known collectively as ‘3TG minerals’) are primarily sourced from Central Africa, specifically the Democratic Republic of Congo (DRC) and its surrounding areas. In this region, the extraction of these minerals can be linked to armed conflict, human rights abuses and political instability.
Not all minerals from the DRC and surrounding areas are conflict-linked, but due to the challenges in tracing supply chains, many companies are advised to proceed with caution when sourcing from the region.
Volex is a manufacturer of electrical power and data cabling and related components. We discussed how the company approaches responsible sourcing of 3TG minerals.
As a smaller company, we were impressed by the team’s level of awareness and the structure Volex has developed to assess responsible minerals sourcing, particularly given the complexity of tracing 3TG supply chains.
As a smaller company, we were impressed by the team’s level of awareness and the structure Volex has developed to assess responsible minerals sourcing, particularly given the complexity of tracing 3TG supply chains.
Volex has a Responsible Minerals Sourcing Policy (updated from an earlier conflict minerals policy statement) which is reviewed at least annually. The company stated that the policy is board approved, which aligns with recognised best practice and is relatively advanced governance for a company of this size.
Volex acknowledged that 3TG minerals are present in its products and supply chain, but noted that it does not directly source or process raw minerals. The company has started mapping which product categories contain which minerals (e.g., gold in power cords) and shared an internal “heat map” of estimated exposure, with plans to add more quantitative detail over time.
Volex indicated that its current programme covers around 50% of its supply chain, largely due to the integration of acquired businesses. A key priority is bringing acquired operations up to the same standard. This is an area for ongoing engagement with the company.
We were especially pleased that the company framed responsible minerals as a business risk issue (with regulatory and customer expectations as key drivers) and noted that investor engagement is helpful in building internal awareness and momentum.
We were especially pleased that the company framed responsible minerals as a business risk issue (with regulatory and customer expectations as key drivers) and noted that investor engagement is helpful in building internal awareness and momentum. We view this risk-based framing positively, as it aligns with how investors typically assess material issues, and it is supported by an evolving set of regulations and reporting expectations in this area.
Outcome: We were impressed by the programme to date, further engagement is required to ensure it extends across the full supply chain.
Written by Ffion Spencer
This article was originally published as part of our Q1 2026 Investment Management Report (IMR).
Information is accurate as at 20.04.2026. Opinions constitute the fund manager’s judgement as of this date and are subject to change without warning. The officers, employees and agents of CIP may have positions in any securities mentioned herein. This material may not be distributed, published or reproduced in whole or in part. With investment, capital is at risk.