1. According to the OECD Guidelines for Multinational Enterprises, due diligence is a process during which companies can 
identify, prevent, mitigate, and account for how they address their actual and potential adverse impacts as an integral part of 
business decision-making and risk management systems. 
Organisation 
Owner 
Document type 
Version 
Volvo Car Corporation 
50130 Global Sustainability  
Position Paper 
3 
 
 
 
 
Document name 
Valid from  
Security class 
Volvo Cars Position on Responsible Sourcing  
2025-01-17 
Public  
Volvo Cars Position on Responsible Sourcing  
Purpose of this document 
The overall intention of Volvo Cars’ position papers is to provide clarity to stakeholders on areas of high 
relevance to the company considering our ambitions and long-term strategies. This paper addresses 
the challenges linked to responsible sourcing and describes how Volvo Cars works to manage related 
risks within our global supply chains. Furthermore, this paper outlines our aim to ensure that the 
materials used in our products are sourced responsibly and do not contribute to armed conflict, human 
rights abuses, or environmental degradation and loss of biodiversity. 
Background and challenge 
The acceleration of electric vehicle (EV) production is crucial for the transition to a low-carbon 
economy. However, a typical electric car requires more critical material inputs (meaning materials with 
high economic importance and high supply risk) compared to a conventional car. Material extraction, 
processing, trade, and transportation may cause or contribute to adverse impacts for people and 
planet, for example child or forced labour, money laundering, pollution, and deforestation. Risks are 
especially prevalent for materials from conflict-affected and high-risk areas (CAHRAs). Hence, risk-
based supply chain due diligence is necessary to enable responsible sourcing1. 
Volvo Cars position 
Volvo Cars aim to protect and improve people’s lives in our value chain and wider society. We 
continuously monitor and assess risks to verify that Volvo Cars’ business operations and products do 
not induce human rights abuses, unethical business conduct, environmental harm, or provide funding 
to conflicts and armed groups. Volvo Cars has identified several minerals, metals, and bio-based 
materials associated with considerable environmental, social, and governance (ESG) risks, which we 
refer to as “Raw Materials of Concern” (RMoC). Targeted due diligence efforts are rolled out gradually 
for these supply chains to enable responsible sourcing practices. Volvo Cars recognises a broad set of 
ESG risks, including but not limited to: 
 
• 
The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-
Affected and High-Risk Areas Annex II risks; and 
• 
the risks related to materials in the Annex X.1 of the EU Batteries Regulation 2023 (EU-Batt-
R), the social and environmental risk categories stipulated in its Annex X.2, and the 
international instruments covering these risks, as referenced in the EU-Batt-R Annex X.3.  
 
We are committed to respecting and complying with international instruments, principles and 
frameworks such as the United Nations Guiding Principles on Business and Human Rights, the 
International Bill of Human Rights including the Universal Declaration of Human Rights, the ILO core

conventions, the OECD Due Diligence Guidance for Responsible Business Conduct, and the OECD 
Guidelines for Multinational Enterprises. We develop and implement procurement practices using a 
risk-based approach in line with global standards and require our suppliers to also implement and 
maintain appropriate policies, management systems, and due diligence measures to identify, prevent 
and mitigate any adverse impacts linked to their business via their own operations or via their 
relationships with third parties. Our approach to human rights due diligence is detailed in our Human 
Rights Statement. 
 
Our Business Partners shall implement the standards and principles set out in our Code of Conduct for 
Business Partners or same principles, with all applicable laws and regulations, and with their 
contractual obligations to Volvo Cars, including our Sustainability Requirements, throughout its 
organisation and extend the requirements to its value chain, ensuring that its Employees, 
subcontractors and other relevant third parties comply with said standards and principles. Violation or 
lack of cooperation, failure to address violations or take timely actions may lead to claims, a loss of 
business and ultimately to the end of the business relationship with Volvo Cars. 
 
Volvo Cars acknowledges that supply chain due diligence is an ongoing, proactive, and reactive 
process, and that information and risk monitoring systems will progressively be improved over time as 
a result from constructive engagement with suppliers and other stakeholders.   
 
Conflict minerals: 
Volvo Cars is committed to conflict-free sourcing, and to responsible sourcing of tin, tantalum, 
tungsten, and gold (referred to as “3TG minerals”), which have been identified as potential conflict 
minerals. Volvo Cars require our suppliers to conduct supply chain due diligence so that the 3TG 
minerals used in the products they supply are sourced from conflict-free origins, and do neither directly 
nor indirectly finance or benefit armed groups in conflict-affected and high-risk areas as defined by 
international standards, including the OECD Due Diligence Guidance for Responsible Supply Chains of 
Minerals from Conflict-Affected and High-Risk Areas. 
 
Battery raw materials: 
Volvo Cars acknowledges the complexity of battery supply chains and is committed to adhere to the 
requirements stipulated in the EU-Batt-R, and to ensure that our management systems are aligned 
with recognised international due diligence frameworks, as we are advancing our electrification 
program. This includes following the 6-step due diligence cycle and ensuring that we have systems of 
control and transparency in place relating to the supply chain of high-risk materials used in batteries. It 
also entails working with our supply chain partners to responsibly source materials associated with 
social and environmental risks, and to participate in our specific programs targeting the supply chains 
of batteries, which include but are not limited to audits, assessments, and training. 
Volvo Cars actions  
As a premium mobility provider, Volvo Cars has a unique opportunity to act as a catalyst for good. By 
working with our suppliers to improve their sustainability performance we can help drive positive 
change across multiple industries and sectors. Our ESG requirements form an important part of the 
sourcing process. We evaluate new and existing suppliers’ performance, and our due diligence efforts 
are prioritised using a risk-based approach. Our business partners are critical to help Volvo Cars reach 
its sustainability targets, including reduced carbon footprint and increased recycled material content in 
our vehicles. We continuously review and improve our management systems, processes, and tools to 
implement best practice and promote sustainability in our value chain. Activities to secure responsible 
sourcing are for example:

• 
Traceability and transparency: Volvo Cars is committed to ensuring supply chain 
traceability and transparency through a range of initiatives and activities. We were the first 
OEM to apply blockchain technology throughout the Cobalt supply chain for our EV 
batteries, and the first to launch an EV battery passport recording the origins of key raw 
materials, components, recycled content, and carbon footprint. Volvo Cars also collaborates 
closely with its suppliers to secure the use of Responsible Minerals Assurance Process 
(RMAP) conformant smelters for 3TG material. All suppliers must provide a completed 
Conflict Minerals Reporting Template (CMRT), annually or upon request by Volvo Cars, 
disclosing the sources of 3TG minerals in their supply chain. 
 
• 
Audits and assessments: Apart from our own assessments, we commission independent 
audits for more in-depth evaluations of suppliers’ sustainability performance to identify 
potential and actual impacts. These support continuous improvement and aims at ensuring 
that workers are treated with respect and dignity, and that business operations are 
environmentally and ethically sound.  
 
• 
Training and capacity building: Volvo Cars offers training and other capacity building 
efforts for suppliers and employees. This to enhance engagement and awareness of the 
importance of sustainability and responsible sourcing, to promote continuous improvement 
and prevent and mitigate potential and actual impacts of the business.  
 
• 
Grievance mechanism: The Volvo Cars Tell Us reporting line can be utilised for raising 
compliance, including supply chain related, concerns. It is operated by an independent third 
party, enables reporting in more than 60 different languages, and is available 24/7, 365 
days per year. All reports will be treated as confidential, and all concerns are taken seriously. 
Appropriate actions will be taken on each report. 
 
• 
Rightsholder engagement: As part of our due diligence activities, Volvo Cars engages with 
affected rightsholders and communities, directly or through their legitimate representatives, 
to inform our understanding of risks as well as potential and actual impacts. 
 
• 
Standards, certifications and partnerships: To promote responsible business behaviour 
across our supply chain, Volvo Cars adopts relevant internationally recognised standards and 
certification schemes. This allows us to benchmark suppliers’ environmental and social 
performance and promote a sustainable development. Volvo Cars actively participates in 
initiatives aiming to reduce negative ESG impacts, increase raw material traceability, and 
improve working and living conditions in local communities. In addition, we are joining forces 
with other end-users to increase the supply of low and zero carbon material, particularly from 
carbon-intensive sectors. For these purposes, we collaborate with actors both within and 
outside of the automotive industry for example through the Responsible Business Alliance 
and Drive Sustainability, as well as the Better Mining and SteelZero initiatives. 
 
• 
Communication and reporting: Volvo Cars publicly discloses information regarding its 
approach to responsible sourcing and sustainable supply chain management on the 
company homepage, in the annual report and in its Human Rights Statement. The annual 
report provides more details our due diligence efforts in specific risk areas, including efforts 
related to 3TG materials and battery supply chains.  
 
Volvo Cars Position on Responsible Sourcing was adopted by Volvo Cars’ Executive Management Team on 
2025-01-17.