Our company operates as a distributor of metal and steel semi‑finished products and as a further processor of these products into parts and components. We source our materials from established industrial supply chains and process them at downstream stages of the value chain. We do not operate any smelters or refineries and are not a Union importer of ores or primary metals within the meaning of Regulation (EU) 2017/821.

Against this background, our role within the supply chain is clearly defined: we are not involved in the extraction, processing or primary transformation of raw materials, but operate as a trading and processing company focused on the supply of semi‑finished products and their subsequent processing. Responsibility for the performance of statutory due diligence obligations at upstream raw material and processing stages therefore generally lies with the respective market participants.

With regard to enquiries concerning standardised questionnaires and reporting formats for supply chain transparency, in particular the Conflict Minerals Reporting Template (CMRT), the Extended Minerals Reporting Template (EMRT) and the Additional Minerals Reporting Template (AMRT), we note that these are voluntary instruments of private initiatives. Such formats serve to facilitate structured information exchange within certain industries but do not constitute legally required declarations or evidence.

Accordingly, there is no statutory obligation for our company to complete or provide such questionnaires. In line with this, our General Terms and Conditions of Sale and Delivery provide that no entitlement exists to the preparation, completion or provision of such reporting formats or comparable supply chain questionnaires, unless expressly agreed in writing on an individual basis.

Notwithstanding the above, we attach great importance to responsible and legally compliant supply chain practices. In our procurement and supplier management processes, we ensure compliance with applicable legal requirements and align our approach with generally recognised supply chain due diligence standards, in particular the guidelines issued by the Organisation for Economic Co‑operation and Development (OECD). In doing so, we apply a risk‑based and proportionate approach that reflects our actual role and influence within the supply chain.

In justified individual cases, for example where specific customer requirements or concrete risk indicators arise, we remain open to a constructive and factual dialogue. However, the blanket or standardised completion of supply chain transparency reporting formats does not form part of our general practice.