Conflict Mineral Report 2020


As a high-quality supplier of special metals, Concept Metal is deeply committed to run its business in a responsible way and make sure none of our activities contribute to human right violations in any part of the world.

We have implemented a dedicated conflict mineral management system to meet and exceed legal requirement and internationally accepted supply chain due diligence standards to ensure responsible sourcing of minerals, referred to as 3 TGs (Tin, Tantalum, tungsten and Gold).

In 2020, in order to meet the USA Dodd Franck Act section 1502 requirements and European conflict mineral regulation (2017/821) we have structured this program as per the OECD due diligence guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Leveraging a clear sourcing policy, we demand our suppliers to trace their suppliers of 3TG and smelters/refiners and country of origin.

In particular, we have traced 100% of our supplies of Tungsten and smelters/refiners involved and have not identified any risk in the process as all smelters/refiners in concept metal supply chain participated and passed an independent 3rd party audit program on responsible sourcing of conflict Minerals.

We have updated our communication program so our new company website reflects our commitment to responsible sourcing and have provided means to receive inquiries, grievance or request for information so we can manage those as early warnings and address any potential risk that would arise.

Our program also ensures any risk identified during the due diligence analysis or grievance received would get visibility up to the highest level of the Company.

OECD Step 1 : Strong company management systems.

In line with Step 1 of the OECD Due Diligence guidance, Concept Metal has defined a robust internal management system to manage responsible sourcing of 3TGs.

Our sourcing policy has been updated to specifically address our requirements on conflict mineral and our Conflict Mineral Policy has been communicated to all suppliers involved in trading of 3TGs or derived products.

In 2020, we have developed capacity to meet and exceed conflict mineral regulatory frameworks (Europe and USA). Our staff has been trained and all suppliers involved in trading of 3TGs in 2020 have been identified and assessed using the RMI approved scheme of conflict mineral reporting template.

As a high-quality supplier of special metals, Concept Metal establish strong engagement with our own suppliers. From 2020 onwards, we have re-emphasized conflict mineral management in all new suppliers’ qualification and existing suppliers ‘audits.

Concept Metal Managing Director has direct control on all elements of this management system.

OECD Step 2 Identify and assess risk in the supply chain.

For European regulation, thresholds published in Annex I and subsequent amendments have been checked for all relevant CN codes.

Based on those thresholds, Concept Metal was concerned by the European Regulation for Tungsten.

All suppliers of Tungsten have been identified and Conflict Mineral Reporting Templates (CMRT) have been collected accordingly.

For 2020, we have standardized on revision 6.01 of CMRT as published by the Responsible Minerals Initiative (RMI).

Reports collected have been evaluated against internal quality standards to ensure we have relevant, quality responses from our suppliers.

All smelters / refiners declared in CMRT have been checked for conformance to RMI‘s RMAP process and audit status has been checked.

In 2020, all smelters/refiners declared were conformant with audit validity extending beyond 2021.

Therefore, no risk was identified as part our due diligence control mechanism and no grievance had been received on the matter either.

OECD Step 3 respond to identified risks

No risk had been identified in 2020.

However, shall any risk been identified, Concept Metal has implemented a company management system to provide visibility to senior management, report on progress and monitor outcome of actions and would evaluate any required mitigating actions including:

∙ Continuing trade while closely monitoring an improvement action plan
∙ Temporarily suspending trade until the risk is addressed through measurable actions
∙ Terminating the contract in case sufficient actions is not undertaken by supplier

OECD Step 4 third-party audit of supply chain due diligence

Concept Metal has chosen to leverage the industry widely recognized CMRT scheme from RMI (

We understand this scheme is approved, including with regards to European Regulation requirement hence no additional independent 3rd Party audit was required.

However, we pay attention to the RMAP status and audit results of all smelters/refiners declared by our suppliers and thoroughly check these against latest publications from RMI.

OECD Step 5 Report on supply chain due diligence

This report is our first edition on our due diligence requirement and will be updated annually from now on.

Upon customer request, we can also provide our own Conflict Mineral Reporting Template as per RMI’s 6.01 template.


Concept Metal is not involved in trading or import of mineral and therefore we are a downstream company in the conflict mineral supply chain.

In 2020, Concept Metal has established a strong company management system for due diligence on sourcing Conflict Mineral and conducted a complete analysis of our tungsten supply chain.

This analysis has not identified any risk related to souring of 3TGs and we have not received any alert or grievance on the matter throughout the year.

Concept Metal will continue to deliver on its commitment to responsible sourcing of conflict mineral and therefore participate in all industry efforts to improve due diligence on sourcing of Conflict Mineral and control any undesired impact on human rights practices in conflict areas indirectly deriving from our business activities.

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