Conflict Minerals / Responsible Sourcing Policy

1. Purpose and Scope

EVEK GmbH is committed to responsible sourcing of minerals and metals. This policy describes our approach to compliance with Regulation (EU) 2017/821 regarding the import of tin, tantalum, tungsten and gold (3TG).

2. Regulatory Framework

EVEK GmbH acts in accordance with Regulation (EU) 2017/821 and follows a risk-based approach aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

3. Position in the Supply Chain

EVEK GmbH operates primarily as a distributor and trading company. We do not mine, smelt or refine minerals ourselves. Our due diligence activities are therefore proportionate to our role in the supply chain.

4. Supplier Selection and Risk Assessment

Suppliers are selected based on long-term business relationships, reliability, product quality and compliance with contractual obligations.

As part of our risk-based approach, we take into account:

the country of production,

the nature of the supplier,

information and declarations provided by our direct suppliers.

Where appropriate, suppliers are requested to confirm that supplied materials do not originate from conflict-affected or high-risk areas.

5. Risk Mitigation

If potential risks are identified, EVEK GmbH will seek clarification from the supplier and assess appropriate measures, which may include additional information requests or review of the business relationship.

6. Transparency and Disclosure

EVEK GmbH is committed to transparency and will make relevant information regarding its responsible sourcing approach publicly available in accordance with Article 7 of Regulation (EU) 2017/821. Further information will be provided to authorities upon request.

7. Continuous Improvement

EVEK GmbH regularly reviews its sourcing practices and will further develop its due diligence processes where necessary.