Molytun GmbH is committed to the responsible sourcing of minerals and metals. As a Union importer of tungsten, we fulfil our supply chain due diligence obligations under Regulation (EU) 2017/821 (the EU Conflict Minerals Regulation), the German Minerals Due Diligence Act (Mineralische-Rohstoffe-Sorgfaltspflichten-Gesetz, MinRohSorgG) and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
In the interest of transparency and in accordance with Art. 7 of Regulation (EU) 2017/821, this page publishes our supply chain policy, our grievance mechanism and our annual disclosure report.
1. Supply Chain Policy (Lieferkettenpolitik)
Molytun GmbH is committed to the responsible sourcing of minerals and metals, in particular tungsten, molybdenum, tantalum and their alloys. Our supply chain policy is based on Regulation (EU) 2017/821, the OECD Due Diligence Guidance (3rd edition) and the MinRohSorgG, and rests on the following principles:
Zero tolerance towards serious human rights abuses
We do not tolerate the sourcing of minerals and metals that are directly or indirectly connected to torture, cruel or degrading treatment, forced or compulsory labour, child labour (as defined in ILO Convention No. 182), sexual violence, war crimes or other serious human rights abuses.
No support for armed conflict
We ensure that our sourcing activities do not contribute to the financing or support of non-state armed groups — whether through mineral trade or through the illegal control or taxation of mining sites, transport routes or trading points.
Transparency and traceability
We determine and document the origin of the minerals and metals we import, identify the smelters and refiners involved, operate a supply chain traceability system and disclose all relevant information to the competent authorities upon request.
Risk assessment and risk mitigation
We regularly assess the risks in our supply chain — with regard to origin from conflict-affected and high-risk areas (in accordance with EU/OECD lists), compliance with due diligence obligations by smelters and refiners, and possible red flags under Annex II of the OECD Guidance.
Integration into supplier relationships
Our Purchasing Terms and Conditions (Allgemeine Einkaufsbedingungen) contain a compliance clause on adherence to the due diligence obligations under Regulation (EU) 2017/821 and are referenced in every purchase order. As Molytun GmbH purchases on an order-by-order basis without framework agreements, suppliers are bound in this way. Our supply chain policy is communicated to active suppliers; suppliers are obliged to provide information on request regarding the origin of the minerals and metals supplied and the smelters and refiners involved.
2. Grievance Mechanism (Beschwerdemechanismus)
Molytun GmbH provides a grievance mechanism through which internal and external stakeholders can report concerns regarding our conflict minerals supply chain. All incoming reports are documented, treated confidentially and processed within 30 days.
- Email: compliance@molytun.com
- By post: Molytun GmbH, attn. Quality Management Officer, Gaußstraße 10, 85757 Karlsfeld, Germany
- Responsible: Quality Management Officer (Qualitätsmanagementbeauftragter, QMB)
3. Disclosure Report 2024 (Offenlegungsbericht)
In accordance with Art. 7 of Regulation (EU) 2017/821 · reporting year 2024
Raw materials and imports concerned
In the 2024 reporting year, Molytun GmbH released only tungsten (CN code 8101 99) — a raw material covered by Annex I of the Regulation — into free circulation within the European Union. As an importer of metals, not ores, Molytun GmbH relies on Art. 6(2) of the Regulation; the conformance of the smelters in the supply chain is evidenced through RMAP audit reports issued by independent third-party auditors.
Smelters identified and conformance
The smelters were identified through the suppliers’ Conflict Minerals Reporting Template (CMRT) (100 % response rate). Both smelters are validated under the Responsible Minerals Assurance Process (RMAP) of the Responsible Minerals Initiative. The RMAP is recognised by Commission Implementing Decision (EU) 2025/2071 of 16 October 2025 as a due diligence scheme equivalent to the requirements of Regulation (EU) 2017/821.
| Smelter / Refiner | Smelter ID | Auditor | Result |
|---|---|---|---|
| Xiamen Tungsten Co., Ltd. | CID002082 | SGS | Conformance confirmed |
| Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | UL Responsible Sourcing | Conformance confirmed |
Result of the 2024 risk assessment
For the 2024 reporting year, no specific risks were identified indicating a connection between the imported tungsten products and conflict financing or human rights abuses. All identified smelters are RMAP-validated.
Contact
For questions regarding our supply chain due diligence or to request the full disclosure report, please contact:
Molytun GmbH
Gaußstraße 10 · 85757 Karlsfeld, Germany
Email: compliance@molytun.com
Last updated: June 2026 · This information is reviewed annually and updated as required. This English text is a convenience translation; the German version is authoritative.