2025 Annual Report – Implementation of Due Diligence Obligations under Regulation (EU) 2017/821
Reporting period: January 2025 – December 2025
1. Introduction
E. WAGENER GmbH is active in the trade of metallic raw materials. In light of the potential negative impacts of the extraction, processing and trade of certain minerals from conflict-affected and high-risk areas, the company is committed to responsible sourcing and compliance with the relevant legal requirements.
This report documents the measures implemented during the reporting period to fulfil the due diligence obligations under Regulation (EU) 2017/821.
2. Company Profile and Scope of Application
E. WAGENER GmbH sources, among other materials, molybdenum, niobium, tantalum, titanium, tungsten and zirconium.
Regulation (EU) 2017/821 may apply to tantalum and tungsten, provided that import constellations and thresholds are affected. Gold and tin are not offered for sale by E. WAGENER GmbH.
3. Management System for Implementing Due Diligence Obligations (Art. 4)
The following structures and procedures are in place to ensure compliance with the legal requirements:
- Responsibilities: Internal responsibilities for procurement, documentation and assessment of supply chain information are defined.
- Documentation: Supply and origin documents for relevant raw materials are systematically recorded and archived.
- Supplier communication: Suppliers are informed about the requirements of the Regulation and encouraged to provide transparency regarding origin and processing.
4. Risk Analysis and Management (Art. 5)
E. WAGENER GmbH carries out an annual assessment of the supply chains for relevant raw materials:
- Origin verification: Review of supply documents and certificates of origin, with particular attention to potential conflict-affected or high-risk areas.
- Risk assessment: Assessment of geographic risks, levels of transparency and any ambiguities in the supply chain.
- Measures: Where risks are identified, queries and clarifications are made with suppliers; in the event of persistent lack of transparency, procurement decisions may be adjusted.
5. Audit Mechanisms (Art. 6)
Where legally required, E. WAGENER GmbH prepares for the conduct of independent external audits. This includes the provision of relevant documents, the presentation of internal procedures, and the implementation of any audit findings.
6. Disclosure of Implemented Measures (Art. 7)
With this publication, E. WAGENER GmbH discloses the key steps taken to fulfil its due diligence obligations:
- Designated internal responsibilities (Art. 4–7)
- Structured collection and storage of supply chain information
- Regular risk assessments
- Defined decision-making and escalation processes
- Preparation for external audits, where applicable
7. Cooperation and Further Development
E. WAGENER GmbH maintains ongoing dialogue with its suppliers to improve transparency and traceability. Internal documentation and processes are reviewed regularly and adapted to regulatory developments as needed.
8. Contact
For questions or notices relating to due diligence obligations, E. WAGENER GmbH has established an internal point of contact:
Email: info@ewagener.de