Due dilligence step 5_RMI
Annual Published Due Diligence Report on Conflict Minerals
- Company information
Company name: S.P.T. spol, s.r.o. (SPT)
RMI CID: CID005068
Registered address: Pražská 600, Mníšek pod Brdy, Czech Republic
3TG material processed: Tungsten
Operations summary: SPT operates two metallurgical facilities: Facility A (recycles molybdenum‑containing materials) and Facility B (recycles tungsten‑containing materials). Tungsten feedstock comprises secondary waste materials produced solely by suppliers within the EU.
- RMAP assessment summary
Facility B underwent an RMAP assessment on 11–12 February 2025 for the assessed period 01 January 2024 – 31 December 2024. The assessment was conducted by BDO LLP (London). A public summary URL is not yet available; SPT will update this report and its website once the summary is published or becomes accessible. [responsibl…iative.org]
- Supply chain policy
SPT maintains a Responsible Minerals Supply Chain Policy aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‑Affected and High‑Risk Areas (OECD Guidance) and the RMI RMAP Tungsten Standard. The policy addresses all Annex II risks and applies globally. Senior management reviews and approves the policy and supports implementation. The policy, together with our “Raw Material Procurement Statement” and “Modern Slavery Act Statement,” is communicated to relevant stakeholders and available at www.sptltd.eu/services. [oecd.org], [responsibl…iative.org]
- Management systems
Governance: The COO holds ultimate accountability for supply chain due diligence.
Responsibilities: The Procurement Director / Due Diligence Program Manager oversees responsible sourcing, supported by the Procurement Manager for implementation.
Training: All responsible sourcing team members receive initial and annual refresher training covering the Supply Chain Policy, SPT’s Code of Business Conduct, relevant industry codes and the RMI’s due‑diligence expectations. SPT reviews its Manual for Responsible Supply Chains annually, defines actions to address any gaps, and reports results to senior management. [responsibl…iative.org]
- Internal systems of control
SPT maintains controls aligned with the OECD five‑step framework, including: policy communication to upstream suppliers; supplier onboarding and documentation; transaction‑level checks; risk assessment workflows; and approval controls to ensure only approved materials are released to tungsten production. [oecd.org]
- Record‑keeping and mass balance
SPT retains due‑diligence records for at least five years, including inbound and outbound shipment records. SPT operates a mass‑balance process to calculate and track all tungsten‑containing materials across inputs, WIP and outputs. [responsibl…iative.org]
- Risk identification and assessment
Know‑Your‑Supplier (KYS): SPT collects and reviews legal identity, beneficial ownership, operational mapping and risk indicators for all suppliers. Inconsistencies or gaps are investigated and resolved.
CAHRA determination: SPT determines whether any materials originate in or transit via Conflict‑Affected and High‑Risk Areas (CAHRAs). Determinations reference the EU’s indicative, non‑exhaustive CAHRA list, complemented by broader open‑source monitoring. SPT reviews its CAHRA determination at least quarterly and upon material new information.
Red‑flag review: SPT screens for red‑flag indicators as set out in the OECD Guidance and the RMAP Tungsten Standard. Any red flags trigger enhanced due diligence commensurate with risk. [cahraslist.net], [eur-lex.europa.eu] [oecd.org], [responsibl…iative.org]
2024 risk determination: Based on the procedures above, SPT received materials from low‑risk sources in 2024 and did not source from countries or sub‑regions included on the EU CAHRA list. (SPT nonetheless continues to apply OECD‑aligned due diligence to all sources.) [cahraslist.net], [eur-lex.europa.eu]
- Risk management and mitigation
SPT applies proportionate mitigation consistent with OECD Step‑3 where risks are identified, including engagement with suppliers, corrective‑action planning, escalation to senior management, and (where warranted) suspension or disengagement for the most severe impacts. Monitoring tracks implementation and effectiveness over time. [oecd.org]
- Stakeholder engagement & grievance mechanisms
SPT maintains an open‑door, confidential grievance mechanism for internal and external stakeholders via spt@sptltd.eu, telephone +420 318 591 379, and via management contacts listed at www.sptltd.eu/services. Concerns are documented, investigated, and remediated per RMAP expectations. SPT also recognizes and uses the RMI Grievance Mechanism and the cross‑industry Minerals Grievance Platform (MGP) for grievances linked to 3TG supply chains. [responsibl…iative.org], [mineralsgr…atform.org]
- Regulatory context
SPT’s due diligence framework aligns with the EU Conflict Minerals Regulation (EU) 2017/821, which requires EU importers of 3TG to implement OECD‑aligned due diligence for supply chains potentially linked to CAHRAs. [eur-lex.europa.eu]
- 2024 outcomes and continuous improvement
During the reporting period, SPT’s due‑diligence activities (KYS, CAHRA determination, red‑flag screening and transaction‑level controls) did not identify Annex II risks in the tungsten supply chain. SPT will continue to strengthen its systems, maintain quarterly CAHRA reviews, and implement any improvements recommended during the February 2025 RMAP assessment, including timely closure of any corrective actions.
