Luxembourg, August 29, 2025.

As a leading global commodities trader, Traxys is firmly committed to working with responsible supply chains, particularly when sourcing minerals from Conflict-Affected and High-Risk Areas (CAHRAs) such as the Great Lakes Region of Central Africa. This region has recently drawn heightened attention in Europe due to concerns regarding the situation in the eastern provinces of the Democratic Republic of Congo.

Traxys has proudly conducted business in Central Africa for over thirty years and has developed strong relationships and a reputation for excellence based on transparency and integrity in our operations. We adhere to all applicable laws, regulations, and international frameworks, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, EU Regulation 2017/821 on supply chain due diligence for tin, tantalum, and tungsten (together: “3T”) originating from CAHRAs, and EU Regulation 2024/1252 on a secure and sustainable supply of raw materials, as well as the Responsible Minerals Initiative (RMI). These frameworks recognize that continued responsible trade in minerals from Central Africa can provide critical income to tens of thousands of families in the region.

Traxys is committed to ethical, transparent and responsible business in Central Africa, including the DRC and neighboring countries, and does so with high standards of traceability and due diligence. Our responsible sourcing of 3T minerals from the region is based on three main pillars of due diligence, in accordance with the OECD guidance:
 

• Documentary due diligence: this starts with a rigorous Know Your Customer process during supplier onboarding, and follows through to independent, third-party, industry accepted, and OECD aligned traceability services provided for every cargo that Traxys sources from suppliers. This means that every tonne of product is physically tagged by independent traceability providers and documented as coming from conflict free mines, located in the country where it is documented to be sourced from. Such tagging is a contractual requirement – Traxys does not accept material that does not comply.
• Plausibility assessments: Throughout Traxys’ many years of sourcing in CAHRAs, we have become aware of what to expect from suppliers in terms of volume, grade, material appearance and specifications, including radiation. We employ the services of independent and reputable surveyors to sample, assay and photograph all our cargoes to mitigate material substitution risks and insert an additional check to all our sourcing in the regions where we operate. Contrary to what unsubstantiated allegations about Traxys have suggested, there is no credible evidence of meaningful variations in volume, appearance or specification of the minerals that Traxys has sourced in Rwanda since the re-commencement of the conflict in eastern DRC.
• On-the-ground due-diligence: Traxys has an in-region presence in Central Africa with our own employees regularly attending the loadings and monitoring the aggregation of our cargoes, further substantially reducing risks of minerals of potential conflict origin from entering our supply chains. Alongside monitoring the operations of suppliers, Traxys regularly exercises contractual inspection rights. Both our own employees and our suppliers’ due diligence officers conduct dozens of mine visits annually to ascertain the plausibility of output and material specifications every year. These mine visits and reports are conducted in accordance with the standards set by the RMI for audits of 3T smelters.

We remain vigilant and are confident that our enhanced due diligence practices, which have been further strengthened following the escalation of conflict in Central Africa, will continue to mitigate risks of contamination by illicit trade, smuggling, or any flows that finance rebel groups in the area.

Beyond sourcing, Traxys takes an active role in the due diligence of our onward supply chains of 3T minerals. All cargoes of mineral concentrates that Traxys has sourced from the Great Lakes Region of Central Africa have been delivered to smelters worldwide that have successfully passed Responsible Minerals Assurance Process (RMAP) audits and have conformant smelter status with the RMI.

Traxys firmly believes that ongoing responsible trade and access to international markets play a crucial role in supporting small artisanal miners and their communities in Central Africa as well as in generating tax revenue and stronger institutions. However, we recognize the challenges inherent in this sector and region and remain committed to clear, transparent, and constructive engagement with our partners and with regulators to strengthen frameworks that safeguard global supply chains. By holding ourselves and our business partners to high compliance standards, we strive to ensure that the sector operates responsibly and sustainably, enabling positive impacts for both local communities and international markets.    

TRAXYS S.à.r.l., Luxembourg

www.TRAXYS.com

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FGS Global: [email protected]