Conflict Minerals Policy

Wogen Group (“Wogen”) condemns all activities in the raw material sector connected to illegal or unlawful exploitation of commodities and resources that, directly or indirectly, finances or benefits armed groups in conflict areas.

Wogen supports the goals and objectives of Section 1502 (“Section 1502”) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Act”), which aims to prevent the use of “Conflict Minerals” that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or adjoining countries (as defined in the Act).

The definition of “Conflict Minerals” refers to columbite-tantalite (coltan) (i.e., tantalum), cassiterite (i.e., tin), gold, wolframite (i.e., tungsten) or their derivatives, or others as may be designated by the U.S. Secretary of State in future, regardless of where they are sourced, processed or sold.

Wogen is committed to avoiding the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.

Wogen is committed to supporting its customers to comply with their reporting obligations required under Section 1502 of the Act, as well as the related rules and regulations issued by the SEC to ensure transparency and corporate social responsibility throughout the supply chain.

Wogen evaluates its suppliers on an ongoing basis to ensure continued compliance with this policy.  Wogen reserves the right to request any documentation from its suppliers regarding the source of any Conflict Minerals included in its products.  In addition, suppliers are required to maintain, and provide to Wogen upon request, historical traceability data.


  1. To support the aims and objectives of the U.S. legislation and other guidelines produced by international organisations on the supply of “conflict minerals”.
  2. To not procure specified metals that originate from facilities in the “Conflict Region” that are not proven as “conflict free” or in relation to which a relevant checklist has not been completed and certified by the supplier.
  3. To ensure compliance with these requirements, and ask our suppliers to undertake reasonable due diligence with their supply chains in order to ensure that specified metals are being sourced only from:
    • Mines and smelters outside the “Conflict Region” or;
    • Mines and smelters which have been deemed as “conflict free” if sourced within the “Conflict Region” as evidenced by all supporting traceability documentation as outlined in the OECD guidelines.

John Craig, CEO