Hague Fasteners Limited is committed to responsible sourcing and supply chain transparency in relation to Conflict Minerals, including tin, tantalum, tungsten and gold (3TG).
As a downstream manufacturer of bespoke fasteners and precision components, our approach aligns with internationally recognised due diligence frameworks, including the OECD Due Diligence Guidance and the Responsible Minerals Initiative.
This page outlines our policy, our position within the global supply chain, and provides access to our latest Conflict Minerals Reporting Template (CMRT).
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Our Position in the Supply Chain
Hague Fasteners Limited operates strictly as a downstream manufacturer. We do not source raw minerals directly from mines, smelters or refiners.
Our materials are procured as certified steel and alloy products via established stockholders and global distributors. These materials originate from complex international supply chains involving primary production, secondary processing and recycled content.
Material Traceability
Material origin and traceability are established through mill certification, which provides:
- Country of melt
- Producing mill identification
- Chemical and mechanical properties
Mill certification represents the recognised and auditable point of origin within the steel supply chain.
Traceability beyond this point, including attribution of specific smelters or refiners to individual parts, is not maintained within the industry and cannot be validated at component level.
Conflict Minerals Due Diligence
Our due diligence approach is aligned with internationally recognised frameworks:
- OECD Due Diligence Guidance
- EU Regulation 2017/821
- Responsible Minerals Initiative (RMI)
Further information can be found at:
https://www.responsiblemineralsinitiative.org/minerals-due-diligence
https://www.oecd.org/daf/inv/mne/mining.htm
https://policy.trade.ec.europa.eu/development-and-sustainability/conflict-minerals-regulation_en
Our process includes:
- Collection of supplier CMRT declarations
- Review and assessment of supply chain data
- Risk-based evaluation using reasonable country of origin inquiry (RCOI)
- Ongoing monitoring of supplier compliance
Scope and Limitations of CMRT Data
The Conflict Minerals Reporting Template (CMRT) is an industry-standard due diligence tool designed for company-level or defined supply chain reporting.
Accordingly:
- CMRT data is based on aggregated supplier information
- It reflects due diligence, not material certification
- It does not confirm the presence of 3TG within specific products
- It does not identify smelters linked to individual parts or batches
Product-level smelter attribution is not supported by steel supply chain traceability systems and cannot be substantiated.
Position on Product-Level Smelter Requests
Requests for product-level declarations requiring identification of specific smelters or refiners:
- Fall outside recognised due diligence frameworks
- Cannot be validated through mill certification
- Are not applicable to downstream manufacturers of steel components
Customers are encouraged to review the frameworks referenced above to understand the intended scope of Conflict Minerals reporting.
Our Commitment
Hague Fasteners Limited remains committed to responsible sourcing and ethical supply chain management.
We will not knowingly procure materials that contribute to conflict, human rights abuses or unethical practices. We require our suppliers to uphold equivalent standards and provide appropriate due diligence documentation.