https://www.najaru.com/uk/

AUDIT SUMMARY REPORTTHIRD – PARTY AUDIT
according REGULATION (EU) 2017/821 OF THE EUROPEANPARLIAMENT AND OF THE COUNCIL of 17 May 2017
laying down supply chain due diligence obligations for Union importers of tin,tantalum and tungsten, their ores, and gold originating from conflict-affected
and high-risk areas
according Article 6.1.

Audited company:
SENJU METAL EUROPE GMBH
Kirchnerstrasse 6-8,
Frankfurt am Main, 60311,
GERMANY

Audit date: 15.3.2024

Audit Report
SENJU METAL EUROPE GMBH

1. Audit information:
1.1. Audit Objectives (6.1.b): The determination of conformity of the SENJU METAL EUROPE GMBH 's
supply chain due diligence practices with Articles 4, 5 and 7 according REGULATION (EU) 2017/821.
Further step is the determination of conformity of the SENJU METAL EUROPE GMBH management
system with ISO 9001:2015 connected with supply chain due diligence practices with Articles 4, 5 and
7 according REGULATION (EU) 2017/821.
1.2. Audit scope according REGULATION (EU) 2017/821 (6.1.a): all of SENJU METAL EUROPE GMBH
activities, processes and systems used to implement supply chain due diligence regarding minerals ormetals, including SENJU METAL EUROPE GMBH management system, risk management, and disclosureof information in accordance with Articles 4, 5 and 7 respectively.
Audit scope according ISO 9001:2015: Selling and marketing of solder-materials.
Remark: In the company is no manufacturing shift, in company is administration office working hours
8:30-17:00.
1.3. Audited company: SENJU METAL EUROPE GMBH, Kirchnerstrasse 6-8, Frankfurt am Main, 60311,GERMANY.
1.4. Auditor: Mrs. Jana Rumanová, NAJARU Services s.r.o.
Me, auditor Jana Rumanova confirm independence and free of conflicts of interest and I confirm, thatthe audit I provided it with audit principles with integrity, fairness, professionalism, confidentiality,independence, evidence-based approach, risk -based approach, competence and accountability. I
confirm that all information connected with this audit are confidential.
The auditor Jana Rumanova is a qualified, independent third-party auditor, free of conflicts of interest,
having demonstrated relevant experience. Details of competence are in the final report.
1.5. Audit type: 3th party audit, Statutory/Regulatory
1.6. Audit date: 15.3.2024
1.7. Audit done: remotely
1.8. Standard for auditing: ISO 19011:2018
1.9. Audit language: English, German
1.10. Audit criteria: Requirements of REGULATION (EU) 2017/821 OF THE EUROPEAN PARLIAMENTAND OF THE COUNCIL of 17 May 2017 laying down supply chain due diligence obligations for Union
importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected andhigh-risk areas, Articles 4, 5 and 7 (hereinafter “Regulation (EU) 2017/821”), OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third
Edition, ISO 9001:2015.
1.11. Legislative: Requirements of REGULATION (EU) 2017/821 OF THE EUROPEAN PARLIAMENT AND
OF THE COUNCIL of 17 May 2017 laying down supply chain due diligence obligations for Union
importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and2
Copyright © 2024 NAJARU Services s.r.o . All Rights Reserved

Audit date 15.3.2024

Audit Report
SENJU METAL EUROPE GMBH

high-risk areas, Articles 4, 5 and 7 and the related OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition
1.12. Standard: ISO 9001:2015
1.13. Assessment Period: years 2023, partially year 2024 to the day 14.3.2024
1.14. Audit principles: Audit was provided according audit principles as are defined in ISO 19011:2018,according integrity, fairness, professionalism, confidentiality, independence, evidence-based
approach, risk -based approach and further competence and accountability.

2.1. General information
The audit is process-oriented and focused on risks. The audit was based on sampling therefore not allfindings found in the system may have been identified. Further the audit was targeted towards reliable
evidence. During audit were using interviews, observation of processes and activities, review ofdocumentation and records.

3. Audit Conclusion:
The audit was conducted in accordance with standard for auditing ISO 19011:2018 to focus thedetermination of conformity of the SENJU METAL EUROPE GMBH 's supply chain due diligencepractices with Articles 4, 5 and 7 according "REGULATION (EU) 2017/821 OF THE EUROPEANPARLIAMENT AND OF THE COUNCIL of 17 May 2017 laying down supply chain due diligence obligations
for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflictaffected and high-risk areas" 7 (hereinafter “Regulation (EU) 2017/821”).
Further step was the determination of conformity of the SENJU METAL EUROPE GMBH management
system with ISO 9001:2015 connected with supply chain due diligence practices with Articles 4, 5 and7 according REGULATION (EU) 2017/821.
The auditor verified the scope, selected samples, and gathered objective evidence throughdocumentation review, interviews, and visual observations.
Audit was provided according audit plan. There were no limitations to this audit.
In ANNEX III see Evaluation and Information about Requirements acc. REGULATION (EU) 2017/821.

Overall evaluation:
The company worked very proactively to meet requirements of the of "Regulation (EU) 2017/821",
Articles 4, 5 and 7 and OECD Due Diligence Guidance for Responsible Supply Chains of Minerals fromConflict-Affected and High-Risk Areas Third Edition” and ISO 9001:2015. The auditor confirm that theauditee’s due diligence system does comply fully with the requirements of the of "Regulation (EU)2017/821", Articles 4, 5 and 7 and OECD Due Diligence Guidance for Responsible Supply Chains ofMinerals from Conflict-Affected and High-Risk Areas Third Edition” and ISO 9001:2015. During audit
15.3.2024 were not detected nonconformities. During audit 15.3.2024 were checked and confirmed
the effective implemented corrective actions to the findings from audit 23.3.2023. Recommendations
from previous audit were implemented and closed too. Next, all measures regarding the findings fromDEKSOR from 6.3.2023 were effectively closed and confirmed from DEKSOR on 17.7.2023. No newrecommendations to the union importer from audit 15.3.2024 needed according audit result.

3Copyright © 2024 NAJARU Services s.r.o . All Rights Reserved

Audit date 15.3.2024