How to complete the Declaration on Honour?
The Declaration on Honour (DoH) is a mandatory document required for registering on the Platform and subscribing to the Raw Materials Mechanism (with a specific DoH for the role of central buyer). Please ensure that all sections of the DoH are completed thoroughly and accurately. This is essential to facilitate a smooth validation process of your registration and subscription request.
By signing the DoH, you (as the Administrator-User) make several specific declarations on behalf of your organisation (the Participant). This answer provides a summary and explanation of the DoH and those declarations. The DoH remains the only formal document that commits the Participant and serves as the exclusive reference for the content and scope of their declarations and commitments.
As a first step, you are asked to insert the name of the person who will act as Administrator-User. Then, you are asked to complete a table with the key information identifying your organisation (the Participant).
This section sets out the commitments and acknowledgements to be made by your organisation (the Participant) in relation to the general rules governing the Platform and the Raw Material Mechanism. By signing this declaration, your organisation:
- Confirms its intention to use the Platform in line with Articles 17 and 25 of Regulation (EU) 2024/1252, based on a genuine interest in submitting demand or supply, aggregating demand or offering services for strategic raw materials as defined in Annex I of Regulation (EU) 2024/1252;
- When acting as supplier or producer in the Raw Materials Mechanism, your organisation agrees to provide truthful information and supporting evidence regarding the origin of its supplies, to the best of their knowledge, and to provide additional complementary evidence upon request by the Commission;
- Confirms that it complies with all EU laws and standards necessary to participate in the Mechanism, including all relevant legislation and standards to place the materials under the scope of the Mechanism on the European market;
- Acknowledges that the use of the Platform is at its own responsibility, that any contract negotiation may take place outside the Platform, and that the Platform assumes no responsibility for the outcome of such negotiations;
- Agrees to comply with the Platform's Terms and Conditions, and
- Understands that information related to financial products, central buyer and storage services is provided for reference only and does not create any legal obligations.
In addition to the paragraph above, where the Participant registers as a Central Buyer, by signing the Declaration on Honour for participation as a Central Buyer, your organisation:
- Confirms its intention to use the Platform in line with Articles 17 and 25 of Regulation (EU) 2024/1252, based on a genuine interest in acting on behalf of other registered participants to submit demand for strategic raw materials as defined in Annex I of Regulation (EU) 2024/1252;
- Confirms that it will submit joint demand submission exclusively on behalf of participants with an active subscription to the Raw Materials Mechanism, on their request and with their consent;
- Acknowledges that acting as a Central Buyer is at its own risk, that any consent collection must take place outside the Platform, and that the Platform assumes no responsibility for the consent of registered participants.
Under point 1, you (as Administrator-User) confirm that your organisation (the Participant):
- Is not subject to EU sanctions banning transfer of economic resources or involving asset freezes;
- Is not owned, controlled, or acting on behalf of any individual or entity that is subject to such EU sanctions;
Under point 2 of this section, you also confirm that no funds or resources resulting from the involvement of your organisation in the Platform are provided, either directly or indirectly:
- To any person or entity that is subject to EU sanctions of the type described above; or
- To any person or entity that are owned, controlled by, or acting on behalf of, a person or entity under such sanctions.
This section of the DoH seeks to ensure that the Participant meets integrity, legal, and financial eligibility standards required for participation in the Platform. Such standards are equivalent to those applicable to economic operators participating in public procurement procedures organized by the EU institutions or Member States’ authorities.
Under this section, you (as the Administrator-User) declare that your organisation (the Participant) is not in one of the following situations:
- is not bankrupt or in insolvency, liquidation, or similar proceedings;
- has not been officially found to have failed to pay taxes or social security contributions;
- has not been found guilty of serious professional misconduct, such as violating laws, ethical standards, or engaging in dishonest or anti-competitive behaviour;
- has not been convicted of crimes such as fraud, corruption, involvement in organised crime, money laundering, terrorism, child labor, or human trafficking;
- has not seriously failed to meet key obligations under any past EU-funded contracts or agreements;
- has not been found guilty of committing financial irregularities affecting EU funds;
- has not created a company in another country to avoid taxes, social or legal obligations;
- was not itself created for the purpose of avoiding such legal obligations.
In this section, you (as the Administrator-User) are asked to provide details on your organisation's ownership structure. This information is required (and will be used) solely for the validation process, as part of the due diligence system regarding the legal requirements for participation in the Platform.
Please complete all tables in this section of the DoH thoroughly and accurately to help ensure a smooth validation of your registration and subscription request.
First, you must specify whether your organisation is listed on a stock exchange market and if it is a subsidiary of another listed company or controlled by one.
If yes, you must specify the stock exchange, the name of the listed company, and the floating share.
| D.1 Listing on a stock exchange | |
|---|---|
| D.1.a) Is the Participant listed on a stock exchange? | YES/NO |
| D.1.b) Is the Participant a subsidiary of a listed company? | YES/NO |
| D.1.c) Is the Participant controlled by a listed company? | YES/NO |
| If the reply is YES to any of questions D.1.a), D.1.b), or D.1.c) please answer the following questions: | |
| D.1.e) Which stock exchange? | |
| D.1.f) Legal name of the listed company: | |
D.1.g) Share of the float in the total outstanding shares: 'Floating stock' is the result of subtracting closely-held shares from the total number of issued shares. It represents the portion available for unrestricted trade on a regulated stock market. | |
Second, you must provide information on any significant owner or shareholder of your organisation (the Participant) following the instructions in the box.
| D.2 Ownership structure and specific rights | ||||
|---|---|---|---|---|
In the table below, detail any owners of the Participant that:
[1] This includes voting agreements between shareholders that would together have more than 5% of the voting rights or 5% of the capital. Please add rows if needed. | ||||
| Owner name | Country of establishment/ or nationality | How is the ownership/control held | Specific rights attached to shares | |
| By share [%] | By voting right [%] | |||
Third, you must indicate whether your organisation is state-owned, following the instructions provided in the box.
If it is, please specify the percentage of State ownership and identify the State concerned.
| D.3 State ownership | |
|---|---|
| D.3.a) Is the Participant partly or fully state-owned, directly or through public bodies, institutions, funds, investment vehicles or state-owned enterprises? | YES/NO |
| If YES, please answer the following questions: | |
| D.3.b) What is the share of State ownership? | [Please indicate share of State ownership] |
| D.3.c) Which State? | [Please indicate State] |
Fourth, you must indicate whether your organisation has received public funds (such as grants, subsidies, loans, or guarantees) or been awarded public contracts that required integrity screening within the past two years. The two-year period should be calculated from the date of the agreement granting public funds or the public contract.
If applicable, please specify the country of the public authority that provided the funding or awarded the contract.
| D.4 Public funding and public contracts | |
|---|---|
| D.4.a) In the last two years, was the Participant granted (EU or national) public funds (in the form of grants, subsidies, loans or guarantees) requiring integrity screening? | YES/NO |
| D.4.b) In the last two years, was the Participant awarded public contracts requiring integrity screening? | YES/NO |
| If YES, please answer the following questions: | |
| D.4.c) In which country is the authority that granted the public funds or awarded the public contract based? | [Please indicate country] |
Fifth, you must provide details on the beneficial owners of your organisation, following the instructions provided in the box. This refers to the concept of beneficial ownership as defined in anti-money laundering and counter-terrorism financing rules - specifically, Article 3(6) of Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
| D.5 Beneficial ownership | |||||
|---|---|---|---|---|---|
In the table below, provide details about any natural person(s) who ultimately owns or controls the Participant through direct or indirect ownership of a sufficient percentage (at least 25%) of the shares or voting rights or ownership interest, including through bearer shareholdings, or through control via other means. Please add rows if needed. | |||||
| Beneficial owner name | Country of nationality | Date of birth | Place of birth | How is the ownership/control held | |
| By share [%] | By voting right [%] | ||||
In the final section of the DoH, you (as the Administrator-User) confirm that the declaration is truthful, and that the ownership information provided is accurate. You also confirm, to the best of your knowledge, that your organisation is not directly or indirectly controlled by individuals or entities subject to EU sanctions, including through any other arrangements or financial and commercial links.
The Administrator-User certifies that
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In this section of the DoH, you (as the Administrator-User) declare that if the Participant is acting on behalf of third parties—such as through a consortium—all such third parties also comply with the terms of the Declaration on Honour.
You acknowledge that the Commission may request any necessary documents to verify the declarations made by the Participant or any third party it represents. A separate DoH may also be required from those third parties.
In the final declarations, you (as the Administrator-User) confirm that your organisation (the Participant) accepts the Platform's terms and conditions, is not in a conflict of interest, and agrees to comply with EU and national laws. They acknowledge that the Commission may revoke access if false or incomplete information is provided, and that any changes to the situations as declared must be reported immediately.
The Declaration on Honour must be signed by a representative authorised to act on behalf of the Participant, using a Qualified Electronic Signature (QES) that complies with the eIDAS Regulation.
Alternatively, the DoH may be signed with handwritten signature. In that case, a scan of the signatory's ID document (passport or national identity card) must be uploaded during the Participant's registration, and the original document must be retained for verification purposes.
Participants who need to update or change their Declaration on Honour (DoH) should contact the Platform support team directly for assistance.
You can find the Declaration on Honour template for the Raw Materials Mechanism here.