CMCulmen Metals
deen

Compliance

Brokerage without ownership – set out step by step.

Trust is built on verifiable procedures. This page explains the role Culmen Metals takes, which agreements govern the cooperation and at which point the success-based commission arises.

A role without ownership

Culmen Metals acts solely as an intermediary. Purchase and supply contracts are concluded directly between feedstock supplier, processor and offtaker. This results in a clear division of responsibilities:

  • No ownership of the material and no proprietary trading on our own account.
  • No hidden margin inside the material price; our compensation is disclosed.
  • No storage, no transport and no waste holder status on our side.
  • Both market sides know the broker's role before conversations begin.

Contractual basis

Before identifying information is exchanged, the framework is put in writing.

NDA
Non-disclosure agreement covering technical data, assays and volumes before any details are shared.
NCNDA
Non-Circumvention, Non-Disclosure Agreement: protects the introduced contacts on both sides against circumvention and defines how long that protection lasts.
IMFPA
Irrevocable Master Fee Protection Agreement: irrevocably fixes the amount, calculation basis, due date and payment route of the commission.
Brokerage agreement
Concluded in addition between Culmen Metals and the paying party; German law, place of jurisdiction Offenbach am Main.

From first contact to commission

01

Initial call and classification

Clarifying the market side, the material and the timeframe. No counterparties are named at this stage.

02

NDA and material data

Once the non-disclosure agreement is signed, specification, assay values, volumes and proof of origin follow.

03

Due diligence on both sides

Company identification, sanctions and export control screening, waste law classification and plausibility of origin.

04

NCNDA/IMFPA and introduction

With non-circumvention signed and the commission fixed, the parties are introduced to each other.

05

Negotiation and sampling

The parties negotiate price and terms directly. Sampling, analysis and release take place between them; we accompany the process.

06

Closing and commission

Once the brokered transaction is fulfilled – delivery and payment received – the commission agreed in the IMFPA falls due.

Success-based commission

Amount
Agreed individually for each transaction – depending on material, volume, market situation and effort.
Calculation basis
The invoiced value of the brokered transaction as fixed in the IMFPA.
When it arises
Only on successful closing and fulfilment – no upfront or retainer fees.
Paying party
Agreed case by case, usually the side that wins the deal.
Transparency
Both sides are informed that a commission exists and at what level.

Checks before every introduction

  1. 01Identification of the companies involved and the individuals acting for them.
  2. 02Screening against EU sanctions lists and review of export control requirements.
  3. 03Waste and transport law classification of the material, including shipment questions.
  4. 04Plausibility review of origin, assay values and volumes.
  5. 05Documentation of all review steps to keep the supply chain traceable.

Request the documents

NDA, NCNDA and IMFPA templates are available on request. Tell us your market side and your material.

Go to enquiry

This description sets out the usual procedure and does not constitute legal advice. The agreements concluded in each individual case prevail.