Exhibit 1.01
Conflict Minerals Report
For Calendar Year 2017
This is The Walt Disney Company’s 2017 (January 1 to December 31, 2017) Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 of the Securities and Exchange Commission (the “Conflict Minerals Rule”).
Background
The Walt Disney Company, together with its subsidiaries, is a diversified worldwide entertainment company. Throughout 2017, the Company operated with four business segments: Media Networks, Parks and Resorts, Studio Entertainment and Consumer Products and Interactive Media. For convenience, the terms “Company,” “Disney” and “we” are used in this CMR to refer collectively to the parent company and its consolidated subsidiaries through which our various businesses are actually conducted.
The Company derives the vast majority of its revenues from the licensing of intellectual property, the sale of advertising time, and charges for entertainment, lodging and associated food and beverage sales at its theme parks, resorts, and cruise lines. We also derive revenue from the sales of physical products (such as physical copies of films and music) that we have determined do not include columbite-tantalite, cassiterite, gold, wolframite or their derivatives (collectively, the “Subject Minerals”) as necessary to the products’ functionality or production (“necessary Subject Minerals”).
The products we sell that may include necessary Subject Minerals are items such as clothing, accessories, electronic toys, jewelry, and other consumer goods. We classify these items together as retail merchandise, and that is the product category covered by this CMR. We sell many of these items directly through Disney Stores throughout the world, including our online stores, and at our entertainment venues, including our parks and resorts. We also sell retail merchandise wholesale to other retailers.
The sale of retail merchandise constituted less than 10% of our revenue in calendar 2017. The number of individual items sold is, however, large. We estimate that we sold retail merchandise with approximately 181,000 stock-keeping units (SKUs) in calendar 2017. Moreover, due to the dynamic nature of our business, the items we sell change rapidly, with many items sold for only a few months, and then replaced by other items sourced from other suppliers.
The Company does not manufacture any of the retail merchandise it sells, sourcing the specific merchandise items that may contain Subject Minerals from over 1,000 suppliers in calendar 2017. Many of our suppliers themselves source components of these items from numerous other suppliers, and our direct suppliers are often many steps removed from the source of the raw materials contained in the items. In addition, in many cases the items we acquire from a supplier represent a small portion of the supplier’s total production.
The number, diversity and frequent turnover of the retail merchandise we sell, the number and turnover of suppliers, and our remote position in the supply chain make it difficult for us to determine and track
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the source of individual items, the nature of the raw materials included in the items, and the source of those raw materials. Nevertheless, our Conflict Minerals Compliance Program is designed to gain relevant information about the sources of raw materials in our products that is as complete as reasonably possible given the large number and diversity of products we sell and in light of our position in the supply chain.
Our Conflict Minerals Compliance Program (the “Program”) is focused on identifying suppliers of retail merchandise that may contain necessary Subject Minerals and gathering information about the supply chain practices of those suppliers. The Program conforms to the elements of the guidance set forth in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD Guidance) that are required by the Conflict Minerals Rule, and thus includes:
| • | strong company management systems (including a Conflict Minerals Policy and an established internal management structure); |
| • | identification and assessment of risk in the supply chain through a reasonable country of origin inquiry; |
| • | a strategy to respond to identified risks through due diligence procedures that include follow up with suppliers who either provide insufficient information to identify sources of necessary Subject Minerals or who provide information indicating that they may source necessary Subject Minerals that may have originated in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”); and |
| • | reporting on results of the Program. |
These elements of the Program, and the results of the Program for 2017, are described below.
Company Management Systems
| 1. | Conflict Minerals Policy. The Company’s Conflict Minerals Policy sets forth the steps we are taking to comply with the Conflict Minerals Rule. These steps include: the establishment of the internal management structure described below; engagement with suppliers as described in this report; reporting required by the Conflict Minerals Rule; and monitoring developments relating to conflict minerals with an eye to enhancing the Program. Our policy was distributed to suppliers who may supply us with products covered by the rule and is posted on our website at https://www.thewaltdisneycompany.com/wp-content/uploads/Conflict-Minerals-Policy.pdf. The policy includes a mechanism for reporting concerns or asking questions regarding the policy. |
| 2. | Internal Management Structure. A management oversight structure that includes input from executive-level representatives of Legal, Investor Relations, Controllership, Corporate Communications, Global Public Policy, and Global Product & Labor Standards. These executives are responsible for providing governance and oversight over the execution of the Program and for monitoring the Program’s compliance with regulatory requirements and satisfaction of enterprise goals. The day-to-day implementation of the Program is conducted by a Conflict Minerals Compliance Program Team within our Global Product & Labor Standards organization, which reports to an executive officer of the Company. |
| 3. | Chain of Custody and Traceability. Support for and engagement with the Responsible Minerals Initiative (RMI). The data on which we relied for certain statements in this report |
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was obtained through our membership in RMI, using the Reasonable Country of Origin Inquiry report for member DISN.
Identification and Assessment of Risk Through Reasonable Country of Origin Inquiry
Based on lists of historic suppliers of retail merchandise updated through interviews with sourcing executives, we compile a list each year of the suppliers we are able to identify as supplying retail merchandise in the prior calendar year that may contain necessary Subject Minerals.
Each year, we distribute a survey to these suppliers regarding their supply chain practices relating to Subject Minerals. The 2017 survey was based on RMI’s Conflict Minerals Reporting Template (CMRT), revision 5.0 or higher. We supplemented this template with additional multi-language questions designed to provide visibility into our suppliers’ sourcing activities, including the basis for their responses regarding the source of Subject Minerals in the retail merchandise they supplied to us. We also provided suppliers with access to a live technical support specialist via chat during the survey phase, provided multi-language training documents highlighting Frequently Asked Questions on Conflict Minerals and Section 1502 of the Dodd-Frank Wall-Street Reform and Consumer Protection Act, as well as instructions on how to complete the CMRT. Our communications included our expectations for response and noted that the Conflict Minerals Rule was not intended to stop companies and their suppliers from sourcing from the Covered Countries and that such an embargo would be contrary to the intent of the Conflict Minerals Rule.
In 2017, we continued to refine the method of identifying suppliers that are within the scope of the Conflict Minerals Rule and surveyed 1,064 suppliers of retail merchandise that we sell to our customers. We received survey responses from 763, or 72%, compared to a response rate of 71% for calendar 2016. We received survey responses from, or otherwise corresponded with, 100% of our 100 largest suppliers by spend of merchandise for resale and 95% of the suppliers we initially identified as most likely to be supplying us with products that contained Subject Minerals. Our response rate since the start of our Program is shown in Figure 1 below.
1 For Calendar Year 2014, due to improved systems and processes, we were better able to identify in-scope suppliers thereby resulting in a 46% reduction in the survey population.
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The vast majority of the suppliers who completed the survey responded that the merchandise they supplied to us did not contain any necessary Subject Minerals. Based on survey responses, interviews, and our further review of the retail merchandise supplied, we identified 163 suppliers who manufactured retail merchandise for us that most likely contained necessary Subject Minerals. Of these suppliers:
| • | Eight suppliers responded that the Subject Minerals in all the products it supplied to us did not originate in the Covered Countries, and they provided sufficient information regarding their supply chain program for us to determine that this response was reliable; |
| • | Seven suppliers responded that the Subject Minerals in at least some of the products it supplied to us originated in the Covered Countries. As noted below, we determined that these suppliers only sourced Subject Minerals in the Covered Countries from smelters and refiners that are compliant with the RMI’s Responsible Minerals Assurance Process (RMAP). |
| • | The remaining suppliers could not determine the country of origin of all of the necessary Subject Minerals in products supplied to us for resale by us or could not provide sufficient information regarding the materials used to manufacture our products for us to determine the country of origin. |
Due Diligence Measures Performed
Based on our assessment of survey responses in 2017, we implemented due diligence measures with respect to suppliers who (1) may have manufactured retail merchandise for us containing Subject Minerals and (2) had not reliably demonstrated that the Subject Minerals were not sourced from Covered Countries. These measures included:
| • | Performance of targeted follow-up with suppliers who did not initially respond to the survey. |
| • | Verification of information regarding smelters and refiners provided by our suppliers with the RMI’s list of conflict-free smelters and refiners and other lists provided by accredited organizations such as London Bullion Market Association (LBMA) or Responsible Jewelry Council (RJC). Through this effort, we determined that the smelters and refiners in the Covered Countries that were identified by seven of our suppliers were all compliant with the RMI’s RMAP. |
| • | Requests for additional information (e.g., certificate of material analysis and bill of materials,) from suppliers whom we determined supplied items containing Subject Minerals and who provided information that was insufficient for us to determine reliably the source of Subject Minerals in retail merchandise manufactured for us. Through this effort, we were able to obtain more reliable information about the presence of Subject Minerals in items supplied to us and obtain additional smelter and refiner information. |
| • | Encouragement of suppliers who provided insufficient information regarding their supply chain to develop more robust supply chain information programs and policies. |
| • | Encouragement of suppliers who may have sourced Subject Minerals (or product components from sub-suppliers who may have sourced Subject Minerals) from non-compliant smelters or refiners to source from smelters and refiners who are compliant with the relevant RMAP assessment protocols of the RMI, or from another accredited organization. |
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Smelters, Refiners, and Countries of Origin Information
The suppliers who manufactured retail merchandise for us that we determined contained necessary Subject Minerals identified 259 smelters or refiners that supplied them with Subject Minerals. Although we cannot determine whether retail merchandise manufactured for us contained Subject Minerals from each of these 259 smelters and refiners, we have listed each of them in Attachment A. All but 15 of these smelters and refiners are compliant, or conformant, with the relevant RMAP assessment protocols of RMI and/or another accredited organization. Figure 2 shows compliance by mineral.2
Based on the information provided by our suppliers, we have been able to determine that:
| • | of the 259 smelters and refiners identified in Attachment A, 19 are identified by RMI as sourcing Subject Minerals from Covered Countries; |
| • | each of these 19 smelters and refiners were determined by RMI to be conformant with the relevant RMAP assessment protocols of the RMI; and |
| • | the countries of origin of the Subject Minerals supplied by the smelters and refiners included in Attachment A may include those countries listed in Attachment B. |
However, we cannot determine: whether the 15 smelters and refiners who are not conformant with the relevant RMAP assessment protocols of the RMI, or another accredited organization, sourced from Covered Countries; whether gold smelters certified by the RJC or LBMA sourced from the Covered Countries; and whether the suppliers who provided us with insufficient information regarding the source of Subject Minerals sourced Subject Minerals from the Covered Countries. Therefore, we are unable to determine either the facilities used to process or the source (country, mine or other location) of necessary Subject Minerals for all of the retail merchandise we sell.
2 Of the 95 gold conformant smelters, 71 were also found to be certified by the LBMA and/or RJC.
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Further Development of Disney’s Conflict Minerals Compliance Program
Our efforts with respect to 2017 were devoted to managing the response rate to our supplier survey, improving our conflict minerals survey tool, and implementing internal process efficiencies. We achieved these goals by enhancing our third-party conflict minerals solution and developing our internal expert resources. We continued to encourage suppliers to improve their supply chain policies, source responsibly, and to source Subject Minerals from (or from sub-suppliers who source from) smelters and refiners who are compliant with the relevant RMAP assessment protocols of RMI or any other accredited organization. In 2017 we saw year-over-year improvement from existing suppliers in providing information regarding their supply chain policies and in efforts to identify smelters in their supply chain. Each year we also encourage new suppliers in our supply chain to provide us with this information and to source from compliant smelters and refiners.
We continue to focus on refining our systems for identifying relevant suppliers and the product categories associated with each supplier, and on obtaining additional and more reliable information on each supplier’s own supply chain. We also continue to evaluate the overall quality of supply chain practices of our suppliers, the impact of encouraging adoption of robust supply chain practices in light of developing supply chain certification programs, the practices of our suppliers, and whether it is helpful and feasible to give them further incentives to strengthen their supply chain programs.
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Attachment A
Smelters and Refiners
Identified by Suppliers
The following table identifies each of the smelters and refiners identified by our suppliers as sources of Subject Minerals in retail merchandise manufactured by the supplier. The table includes the name of the smelter or refiner, the Subject Minerals supplied by the smelter or refiner, and the location of the smelter or refiner. Our suppliers could not confirm whether each smelter or refiner they used supplied Subject Minerals in retail merchandise manufactured for the Company. All but 15 of the smelters and refiners identified below are currently conformant with RMAP assessment protocols of the RMI or other accredited organizations. Disney has encouraged its suppliers to work with the non-conformant smelters to gain certification from RMI or other accredited organization, or to source from certified smelters or refiners.
| Subject Mineral | Smelter or Refiner Name | Location |
| Gold | Advanced Chemical Company | United States of America |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | Asahi Refining USA Inc. | United States of America |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Aurubis AG | Germany |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Boliden AB | Sweden |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Chimet S.p.A. | Italy |
| Gold | Daejin Indus Co., Ltd. | Korea, Republic of |
| Gold | DODUCO GmbH | Germany |
| Gold | Dowa | Japan |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of |
| Gold | Eco-System Recycling Co., Ltd. | Japan |
| Gold | Elemetal Refining, LLC ** | United States of America |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Geib Refining Corporation | United States of America |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Guangdong Jinding Gold Limited *** | China |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
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| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Japan Mint | Japan |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States of America |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | Materion | United States of America |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Metalor USA Refining Corporation | United States of America |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | OJSC Novosibirsk Refinery | Russian Federation |
| Gold | PAMP S.A. | Switzerland |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | PX Précinox S.A. | Switzerland |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Republic Metals Corporation | United States of America |
| Gold | Royal Canadian Mint | Canada |
| Gold | SAAMP | France |
| Gold | Safimet S.p.A | Italy |
| Gold | Samduck Precious Metals | Korea, Republic of |
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| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | Schone Edelmetaal B.V. | Netherlands |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province of China |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | T.C.A S.p.A | Italy |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Torecom | Korea, Republic of |
| Gold | Umicore Brasil Ltda. | Brazil |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | United Precious Metal Refining, Inc. | United States of America |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Western Australian Mint trading as The Perth Mint | Australia |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | Conghua Tantalum and Niobium Smeltry | China |
| Tantalum | D Block Metals, LLC | United States of America |
| Tantalum | Exotech Inc. | United States of America |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Global Advanced Metals Boyertown | United States of America |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | H.C. Starck Inc. | United States of America |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
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| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | KEMET Blue Powder | United States of America |
| Tantalum | King-Tan Tantalum Industry Ltd. ** | China |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Mineração Taboca S.A. | Brazil |
| Tantalum | Mitsui Mining & Smelting | Japan |
| Tantalum | Molycorp Silmet A.S. | Estonia |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | Power Resources Ltd. | Macedonia, the former Yugoslav Republic of |
| Tantalum | QuantumClean | United States of America |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemicals | Japan |
| Tantalum | Telex Metals | United States of America |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China |
| Tin | Alpha | United States of America |
| Tin | An Vinh Joint Stock Mineral Processing Company *** | Vietnam |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. ** | China |
| Tin | Cooperativa Metalurgica de Rondonia Ltda. ** | Brazil |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | CV Dua Sekawan | Indonesia |
| Tin | CV Gita Pesona | Indonesia |
| Tin | CV Serumpun Sebalai | Indonesia |
| Tin | CV Tiga Sekawan | Indonesia |
| Tin | CV United Smelting | Indonesia |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Dowa | Japan |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company *** | Vietnam |
| Tin | EM Vinto | Bolivia |
| Tin | Estanho de Rondonia S.A. *** | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China |
| Tin | Gejiu Jinye Mineral Company | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
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| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. * | China |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tin | Linwu Xianggui Smelter Co. ** | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | Metallic Resources, Inc. | United States of America |
| Tin | Metallo Belgium N.V. | Belgium |
| Tin | Metallo Spain S.L.U. | Spain |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | Minsur | Peru |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | Modeltech Sdn Bhd * | Malaysia |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company *** | Vietnam |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Operaciones Metalurgical S.A. | Bolivia |
| Tin | Pongpipat Company Limited *** | Myanmar |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | PT Bangka Serumpun | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT DS Jaya Abadi | Indonesia |
| Tin | PT Eunindo Usaha Mandiri | Indonesia |
| Tin | PT Inti Stania Prima | Indonesia |
| Tin | PT Karimun Mining | Indonesia |
| Tin | PT Kijang Jaya Mandiri | Indonesia |
| Tin | PT Lautan Harmonis Sejahtera | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
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| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Sumber Jaya Indah | Indonesia |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Rui Da Hung | Taiwan, Province of China |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Super Ligas *** | Brazil |
| Tin | Thaisarco | Thailand |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company *** | Vietnam |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Yunnan Tin Company Limited | China |
| Tungsten | A.L.M.T. Tungsten Corp. | Japan |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States of America |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China |
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| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Kennametal Fallon | United States of America |
| Tungsten | Kennametal Huntsville | United States of America |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Moliren Ltd | Russian Federation |
| Tungsten | Niagara Refining LLC | United States of America |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam |
| Tungsten | Wolfram Bergbau und Hütten AG | Austria |
| Tungsten | Woltech Korea Co., Ltd. | Korea, Republic of |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
* These smelters are engaged in communication with RMI but not yet conformant.
** These smelters have ceased operations.
*** These smelters are not conformant with RMI’s RMAP or any other accredited organizations.
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Attachment B
Countries of Origin
The following table identifies the countries of origin of the smelters and refiners identified in Attachment A and is based on the smelters and refiners provided by our suppliers and the RMI's reasonable country of origin data, which provides country of origin data for those smelters and refiners.
| Argentina | Laos |
| Australia | Madagascar |
| Austria | Malaysia |
| Benin | Mali |
| Bolivia | Mexico |
| Brazil | Mongolia |
| Burkina Faso | Mozambique |
| Burundi | Myanmar |
| Cambodia | Namibia |
| Canada | Nicaragua |
| Chile | Nigeria |
| China | Panama |
| Colombia | Peru |
| Democratic Republic of the Congo | Portugal |
| Ecuador | Russian Federation |
| Eritrea | Rwanda |
| Ethiopia | Senegal |
| France | Sierra Leone |
| Germany | South Africa |
| Ghana | Spain |
| Guatemala | Thailand |
| Guinea | Togo |
| Guyana | Uganda |
| Honduras | United Kingdom of Great Britain and Northern Ireland |
| India | United States of America |
| Indonesia | Uzbekistan |
| Japan | Vietnam |
| Kazakhstan | Zimbabwe |
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