Baxter International Inc.
Conflict Minerals Report
For The Year Ended December 31, 2019
This Conflict Minerals Report for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Exchange Act). Rule 13p-1 under the Exchange Act (Rule 13p-1) imposes certain reporting obligations on Securities and Exchange Commission (SEC) registrants whose manufactured products contain minerals specified in Rule 13p-1 which are necessary to the functionality or production of their products. These minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively 3TG) for the purposes of Rule 13p-1. These requirements apply to registrants whatever the geographic origin of the 3TGs and whether or not they fund armed conflict.
Certain products manufactured by Baxter International Inc. (Baxter or the Company) are comprised of materials and components that contain 3TG that are necessary to the functionality and/or production of such product (see “Product Description” below). Due to the depth of its supply chain, the Company is far removed from the sources of ore from which these metals are produced and the smelters and refiners that process those ores. Additionally, the amount of information available globally on the traceability and sourcing of these ores is extremely limited, which is a situation that is not unique to the Company. As a result, the efforts undertaken by the Company to identify the countries of origin of those ores reflect the Company’s respective position in the supply chain and the challenge presented to it by the limited availability of information. The Company has taken steps to identify the applicable smelters and refiners of the 3TG in its supply chain and their respective source, but in general, the Company believes that these smelters and refiners are best situated to identify the sources and countries of origin of these metals. The efforts described herein were undertaken on the products manufactured by the Company (as described below) during the year ended 2019.
Product Description
The Company, through its subsidiaries, provides a broad portfolio of essential healthcare products, including acute and chronic dialysis therapies; sterile intravenous solutions; infusion systems and devices; parenteral nutrition therapies; inhaled anesthetics; generic injectable pharmaceuticals; and surgical hemostat and sealant products.
For the year ended December 31, 2019, this Conflict Minerals Report covers products manufactured by the Company and its subsidiaries. The following Company products are subject to disclosure under Rule 13p-1: hemodialysis machines, monitors and infusion pumps. The table below provides examples of where 3TG may be present in the Company’s products:
| | | | | | | | |
| Metal | Industry Applications | Applications in Baxter |
Tantalum Refined from Columbite-tantalite (coltan) | Capacitors, resistors | Tantalum Capacitors, Alloys |
Tin Refined from Cassiterite | Chemical solutions, capacitors, electrodes, Tin alloys, dioxide, electroplating | Integrated Circuits, Pins, Resistors, Capacitors, PCBs, and Soldering |
Tungsten Refined from Wolframite | Tungsten Carbide, Alloy, light bulb, heating elements, and Tungsten Inert Gas Welding | Electrodes, Welding |
| Gold | Electrical wiring, connectors, contact, and gold plating | Contacts, Pins, Connectors, Cable Harness, Wire Harness, gold plating |
Reasonable Country of Origin Inquiry (RCOI)
Direct suppliers of materials reasonably believed to contain 3TG were asked to provide answers to the Responsible Minerals Initiative’s (RMI) Conflict Mineral Reporting Template (CMRT) reflecting the Company’s position in the supply chain as described above. The RMI CMRT is regarded as the preferred reporting tool for 3TG content and sourcing information worldwide.
The Company, in conjunction with its third-party vendor, reviewed the CMRTs received for completeness and consistency of answers. Suppliers were asked to provide corrections and clarifications where needed. As a result, the Company believes that its RCOI process was reasonably designed and performed in good faith.
In 2020, the Company surveyed 318 significant suppliers, as determined by the Company, of which approximately 97.5% responded. However, these responses reflect the supplier’s overall supply chain and do not specify whether the 3TG was used in materials supplied to the Company.
Due diligence
Design of due diligence
The Company’s overall Conflict Minerals Program is designed to conform to the five-step framework of the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the relevant supplements on 3TG, as applicable to the Company’s circumstances and position in the supply chain as a “downstream” company with no direct influence on smelters and refiners. The Company designed its due diligence measures to conform in all material respects with the due diligence framework relevant to 3TGs provided by the OECD.
The large majority of the responses received provided data at the supplier company level or a division/segment level relative to the supplier, rather than at a level directly relating to a product supplied to us, or were otherwise unable to specify the smelters or refiners used for components supplied to us. We were therefore unable to determine whether the 3TG that these suppliers reported were contained in components or parts that the suppliers supplied to us or to validate that any of these smelters or refiners are actually in our supply chain.
Due diligence performed
Establish strong company management systems
Conflict minerals policy
The Company’s position on 3TGs is publicly posted at https://www.baxter.com/policies-positions/conflict-minerals-policy-position-statement. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Internal team
In 2019, the internal Conflict Minerals Core Team (Core Team) consisted of representatives from the Company’s procurement, environmental compliance, legal, and supplier quality functions. This Core Team reports regularly to senior management on direct suppliers’ responses to 3TGs information requests. The Core Team governs our conflict minerals compliance effort and is responsible for providing guidance and direction for the implementation of our Conflict Minerals Program.
We have also taken on other management systems that include the use of a third-party vendor. Through our vendor’s tool, we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor risks in our supply chain. The use of these tools and services has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
Control systems and grievance mechanism
Controls include a Code of Conduct (Code) that outlines expected behaviors for all employees, contractors, agents and third parties. This Code is publicly available on our website at https://www.baxter.com/our-story/our-governance/code-conduct. To this end, anyone can utilize our Ethics and Compliance Hotline as detailed in our Code to proactively report a violation of our Code or policies, including our Conflict Minerals Policy and related program efforts.
Maintain records
We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and provides for the maintenance of documentation for a period of 10 years.
Supplier engagement
With respect to the OECD objective to strengthen engagement with suppliers, we have utilized the CMRT version 5.11 or higher and a third-party vendor’s web-based reporting tool for collecting conflict minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our Conflict Minerals Program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.
We continue to emphasize supplier education and training. To accomplish this, we utilized our third-party vendor’s learning management system and provided all in-scope suppliers access to their conflict minerals training course. This training was tracked and evaluated based on completion. All suppliers were encouraged to complete all modules within this course.
Identify and assess risks in the supply chain
Due to the complexity of our products and the depth, breadth, and constant changes to our supply chain, it is difficult to identify sub-tier suppliers from our direct suppliers. We have relied on supplier responses to provide us with the information about the source of conflict minerals contained in the parts and components they supply to us.
Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. The basis of this understanding stems from smelter or refiner (SOR) information. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:
1.Geographic proximity to the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries);
2.Responsible Minerals Assurance Process (RMAP) audit status;
3.Known or plausible evidence of unethical or conflict sourcing.
We also calculate overall supplier risk based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of Rule 13p-1, however evaluating and tracking the strength of the program does meet the OECD Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria (items A, E, G and H from the CMRT) used to evaluate the strength of the program are:
A. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?
When suppliers meet or exceed the above criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
As a member of the RMI (Member Company ID: 5456), we support engagement by the RMI with SOR(s) and the obtainment of information on country of mineral origin, transit and transportation routes used between mine and smelters/refiners. We also support the RMI’s Responsible Minerals Assurance Process (RMAP), which includes an assessment of whether SORs have carried out all five steps of due diligence for responsible supply chains of 3TG from the Covered Countries and contribute directly to the RMI’s RMAP, which uses an independent third-party audit to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TG in our Covered Products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
Design and implement a strategy to respond to identified risks
We report our findings annually to the Core Team prior to the issuance of Form SD and this Conflict Minerals Report. We also report any significant due diligence findings to the Core Team as they arise. For example, if we find that we source 3TG that directly or indirectly finances or benefits armed groups in the Covered Countries, Baxter will assess the supplier relationship and encourage the supplier in question to establish an alternative source of 3TG that does not support such conflict. We have found no instance where it was necessary to implement risk mitigation efforts as a result of a supplier’s response to our information request.
Based on the smelter or refiner risk criteria noted above, for any facilities identified as being of highest concern to the supply chain as reported on a CMRT by any of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, submissions that include any of these high risk facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Baxter, and escalating up to removal of these high risk smelters from their supply chain.
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain. Furthermore, suppliers are guided to our third-party vendor’s learning management system to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
As a member of the RMI, we exercised leverage over upstream suppliers as the RMI provides in-region components of risk assessment and mitigation. Additionally, through this membership, we support the RMI’s efforts to monitor whether SOR(s) demonstrate significant and measurable improvement within six months from the adoption of their risk
management plans and, as noted above, we support the RMI’s independent third party audits of the SOR’s due diligence practices through the RMAP.
Carry-out independent third party audit of supply chain due diligence at identified points in the supply chain
We do not have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities. However, as noted above, we support the independent third-party audits of the SOR’s due diligence practices through the RMI's Responsible Minerals Assurance Process.
Report on supply chain due diligence
This Conflict Minerals Report, which constitutes our annual report on our due diligence efforts, is available on our website at https://www.baxter.com/policies-positions/conflict-minerals-policy-position-statement. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Results of due diligence
Survey results
As described above, Baxter actively surveys our supply chain and reviews the responses against criteria developed to determine whether further engagement is required. These criteria include: untimely responses, incomplete responses and inconsistencies within the data reported in the CMRT.
As of May 4th, 2020, we received responses from approximately 97.5% of our 318 surveyed suppliers for the 2019 year.
Efforts to determine mine or location of origin
Given that we do not have relationships with the ultimate smelters and refiners from which the 3TG in our products is sourced, we have determined that requesting our suppliers to complete the RMI Template and supporting the RMI programs and initiatives represent our good faith effort to determine the mines or locations of origin of 3TG in our supply chain.
Smelters and refiners
Of the suppliers surveyed, many completed the RMI template at the company, business unit or entity level and are unable to represent that 3TG from the processing facilities they listed had actually been included in components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continue to be varied. Many of the responses provided by supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit the form and include smelter information. There are still suppliers that are unable to provide SORs used for the materials supplied to us.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 235 smelters that are deemed RMAP Conformant – this indicates these smelters or refiners are compliant with the Responsible Minerals Assurance Process assessment protocols. There are seven more smelters or refiners that are deemed RMAP Active - smelters and refiners on the Active list have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 65 smelters listed have not yet been confirmed as Conflict-Free or are not part of RMAP. We have assessed these facilities and determined that most of these are of low risk due to their geographic location.
As detailed above, risk mitigation activities were initiated on the suppliers submitting high risk entries in their CMRT. These smelters or refiners, however, may not be present in the Baxter supply chain as these Baxter suppliers were only
able to provide company-level CMRTs which do not directly link those smelters or refiners to the products they provide to Baxter.
Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that our third-party has not been able to validate. Appendix B includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI.
Steps to be taken
We are committed to complying with the provisions of Rule 13p-1 and Form SD and expect to continue our Conflict Minerals Program and related due diligence. Our next steps may include, but are not limited to the following:
•Engage with suppliers and direct them to training resources increasing the number of suppliers who utilize our third-party vendor’s learning management system, with a goal of increasing our response rate, improving the content of responses and enhancing our RCOI process and efforts to determine the processing facilities for and country of origin of our 3TG with the greatest specificity possible;
•Via our third-party vendor, increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program
•Via our third-party vendor, encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
Appendix A:
The following smelters and refiners were reported by our suppliers as being in their supply chains.
| | | | | | | | |
| Metal | Standard Smelter Name | Smelter Facility Location |
| Gold | 8853 S.p.A. | Italy |
| Gold | Abington Reldan Metals, LLC | United States |
| Gold | Advanced Chemical Company | United States |
| Gold | African Gold Refinery | Uganda |
| 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 Corrego do Sitio Mineracao | 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 |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Aurubis AG | Germany |
| Gold | Bangalore Refinery | India |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Boliden AB | Sweden |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | C.I Metales Procesados Industriales SAS | Colombia |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Chimet S.p.A. | Italy |
| Gold | Chugai Mining | Japan |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Gold | DODUCO Contacts and Refining GmbH | Germany |
| Gold | Dowa | Japan |
| | | | | | | | |
| Gold | DS PRETECH Co., Ltd. | Korea, Republic of |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Geib Refining Corporation | United States |
| Gold | Gold Coast Refinery | Ghana |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Italpreziosi | Italy |
| Gold | JALAN & Company | India |
| 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 | Kaloti Precious Metals | United Arab Emirates |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| | | | | | | | |
| Gold | Kennecott Utah Copper LLC | United States |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of |
| Gold | Kundan Care Products Ltd. | India |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | LT Metal Ltd. | Korea, Republic of |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
| Gold | Materion | United States |
| 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 |
| 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 | Modeltech Sdn Bhd | Malaysia |
| Gold | Morris and Watson | New Zealand |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | NH Recytech Company | Korea, Republic of |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ogussa Osterreichische 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 | Pease & Curren | United States |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | QG Refining, LLC | United States |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Royal Canadian Mint | Canada |
| Gold | SAAMP | France |
| Gold | Sabin Metal Corp. | United States |
| Gold | Safimet S.p.A | Italy |
| Gold | SAFINA A.S. | Czech Republic |
| Gold | Sai Refinery | India |
| Gold | Samduck Precious Metals | Korea, Republic of |
| Gold | Samwon Metals Corp. | Korea, Republic of |
| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Singway Technology Co., Ltd. | Taiwan |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan |
| Gold | Sovereign Metals | India |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of |
| 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 | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Tony Goetz NV | Belgium |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| 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 |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Tantalum | Asaka Riken Co., Ltd. | Japan |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | CP Metals Inc. | United States |
| Tantalum | D Block Metals, LLC | United States |
| Tantalum | Exotech Inc. | United States |
| 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 |
| 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 |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | 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 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | PRG Dooel | N Macedonia, Republic of |
| Tantalum | QuantumClean | United States |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Telex Metals | United States |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Tin | Alpha | United States |
| 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 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Dowa | Japan |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | EM Vinto | Bolovia |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| 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 New Nanshan Technology Ltd. | China |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | 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 |
| 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 Metalurgicas S.A. | Bolivia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Precious Minerals and Smelting Limited | India |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Timah Tbk Kundur | Indonesia |
| Tin | PT Timah Tbk Mentok | Indonesia |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Rui Da Hung | Taiwan |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Super Ligas | Brazil |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Vietnam |
| Tin | Thaisarco | Thailand |
| Tin | Tin Technology & Refining | United States |
| 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 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Tungsten | A.L.M.T. Corp. | Japan |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | China Molybdenum Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tungsten | CP Metals Inc. | United States |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Haichuang 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 | GEM Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tungsten | H.C. Starck Tungsten GmbH | 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 | Hunan Litian Tungsten Industry 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 Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| | | | | | | | |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | Kennametal Fallon | United States |
| Tungsten | Kennametal Huntsville | United States |
| Tungsten | KGETS Co., Ltd. | Korea, Republic of |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | Vietnam |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Niagara Refining LLC | United States |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Wolfram Bergbau und Hutten 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 |
Appendix B:
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Argentina, Australia, Austria, Azerbaijan, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Burkina Faso, Burundi, Canada, Chile, China, Colombia, Congo - Democratic Republic of the, Cuba, Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, France, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Iran, Ivory Coast, Japan, Kazakhstan, Kenya, Laos, Liberia, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Portugal, Puerto Rico, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Slovakia, Solomon Islands, Somaliland, South Africa, Spain, Suriname, Swaziland, Sweden, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Viet Nam, Zambia, Zimbabwe
