Exhibit 1.01
CONFLICT MINERALS REPORT OF PHILIP MORRIS INTERNATIONAL INC. FOR THE YEAR ENDED DECEMBER 31, 20191
INTRODUCTION
Philip Morris International Inc. is a Virginia holding company incorporated in 1987. Our subsidiaries and affiliates and their licensees are engaged in the manufacture and sale of cigarettes, other tobacco products and other nicotine-containing products in markets outside of the United States of America.
This Conflict Minerals Report (the “Report”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1 to December 31, 2019.
Conflict Minerals are defined by the Securities and Exchange Commission (“SEC”) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, “3TGs”). During the reporting period, we contracted to manufacture the following products:
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| • | Platform 1 - a precisely controlled heating device incorporating our IQOS HeatControl Technology, commercialized under the IQOS brand name, into which a specially designed and proprietary tobacco unit is inserted and heated to create an aerosol, as well as related accessories and parts; and |
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| • | Platform 4 - battery powered e-vapor products that produce an aerosol by vaporizing a nicotine-containing liquid solution; the current generation technology products, commercialized under the Nicocigs and Vivid brand names, and the new e-vapor technology products, commercialized using the IQOS MESH brand name. |
In this report, we refer to Platform 1 and Platform 4 products as “Covered Products.”
In 2019, we sourced the Covered Products from only four direct suppliers (the “Direct Suppliers”). The electronic components of the Covered Products contain one or more 3TGs; such 3TGs are necessary for the functionality or production of the Covered Products.
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1 In this report, “PMI,” “Company,” “we,” “us,” and “our” refers to Philip Morris International Inc. and its subsidiaries. Trademarks and science marks in this report are the intellectual property of, or licensed by, the subsidiaries of Philip Morris International Inc. and are italicized.
We have implemented policies, procedures and a due diligence process to determine whether any of the 3TGs contained in the Covered Products are sourced from the Democratic Republic of the Congo (“DRC”) or any of its adjoining countries (“Covered Countries”) and finance armed conflict in the region. In order to support the economic activity in the region, we have communicated to our Direct Suppliers that we do not discourage them from sourcing 3TGs from the Covered Countries under our Conflict Minerals Policy (“Policy”), so long as they are determined to be “DRC conflict-free.”
We are far removed from the sources of ores from which the 3TGs contained in the Covered Products are procured and the smelters and refiners that process those ores (“SORs”). Therefore, the efforts to identify the countries of origin for the 3TGs reflect both (i) our downstream position in the supply chain2; and (ii) the applicable OECD guidance described below.
DUE DILIGENCE MEASURES
A. Design of Our Due Diligence Measures
Our Conflict Minerals due diligence was performed in line with the internationally recognized due diligence framework provided by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”), as applicable for 3TGs and downstream companies (as the term “downstream companies” is defined in the OECD Guidance). Our due diligence measures in relation to Covered Products included:
1. Establishing Company management systems and forming a dedicated cross-functional team for carrying out Conflict Minerals supply chain due diligence and reporting compliance;
2. Identifying and assessing Conflict Minerals risks in our supply chain;
3. Designing and implementing strategies to respond to Conflict Minerals risks to the extent identified;
4. Encouraging the reliance by our Direct Suppliers on an independent third-party audit protocol for assessing the due diligence practices of SORs relevant to Covered Products; and
5. Reporting on our supply chain due diligence activities, as required by Rule 13p-1.
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2 As a result of our downstream position in the supply chain, our due diligence processes are based on the necessity of seeking data from our Direct Suppliers and those suppliers seeking similar information in their respective supply chains to identify the original sources of the applicable Conflict Minerals. We also rely, to a large extent, on information collected and provided by third-party validation programs. Such sources may yield inaccurate or incomplete information.
B. Due Diligence Program Elements
1. Management Systems
Conflict Minerals Policy
We adopted our Conflict Minerals Policy and communicated it to our Direct Suppliers to help achieve responsible sourcing of 3TGs in our supply chain. We are committed to operating with integrity and are focused on the responsible sourcing of 3TGs. Our Policy is subject to regular reviews, is attached to this Report as Appendix A, and is publicly available on our website at: https://www.pmi.com/principles-and-positions/standards/transparency.
Internal Team
Under the oversight of our Senior Vice President, Operations, we have a cross-functional conflict minerals team, with the expertise in sourcing, operations, sustainability, investor relations, finance and law. In addition, the conflict minerals team has access to specialists working in various functions throughout PMI.
The conflict minerals team has the overall responsibility for developing and implementing our Conflict Minerals compliance strategy, as well as for reviewing the ongoing progress and effectiveness of the Conflict Minerals reporting.
As part of our organizational framework, our Product Stewardship Team verifies ingredients and materials used in our direct materials. During this process, any Conflict Minerals reporting and compliance issues are analyzed and addressed by the conflict minerals team.
Members of the team also interact with our Direct Suppliers to further improve the quality of the Conflict Minerals reporting.
Our senior management is informed of the results of our due diligence efforts, supply chain integrity and relationships with our Direct Suppliers.
Control System and Supply Chain Transparency
PMI’s control system and supply chain transparency combines internal activities, collaboration with our Direct Suppliers and reliance on the information published by industry programs such as the Responsible Minerals Initiative (“RMI”).
We relied on the RMI Conflict Minerals Reporting Template (“CMRT”) that was sent to our Direct Suppliers to collect and retain the necessary information on the chain of custody of the 3TGs contained in the Covered Products, including information about the SORs.
The CMRT is generally regarded as the most widely-used standard form to collect information about Conflict Minerals through the supply chain and was developed by several of the world’s leading consumer electronics companies.
Supplier Engagement and Other Compliance Efforts
Our agreements pertaining to the supply of Covered Products include Conflict Minerals-related provisions that are consistent with our Policy, and that recognize the need for cooperation by our Direct Suppliers in respect of Conflict Minerals reporting. We require our Direct Suppliers to comply with our due diligence requests and encourage them to participate in industry-wide or material-specific supply chain mapping initiatives.
In addition, as we stated in the Conflict Minerals report for the period ended December 31, 2018 (the “2018 Report”), in 2019 we undertook the following efforts to further improve due diligence and supplier engagement:
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| • | We continue to train our employees on compliance with our Conflict Minerals policy and the underlying regulations. In 2018, we rolled out standardized web-based employee training programs that address various procurement activities, including the sourcing of minerals, which are now available to our employees worldwide and are mandatory for those employees who are responsible for procurement. In 2019, we also conducted workshops for our supply chain employees that covered the sourcing of minerals, achieving approximately 80% attendance. |
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| • | Our employees continued to communicate our Policy and our Responsible Sourcing Principles to our Direct Suppliers, our commitment to responsible sourcing, compliance expectations and information requirements, including grievance mechanisms. These communications focused on improving and continuing to maintain the understanding of the Conflict Minerals regulation in our Direct Suppliers’ supply chain, reviewing the due diligence process in terms of accuracy and timeliness of responses, and fostering efforts to further improve compliance. In 2019, we continued to see satisfactory levels of both timeliness and completeness of the information submitted to us by our Direct Suppliers. |
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| • | In 2019, we provided training on our Policy and Responsible Sourcing Principles to our Direct Suppliers. In particular, we hosted a Responsible Sourcing Principles workshop session for our Direct Suppliers. |
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| • | In 2019, we implemented a supplier due diligence platform to assess our suppliers’ compliance with the Responsible Sourcing Principles, which also covers the responsible sourcing of minerals. Suppliers who supply materials containing 3TGs are required to answer questions regarding their processes. |
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| • | We have communicated to our Direct Suppliers our expectation that for the manufacture of the Covered Products they should increasingly use SORs certified as “conflict-free” through the available third-party validation mechanisms (“Compliant SORs”), and have held in-person meetings with our Direct Suppliers to reinforce this expectation. For the 2019 fiscal year, all four Direct Suppliers reported that they used Compliant or Active smelters for the relevant Covered Products during the period covered in this Report.3 Please see Section C for additional information. |
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3 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of the audit, such SORs become Compliant SORs.
Grievance Mechanism
We have a grievance mechanism that allows our employees to report any suspected violation of PMI´s principles and practices to the senior management or the Ethics & Compliance Department. Reports can be made through face-to-face discussions or via email if the employee prefers to remain anonymous. We maintain both a dedicated email address: PMI.Compliance@pmi.com, and an independently operated and confidential Compliance Helpline, that operates a phone line and a webline. Concerns can also be reported by our employees confidentially or anonymously. Any such reports are to be forwarded to the Conflict Minerals Team that will review them and help design appropriate response measures. In addition, we encourage our suppliers to establish their own grievance mechanisms.
Maintain Records
We have a records retention policy applicable to Conflict Minerals-related documentation that provides for the retention of relevant records for prescribed periods.
2. Identify and Assess Risk in the Supply Chain
We reviewed the answers to the CMRT received from our Direct Suppliers and assessed their completeness, clarity and consistency. We worked with our Direct Suppliers to understand their due diligence process, confirmed that they have established a Conflict Minerals policy and obtained a list of SORs in their respective supply chains for the Covered Products.
Our Direct Suppliers confirmed that some of the SORs in their supply chain may source 3TGs from the Covered Countries and that the 3TGs may not be from recycled or scrap sources. As part of our risk assessment, we checked whether these SORs were Compliant SORs by comparing the facilities identified by our Direct Suppliers against the list provided by the RMI and its Responsible Minerals Assurance Process (“RMAP”) as well as the list provided by the London Bullion Market Association (“LBMA”). We also followed up with additional information requests to obtain the necessary details to better assess the reliability of the responses and the risks in our supply chain in instances where the responses received were not clear or where the SORs were not certified "conflict-free" through the available third-party validation mechanisms.
Please also see Section B.1 for the discussion of our efforts in 2019 to help identify and assess risk in our supply chain.
3. Design and Implement a Strategy to Respond to Risks in the Supply Chain
We designed a strategy to respond to risks in our supply chain. When the Conflict Minerals Team becomes aware that the due diligence of our direct or indirect suppliers needs improvement, it provides feedback, asks clarifying questions and demands corrective actions where necessary. The Conflict Minerals Team has and will continue to provide information and training to our Direct Suppliers and will determine appropriate follow-up actions, if any, to mitigate any identified risks. Follow-up actions may include, but are not limited to, finding alternate sources of supply or terminating existing supplier relationships, as appropriate. We have encouraged our Direct Suppliers to further implement, and require their suppliers to implement, the due diligence standards that reflect the OECD guidance. Steps to improve the accuracy of the due diligence process are described in Sections B.1 above and D below. For 2019, we found no instances where it was necessary to find replacement sources of supply of Covered Products or terminate a supplier relationship due to a failure to comply with Conflict Minerals requirements. To the extent we expand our supplier base for the relevant products, Conflict Minerals compliance, commitment and readiness are among our criteria for selecting new suppliers.
4. Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We rely on the RMI’s Responsible Minerals Assurance Process for the performance of third-party audits of SORs. To the extent possible, we review whether any 3TGs sourced from the Covered Countries are “DRC conflict-free” based on the information provided by our Direct Suppliers and the information available on the RMI’s website. We encourage our suppliers to support industry organizations’ efforts to ensure that smelters’ due diligence sourcing practices are audited by independent third party auditors.
5. Report on Supply Chain Due Diligence
This Report will be filed with the SEC and is publicly available at https://www.pmi.com/principles-and-positions/standards/transparency.
C. Reasonable Country of Origin Inquiry ("RCOI") and Due Diligence on the Source and Chain of Custody
We asked our Direct Suppliers to provide answers to the CMRT to ascertain whether the 3TGs contained in the Covered Products originated from Covered Countries. Based on the evaluation of our Direct Suppliers’ responses to their CMRT, we had reasons to believe that some of the 3TGs in the Covered Products manufactured in 2019 may have originated in the Covered Countries and were not entirely from recycled or scrap sources.
Through the CMRT, our Direct Suppliers informed us that: (i) 100% of their suppliers provided responses to the CMRT; (ii) 3TGs contained in some Covered Products may have originated from the Covered Countries; (iii) 3TGs contained in Covered Products are not entirely from recycled or scrap sources; (iv) 100% of the SORs supplying 3TGs contained in the Covered Products and their locations were identified and reported; and (v) our Direct Suppliers reported that they used Compliant or Active smelters for the respective Covered Products with the exceptions described below. We compared the facilities that the Direct Suppliers identified in their respective CMRTs to the list of SORs that are certified as “conflict-free” with the RMI and the LBMA. While two SORs identified by one of our Direct Suppliers were not on the RMI list of Compliant SORs at the time of our review, we followed up with the relevant Direct Supplier and were informed by such Direct Supplier that the SORs were Active SORs during the reporting period.4
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4 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of such audit, such SORs would become Compliant SORs.
D. Steps to Further Improve Due Diligence
We plan to concentrate on the following steps in the future:
•Continue to engage with our Direct Suppliers to communicate our expectation that they should increasingly source minerals for our products from Compliant SORs;
•Encourage our Direct Suppliers to further strengthen due diligence efforts consistent with the OECD guidance, thereby improving the quality and completeness of supply chain information available to us;
•Continue to mandate conflict minerals due diligence based on OECD guidance and training as a prerequisite to engagement with any new direct suppliers of electronics;
•Encourage our Direct Suppliers to continue to enforce their respective Conflict Minerals policies;
•Continue to communicate and provide training on our Policy, grievance mechanism requirements, compliance expectations and information to our present and future direct suppliers;
•Continue engagement with our Direct Suppliers to review measures for improvement of the due diligence process;
•Continue to use our supplier due diligence platform to determine our Direct Suppliers' compliance with our RSPs;
•Continue communicating our conflict minerals guidance to our Direct Suppliers; and
•Continue training our employees, specifically, through our standardized web-based programs, such training to continue to be mandatory for all employees responsible for procurement and those in related supporting roles.
E. Independent Private Sector Audit
Pursuant to Rule 13p-1, an independent private sector audit is not required for this Report.
Appendix A - Conflict Minerals Policy
The United States Securities and Exchange Commission (SEC) requires our company to disclose if our products contain certain minerals (gold, tin, tungsten, and tantalum) that:
•originate in the Democratic Republic of the Congo (DRC) or an adjoining country
•contribute to the financing of armed groups that are committing human rights abuses
These minerals are known as conflict minerals. PMI’s policy and due diligence process on the use of conflict minerals is not to knowingly procure conflict minerals that originate from the DRC or an adjoining country – and we ask our direct suppliers to undertake reasonable due diligence with their supply chains to assure the same – unless those minerals are determined to be “conflict-free.”
Appendix B - List of SORs identified by our Direct Suppliers as part of the supply chain for Covered Products5
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| Subject Mineral | Smelter or Refiner Name | Country Location of Smelter or Refiner |
| Gold | Metalor Technologies (Suzhou) Ltd.* | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. * | CHINA |
| Gold | 8853 S.p.A. * | ITALY |
| Gold | Advanced Chemical Company* | UNITED STATES OF AMERICA |
| Gold | Aida Chemical Industries Co., Ltd. * | JAPAN |
| 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 OF AMERICA |
| Gold | Asaka Riken Co., Ltd. * | JAPAN |
| 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 | CCR Refinery - Glencore Canada Corporation* | CANADA |
| Gold | Cendres + Metaux S.A. * | SWITZERLAND |
| Gold | Chimet S.p.A. * | ITALY |
| Gold | Chugai Mining* | JAPAN |
| Gold | DSC (Do Sung Corporation) * | SOUTH KOREA |
| Gold | DODUCO Contacts and Refining GmbH* | GERMANY |
| Gold | Dowa* | JAPAN |
| Gold | DS PRETECH Co., Ltd. * | SOUTH KOREA |
| Gold | Eco-System Recycling Co., Ltd. * | JAPAN |
| Gold | Emirates Gold DMCC* | UNITED ARAB EMIRATES |
| Gold | OJSC Novosibirsk Refinery* | RUSSIAN FEDERATION |
| Gold | Geib Refining Corporation* | UNITED STATES OF AMERICA |
| Gold | HeeSung Metal Ltd. * | SOUTH KOREA |
| Gold | Heimerle + Meule GmbH* | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. * | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY |
| 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 | Italpreziosi* | ITALY |
| Gold | Japan Mint* | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. * | CHINA |
| 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 | KGHM Polska Miedz Spolka Akcyjna* | POLAND |
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| Gold | Kojima Chemicals Co., Ltd. * | JAPAN |
| Gold | Korea Zinc Co., Ltd. * | SOUTH KOREA |
| Gold | Kyrgyzaltyn JSC* | KYRGYZSTAN |
| Gold | L'Orfebre S.A. * | ANDORRA |
| Gold | LS-NIKKO Copper Inc. * | SOUTH KOREA |
| Gold | Marsam Metals* | BRAZIL |
| 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 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.S. * | TURKEY |
| 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 | PAMP S.A. * | SWITZERLAND |
| 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 | Rand Refinery (Pty) Ltd. * | SOUTH AFRICA |
| Gold | REMONDIS PMR B.V. * | NETHERLANDS |
| Gold | Royal Canadian Mint* | CANADA |
| Gold | SAAMP* | FRANCE |
| Gold | Safimet S.p.A* | ITALY |
| Gold | Samduck Precious Metals* | SOUTH KOREA |
| Gold | SAXONIA Edelmetalle GmbH* | GERMANY |
| Gold | SEMPSA Joyeria Plateria S.A. * | SPAIN |
| 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 | Sumitomo Metal Mining Co., Ltd. * | JAPAN |
| Gold | SungEel HiMetal Co., Ltd. * | SOUTH KOREA |
| 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* | SOUTH KOREA |
| 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 |
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| 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 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. * | CHINA |
| Gold | SAFINA A.S. ** | CZECHIA |
| Gold | Al Etihad Gold Refinery DMCC* | UNITED ARAB EMIRATES |
| Gold | TOO Tau-Ken-Altyn* | KAZAKHSTAN |
| Gold | Eco-System Recycling Co., Ltd. North Plant* | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant* | JAPAN |
| Tantalum | Asaka Riken Co., Ltd. * | JAPAN |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. * | CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. * | 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 Tantalum and Niobium GmbH* | GERMANY |
| 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 |
| 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 | 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 | NPM Silmet AS* | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. * | CHINA |
| Tantalum | Power Resources Ltd. * | NORTH MACEDONIA |
| Tantalum | QuantumClean* | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. * | BRAZIL |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. * | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO* | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co., Ltd. * | JAPAN |
| Tantalum | Telex Metals* | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
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| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. * | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. * | CHINA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. * | CHINA |
| Tin | Yunnan Tin Company Limited* | CHINA |
| Tin | Alpha* | UNITED STATES OF AMERICA |
| 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 | CV Ayi Jaya* | INDONESIA |
| Tin | CV Dua Sekawan* | INDONESIA |
| Tin | CV Gita Pesona* | INDONESIA |
| Tin | PT Aries Kencana Sejahtera* | INDONESIA |
| Tin | PT Rajehan Ariq* | INDONESIA |
| Tin | CV United Smelting* | INDONESIA |
| Tin | CV Venus Inti Perkasa* | INDONESIA |
| Tin | Dowa* | JAPAN |
| Tin | Metallo Spain S.L.U. * | SPAIN |
| Tin | EM Vinto* | BOLIVIA |
| Tin | Fenix Metals* | POLAND |
| Tin | Gejiu Fengming Metallurgy Chemical Plant* | 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 | Gejiu Kai Meng Industry and Trade LLC* | CHINA |
| 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 OF AMERICA |
| Tin | Metallo Belgium N.V. * | BELGIUM |
| Tin | Mineracao Taboca S.A. * | BRAZIL |
| Tin | Minsur* | PERU |
| Tin | Mitsubishi Materials Corporation* | JAPAN |
| Tin | Jiangxi New Nanshan Technology Ltd. * | CHINA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. * | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. * | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. * | BOLIVIA |
| 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 Tin Industry* | INDONESIA |
| Tin | PT Belitung Industri Sejahtera* | INDONESIA |
| Tin | PT Bukit Timah* | INDONESIA |
| Tin | PT DS Jaya Abadi* | INDONESIA |
| Tin | PT Inti Stania Prima* | INDONESIA |
| Tin | PT Menara Cipta Mulia* | INDONESIA |
| Tin | PT Mitra Stania Prima* | INDONESIA |
| 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 Timah Tbk Kundur* | INDONESIA |
| Tin | PT Timah 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 |
| Tin | Soft Metais Ltda. * | BRAZIL |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. * | VIETNAM |
| Tin | Thaisarco* | THAILAND |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. * | CHINA |
| Tin | Tin Technology & Refining* | UNITED STATES OF AMERICA |
| Tin | White Solder Metalurgia e Mineracao Ltda. * | BRAZIL |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. * | CHINA |
| Tin | PT Premium Tin Indonesia* | INDONESIA |
| Tin | PT Bangka Serumpun* | INDONESIA |
| Tin | PT Babel Surya Alam Lestari* | INDONESIA |
| Tin | PT Karimun Mining* | INDONESIA |
| Tin | PT Kijang Jaya Mandiri* | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa* | INDONESIA |
| Tin | PT Sumber Jaya Indah* | INDONESIA |
| Tin | PT Tirus Putra Mandiri* | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera* | INDONESIA |
| Tungsten | A.L.M.T. Corp. * | JAPAN |
| Tungsten | ACL Metais Eireli* | BRAZIL |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. * | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten 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 | Global Tungsten & Powders Corp. * | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. * | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH* | GERMANY |
| 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 Yaosheng Tungsten Co., Ltd. * | CHINA |
| Tungsten | Kennametal Fallon* | UNITED STATES OF AMERICA |
|
| | |
| Tungsten | Kennametal Huntsville* | UNITED STATES OF AMERICA |
| Tungsten | KGETS Co., Ltd. * | SOUTH KOREA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. * | CHINA |
| Tungsten | Moliren Ltd. * | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC* | UNITED STATES OF AMERICA |
| Tungsten | Masan Tungsten Chemical LLC (MTC) * | VIETNAM |
| 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. * | SOUTH KOREA |
| 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 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. * | VIETNAM |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. ** | CHINA |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. * | CHINA |
| Tungsten | Lianyou Metals Co., Ltd. * | TAIWAN |
_________
5 SORs that were designated, to our knowledge, as Compliant as of December 31, 2019 are marked with an asterisk (unless stated otherwise). SORs that were designated, to our knowledge, as Active as of December 31, 2019 are marked with two asterisks (unless stated otherwise).
