Exhibit 1.01
Conflict Minerals Report
Capri Holdings Limited has included this Conflict Minerals Report as an exhibit to its Form SD in respect of the calendar year ended December 31, 2021 (“calendar 2021”) as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 27, 2022.
Unless the context indicates otherwise, the terms “we,” “its,” “us,” “our” and the “Company” refer to Capri Holdings Limited and its consolidated subsidiaries. As used herein, “Conflict Minerals” or “3TG” are cassiterite (tin), columbite-tantalite (tantalum), gold and wolframite (tungsten), without regard to the location of origin of the minerals or derivative metals.
Forward-Looking Statements
The statements in this document that refer to plans and expectations for future periods are forward-looking statements within the meaning of federal securities laws. These forward-looking statements are based on management’s current expectations. Words such as “expects,” “anticipates,” “plans,” “believes,” “estimates,” “may,” “will,” “should,” “intends,” “could,” “would,” “might” and variations of such words and similar expressions are intended to identify such forward-looking statements. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG benefit armed groups. You should not place undue reliance on such statements. These forward-looking statements are subject to a number of risks and uncertainties, many of which are beyond the Company’s control, which could cause the Company’s actual results to differ materially from those indicated in these forward-looking statements. These risks and uncertainties may include, but are not limited to, the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers, on a timely basis or at all, whether smelters and refiners (“SORs”) and other market participants responsibly source 3TG, and political, regulatory and economic developments, whether in the Democratic Republic of the Congo (“DRC”) region (the “Covered Countries”), the United States or elsewhere. The Company undertakes no obligation to update or revise any forward-looking statements to reflect subsequent events or circumstances, except as required by applicable laws or regulations.
Applicability of the Conflict Minerals Rule to Our Company
We are a global fashion luxury group, consisting of iconic brands that are industry leaders in design, style and craftsmanship. Our brands (Versace, Jimmy Choo and Michael Kors) cover the full spectrum of fashion luxury categories, including women’s and men’s accessories, footwear and apparel as well as wearable technology, watches, jewelry, eyewear and a full line of fragrance products. In-scope product information in respect of calendar 2021 is provided under “Product Information” below. We believe that we are subject to the Conflict Minerals Rule because some of the products that we contract to manufacture may contain 3TG that are necessary to the functionality or production of such products.
Through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below. With the exception of one directly owned facility located in Pistoia, Italy, we contracted to manufacture, but did not directly manufacture, products during calendar 2021. We did not directly source 3TG from mines or SORs during calendar 2021, and are many levels removed from these market participants. The efforts undertaken to identify the origin of 3TG in our products reflect our circumstances and position in the supply chain, and we work with our direct suppliers so that they may provide us with accurate information about the origin of necessary 3TG minerals in the products that we manufacture or contract to manufacture.
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Our Conflict Minerals Policy
We are opposed to human rights abuses such as those that are occurring in connection with the mining of certain minerals from locations in the DRC. We also take our obligations under U.S. Securities and Exchange Commission regulations and the laws in countries in which we operate seriously, including our compliance obligations under the Conflict Minerals Rule. In addition, we are committed to principles of ethical business practice and recognition of the dignity of others, including the responsible sourcing of 3TG, and we expect that our suppliers share this commitment.
In furtherance of the foregoing, we have adopted and communicated to our suppliers and the public a Company policy (the “Conflict Minerals Policy” or “Policy”) for determining the use and origin of 3TG in our supply chain. Our Conflict Minerals Policy is available on our website at www.capriholdings.com under the caption “Responsibility”. The information contained on our website is not incorporated by reference into this Conflict Minerals Report or the Form SD and should not be considered part of this Conflict Minerals Report or the Form SD.
The Conflict Minerals Policy includes, but is not limited to, our expectations that our suppliers:
1. | put in place procedures for the traceability of 3TG; |
2. | cooperate with our 3TG due diligence process, including by providing us, from time to time, with written certifications and other information concerning the origin of 3TG included in products and/or components supplied to us; |
3. | maintain reviewable business records supporting the source of 3TG; |
4. | adopt policies and procedures with respect to 3TG consistent with our Conflict Minerals Policy and 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, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (collectively, the “OECD Guidance”), including the adoption of a risk mitigation strategy to respond to identified risks in the supply chain, and communicate such policies and procedures to their personnel, direct suppliers and indirect suppliers; and |
5. | require their direct and indirect suppliers to adopt policies and procedures that are consistent with our Conflict Minerals Policy. |
We do not support the embargoing of responsibly sourced 3TG from the Covered Countries or other conflict-affected and high-risk areas.
In addition, our Code of Conduct for Business Partners (the “Supplier Code of Conduct”) indicates that we encourage our suppliers that use 3TG that are necessary to the functionality or production of products that we manufacture or contract to manufacture, to source product in a socially and environmentally responsible manner and in accordance with our Conflict Minerals Policy. The Supplier Code of Conduct is available on our website at www.capriholdings.com under the caption “Responsibility”.
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Reasonable Country of Origin Inquiry
As required by the Conflict Minerals Rule, for calendar 2021, we conducted a “reasonable country of origin inquiry” (“RCOI”). We designed our RCOI in good faith to determine the origin of 3TG that are necessary to the functionality or production of products that we contract to manufacture. The results of our RCOI are discussed in Annex A to this Conflict Minerals Report. To the extent applicable, for our RCOI, we utilized the same processes and procedures as for our due diligence, particularly Steps 1 and 2 of the OECD Guidance design framework, which are described below in this Conflict Minerals Report.
We determined which of our products were in-scope or potentially in-scope for purposes of the Conflict Minerals Rule through product specifications, visual inspection, supplier inquiries and other information known to us. We also considered the degree of influence that we exercised over the materials, parts and components of the products. Our outreach included 468 suppliers that produce in-scope or potentially in-scope products (the “Suppliers”).
Pursuant to the Conflict Minerals Rule, based on the results of our RCOI, we exercised due diligence for calendar 2021. These due diligence efforts are discussed below.
Due Diligence Program Design and Execution
Design Framework
We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the OECD Guidance.
Selected Elements of Compliance Program
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our compliance program are discussed below. However, these are not all of the discrete elements of the program that we have put in place to provide for the responsible sourcing of 3TG contained in our products. The headings below conform to the headings used in the OECD Guidance for each of the five steps.
1. | OECD Guidance Step One: “Establish strong company management systems” |
a. | We have a Conflict Minerals Policy and Supplier Code of Conduct, as described earlier in this Conflict Minerals Report. The Conflict Minerals Policy is communicated internally by email and Intranet. The Conflict Minerals Policy is also communicated to suppliers utilizing our web-based compliance management software and is posted on our website. |
b. | We have a team under the Senior Vice President, General Counsel and Chief Sustainability Officer charged with managing our 3TG compliance program. The following functional areas are represented on the working group: Global Social Compliance; Production/Licensing; Internal Audit; and Legal. Appropriate members of these functional areas are educated on the Conflict Minerals Rule, the OECD Guidance, our Policy and our compliance program, including the procedures for reviewing and validating supplier responses to our inquiries. |
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c. | We have a Standard Operating Procedure that contains standard processes, timelines and communications for our compliance with the Conflict Minerals Rule. |
d. | We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Initiative (the “RMI”) to identify SORs in our supply chain. |
e. | Supplier requests for a completed CMRT are accompanied by the Conflict Minerals Policy or include a link to the Policy. |
f. | We consider on an ongoing basis whether any suppliers may benefit from receiving training or orientation materials concerning the Conflict Minerals Rule, the OECD Guidance, the Conflict Minerals Policy and/or our survey process. If so, we arrange for the relevant supplier(s) to receive those materials and/or recommend training or informational resources to those supplier(s). |
g. | We maintain records relating to 3TG due diligence, including records of our due diligence processes, findings and resulting decisions, in an electronic database. Our policy is to maintain these records for at least five years. |
h. | We have an anonymous email mailbox for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy. The email address is conflictmineralscompliance@capriholdings.com. We also have a confidential hotline through which parties may report violations. The country-specific hotline telephone numbers are set forth in the Annex to our Code of Business Conduct and Ethics available on our website at www.capriholdings.com under the caption “Responsibility”. The foregoing serve as our grievance reporting mechanisms. |
2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” |
a. | We requested through our web-based compliance management software that the Suppliers provide us with information, through the completion of a CMRT, concerning the usage and source of 3TG in their products as well as their related compliance efforts. We sent requests to 480 Suppliers to provide us with a completed CMRT. We followed up by email or phone with all Suppliers that did not respond to the request within the specified time frame. We requested that the Suppliers furnish us with a completed template at the product level. We received responses from approximately 97% of the Suppliers. |
b. | We reviewed the responses received from the Suppliers for completeness, accuracy, reasonableness, credibility and “red flags” using written guidelines that we have developed. We followed up by email or phone with the Suppliers that submitted a response that was rejected under our written guidelines, requesting the Supplier submit an updated or corrected CMRT. |
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c. | SOR information provided by the Suppliers was reviewed against the Smelter Look-up tab list of the CMRT. To the extent that a SOR identified by a Supplier was not on that list, we took additional steps to attempt to determine whether the listed entity is a SOR. |
d. | SOR information provided by the Suppliers also was reviewed against the lists of Conformant and Active (both as later defined) SORs published by the RMI. To the extent that a SOR identified by a Supplier was not listed as Conformant by the RMI, we requested further information from the Supplier or consulted publicly available information to determine whether the SOR obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in a Covered Country. |
3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” |
a. | Our 3TG compliance team reported the findings of its supply chain risk assessment to our Senior Vice President, General Counsel and Chief Sustainability Officer. |
b. | If our due diligence does not result in a reasonable belief that the applicable 3TG originated outside of the Covered Countries or came from recycled or scrap sources, we assess the risk that the 3TG may benefit armed groups in the Covered Countries. |
c. | Under our written procedures, risk mitigation measures include escalation of the supplier inquiry process, working with the supplier to establish a corrective action plan and possible termination of the supplier relationship. |
4. | OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” |
To that extent that SORs of 3TG in our supply chain are identified to us, we utilize and rely on information made publicly available by the RMI concerning independent third-party audits of SORs to assess SOR due diligence and to determine whether the SOR is Conformant.
5. | OECD Guidance Step Five: “Report on supply chain due diligence” |
We file a Form SD and a Conflict Minerals Report with the U.S. Securities and Exchange Commission and make these documents available on our website.
Product Information; Identified Smelters and Refiners
For calendar 2021, the following categories of products that may include tin, tantalum, tungsten and/or gold were potentially in-scope:
• | women’s and men’s accessories, including handbags and small leather goods |
• | footwear |
• | ready-to-wear, including womenswear, menswear, swimwear and outerwear |
• | wearable technology |
• | watches |
• | jewelry |
• | eyewear |
• | home furnishings |
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For a further discussion of our products, see our Annual Report on Form 10-K for the fiscal year ended March 27, 2021 (the “Annual Report”). The information contained in our Annual Report is not incorporated by reference into our Form SD or this Conflict Minerals Report and should not be considered part of this report or the Form SD.
We endeavored to determine the mine or location of origin of the 3TG contained in our in-scope products by requesting that the Suppliers provide us with a completed CMRT at the product level and through the other measures described in this Conflict Minerals Report.
In connection with our RCOI or due diligence, as applicable, the Suppliers identified to us the facilities listed on Annex A as potentially having processed the necessary 3TG contained in our potentially in-scope products for calendar 2021. Due to our position in the supply chain, we rely on the Suppliers for accurate SOR information. Our due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our potentially in-scope products for calendar 2021. Many of the Suppliers provided company level CMRT declarations rather than product level declarations. Therefore, we do not know if the SORs identified in these declarations relate specifically to products those Suppliers made for us.
Of the 286 SORs identified to us by our Suppliers, a substantial portion were identified by a single Supplier that manufactures watches and jewelry for us (including connected devices). We have not been able to confirm that all of the SORs identified by this Supplier actually processed the 3TG in our products, and given the large number of identified SORs, we believe that the SOR list provided by that Supplier is likely over-inclusive.
Please see the notes accompanying Annex A for additional information relevant to the table below. The number of Conformant SORs reflected in the table exceeds the number of unique Conformant SORs reported because some SORs processed more than one 3TG mineral.
Conformant | Active | On Smelter Look-up List Tab Only | ||||||||||
Tantalum (Total Unique SORs = 18) | 17 | 0 | 1 | |||||||||
Tin (Total Unique SORs = 79) | 56 | 6 | 17 | |||||||||
Tungsten (Total Unique SORs = 27) | 24 | 2 | 1 | |||||||||
Gold (Total Unique SORs = 162) | 102 | 5 | 55 |
Additional Risk Mitigation Efforts
We intend to take the following additional steps in respect of the calendar year ending December 31, 2022 (“calendar 2022”) to mitigate the risk that our necessary in-scope 3TG benefit armed groups, to the extent applicable:
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1. | Encourage Suppliers that provided company-level information for calendar 2021 to provide product level information for calendar 2022 through ongoing outreach with these Suppliers. |
2. | Engage with Suppliers that provided incomplete responses or that did not provide responses for calendar 2021 to provide requested information for calendar 2022. |
3. | Provide additional materials, informational resources and/or training to selected suppliers. |
4. | Communicate to new potentially in-scope suppliers our sourcing expectations, including through the dissemination of the Conflict Minerals Policy. In addition, as new in-scope suppliers are added, work with these suppliers to ensure that they understand the requirements of our Conflict Minerals Policy, the Conflict Minerals Rule and the OECD Guidance. |
All of the foregoing steps are in addition to the steps that we took in respect of our calendar 2021 inquiry described earlier in this Conflict Minerals Report, which we intend to continue to take in respect of our calendar 2022 inquiry to the extent applicable.
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Annex A
Capitalized terms used and not otherwise defined in this Annex have the meanings indicated in our Conflict Minerals Report.
In connection with our RCOI or due diligence, as applicable, our Suppliers identified to us the SORs listed below as potentially having processed the necessary 3TG contained in our potentially in-scope products in calendar 2021. As noted earlier in this Conflict Minerals Report, a substantial portion of the 286 SORs listed below were identified only by a single Supplier that manufactures watches and jewelry for us (including connected devices).
Mineral | SOR Name | SOR Location | Status | |||
Gold | 8853 S.p.A. | ITALY | Conformant | |||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant | |||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant | |||
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant | |||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant | |||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant | |||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant | |||
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant | |||
Gold | Asahi Pretec Corp. | JAPAN | Conformant | |||
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant | |||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant | |||
Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant | |||
Gold | Aurubis AG | GERMANY | Conformant | |||
Gold | BALORE REFINERSGA | INDIA | Conformant | |||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant | |||
Gold | Boliden AB | SWEDEN | Conformant | |||
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant | |||
Gold | CCR | CANADA | Conformant | |||
Gold | Cendres + M?taux SA | SWITZERLAND | Conformant |
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Gold | Chimet S.p.A. | ITALY | Conformant | |||
Gold | China Henan Zhongyuan Gold Smelter | CHINA | Conformant | |||
Gold | Chugai Mining | JAPAN | Conformant | |||
Gold | Do Sung Corporation | KOREA, REPUBLIC OF | Conformant | |||
Gold | Doduco | GERMANY | Conformant | |||
Gold | Dowa | JAPAN | Conformant | |||
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant | |||
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant | |||
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant | |||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant | |||
Gold | Fujian Zijin mining stock company gold smelter | CHINA | Conformant | |||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant | |||
Gold | Heimerle + Meule GmbH | GERMANY | Conformant | |||
Gold | Heraeus Ltd. Hong Kong | CHINA | Conformant | |||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant | |||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant | |||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant | |||
Gold | Istanbul Gold Refinery | TURKEY | Conformant | |||
Gold | Italpreziosi | ITALY | Conformant | |||
Gold | Japan Mint | JAPAN | Conformant | |||
Gold | JCC | CHINA | Conformant | |||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant | |||
Gold | Kazzinc | KAZAKHSTAN | Conformant | |||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant | |||
Gold | KGHM Polska Miedz S.A. | POLAND | Conformant | |||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
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Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
Gold | Kosak Seiren | JAPAN | Conformant | |||
Gold | L’Orfebre S.A. | ANDORRA | Conformant | |||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant | |||
Gold | Marsam Metals | BRAZIL | Conformant | |||
Gold | Materion | UNITED STATES OF AMERICA | Conformant | |||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant | |||
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant | |||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant | |||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant | |||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant | |||
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant | |||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant | |||
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | |||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant | |||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant | |||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant | |||
Gold | NH Recytech Company | KOREA, REPUBLIC OF | Conformant | |||
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant | |||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant | |||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant | |||
Gold | PAMP S.A. | SWITZERLAND | Conformant | |||
Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant | |||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant | |||
Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
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Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant | |||
Gold | Remondis Argentia B.V. | NETHERLANDS | Conformant | |||
Gold | Royal Canadian Mint | CANADA | Conformant | |||
Gold | SAAMP | FRANCE | Conformant | |||
Gold | Safimet S.p.A | ITALY | Conformant | |||
Gold | SAFINA A.S. | CZECHIA | Conformant | |||
Gold | Samdok Metal | KOREA, REPUBLIC OF | Conformant | |||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant | |||
Gold | Shan Dong Huangjin | CHINA | Conformant | |||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant | |||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant | |||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant | |||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
Gold | T.C.A S.p.A | ITALY | Conformant | |||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant | |||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant | |||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant | |||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant | |||
Gold | Torecom | KOREA, REPUBLIC OF | Conformant | |||
Gold | Umicore Precious Metals Refining Hoboken | BELGIUM | Conformant | |||
Gold | Umicore Precious Metals Thailand | THAILAND | Conformant | |||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant | |||
Gold | Valcambi S.A. | SWITZERLAND | Conformant |
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Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant | |||
Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant | |||
Gold | Yamakin Co., Ltd. | JAPAN | Conformant | |||
Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant | |||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Active | |||
Gold | Alexy Metals | UNITED STATES OF AMERICA | Active | |||
Gold | Augmont Enterprises Private Limited | INDIA | Active | |||
Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | Active | |||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Active | |||
Gold | African Gold Refinery | UGANDA | Smelter Look-up List Tab Only | |||
Gold | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | ATAkulche | TURKEY | Smelter Look-up List Tab Only | |||
Gold | AU Traders and Refiners | SOUTH AFRICA | Smelter Look-up List Tab Only | |||
Gold | Caridad | MEXICO | Smelter Look-up List Tab Only | |||
Gold | CGR Metalloys Pvt Ltd. | INDIA | Smelter Look-up List Tab Only | |||
Gold | CHALCO Yunnan Copper Co. Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | DEGUSSA | GERMANY | Smelter Look-up List Tab Only | |||
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | Smelter Look-up List Tab Only | |||
Gold | Federal State Unitary Enterprise Moscow Special Processing Plant (FSUE MZSS) | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Smelter Look-up List Tab Only | |||
Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION | Smelter Look-up List Tab Only |
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Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | Smelter Look-up List Tab Only | |||
Gold | Gold Coast Refinery | GHANA | Smelter Look-up List Tab Only | |||
Gold | Great Wall Precious Metals Co,. LTD. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Guangdong Gaoyao Co | CHINA | Smelter Look-up List Tab Only | |||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Smelter Look-up List Tab Only | |||
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | Smelter Look-up List Tab Only | |||
Gold | JALAN & Company | INDIA | Smelter Look-up List Tab Only | |||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Smelter Look-up List Tab Only | |||
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Smelter Look-up List Tab Only | |||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Smelter Look-up List Tab Only | |||
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | L’azurde Company For Jewelry | SAUDI ARABIA | Smelter Look-up List Tab Only | |||
Gold | LinBao Gold Mining | CHINA | Smelter Look-up List Tab Only | |||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Smelter Look-up List Tab Only |
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Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Modeltech Sdn Bhd | MALAYSIA | Smelter Look-up List Tab Only | |||
Gold | Morris and Watson | NEW ZEALAND | Smelter Look-up List Tab Only | |||
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | Pease & Curren | UNITED STATES OF AMERICA | Smelter Look-up List Tab Only | |||
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | Smelter Look-up List Tab Only | |||
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Smelter Look-up List Tab Only | |||
Gold | Sai Refinery | INDIA | Smelter Look-up List Tab Only | |||
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Smelter Look-up List Tab Only | |||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Smelter Look-up List Tab Only | |||
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Shandong Tarzan Bio-Gold Industry Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Gold | Shyolkovsky | RUSSIAN FEDERATION | Smelter Look-up List Tab Only | |||
Gold | Sovereign Metals | INDIA | Smelter Look-up List Tab Only | |||
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Smelter Look-up List Tab Only | |||
Gold | Sudan Gold Refinery | SUDAN | Smelter Look-up List Tab Only |
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Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Smelter Look-up List Tab Only | |||
Gold | Tony Goetz NV | BELGIUM | Smelter Look-up List Tab Only | |||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant | |||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant | |||
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant | |||
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant | |||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant | |||
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | Conformant | |||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant | |||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant | |||
Tantalum | H.C. Starck Ltd. | JAPAN | Conformant | |||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | |||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant | |||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant | |||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant | |||
Tantalum | NPM Silmet AS | ESTONIA | Conformant | |||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant | |||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant | |||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Smelter Look-up List Tab Only | |||
Tin | Alpha | UNITED STATES OF AMERICA | Conformant | |||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant | |||
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant | |||
Tin | China Tin (Hechi) | CHINA | Conformant | |||
Tin | CRM Synergies | SPAIN | Conformant |
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Tin | Dowa | JAPAN | Conformant | |||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
Tin | Estanho de Rondonia S.A. | BRAZIL | Conformant | |||
Tin | Fenix Metals | POLAND | Conformant | |||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant | |||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant | |||
Tin | Gejiu Zi-Li | CHINA | Conformant | |||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant | |||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant | |||
Tin | Hulterworth Smelter | MALAYSIA | Conformant | |||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant | |||
Tin | Luna Smelter, Ltd. | RWANDA | Conformant | |||
Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | Conformant | |||
Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Conformant | |||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant | |||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant | |||
Tin | Metallo Belgium N.V. | BELGIUM | Conformant | |||
Tin | Metallo Spain S.L.U. | SPAIN | Conformant | |||
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant | |||
Tin | Minsur | PERU | Conformant | |||
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant | |||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant | |||
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant | |||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant | |||
Tin | PT Babel Inti Perkasa | INDONESIA | Conformant | |||
Tin | PT Babel Surya Alam Lestari | INDONESIA | Conformant |
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Tin | PT Bangka Serumpun | INDONESIA | Conformant | |||
Tin | PT Bukit Timah | INDONESIA | Conformant | |||
Tin | PT Cipta Persada Mulia | INDONESIA | Conformant | |||
Tin | PT Menara Cipta Mulia | INDONESIA | Conformant | |||
Tin | PT Mitra Stania Prima | INDONESIA | Conformant | |||
Tin | PT Prima Timah Utama | INDONESIA | Conformant | |||
Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant | |||
Tin | PT Rajehan Ariq | INDONESIA | Conformant | |||
Tin | PT Refined Bangka Tin | INDONESIA | Conformant | |||
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant | |||
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant | |||
Tin | PT Timah Tbk Kundur | INDONESIA | Conformant | |||
Tin | PT Timah Tbk Mentok | INDONESIA | Conformant | |||
Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant | |||
Tin | Resind Ind e Com Ltda. | BRAZIL | Conformant | |||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant | |||
Tin | Soft Metais Ltda. | BRAZIL | Conformant | |||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Conformant | |||
Tin | Thaisarco | THAILAND | Conformant | |||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant | |||
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant | |||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant | |||
Tin | Yunnan Tin Company Limited | CHINA | Conformant | |||
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Active | |||
Tin | CV Venus Inti Perkasa | INDONESIA | Active | |||
Tin | PT Aries Kencana Sejahtera | INDONESIA | Active | |||
Tin | PT Sukses Inti Makmur | INDONESIA | Active | |||
Tin | PT Timah Nusantara | INDONESIA | Active |
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Tin | Super Ligas | BRAZIL | Active | |||
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Smelter Look-up List Tab Only | |||
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Smelter Look-up List Tab Only | |||
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Smelter Look-up List Tab Only | |||
Tin | Melt Metais e Ligas S.A. | BRAZIL | Smelter Look-up List Tab Only | |||
Tin | Modeltech Sdn Bhd | MALAYSIA | Smelter Look-up List Tab Only | |||
Tin | �� | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Smelter Look-up List Tab Only | ||
Tin | Pongpipat Company Limited | MYANMAR | Smelter Look-up List Tab Only | |||
Tin | Precious Minerals and Smelting Limited | INDIA | Smelter Look-up List Tab Only | |||
Tin | PT Belitung Industri Sejahtera | INDONESIA | Smelter Look-up List Tab Only | |||
Tin | PT Panca Mega Persada | INDONESIA | Smelter Look-up List Tab Only | |||
Tin | PT Tirus Putra Mandiri | INDONESIA | Smelter Look-up List Tab Only | |||
Tin | PT Tommy Utama | INDONESIA | Smelter Look-up List Tab Only | |||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Smelter Look-up List Tab Only | |||
Tin | VQB Mineral and Trading Group JSC | VIET NAM | Smelter Look-up List Tab Only | |||
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Smelter Look-up List Tab Only | |||
Tungsten | A.L.M.T. Corp. | JAPAN | Conformant | |||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant | |||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
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Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant | |||
Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant | |||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant | |||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant | |||
Tungsten | GEM Co., Ltd. | CHINA | Conformant | |||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant | |||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant | |||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | |||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant | |||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant | |||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant | |||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant | |||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant | |||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant | |||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant | |||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant | |||
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | Conformant | |||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant | |||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant | |||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant | |||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant | |||
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | Active | |||
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | Active | |||
Tungsten | Artek LLC | RUSSIAN FEDERATION | Smelter Look-up List Tab Only |
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We note the following in connection with the information in the table:
(a) | Not all of the included SORs may have processed the necessary 3TG contained in our in-scope products. Some Suppliers may have reported SORs that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. In addition, the SORs reflected above may not include all of the SORs in our supply chain, since some Suppliers did not identify all of the SORs used to process the necessary 3TG content contained in our in-scope products and because not all Suppliers responded to our inquiries, as discussed above. |
(b) | All information in the table is as of May 18, 2022. |
(c) | “Conformant” means that a SOR has successfully completed an assessment against the applicable Responsible Minerals Assurance Process (“RMAP”) standard or an equivalent cross-recognized assessment. Included SORs were not necessarily Conformant for all or part of calendar 2021 and may not continue to be Conformant for any future period. |
(d) | “Active” means that the SOR is currently engaged in the RMAP but a conformance determination has yet to be made. |
(e) | “Smelter Look-up List Tab Only” means that a SOR is listed on the Smelter Look-up list tab of the CMRT, but is not listed as “Conformant” or “Active.” The RMI notes on its website that the operational impacts of COVID-19 have led to postponements of some RMAP assessments. The RMI website also notes that, due to the eligibility criteria for an RMAP assessment, SORs are sometimes removed from the Conformant list because they are no longer operational and not because they are non-conformant to the standard. |
(f) | The compliance status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us. |
(g) | SOR location is the location of the smelter or refiner. |
Country of Origin Information
The countries of origin of the 3TG processed by the Conformant SORs listed above may include the countries listed below, as well as possibly other countries.
Argentina Armenia Australia Austria Azerbaijan Belgium Benin Bolivia Botswana Brazil Bulgaria Burkina Faso Burundi* Canada Chile China Colombia Costa Rica Cyprus Democratic Republic of the Congo* Dominican Republic Ecuador Eritrea | Ethiopia Fiji Finland France French Guiana Georgia Germany Ghana Guatemala Guinea Guyana Honduras India Indonesia Ivory Coast Japan Kazakhstan Kenya Kyrgyzstan Laos Liberia Madagascar Malaysia | Mali Mauritania Mexico Mongolia Montenegro Morocco Mozambique Myanmar Namibia New Zealand Nicaragua Niger Nigeria Oman Papua New Guinea Peru Philippines Portugal Russian Federation Rwanda* Saudi Arabia Senegal Serbia | Sierra Leone Singapore Slovakia Solomon Islands South Africa South Korea Spain Sudan Suriname Swaziland Sweden Taiwan Tajikistan Tanzania* Thailand Turkey Uganda* United Kingdom of Great Britain and Northern Ireland United States of America Uruguay Uzbekistan Vietnam Zimbabwe |
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* | Represents a Covered Country. |
In addition, some of the listed Conformant SORs may have processed 3TG originating from recycled or scrap sources.
For calendar 2021, we were not able to determine the possible countries of origin of the 3TG processed by any of the SORs listed as “Active” or “On Smelter Look-up List Tab Only.”
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