Exhibit 1.01
CNH Industrial N.V.
Conflict Minerals Report
For The Year Ended December 31, 2019
| I. | Overview |
This report has been prepared by CNH Industrial N.V. (herein referred to as “CNH Industrial,” or the “Company,” “we,” “us,” or “our”) pursuant to Rule13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934 (the “Exchange Act”). References to internet websites herein are provided only as required by the Rule and information available through these websites is not incorporated by reference into this Form SD.
We are a leading global capital goods company engaged in the design, production, marketing, sale and financing of agricultural and construction equipment, trucks, commercial vehicles, buses and specialty vehicles for firefighting, defense and other uses, as well as engines, transmissions and axles for those vehicles and engines for marine and power generation applications. We have industrial and financial services companies located in 44 countries and a commercial presence in approximately 180 countries around the world.
Our principal products include agricultural and construction equipment, commercial vehicles and engines, transmissions and axles. Tin, tantalum, tungsten and gold (“3TG”) can be found in all of our products.
Our products are highly complex, typically containing thousands of parts from many direct suppliers. We have relationships with a vast network of suppliers throughout the world. Many of our suppliers are located outside the United States and include foreign entities that are not subject to the Rule. In addition, there are generally multiple tiers between the 3TG mines and our suppliers. Therefore, we must rely on our direct suppliers to work with their upstream suppliers to provide us with accurate information on the origin of the 3TG contained in components and materials purchased by us.
| II. | Reasonable Country of Origin Inquiry (“RCOI”) |
We conducted an inquiry of our suppliers to determine the country of origin of the components provided to CNH Industrial. Our RCOI comprised identification of relevant suppliers and a survey of those suppliers.
Because of the scope and complexity of our supply chain, we developed a risk-based approach that focused on our major direct suppliers as well as direct suppliers that we believed were likely to provide us with components containing 3TG (collectively, the “Surveyed Suppliers”). Surveyed Suppliers represented approximately 83% of the purchases (by dollar value) that we made for goods from suppliers. For purposes of this report, the “Covered Countries” means the Democratic Republic of Congo (the “DRC”) and its adjoining countries.
We requested that all Surveyed Suppliers provide information to us regarding 3TG and smelters using the template developed by the Responsible Minerals Initiative (“RMI”), known as the Conflict Minerals Reporting Template (the “Template”). The Template is a free, standardized reporting template that facilitates disclosure and communication of information regarding smelters and refiners that provide 3TG to a manufacturer’s supply chain. It includes questions regarding a direct supplier’s conflict-free policy and its due diligence process, and requests information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TG used by such smelters and refiners. The information we receive is submitted into an electronic database to facilitate information analysis.
| III. | Due Diligence Design and Performance |
Design of Due Diligence
Pursuant to the Rule, we undertook due diligence efforts on the source and country of origin of 3TG in our supply chain. The Rule requires that a registrant’s due diligence follow a nationally or internationally recognized due diligence framework. Presently, the only nationally or internationally recognized due
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diligence framework available is the Organisation for EconomicCo-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements for each of the conflict minerals (the “OECD Guidance”). The OECD Guidance is a framework for risk-based due diligence for responsible supply chains of conflict minerals from conflict-affected and high-risk areas that is described in the five-steps noted in Section IV below.
CNH Industrial designed its due diligence measures to be in conformity, in all material respects, with the OECD Guidance.
| IV. | Due Diligence Performed |
This section IV describes measures performed by us to exercise due diligence on the source and chain of custody on the 3TG contained in our products.
OECD Step 1. Establish Strong Company Management Systems
Conflict Minerals Policy
We have adopted a conflict minerals policy that is publicly available on our website at
http://www.cnhindustrial.com/en-us/governance/policies_and_guidelines/Pages/sustainability_guidelines.aspx
Internal Team
We have established a management system to support supply chain due diligence related to goods that may contain 3TG. Our management system includes a cross-functional executive steering committee sponsored by senior legal and compliance staff, and a team of subject matter experts from functions such as purchasing, parts and service and internal audit. A working group, reporting to the Steering Committee, was formed to develop and implement a Conflict Minerals compliance program approved by the Steering Committee.
Control Systems
We do not have a direct relationship with 3TG smelters and refiners; therefore, we rely on suppliers to provide information on the origin of the 3TG contained in the components and materials supplied to us. We are a member of RMI (RMI Member Code: CNHI). RMI serves as a resource for companies from a range of industries to help them make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. RMI program initiatives include the Responsible Minerals Assurance Process (“RMAP”), which identifies smelters and refiners that source minerals in conformance with RMAP, and the Template. We use the Template in our RCOI and RMAP data and information in our identification and assessment of risks in the supply chain. The control systems that we have in place include, but are not limited to, a dedicated email address for conflict minerals information, supplier retention response through our third-party software tool and a smelter outreach program through RMI.
Supplier Engagement
We have engaged our direct suppliers through direct communication, including multiple communications regarding the Rule. We provided the Surveyed Suppliers with instructions for responding to the Template and access to a conflict minerals compliancee-mail address, monitored by a member of the Conflict Minerals working group, which Surveyed Suppliers could use to seek assistance in interpreting and completing the Template. Our standard purchase order terms and conditions and purchase agreements require our suppliers to provide us with supporting information and documentation evidencing due diligence of 3TG in their respective supply chains. We have adopted and made available to our suppliers a Supplier Code of Conduct that requires, among other things, all suppliers to exercise due diligence, in accordance with the OECD Guidance, on its entire supply chain with respect to the sourcing of all 3TG to determine whether those metals are from the Covered Countries and, if so, to determine whether those metals directly or indirectly financed or benefited armed groups that are perpetrators of serious human rights abuses in the Covered Countries.
Grievance Mechanism
We have processes to collect and act on concerns expressed by employees and others about possible improper or unethical business practices, violations of company policies (including our Code of Conduct, the Supplier Code of Conduct and Conflict Minerals Policy) or applicable laws. This grievance mechanism is described in our Conflict Minerals Policy.
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OECD Step 2. Identify and Assess Risks in the Supply Chain
Our method for determining the country of origin of 3TG contained in our products was to conduct a supply-chain survey with Surveyed Suppliers using the Template. We have implemented a third-party software solution to collect and manage supplier CMRT data. We use this third-party solution to track communications with suppliers, analyze the CMRT data provided by suppliers, aggregate the supplier CMRT data for our reporting, and follow up with any supplier whose CMRT data we identified to contain incomplete or potentially inaccurate data. We rely on our suppliers to provide information on the origin of 3TG contained in the components and materials supplied to us. These suppliers are similarly reliant upon information provided by their suppliers. Smelters and refiners identified by a supplier in response to our supply-chain survey are compared against the RMI list to identify and assist in assessing the risk that the 3TG used in our products may have originated in the Covered Countries.
OECD Step 3. Design and Implement a Strategy to Respond to Identified Risks
| • | The Steering Committee is periodically briefed about our due diligence efforts. |
| • | We have adopted a conflict minerals policy. |
| • | Suppliers are required to adhere to our Supplier Code of Conduct that requires, among other things, all suppliers to exercise due diligence, in accordance with the OECD Guidance, on its entire supply chain with respect to the sourcing of all 3TG to determine whether those metals are from the Covered Countries and, if so, to determine whether those metals directly or indirectly financed or benefited armed groups that are perpetrators of serious human rights abuses in the Covered Countries. |
| • | Wefollow-up with the Surveyed Suppliers that provide incomplete or inconsistent responses. |
| • | We follow up with Surveyed Suppliers who listednon-compliant or uncertified smelters or refiners in their CMRT. |
OECD Step 4. Carry Out Independent Third Party Audit of Supply Chain Due Diligence At Identified Points In The Supply Chain
We support audits of 3TG smelters and refiners conducted by third parties through our participation in RMI. RMI developed the RMAP, which uses an independent third-party audit to identify smelters and refiners that have management systems and sourcing practices in place to conform with RMAP protocols and global standards.
OECD Step 5. Report Annually on Supply Chain Due Diligence
This Conflict Minerals Report constitutes our annual report on our 3TG due diligence, is available in our websitehttp://www.cnhindustrial.com/en-us/investor_relations/regulatory_filings/Pages/SEC_filings.aspx and is filed with the SEC.
| V. | Due Diligence Results: |
Survey Responses
We reviewed the Surveyed Supplier responses, including those not provided on the Template, to determine whether further engagement was necessary. When reviewing the Surveyed Supplier responses, we focused on incomplete responses as well as inconsistencies within the data reported by those suppliers. We worked directly with such suppliers in an effort to secure revised responses.
The vast majority of the responses received provided data only with respect to the supplier’s overall 3TG sourcing, without specifying if the 3TG was used in the specific goods supplied to us. Consequently, we cannot be certain that the smelters or refiners identified by the vast majority of our Surveyed Suppliers supplied 3TG to us rather than to other customers of that Surveyed Supplier.
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A minority of responses listed specific smelters or refiners. Such responses collectively identified 252 unique facilities as identified by the RMI, of which 224 were included on the RMAP Conformant Smelters and Refiners List. We also identified 40 smelters or refiners that may be sourcing from the Covered Countries and may not have been from recycled or scrap resources. All 40 of these processing facilities have been validated as compliant with RMAP protocols. Please seeAttachment A for a list of smelters and refiners reported to us by the Surveyed Suppliers that listed specific smelters or refiners. The smelters or refiners listed inAttachment A may have processed the 3TG necessary for our products, but we do not have sufficient information to establish a direct link between our products and the smelters or refiners listed inAttachment A.
Efforts to Determine Mine or Location of Origin
We requested our suppliers complete the Template, which includes questions regarding the locations of smelters and refiners or origin for the minerals. When a supplier cannot directly obtain information beyond smelter or refiner name, we consult the RMI to determine the country of origin and whether the smelter or refiner has been validated as RMAP conformant.
Expected Future Actions
Going forward, we intend to build on our efforts in 2019 and continue working with our suppliers to improve the quality of the information provided. We also intend to continue to participate in RMI meetings in order to gather best practices and collaborate with industry peers.
Caution Concerning Forward-Looking Statements |
| Certain statements in this report may be “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995 and Section 21E of the Securities Exchange Act of 1934. These statements may include terminology such as “may”, “will”, “expect”, “could”, “should”, “intend”, “estimate”, “anticipate”, “believe”, “outlook”, “continue”, “remain”, “on track”, “design”, “target”, “objective”, “goal”, “forecast”, “projection”, “prospects”, “plan”, or similar terminology. Forward-looking statements are not guarantees of future performance. Rather, they are based on current views and assumptions and involve known and unknown risks, uncertainties and other factors, many of which are outside our control and are difficult to predict. If any of these risks and uncertainties materialize or other assumptions underlying any of the forward-looking statements prove to be incorrect, the actual results or developments may differ materially from any future results or developments expressed or implied by the forward-looking statements. Actual results could differ materially from those anticipated in such forward-looking statements. Forward-looking statements speak only as of the date on which such statements are made, and we undertake no obligation to update or revise publicly any forward-looking statements. |
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Attachment A
The processing facilities listed in the table below represent the smelters and refiners provided by the Surveyed Suppliers that provided a list of smelters or refiners.The smelters or refiners may have processed the 3TG necessary for our products, but we do not have sufficient information to determine with certainty that is the case. Additionally, we are unable to conclusively determine the country of origin information for our necessary 3TG, but based on the data gathered from RMI, we believe that the sources may include the countries listed following the table.
| Metal | Smelter | Smelter Country | RMI Audit Status | |||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Compliant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant | |||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Compliant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Compliant | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Compliant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant | |||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Compliant | |||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
| Tantalum | NPM Silmet AS | ESTONIA | Compliant | |||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Compliant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant |
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| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Compliant | |||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tin | Alpha | UNITED STATES OF AMERICA | Compliant | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Outreach Required | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Compliant | |||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Compliant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Compliant | |||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | Non-compliant | |||
| Tin | Dowa | JAPAN | Compliant | |||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Compliant | |||
| Tin | Estanho de Rondonia S.A. | BRAZIL | In Communication | |||
| Tin | Fenix Metals | POLAND | Compliant | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Compliant | |||
| Tin | GejiuNon-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Compliant | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Compliant | |||
| Tin | Guangdong HanheNon-Ferrous Metal Co., Ltd. | CHINA | Compliant | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Compliant | |||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Compliant | |||
| Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | Compliant | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Compliant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant | |||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Compliant | |||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tin | Metallo Belgium N.V. | BELGIUM | Compliant | |||
| Tin | Metallo Spain S.L.U. | SPAIN | Compliant | |||
| Tin | Mineracao Taboca S.A. | BRAZIL | Compliant | |||
| Tin | Minsur | PERU | Compliant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Non-compliant | |||
| Tin | Nghe TinhNon-Ferrous Metals Joint Stock Company | VIET NAM | Outreach Required |
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| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant | |||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Compliant | |||
| Tin | Pongpipat Company Limited | MYANMAR | Outreach Required | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Compliant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Compliant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Compliant | |||
| Tin | PT Timah Tbk Kundur | INDONESIA | Compliant | |||
| Tin | PT Timah Tbk Mentok | INDONESIA | Compliant | |||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Compliant | |||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Compliant | |||
| Tin | Soft Metais Ltda. | BRAZIL | Compliant | |||
| Tin | Super Ligas | BRAZIL | Outreach Required | |||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Compliant | |||
| Tin | Thaisarco | THAILAND | Compliant | |||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Compliant | |||
| Tin | Tuyen QuangNon-Ferrous Metals Joint Stock Company | VIET NAM | Outreach Required | |||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Compliant | |||
| Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tin | Yunnan Tin Company Limited | CHINA | Compliant | |||
| Tin | Yunnan YunfanNon-ferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Compliant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold | AllgemeineGold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant | |||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Compliant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Compliant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Compliant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Compliant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Compliant | |||
| Gold | Aurubis AG | GERMANY | Compliant |
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| Gold | Bangalore Refinery | INDIA | Compliant | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant | |||
| Gold | Boliden AB | SWEDEN | Compliant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant | |||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Compliant | |||
| Gold | Chimet S.p.A. | ITALY | Compliant | |||
| Gold | Chugai Mining | JAPAN | Compliant | |||
| Gold | DayeNon-Ferrous Metals Mining Ltd. | CHINA | Compliant | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Outreach Required | |||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Compliant | |||
| Gold | Dowa | JAPAN | Compliant | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | In Communication | |||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Compliant | |||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Compliant | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Compliant | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Outreach Required | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Compliant | |||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Compliant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Compliant | |||
| Gold | Italpreziosi | ITALY | Compliant | |||
| Gold | Japan Mint | JAPAN | Compliant | |||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Compliant | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | In Communication | |||
| Gold | Kazzinc | KAZAKHSTAN | Compliant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Compliant | |||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Compliant | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant |
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| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant | |||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Outreach Required | |||
| Gold | L’Orfebre S.A. | ANDORRA | Compliant | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Outreach Required | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Marsam Metals | BRAZIL | Compliant | |||
| Gold | Materion | UNITED STATES OF AMERICA | Compliant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Compliant | |||
| Gold | Metalor Technologies S.A. | SWITZERLAND | Compliant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Compliant | |||
| Gold | MetalurgicaMet-Mex Penoles S.A. De C.V. | MEXICO | Compliant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Compliant | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Compliant | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Compliant | |||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold | OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant | |||
| Gold | PAMP S.A. | SWITZERLAND | Compliant | |||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | Outreach Required | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Planta Recuperadora de Metales SpA | CHILE | Compliant | |||
| Gold | Prioksky Plant ofNon-Ferrous Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant | |||
| Gold | PX Precinox S.A. | SWITZERLAND | Compliant | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant | |||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Outreach Required |
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| Gold | REMONDIS PMR B.V. | NETHERLANDS | Compliant | |||
| Gold | Royal Canadian Mint | CANADA | Compliant | |||
| Gold | SAAMP | FRANCE | Compliant | |||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Outreach Required | |||
| Gold | Safimet S.p.A | ITALY | Compliant | |||
| Gold | Sai Refinery | INDIA | Outreach Required | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Compliant | |||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Compliant | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Compliant | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Compliant | |||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Outreach Required | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | T.C.A S.p.A | ITALY | Compliant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Compliant | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Compliant | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Compliant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Gold | Valcambi S.A. | SWITZERLAND | Compliant | |||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Compliant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Compliant | |||
| Gold | Yamakin Co., Ltd. | JAPAN | Compliant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant | |||
| Tungsten | A.L.M.T. Corp. | JAPAN | Compliant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Compliant |
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| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Compliant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | Compliant | |||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Compliant | |||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Compliant | |||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Compliant | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
*Processing facility name and location as reported by the Responsible Minerals Initiative (RMI)
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Country of Origin for the Conflict Minerals processed by the facilities listed above may include:
Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea (Republic Of), Kyrgyzstan, Lithuania, Malaysia, Mexico, Myanmar, Netherlands, Peru, Philippines, Poland, Russian Federation, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan (Province Of China), Thailand, Turkey, United Arab Emirates, United States Of America, Uzbekistan, Vietnam
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