Exhibit 1.01
Allegion plc
Conflict Minerals Report
For the reporting period from January 1 to December 31, 2016
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Contents
Background | 3 | |
Covered Minerals | 3 | |
Company Overview | 4 | |
Conflict Minerals Program Overview | 4 | |
OECD Due Diligence Framework in Practice | 5 | |
Step 1: Establishing Strong Company Management System | 5 | |
Step 2: Identify and Assess Risks in the Supply Chain | 6 | |
Step 3: Design and Implement a Strategy to Respond to Identified Risks | 9 | |
Step 4: Carry out Independent Third-Party Audit of Smelter / Refiner's Due Diligence Practice | 9 | |
Step 5: Report Annually on Supply Chain Due Diligence | 9 | |
2016 Results | 10 | |
Due Diligence Determination | 11 | |
Independent Private Sector Audit | 11 | |
Future Initiatives | 11 | |
Product Description | 11 | |
Reported Entities | 13 | |
Definitions | 20 |
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Background
This Specialized Disclosure Report on Form SD of Allegion plc ("Allegion," "we," "us" or "the Company") for the year ended December 31, 2016 was prepared to comply with the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("the Dodd-Frank Act"). Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), adopted pursuant to Section 1502 the Dodd-Frank Act, was approved by the U.S. Securities and Exchange Commission (the "SEC") on August 22, 2012, and imposes annual reporting requirements on SEC reporting companies relating to the presence of conflict minerals in the products that they manufacture or contract to manufacture.
The rule on conflict minerals focuses on the Democratic Republic of the Congo ("DRC") and surrounding countries (the “Covered Countries”), a central African region with vast mineral wealth, including reserves of conflict minerals.
Covered Minerals
The minerals covered by the SEC rules go by the name conflict minerals but are also referred to as 3TGs, an abbreviation for Tin, Tantalum, Tungsten and Gold. These conflict minerals are used in many manufactured goods across many industries, including the aerospace, appliances, automotive, electronics, jewelry, medical and tool and die industries. The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other minerals or derivatives designated by the Secretary of State in the future, although no additional minerals or derivatives have been so designated at this time.
![drcmap.jpg](https://capedge.com/proxy/SD/0001579241-17-000024/drcmap.jpg)
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Company Overview
We are a leading global provider of security products and solutions that keep people safe, secure and productive. We make the world safer as a company of experts, securing the places where people thrive and we create peace of mind by pioneering safety and security. We offer an extensive and versatile portfolio of mechanical and electronic security products across a range of market-leading brands. Our experts across the globe deliver high-quality security products, services and systems, and we use our deep expertise to serve as trusted partners to end-users who seek customized solutions to their security needs. We have prepared this report to satisfy the requirements of Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Exchange Act.
Conflict Minerals Program Overview
As a purchaser, we are many layers removed from the mining of the conflict minerals, and we do not directly purchase raw ore or unrefined conflict minerals. We rely on collaboration with our supplier base by building awareness through training and provide support in order to identify the downstream supply chain and the originating smelter(s)/refiner(s) for the conflict minerals that ultimately are found in our products.
This effort is both challenging and demanding, as many of our suppliers are private entities that are not directly affected by the Rule, and many times do not have the financial and human resources to comply with the requests. Furthermore, our suppliers have their own supply chains and need to collaborate with their own downstream suppliers in order provide transparency of the end-to-end supply chain and to identify the smelter(s)/refiner(s).
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals by utilizing the conflict minerals reporting template (“CMRT”) developed by the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”). Our RCOI was designed to determine whether any of the necessary conflict minerals in our 2016 products originated in the covered countries or were from recycled or scrap sources by asking our suppliers to identify the smelters and refiners of the conflict minerals contained in the products they supply to us. We then reviewed the information our suppliers provided and compared it to publicly available information about such smelters and refiners. We also performed due diligence work on the source and chain of custody of our conflict minerals using the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD”), an internationally recognized due diligence framework. Further, we leveraged the Committee of Sponsoring Organizations of the Treadway Commission’s (“COSO”) risk assessment approach to conduct risk segmentation of our products (risk identification, risk assessment, risk prioritization and risk monitoring).
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OECD Due Diligence Framework in Practice
STEP 1: Establish Strong Company Management Systems
Company Conflict Minerals Policy
Our policy is to support the legitimate businesses within the Covered Countries, and we expect our suppliers to source conflict minerals responsibly by establishing conflict minerals compliance policies and a due diligence process to support their conflict minerals data collection efforts.
To view our complete Conflict Minerals Policy, visit our webpage located at: http://investor.allegion.com/company-profile/conflict-minerals.
Internal Team
Our conflict minerals program is designed to conform to the internationally recognized standards of OECD. The framework includes standard operating procedures, supplier risk segmentation, due diligence process for RCOI and escalation, training and communication, as well as, an external and internal website containing our Conflict Minerals Policy with information about the regulation, email contact information, and the latest Form SD filing.
We have an established risk management team that reports directly to the Chief Procurement Officer (CPO) of the Global Supply Management function and is responsible to the Office of General Counsel for the Form SD report creation, and focuses on driving the compliance efforts of the conflict minerals program, executing the procedures, and working closely with a third party regulatory compliance consulting firm to advance the maturity and sophistication of the program, and further strengthening the conformance with the OECD framework and standards. Our continued conflict minerals program maturity progress can be attributed to several successfully executed initiatives since our last filing:
▪ | Best practice conflict minerals conference; |
▪ | Allegion conflict minerals program benchmarking; |
▪ | Keeping a pulse on the regulation (following news releases, webinars, industry initiatives); |
▪ | Conflict Free Sourcing Initiative membership; and |
▪ | Third party software solution and consulting services |
◦ | We leveraged this software to upload related legacy documents for retention purposes and will retain the records for a period of 5 years per OECD guidelines and, |
◦ | We are also leveraging this software’s LMS component for training and updates for suppliers. |
We collaborate closely with our suppliers by developing long lasting relationships, and have teams who help to deepen many of those relationships. We invest in a supplier development team whose responsibility is to
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qualify and develop our suppliers, including acknowledgement of the supplier manual that lays out the expectations of compliance with local, state and national regulations, including the conflict minerals rule.
Further, we have a dedicated commodity team who is responsible for maintaining relationships with suppliers within their commodities, and we maintain an Approved Supplier List that helps preserve the stability and longevity of the supplier relationships. Our supplier contracts contain a regulatory clause that explicitly lays out the expectations with the suppliers to comply with laws, including the conflict minerals rule, and allows our company to audit and inspect data, records and other materials to evidence conflict minerals use and controls.
Per the OECD recommended guidelines, we retain and maintain our records for a period of five years on a company share drive system, along with a backup copy on an external hard drive. These legacy records will be loaded into our new third party software system, and going forward we will leverage the solution for record keeping purposes.
Grievance Mechanism
Allegion has established a Helpline for ethical and compliance situations as part of our continuing efforts to ensure lawful and ethical behavior and to maintain compliance with Allegion’s Code of Conduct and Ethical Sourcing Policies & Guidelines.
This is a confidential, non-retaliatory resource for any stakeholder to inform Allegion of concerns or report findings of non-compliance by sending an e-mail or by using by our third-party hotline.
Reports can be made anonymously and will be kept confidential to the extent practicable and allowed by law.
Email: EthicsandCompliance@allegion.com
For the United States and Canada: (855) 807-3267
For all other countries, please visit: http://www.allegion.com - "About Allegion" - "Corporate Governance"
STEP 2: Identify and Assess Risks in the Supply Chain
Scope Identification
We performed a COSO risk based approach in our due diligence that included:
Risk Identification through a product segmentation across the company for products that either contained conflict mineral(s) (electronic products or products containing electronic components) or were suspected of containing conflict mineral(s) (products with alloys - e.g., Mechanical Hardware Products)
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Risk Assessment and prioritization of product risk based on information about the product from engineering, catalogs, category managers and commodity-taxonomy definition. Our risk categories were as follow:
• | High Risk (‘Significant Suppliers’) |
◦ | Electronic products/components |
◦ | Suppliers responding ‘YES’ in the CMRT for the 2014 or 2015 calendar year |
• | Medium Risk |
◦ | Mechanical products with alloys or plating |
• | Low Risk |
◦ | Molded products, finishing, powered coats |
• | No Risk |
◦ | Plastics extrusions, foam/insulation, aluminum |
◦ | Suppliers responding ‘NO’ in the CMRT for the 2014 or 2015 calendar year |
• | Out of scope |
◦ | Packaging, paper, wood, chemicals, etc. |
Risk Monitoring of the product risk universe (e.g., new suppliers, additional information learned about the product through engineering, research, etc.).
• | As we purchase goods, materials or products from new suppliers, we conduct a risk assessment of these new suppliers to determine whether we would consider these new suppliers to be Significant Suppliers. Based on this assessment, we then engage the new suppliers that we deem to be Significant Suppliers to educate them on conflict minerals generally and our conflict minerals policy and also request that they complete and return the CMRT to us. |
Execution
For our 2016 campaign, we retained Assent Compliance (“Assent”), our third-party service provider, to assist us in reviewing our supply chain. Assent initiated this campaign with a communication to our supply base by providing a ‘campaign kick-off’ letter in multiple languages that laid out the timing of the 2016 CMRT campaign, the process, and expectations. Following the ‘campaign kick-off’, Assent provided each supplier with (in multiple languages):
• | Allegion’s Conflict Minerals Policy; |
• | Information about the conflict minerals regulations; |
• | Training materials for the program and CMRT form; |
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• | Allegion contact information and conflict minerals website; and |
• | CMRT response deadline. |
We followed a pre-established process for all suppliers with reminders to complete and return the CMRT, and validated the CMRT responses for completion and accuracy. In addition, we followed an escalation process for all Significant Suppliers who failed to timely complete and return the CMRT or who provided incomplete or inconsistent responses - the process included alternative communication medium (e.g., phone calls or emails from private accounts as opposed to company accounts), leveraging the commodity managers (including local commodity managers in other regions of the world) who had established relationships with the suppliers, and online research of the suppliers to see if they provided any public information regarding conflict minerals (e.g., policy or Form SD filing).
The smelter information provided by the suppliers was validated using the most recent smelter and refinery validation list from the Conflict Free Sourcing Initiative (“CFSI”). Before the validation, the lists were reviewed and scrubbed for:
• | Electronic component suppliers declaring NO 3TGs; |
• | Convert old smelter identification number (“CID”) to new CID; |
• | Remove duplicates and non-actionable submissions; |
• | Identify the CID based on the mineral, name, location; |
• | Remove any entries that don’t meet the CFSI definition of a smelter or refiner; and |
• | Correct misspelled smelters/refiners. |
We reviewed the list to identify smelters/refiners that were participating in the Conflict-Free Smelter Program (“CFSP”) while a risk based assessment was also performed on the remaining smelters/refiners in order to determine which suppliers posed increased risks in the supply chain. This risk assessment and further investigation consisted of, among other things:
• | Reviews of Dun and Bradstreet reports; |
• | Checks of the Department of Commerce Conflict Mineral processing facilities; |
• | Verification of country of origin risk as listed in the CFSP Audit Procedure; and |
• | Internet searches. |
We followed up with suppliers that we deemed high risk in order to educate them on conflict minerals and to assist them in understanding their risk level, and the future implications that this continued risk could have on their customers’ conflict minerals programs.
Due to our continued partnership with Assent Compliance, we were able to leverage the provider to assist us with the smelter review and country-of-origin determination for the data we collected during our due diligence and supplier campaign.
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In 2016, we continued efforts of previous years to refine our supplier scoping process. We completed a detailed product/commodity deep dive for each supplier to remove additional out of scope suppliers to allow focus on high risk suppliers and suppliers who report using 3TGs. Additionally, suppliers who were left out of the 2015 survey due to their answers in the 2014 survey were included once again to collect their biennial response.
STEP 3: Design and Implement a Strategy to Respond to Identified Risks
We report the progress of our campaign process to the CPO of the Global Supply Management on a monthly basis. On an annual basis, we provide an update to the Executive Leadership about the state of our conflict minerals program, and have a separate meeting with the Chief Operating Officer (COO) and the Deputy General Counsel where we review the process, efforts, challenges, milestones, and results before the final Form SD report is signed by the COO, and filed with the SEC.
If there is a need for any meetings outside of the regular cadence to discuss emergency/escalation matters, our COO and Deputy General Counsel are available at short notice. Further, we have established an oversight governing body (Conflict Minerals Risk Team) who is responsible for discussing and deciding the next steps for escalated high-risk/non-compliant suppliers (including any need for renegotiation of supplier terms, termination of supplier relationships, creation of a remediation plan, etc.). The members of the team are:
• | Deputy General Counsel |
• | Chief Procurement Officer |
• | Internal Audit Executive |
• | Manager, Conflict Minerals Risk Management Team |
STEP 4: Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
As a downstream supplier, we do not have a direct relationship with conflict minerals smelters, and we do not have a team of resources to independently audit the smelters/refiners within our supply chain. However, we have partnered with an industry leading organization (the “Conflict Free Sourcing Initiative”) and a ‘best-in-class’ third-party software and regulatory consulting company who perform audits and verification activities of smelters/refiners across the globe as part of their business model, and we encourage our suppliers that use smelters or refiners to participate in the CFSP.
STEP 5: Report Annually on Supply Chain Due Diligence
This is the fourth year that we have reported on our conflict minerals program, our risk assessment and due diligence, and our results. We have experienced a significant maturity from our suppliers in relation to engagement, sophistication of data provided and overall improved transparency in the supply chain.
While significant progress has been made, we were unable to determine with certainty that all of the conflict minerals contained in our products are from conflict free sources due to, among other things, the following:
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a. | A number of our suppliers identified smelters/refiners that do not participate in the CFSP or a similar program and other suppliers failed to identify any smelter/refiner in their responses to us. Furthermore, we were unable to obtain responses from all of our suppliers and other suppliers provided incomplete or inconsistent data. |
b. | Many of our suppliers submitted responses that were declared on a company-wide basis (i.e., representing the smelters and refiners associated with all product offerings of the supplier that contained conflict minerals) and not specific to the materials supplied to Allegion. Therefore, in combination with multiple layers in our supply chain, we believe that these declarations might include smelters and refiners that do not provide the conflict minerals that are in our products. |
As a result, we do not have sufficient information to conclusively determine the country of origin of all of the conflict minerals in our products and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict free sources.
2016 Results
For 2016, we surveyed 908 suppliers (including ‘Significant Suppliers’, Medium and Low Risk suppliers). Of the total supplier base campaigned, 641 suppliers responded for a total response rate of 71%. Our total response rate increased 13% year-over-year, and we believe that was attributed to the following:
• | U.S. conflict minerals rule maturity; |
• | European (EU) Institutions’ proposal and passing of a EU conflict minerals rule (impacting mostly responses from our EU suppliers); |
• | Communication in multiple languages; |
• | Better and/or alternative mediums of communication; |
• | Escalation process; and |
• | Education and assistance to help suppliers understand their submissions (e.g., sharing lessons learned or due diligence findings) |
Based on the due diligence process described above and the information provided by our suppliers, we believe, to the extent reasonably determinable by us, that the facilities used to process the conflict minerals in our products or the other sources of the conflict minerals in our products consist of 317 entities (listed in the Reported Entities section) that we have categorized as follows:
• | 246 smelters were classified as ‘Conflict Free’ |
• | 58 smelters had an ‘Non-Active CFSI’ and ‘Un-Known’ status |
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• | 13 smelters received ‘Active CFSI’ and ‘In-Progress’ status (reflecting the smelters were in process of being certified/re-certified) |
Due Diligence Determination
After performing the due diligence described above, we have better transparency than during the 2015 reporting year. However, we are still unable to determine that all of the conflict minerals contained in the products described below originated from conflict free sources.
For the reasons stated in this report, we also do not have sufficient information to conclusively determine the country of origin of all of the conflict minerals in our products described below and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict free sources.
We have provided this information as of the date of this report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to provide us with complete information, may affect our future determinations under the Rule.
Independent Private Sector Audit
As permitted by Rule 13p-1 and the SEC’s guidance with respect thereto, we did not obtain an independent private sector audit of this Conflict Minerals Report.
Future Initiatives
We plan to execute a number of initiatives to enhance our conflict minerals program, such as:
• | Continued education and training both for our Company and also our supply chain; |
• | Continued partnerships with industry groups and subject matter experts to define and improve best practices and build leverage over our supply chain; |
• | Continued engagement with our suppliers to obtain current, accurate and complete information from them and their downstream supply chain; and |
• | Continued engagement with our third party software solution and consulting company who are working on independently verifying smelters outside of the CFSI smelter certification program. |
Product Description
The following categories of electronic products that we manufacture or contract to manufacture contain conflict minerals that are necessary to the functionality or production of such products:
• | Locks |
• | Doors openers |
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• | Exit devices |
• | Activation sensors |
• | Card readers |
• | Accessories |
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Reported Entities
Metal | Standard Smelter Name | Facility Location |
Gold | Abington Reldan Metals, LLC | UNITED STATES |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | Asahi Refining USA Inc. | UNITED STATES |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | AURA-II | UNITED STATES |
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 | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Cendres + Métaux S.A. | SWITZERLAND |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
Gold | DODUCO GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Elemetal Refining, LLC | UNITED STATES |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Geib Refining Corporation | UNITED STATES |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Gujarat Gold Centre | INDIA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Ltd. Hong Kong | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
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Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES |
Gold | KGHM Polska MiedŸ Spó³ka Akcyjna | POLAND |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | L'Orfebre S.A. | ANDORRA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | Morris and Watson Gold Coast | AUSTRALIA |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | Pease & Curren | UNITED STATES |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox S.A. | SWITZERLAND |
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Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Remondis Argentia B.V. | NETHERLANDS |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Royal Canadian Mint | CANADA |
Gold | SAAMP | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | SAFINA A.S. | CZECH REPUBLIC |
Gold | Sai Refinery | INDIA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | Schone Edelmetaal B.V. | NETHERLANDS |
Gold | SEMPSA Joyería Platería S.A. | SPAIN |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN |
Gold | So Accurate Group, Inc. | UNITED STATES |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN |
Gold | Sudan Gold Refinery | SUDAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | SungEel HiTech | KOREA, REPUBLIC OF |
Gold | T.C.A S.p.A | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Tony Goetz NV | BELGIUM |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES |
Tantalum | Duoluoshan | CHINA |
Tantalum | Exotech Inc. | UNITED STATES |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
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Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck GmbH Goslar | GERMANY |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
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 |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Mineração Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining & Smelting | JAPAN |
Tantalum | Molycorp Silmet A.S. | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Plansee SE Liezen | AUSTRIA |
Tantalum | Plansee SE Reutte | AUSTRIA |
Tantalum | Power Resources Ltd. | MACEDONIA |
Tantalum | QuantumClean | UNITED STATES |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemicals | JAPAN |
Tantalum | Telex Metals | UNITED STATES |
Tantalum | Tranzact, Inc. | UNITED STATES |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES |
Tin | An Thai Minerals Co., Ltd. | VIET NAM |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Dua Sekawan | INDONESIA |
Tin | CV Gita Pesona | INDONESIA |
Tin | CV Serumpun Sebalai | INDONESIA |
Tin | CV Tiga Sekawan | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Dowa | JAPAN |
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Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
Tin | Elmet S.L.U. | SPAIN |
Tin | EM Vinto | BOLIVIA |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
Tin | Gejiu Jinye Mineral Company | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | Metallic Resources, Inc. | UNITED STATES |
Tin | Metallo-Chimique N.V. | BELGIUM |
Tin | Mineração Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Operaciones Metalurgical S.A. | BOLIVIA |
Tin | Phoenix Metal Ltd. | RWANDA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT Cipta Persada Mulia | INDONESIA |
Tin | PT DS Jaya Abadi | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | PT Justindo | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Kijang Jaya Mandiri | INDONESIA |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT O.M. Indonesia | 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 |
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Tin | PT Sukses Inti Makmur | INDONESIA |
Tin | PT Sumber Jaya Indah | INDONESIA |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | PT Wahana Perkit Jaya | INDONESIA |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Thaisarco | THAILAND |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | VQB Mineral and Trading Group JSC | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck 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 Dayu Longxintai Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES |
Tungsten | Kennametal Huntsville | UNITED STATES |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC | UNITED STATES |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
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Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
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Definitions
Conflict Free | Smelters or refiners that have been verified as complying with the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program or an equivalent third-party audit program |
Covered Countries | Refer to the Democratic Republic of the Congo ("DRC") and surrounding countries, a central African region |
OECD Organization for Economic Co-operation and Development
Dodd-Frank Act | Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 |
CID | Smelter Identification Number |
CFSI | Conflict-Free Smelter Initiative |
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