Exhibit 1.01
Allegion plc
Conflict Minerals Report
For the reporting period from January 1 to December 31, 2017
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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 | 6 | |
Company Conflict Minerals Policy | 6 | |
Internal Team | 6 | |
Step 2: Identify and Assess Risks in the Supply Chain | 7 | |
Scope Identification | 7 | |
Execution | 8 | |
When suppliers meet or exceed those criteria (Yes to at least A, E, G, and H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. To date, 61 of our responsive suppliers have been identified as having a weak program. | ||
Step 3: Design and Implement a Strategy to Respond to Identified Risks | 11 | |
Step 4: Carry out Independent Third-Party Audit of Smelter / Refiner's Due Diligence Practices | 11 | |
Step 5: Report Annually on Supply Chain Due Diligence | 11 | |
2017 Results | 12 | |
Due Diligence Determination | 13 | |
Independent Private Sector Audit | 13 | |
Future Initiatives | 13 | |
Reported Entities | 14 | |
Definitions | 21 |
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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, 2017 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 its adjoining countries defined as countries that share an internationally recognized border with the DRC (the “Covered Countries”), a central African region with vast mineral wealth, including reserves of conflict minerals.
![drcmap.jpg](https://capedge.com/proxy/SD/0001579241-18-000024/drcmap.jpg)
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, which are
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currently limited to tantalum, tin and tungsten 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.
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.
The following categories of products we manufacture or contract to manufacture contain conflict minerals that are necessary to the functionality of production of such products:
• | Locks |
• | Door Openers |
• | Exit Devices |
• | Activation Sensors |
• | Card Readers |
• | Accessories |
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).
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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 Responsible Business Alliance’s (RBA) and Global e-Sustainability Initiative (“GeSI”). Our RCOI was designed to determine whether any of the necessary conflict minerals in our 2017 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 smelter and refiners
OECD Due Diligence Framework in Practice
We designed and performed our due diligence measures to conform, in all material respects, with the framework of The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“the Guidance”) and the related Supplements for gold, tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely
1. | Establishing strong company management systems regarding conflict minerals; |
2. | Identifying and assessing risks in our supply chain; |
3. | Designing and implementing a strategy to respond to identified risks in our supply chain; |
4. | Utilizing independent third-party audits of supply chain diligence; and |
5. | Publicly reporting on our supply chain due diligence |
The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.
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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 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 the 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.
• | Best practice conflict minerals conference; |
• | Allegion conflict minerals program benchmarking; |
• | Keeping a pulse on the regulation (following news releases, webinars, industry initiatives); |
• | Participation in the Responsible Minerals Initiative (RMI); 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 qualify and develop our suppliers, including acknowledgment of the supplier manual that lays out the expectations of compliance with local, state and national regulations, including the conflict minerals Rule.
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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, Assent Compliance (“Assent”), 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 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
Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers.
The primary risk we identified with respect to the reporting period ended December 31st, 2017 related to the nature of the responses received. A large number of the responses received provided data at a company or divisional level rather than a product level or were unable to specify the smelters or refiners used for 3TG in the components supplied to Allegion. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
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Based on the supply chain information that we collected, 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) |
▪ | 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 2016 or 2017 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 past reporting periods |
• | Out of scope |
◦ | Packaging, paper, wood, chemicals, service providers 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 request that they complete and return the CMRT to us. |
Execution
For our 2017 campaign, we retained 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-
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off’ letter in multiple languages that laid out the timing of the 2017 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 (version 5.0 or higher); |
• | 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 RMI. 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 RMI definition of a smelter or refiner; and |
• | Correct misspelled smelters/refiners. |
Risks were identified automatically in the Assent Compliance Manage system based on criteria established for supplier response in the system. These risks are addressed by Assent Compliance Supply Chain staff and members of our conflict minerals internally who contact the supplier, gather pertinent data and perform assessment of the supplier’s conflict mineral status.
We reviewed the list to identify smelters/refiners that were participating in the Responsible Minerals Assurance Process (“RMAP”) 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:
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• | 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 RMAP Audit Procedure; and |
• | Internet searches. |
We use three factors to determine the level of risk that each smelter proses to the supply chain by identifying red flags:
• | Geographic Proximity to the DRC and covered countries |
• | Responsible Minerals Assurance Process (RMAP) audit status; and |
• | Credible evidence of unethical or conflict sourcing |
We followed up with suppliers that we deemed high risk based on the smelters reported 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.
Through Assent, submissions that identified high risk facilities immediately produced a receipt instructing the supplier to take their own risk mitigation actions, including a submission of a product specific CMRT to better identify whether minerals from the high-risk facilities are contained in the products that they supply to us.
Due to our continued partnership with Assent, we leveraged 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.
In 2017, 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 us to focus on high risk suppliers and suppliers who report using 3TGs.
Additionally, suppliers were evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:
A. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?
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When suppliers meet or exceed those criteria (Yes to at least A, E, G, and H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. To date, 61 of our responsive suppliers have been identified as having a weak program.
STEP 3: Design and Implement a Strategy to Respond to Identified Risks
We report the progress of our campaign process to the Vice President - Global Procurement 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 Senior Vice President - Global Operations and Integrated Supply Chain and the General Counsel where we review the process, efforts, challenges, milestones, and results before the final Form SD report is signed by the Senior Vice President - Global Operations and Integrated Supply Chain, and filed with the SEC.
If there is a need for any meetings outside of the regular cadence to discuss emergency/escalation matters, our Senior Vice President - Global Operations and Integrated Supply Chain and 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:
• | General Counsel |
• | Senior Vice President - Global Operations and Integrated Supply Chain |
• | Vice President - Global Procurement |
• | Director - Global Supply Strategy and Risk Management |
• | Project Engineer - Materials Compliance |
STEP 4: Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
While we do not have a team of resources to independently audit the smelters/refiners within our supply chain and as a downstream supplier we do not have a direct relationship with the smelter/refiners that process conflict minerals, we have partnered with an industry leading organization (the ”Responsible Minerals 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.
STEP 5: Report Annually on Supply Chain Due Diligence
This is the fifth 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.
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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:
a. | A number of our suppliers identified smelters/refiners that do not participate in the RMAP or a similar program and other suppliers failed to identify any smelter/refiners in their responses to us. Furthermore, we were unable to obtain responses from all of our suppliers while 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.
2017 Results
For 2017, we surveyed 729 suppliers (including ‘Significant Suppliers’, Medium and Low Risk suppliers). Of the total supplier base campaigned, 638 suppliers responded for a total response rate of 88%. From last year to this year, our response rate increased 14% 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), which we have categorized as follows:
• | 256 smelters were classified as ‘Conflict Free’ |
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• | 52 smelters had an ‘Non-Active RMI’ and ‘Un-Known’ status |
• | 9 smelters received ‘Active RMI’ 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 2016 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 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 there to, 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 RMI smelter certification program. |
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Reported Entities
Metal | Standard Smelter Name | Smelter ID |
Gold | Abington Reldan Metals, LLC | CID002708 |
Gold | Advanced Chemical Company | CID000015 |
Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
Gold | Al Etihad Gold LLC | CID002560 |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 |
Gold | Argor-Heraeus S.A. | CID000077 |
Gold | Asahi Pretec Corp. | CID000082 |
Gold | Asahi Refining Canada Ltd. | CID000924 |
Gold | Asahi Refining USA Inc. | CID000920 |
Gold | Asaka Riken Co., Ltd. | CID000090 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 |
Gold | AU Traders and Refiners | CID002850 |
Gold | Aurubis AG | CID000113 |
Gold | Bangalore Refinery | CID002863 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
Gold | Boliden AB | CID000157 |
Gold | C. Hafner GmbH + Co. KG | CID000176 |
Gold | Caridad | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
Gold | Cendres + Métaux S.A. | CID000189 |
Gold | Chimet S.p.A. | CID000233 |
Gold | Chugai Mining | CID000264 |
Gold | Daejin Indus Co., Ltd. | CID000328 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 |
Gold | DODUCO Contacts and Refining GmbH | CID000362 |
Gold | Dowa | CID000401 |
Gold | DSC (Do Sung Corporation) | CID000359 |
Gold | Eco-System Recycling Co., Ltd. | CID000425 |
Gold | Elemetal Refining, LLC | CID001322 |
Gold | Emirates Gold DMCC | CID002561 |
Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | CID002852 |
Gold | Geib Refining Corporation | CID002459 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
Gold | Guangdong Jinding Gold Limited | CID002312 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
Gold | HeeSung | CID000689 |
Gold | Heimerle + Meule GmbH | CID000694 |
Gold | Heraeus Metals Hong Kong Ltd. | CID000707 |
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Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 |
Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
Gold | Hwasung CJ Co., Ltd. | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 |
Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
Gold | Istanbul Gold Refinery | CID000814 |
Gold | Italpreziosi | CID002765 |
Gold | Japan Mint | CID000823 |
Gold | Jiangxi Copper Co., Ltd. | CID000855 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 |
Gold | JSC Uralelectromed | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
Gold | Kaloti Precious Metals | CID002563 |
Gold | Kazakhmys Smelting LLC | CID000956 |
Gold | Kazzinc | CID000957 |
Gold | Kennecott Utah Copper LLC | CID000969 |
Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 |
Gold | Kojima Chemicals Co., Ltd. | CID000981 |
Gold | Korea Zinc Co., Ltd. | CID002605 |
Gold | Kyrgyzaltyn JSC | CID001029 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 |
Gold | L'azurde Company For Jewelry | CID001032 |
Gold | Lingbao Gold Co., Ltd. | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 |
Gold | L'Orfebre S.A. | CID002762 |
Gold | LS-NIKKO Copper Inc. | CID001078 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
Gold | Marsam Metals | CID002606 |
Gold | Materion | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
Gold | Metalor Technologies S.A. | CID001153 |
Gold | Metalor USA Refining Corporation | CID001157 |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 |
Gold | Mitsubishi Materials Corporation | CID001188 |
Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
Gold | Modeltech Sdn Bhd | CID002857 |
Gold | Morris and Watson | CID002282 |
Gold | Morris and Watson Gold Coast | CID002866 |
Gold | Moscow Special Alloys Processing Plant | CID001204 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | CID001220 |
Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
Gold | Nihon Material Co., Ltd. | CID001259 |
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Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 |
Gold | OJSC Novosibirsk Refinery | CID000493 |
Gold | PAMP S.A. | CID001352 |
Gold | Pease & Curren | CID002872 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
Gold | Planta Recuperadora de Metales SpA | CID002919 |
Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
Gold | PX Précinox S.A. | CID001498 |
Gold | Rand Refinery (Pty) Ltd. | CID001512 |
Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 |
Gold | Remondis Argentia B.V. | CID002582 |
Gold | Republic Metals Corporation | CID002510 |
Gold | Royal Canadian Mint | CID001534 |
Gold | SAAMP | CID002761 |
Gold | Sabin Metal Corp. | CID001546 |
Gold | Safimet S.p.A | CID002973 |
Gold | SAFINA A.S. | CID002290 |
Gold | Sai Refinery | CID002853 |
Gold | Samduck Precious Metals | CID001555 |
Gold | SAMWON Metals Corp. | CID001562 |
Gold | SAXONIA Edelmetalle GmbH | CID002777 |
Gold | Schone Edelmetaal B.V. | CID001573 |
Gold | SEMPSA Joyería Platería S.A. | CID001585 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
Gold | Singway Technology Co., Ltd. | CID002516 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
Gold | Solar Applied Materials Technology Corp. | CID001761 |
Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 |
Gold | Sudan Gold Refinery | CID002567 |
Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
Gold | SungEel HiTech | CID002918 |
Gold | T.C.A S.p.A | CID002580 |
Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 |
Gold | Tokuriki Honten Co., Ltd. | CID001938 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
Gold | Tony Goetz NV | CID002587 |
Gold | TOO Tau-Ken-Altyn | CID002615 |
Gold | Torecom | CID001955 |
Gold | Umicore Brasil Ltda. | CID001977 |
Gold | Umicore Precious Metals Thailand | CID002314 |
16
Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 |
Gold | United Precious Metal Refining, Inc. | CID001993 |
Gold | Universal Precious Metals Refining Zambia | CID002854 |
Gold | Valcambi S.A. | CID002003 |
Gold | Western Australian Mint trading as The Perth Mint | CID002030 |
Gold | WIELAND Edelmetalle GmbH | CID002778 |
Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 |
Gold | Yokohama Metal Co., Ltd. | CID002129 |
Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
Tantalum | Asaka Riken Co., Ltd. | CID000092 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 |
Tantalum | D Block Metals, LLC | CID002504 |
Tantalum | Duoluoshan | CID000410 |
Tantalum | Exotech Inc. | CID000456 |
Tantalum | F&X Electro-Materials Ltd. | CID000460 |
Tantalum | FIR Metals & Resource Ltd. | CID002505 |
Tantalum | Global Advanced Metals Aizu | CID002558 |
Tantalum | Global Advanced Metals Boyertown | CID002557 |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 |
Tantalum | H.C. Starck Co., Ltd. | CID002544 |
Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 |
Tantalum | H.C. Starck Inc. | CID002548 |
Tantalum | H.C. Starck Ltd. | CID002549 |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | CID002550 |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | CID002545 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
Tantalum | KEMET Blue Metals | CID002539 |
Tantalum | KEMET Blue Powder | CID002568 |
Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 |
Tantalum | LSM Brasil S.A. | CID001076 |
Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
Tantalum | Mineracao Taboca S.A. | CID001175 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
Tantalum | NPM Silmet AS | CID001200 |
Tantalum | Power Resources Ltd. | CID002847 |
Tantalum | QuantumClean | CID001508 |
Tantalum | Resind Industria e Comercio Ltda. | CID002707 |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 |
17
Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
Tantalum | Taki Chemicals | CID001869 |
Tantalum | Telex Metals | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 |
Tin | Alpha | CID000292 |
Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 |
Tin | China Tin Group Co., Ltd. | CID001070 |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 |
Tin | CV Ayi Jaya | CID002570 |
Tin | CV Dua Sekawan | CID002592 |
Tin | CV Gita Pesona | CID000306 |
Tin | CV Tiga Sekawan | CID002593 |
Tin | CV United Smelting | CID000315 |
Tin | CV Venus Inti Perkasa | CID002455 |
Tin | Dowa | CID000402 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
Tin | EM Vinto | CID000438 |
Tin | Estanho de Rondônia S.A. | CID000448 |
Tin | Fenix Metals | CID000468 |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CID002848 |
Tin | Gejiu Jinye Mineral Company | CID002859 |
Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CID003116 |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 |
Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 |
Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 |
Tin | Malaysia Smelting Corporation (MSC) | CID001105 |
Tin | Melt Metais e Ligas S.A. | CID002500 |
Tin | Metallic Resources, Inc. | CID001142 |
Tin | Metallo Belgium N.V. | CID002773 |
Tin | Metallo Spain S.L.U. | CID002774 |
Tin | Mineracao Taboca S.A. | CID001173 |
Tin | Minsur | CID001182 |
Tin | Mitsubishi Materials Corporation | CID001191 |
Tin | Modeltech Sdn Bhd | CID002858 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
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Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
Tin | Operaciones Metalurgical S.A. | CID001337 |
Tin | Pongpipat Company Limited | CID003208 |
Tin | PT Aries Kencana Sejahtera | CID000309 |
Tin | PT Artha Cipta Langgeng | CID001399 |
Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
Tin | PT Babel Inti Perkasa | CID001402 |
Tin | PT Bangka Prima Tin | CID002776 |
Tin | PT Bangka Serumpun | CID003205 |
Tin | PT Bangka Tin Industry | CID001419 |
Tin | PT Belitung Industri Sejahtera | CID001421 |
Tin | PT Bukit Timah | CID001428 |
Tin | PT DS Jaya Abadi | CID001434 |
Tin | PT Eunindo Usaha Mandiri | CID001438 |
Tin | PT Inti Stania Prima | CID002530 |
Tin | PT Karimun Mining | CID001448 |
Tin | PT Kijang Jaya Mandiri | CID002829 |
Tin | PT Lautan Harmonis Sejahtera | CID002870 |
Tin | PT Menara Cipta Mulia | CID002835 |
Tin | PT Mitra Stania Prima | CID001453 |
Tin | PT O.M. Indonesia | CID002757 |
Tin | PT Panca Mega Persada | CID001457 |
Tin | PT Premium Tin Indonesia | CID000313 |
Tin | PT Prima Timah Utama | CID001458 |
Tin | PT Refined Bangka Tin | CID001460 |
Tin | PT Sariwiguna Binasentosa | CID001463 |
Tin | PT Stanindo Inti Perkasa | CID001468 |
Tin | PT Sukses Inti Makmur | CID002816 |
Tin | PT Sumber Jaya Indah | CID001471 |
Tin | PT Timah (Persero) Tbk Kundur | CID001477 |
Tin | PT Timah (Persero) Tbk Mentok | CID001482 |
Tin | PT Tinindo Inter Nusa | CID001490 |
Tin | PT Tommy Utama | CID001493 |
Tin | Resind Industria e Comercio Ltda. | CID002706 |
Tin | Rui Da Hung | CID001539 |
Tin | Soft Metais Ltda. | CID001758 |
Tin | Super Ligas | CID002756 |
Tin | Thaisarco | CID001898 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 |
Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
Tin | Yunnan Tin Company Limited | CID002180 |
Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 |
Tungsten | ACL Metais Eireli | CID002833 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
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Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CID002536 |
Tungsten | Global Tungsten & Powders Corp. | CID000568 |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 |
Tungsten | H.C. Starck Tungsten GmbH | CID002541 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CID003182 |
Tungsten | Hydrometallurg, JSC | CID002649 |
Tungsten | Japan New Metals Co., Ltd. | CID000825 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
Tungsten | Kennametal Fallon | CID000966 |
Tungsten | Kennametal Huntsville | CID000105 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
Tungsten | Moliren Ltd | CID002845 |
Tungsten | Niagara Refining LLC | CID002589 |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CID002815 |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 |
Tungsten | Unecha Refractory metals plant | CID002724 |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 |
Tungsten | Wolfram Bergbau und Hütten AG | CID002044 |
Tungsten | Woltech Korea Co., Ltd. | CID002843 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 |
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Appendix B
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe
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 adjoining countries, a central African region |
Level 1 Country (L1) | Countries with known active production that are not identified as conflict regions or plausible smuggling routes of conflict minerals |
Level 2 Country (L2) | Known or plausible smuggling routes, export out of Level 3 countries, or transit of conflict minerals (incl. Kenya, Mozambique, and South Africa) |
Level 3 Country (L3) | The Democratic Republic of the Congo (DRC) and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act, commonly referred to as ‘covered countries (incl. Angola, Burundi, Central African Republic, DRC, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia) |
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 |
RMI | Responsible Minerals Initiative |
21