Exhibit 1.01
Allegion plc
Conflict Minerals Report
For the reporting period January 1 to December 31, 2021
EXHIBIT 1.01
Allegion plc
Conflict Minerals Report
For the reporting period from January 1 to December 31, 2021
Contents | |||||
Background | |||||
Forward Looking Statements | |||||
Covered Minerals | |||||
Company Overview | |||||
Product Description | |||||
Conflict Minerals Program Overview | |||||
Reasonable Country of Origin Inquiry | |||||
OECD Due Diligence Framework in Practice | |||||
STEP 1: Establish Strong Company Management Systems | |||||
Company Conflict Minerals Policy | |||||
Internal Team | |||||
Reporting Mechanism | |||||
STEP 2: Identify and Assess Risks in the Supply Chain | |||||
Scope | |||||
Execution | |||||
STEP 3: Design and Implement a Strategy to Respond to Indentified Risks | |||||
STEP 4: Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices | |||||
STEP 5: Report Annually on Supply Chain Due Diligence | |||||
2021 Results | |||||
Due Diligence Determination | |||||
Independent Private Sector Audit | |||||
Future Initiatives | |||||
Reported Entities | |||||
Definitions |
2
Background
This Specialized Disclosure Report on Form SD of Allegion plc ("Allegion," "we," "us" or the “Company") for the year ended Dec. 31, 2021, 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 Aug. 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 (the “Covered Countries”), a central African region with vast mineral wealth, including reserves of conflict minerals.
3
Forward-Looking Statements
Certain statements in this report, other than purely historical information, are “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These forward-looking statements generally are identified by the words “believe,” “project,” “expect,” “anticipate,” “estimate,” “forecast,” “outlook,” “intend,” “strategy,” “future,” “opportunity,” “plan,” “may,” “should,” “will,” “would,” “will be,” “will continue,” “will likely result” or the negative thereof or variations thereon or similar expressions generally intended to identify forward-looking statements.
Forward-looking statements are based on the Company's currently available information and our current assumptions, expectations and projections about future events. They are subject to future events, risks and uncertainties - many of which are beyond the Company’s control - as well as potentially inaccurate assumptions, that could cause actual results to differ materially from those in the forward-looking statements. Further information on these factors and other risks that may affect the Company's business is included in filings it makes with the Securities and Exchange Commission from time to time, including its Form 10-K for the year ended Dec. 31, 2021, and in its other SEC filings. The Company undertakes no obligation to update any forward-looking statements.
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 certain of their derivatives (currently limited to tin, tantalum 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.
4
Company Overview
We are a global pioneer in seamless access, providing security products and solutions that keep people and their assets safe and productive. Focusing on security around the door and adjacent areas, we offer an extensive and versatile portfolio of mechanical, electronic and software products for homes, businesses, schools and institutions. We are dedicated to upholding our values, serving as a trusted partner for end users, distributors, other innovators and the industry, and making the communities where we live and work better. We have prepared this report to satisfy the requirements of Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Exchange Act.
Product Description
The following categories of electronic and other products that we manufacture or contract to manufacture may contain conflict minerals that are necessary to the functionality or production of such products:
• Locks, keys & levers – mechanical locks, master key systems, mechanical levers and handles, padlocks;
• Portable & out of home – portable and action sports locks and security, action sports lights;
• Electronic access & monitoring – electronic and connected locks, access management cards, keypads, credentials, readers, software, services;
• Doors, exits, openers, closers & accessories – doors, exit devices, door openers, latches, other door accessories;
• Other door hardware – weather stripping, threshold solutions, hinges, lites, louvers; and
• Accessibility & wellness – safety and comfort solutions, bath hardware, accessibility aids, quiet solutions.
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
5
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”) provided by the Responsible Business Alliance’s (RBA) and Global e-Sustainability Initiative (“GeSI”) through its Responsible Minerals Initiative (RMI). Our RCOI was designed to determine whether any of the conflict minerals in our products manufactured in 2021, 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 or raw materials that they supply to us. We reviewed the information our suppliers provided and compared it to publicly available information about such smelters and refiners.
OECD Due Diligence Framework in Practice
We designed our due diligence measures to conform, in all material respects, with the framework in 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 (Second Edition) and the related Supplements for gold, tin, tantalum and tungsten (“the Guidance”). 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
6
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 strategic, direct suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.
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:
https://www.allegion.com/corp/en/about/ESG/environmental/conflict-minerals.html.
Internal Team
Our conflict minerals program is designed to conform to the internationally recognized due diligence framework of the OECD. The framework includes standard operating procedures, supplier risk segmentation, established processes for RCOI, due diligence 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 a global supply chain compliance team that reports up to the Senior Vice President - Global Operations and Integrated Supply Chain and is responsible to the Corporate Secretary’s Office for the Form SD report creation, and focuses on driving the compliance efforts of the conflict minerals program, executing the procedures, working closely with a third-party regulatory compliance consulting firm to advance the maturity and sophistication of the program and further
7
strengthening the conformance with the OECD Guidance and standards. Our continued conflict minerals program maturity progress can be attributed to several successfully executed initiatives:
• Attendance at conferences that include topics related to conflict minerals;
• Advancing internal knowledge through continuing education;
• Following any updates to relevant regulations (such as following news releases, webinars, industry initiatives); and
• Third-party software solution and consulting services, such as –
◦ We leveraged this software to upload related legacy documents for retention purposes and will retain the records for a period of five years per the OECD Guidelines;
◦ We are leveraging this software to offer training and updates for suppliers; and
◦ We utilize their resources for benchmarking purposes.
We collaborate closely with our suppliers by developing long-lasting relationships. Our supplier development team has the responsibility to qualify and develop our suppliers. This team conducts periodic reviews of our Global Supplier Requirements Manual, which lays out the Company’s expectations of suppliers with respect to compliance with local, state and national regulations, including the Rule.
Further, we have a dedicated commodity management team responsible for maintaining relationships with suppliers within their assigned commodities. This team also monitors supplier performance and selectively manages strategic relationships with preferred suppliers to help 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 Rule, and allows our company to audit and inspect data, records and other materials to evidence conflict minerals use and controls.
Per the OECD Guidelines, we retain and maintain our records for a period of five years on a company share-drive system. These records are also loaded into our third-party software system, Assent Compliance Manager system (“ACM System”), and we will continue to leverage this system for record keeping purposes.
8
Reporting Mechanism
As part of our continuing efforts to ensure lawful and ethical behavior, the Allegion Code of Conduct and Allegion Business Partner Code of Conduct advise employees and business partners to report legal and ethical questions or concerns. Both documents can be found by clicking on the following link: https://www.allegion.com/corp/en/about/ESG/governance/ethics-and-compliance-program.html.
A variety of options are available for employees and business partners to ask questions or report concerns in the area of ethics and compliance.
Employees. As set forth in the Allegion Code of Conduct (“Code”), employees may contact their manager, local management or local Human Resources partner; they may also contact the Allegion Legal Department, Chief Compliance Officer or Ethics HelpLine (“HelpLine”). Specific instructions for contacting these resources are provided in the Code. Employees contacting the HelpLine may choose to remain anonymous if consistent with applicable local law. The HelpLine is available 24/7 and is staffed by an independent organization. The Code also includes a section entitled “Zero-tolerance for retaliation,” which prohibits retaliation against individuals asking questions or raising concerns.
Business Partners. The Allegion Business Partner Code of Conduct (“Business Partner Code”) states that business partners who wish to seek guidance or report concerns in the ethics and compliance area may send an email to Allegion, submit a report to Allegion via the Internet, send a letter to Allegion by mail or contact the HelpLine. Specific instructions and information (such as email, internet and mailing addresses, and U. S. and international HelpLine phone numbers) on reporting using each of these resources is provided in the Business Partner Code. Examples of business partners noted in the Business Partner Code include agents, distributors, dealers, contractors, suppliers, vendors, service providers, intermediaries, joint venture partners and others.
STEP 2: Identify and Assess Risks in Our 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. Risks are
9
identified automatically in the Assent system based on criteria established for supplier responses. These risks are addressed by Assent Compliance supply chain staff and members of our internal conflict minerals team who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
The primary risk we identified with respect to the reporting period ended Dec. 31, 2021, is related to the nature of the responses received. Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to Allegion. Additionally, some suppliers indicated that they received information regarding their supply chains from 50% or less of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains. Based on the supply chain information we collected, we performed a risk-based approach in our due diligence that included:
▪ Risk Identification through a commodity segmentation across the company for components (including electronic products) or products previously identified as containing, or were suspected of containing, conflict mineral(s).
▪ Risk Assessment and prioritization based on information about purchased components or products from engineering, catalogs, sourcing managers and commodity-taxonomy definition. Our categories were as follows:
• High Concern
◦ Electronic products / components
◦ Materials / mechanical components containing 3TG’s
• Low Concern
◦ Mechanical products, molded components, finishing, powered coats
• No Concern / Out of Scope
◦ Plastics extrusions, foam/insulation
◦ Packaging, paper, wood, chemicals, service providers, etc.
▪ Risk Monitoring of new suppliers and additional information, including changes in regulatory landscape. When new suppliers are identified, we conduct a risk assessment of the anticipated purchases to determine the concern level. Based on this assessment, we engage with all relevant suppliers and request that they complete and return the CMRT.
10
Execution
For our 2021 campaign, we retained Assent Compliance (“Assent”), our third-party service provider, to assist us in reviewing our supply chain. We initiated the campaign with a communication to our supply base authorizing Assent to solicit information from our suppliers. Next, Assent distributed a “campaign kick- off” letter in multiple languages that laid out the timing of the 2021 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 6.1);
• Allegion contact information and conflict minerals website; and
• CMRT response deadline.
We followed this 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 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 Responsible Minerals Initiative (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.
11
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:
• Reviews of Dun and Bradstreet reports;
• Checks of the U.S. Department of Commerce Conflict Mineral processing facilities;
• Verification of country of origin risk, as listed in the RMAP Audit Procedure; and
• Internet searches.
Assent uses three factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags:
• Geographic proximity to the DRC and covered countries;
• RMAP audit status; and
• Credible evidence of unethical or conflict sourcing.
Based on these criteria Assent Compliance identified the following third-party facilities in the received CMRT responses as “SORs of Interest”:
• African Gold Refinery – CID003185 – Uganda;
• Kaloti Metals – CID002563 – UAE;
• Fidelity Printers – CID002515 – Zimbabwe;
• Sudan Refinery – CID002567 – Sudan;
• Industrial Refining Company – CID002587 – Belgium; and
• Kyrgyzaltyn JSC – CID001029 - Kyrgyz Republic.
Through Assent Compliance, submissions that include any of the above facilities immediately produce a response instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to components or products that they supply to us, if any, and escalating up to removal of these “Smelters of Interest” from their supply chain.
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.
12
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD 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 responsible minerals sourcing policy?
E. Have you implemented due diligence measures for responsible 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?
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. As of March 27, 2022, 17% of our responsive suppliers have been identified as having a strong program, and 13% of suppliers have been identified as having a weak program.
STEP 3: Design and Implement a Strategy to Respond to Identified Risks
We provide periodic reports on the progress of our campaign process to our Global Supply Management leadership. On an annual basis, we provide an update to the Executive Leadership Team about the state of our conflict minerals program and have a separate meeting with the Senior Vice President - Global Operations and Integrated Supply Chain (“SVP Global Operations”) and the Deputy General Counsel and Corporate Secretary where we review the process, efforts, challenges, milestones and results before the final Form SD report is signed by the SVP Global Operations and filed with the SEC.
If there is a need for any meetings outside of the regular cadence to discuss emergency/escalation matters, our SVP Global Operations as well as our Deputy General Counsel and Corporate Secretary are available at short notice. Further, we have established an oversight governing body (Conflict Minerals Risk Team) 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 as indicated below. We also review with internal audit members as needed.
13
• Deputy General Counsel and Corporate Secretary
• SVP Global Operations
• Director, Global Quality Processes
• Manager, Supply Chain Compliance
STEP 4: Utilize Independent Third-Party Audits of Supply Chain Diligence Practices
While we do not have a team of resources to independently audit the smelters/refiners within our supply chain, we have partnered with Assent Compliance, a ‘best-in-class’ third-party software and regulatory consulting company, who performs audits and verification activities of smelters/refiners across the globe as part of their business services for Allegion.
STEP 5: Publicly Report on Supply Chain Due Diligence
This is the ninth year that we have reported on our conflict minerals program, our risk assessment and due diligence, as well as 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 progress has been made, we were unable to determine with certainty that all the conflict minerals contained in our products are from conflict-free sources due to, among other things, the following:
a. Several 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 our suppliers, and some 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 these declarations might include smelters and refiners that do not provide the conflict minerals that are in our products.
14
As a result, we do not have sufficient information to conclusively determine the country of origin of all 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.
2021 Results
For 2021, we reviewed 1,002 suppliers and actively engaged with 312 suppliers that we deemed relevant based on historical CMRT responses and purchases. We received CMRT submissions from 185 suppliers (response rate of 59.3%). All CMRTs were reviewed for completeness and accuracy. Out of the received CMRTs, 177 were validated and provided the basis for our list of “Reported Entities,” starting on page 16 of this report.
Based on the due diligence process described under the heading “OECD Due Diligence Framework in Practice” on page 5 of this report 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 the following 339 entities (listed in the Reported Entities section), and that we have categorized as follows:
• 234 smelters were classified as “RMAP Conformant;”
• 68 smelters had a status of “Not Enrolled;”
• 20 smelters are “RMAP Active;” and
• 17 smelters are “Non-Conformant.”
“RMAP Conformant” means the smelter has successfully completed a RMAP audit and maintains good standing in the program, through a continual validation process. These smelters or refiners (SOR’s) have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support their sourcing activities.
Due Diligence Determination
For the reasons stated in this report, we do not have sufficient information to conclusively determine the country of origin of all the conflict minerals in our products described under the heading “Product Description” on page 4 of this report 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.
15
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 several initiatives to enhance our conflict minerals program, such as:
• Continued education and training both for our company and 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.
16
Reported Entities
Metal | Smelter Name | Smelter Facility Location | ||||||
Gold | Advanced Chemical Company | United States Of America | ||||||
Gold | Aida Chemical Industries Co., Ltd. | Japan | ||||||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | ||||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||||||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | ||||||
Gold | Argor-Heraeus S.A. | Switzerland | ||||||
Gold | Asahi Pretec Corp. | Japan | ||||||
Gold | Asaka Riken Co., Ltd. | Japan | ||||||
Gold | Aurubis AG | Germany | ||||||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||||||
Gold | Boliden AB | Sweden | ||||||
Gold | C. Hafner GmbH + Co. KG | Germany | ||||||
Gold | CCR Refinery - Glencore Canada Corporation | Canada | ||||||
Gold | Cendres + Metaux S.A. | Switzerland | ||||||
Gold | Yunnan Copper Industry Co., Ltd. | China | ||||||
Gold | Chimet S.p.A. | Italy | ||||||
Gold | Chugai Mining | Japan | ||||||
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||||||
Gold | DSC (Do Sung Corporation) | Korea, Republic Of | ||||||
Gold | DODUCO Contacts and Refining GmbH | Germany | ||||||
Gold | Dowa | Japan | ||||||
Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | ||||||
Gold | OJSC Novosibirsk Refinery | Russian Federation | ||||||
Gold | Refinery of Seemine Gold Co., Ltd. | China | ||||||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||||||
Gold | LT Metal Ltd. | Korea, Republic Of | ||||||
Gold | Heimerle + Meule GmbH | Germany | ||||||
Gold | Heraeus Metals Hong Kong Ltd. | China | ||||||
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
17
Gold | Hunan Chenzhou Mining Co., Ltd. | China | ||||||
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | ||||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||||||
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | ||||||
Gold | Istanbul Gold Refinery | Turkey | ||||||
Gold | Japan Mint | Japan | ||||||
Gold | Jiangxi Copper Co., Ltd. | China | ||||||
Gold | Asahi Refining USA Inc. | United States Of America | ||||||
Gold | Asahi Refining Canada Ltd. | Canada | ||||||
Gold | JSC Uralelectromed | Russian Federation | ||||||
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||||||
Gold | Kazzinc | Kazakhstan | ||||||
Gold | Kennecott Utah Copper LLC | United States Of America | ||||||
Gold | Kojima Chemicals Co., Ltd. | Japan | ||||||
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||||||
Gold | Lingbao Gold Co., Ltd. | China | ||||||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | ||||||
Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | ||||||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | ||||||
Gold | Materion | United States Of America | ||||||
Gold | Matsuda Sangyo Co., Ltd. | Japan | ||||||
Gold | Metalor Technologies (Suzhou) Ltd. | China | ||||||
Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||||||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||||||
Gold | Metalor Technologies S.A. | Switzerland | ||||||
Gold | Metalor USA Refining Corporation | United States Of America | ||||||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | ||||||
Gold | Mitsubishi Materials Corporation | Japan | ||||||
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
18
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||||||
Gold | Nihon Material Co., Ltd. | Japan | ||||||
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | ||||||
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | ||||||
Gold | PAMP S.A. | Switzerland | ||||||
Gold | 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 Precinox S.A. | Switzerland | ||||||
Gold | Rand Refinery (Pty) Ltd. | South Africa | ||||||
Gold | Royal Canadian Mint | Canada | ||||||
Gold | Sabin Metal Corp. | United States Of America | ||||||
Gold | Samduck Precious Metals | Korea, Republic Of | ||||||
Gold | SEMPSA Joyeria Plateria 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 | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||||||
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | ||||||
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||||||
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||||||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | ||||||
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 | Torecom | Korea, Republic Of | ||||||
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | ||||||
Gold | United Precious Metal Refining, Inc. | United States Of America | ||||||
Gold | Valcambi S.A. | Switzerland | ||||||
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | ||||||
Gold | Yamakin Co., Ltd. | Japan |
19
Gold | Yokohama Metal Co., Ltd. | Japan | ||||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||||||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | ||||||
Gold | Guangdong Jinding Gold Limited | China | ||||||
Gold | Umicore Precious Metals Thailand | Thailand | ||||||
Gold | Geib Refining Corporation | United States Of America | ||||||
Gold | MMTC-PAMP India Pvt., Ltd. | India | ||||||
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | ||||||
Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | ||||||
Gold | Shandong Humon Smelting Co., Ltd. | China | ||||||
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | ||||||
Gold | Emirates Gold DMCC | United Arab Emirates | ||||||
Gold | T.C.A S.p.A | Italy | ||||||
Gold | REMONDIS PMR B.V. | Netherlands | ||||||
Gold | Shirpur Gold Refinery Ltd. | India | ||||||
Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | ||||||
Gold | Marsam Metals | Brazil | ||||||
Gold | TOO Tau-Ken-Altyn | Kazakhstan | ||||||
Gold | SAAMP | France | ||||||
Gold | L'Orfebre S.A. | Andorra | ||||||
Gold | 8853 S.p.A. | Italy | ||||||
Gold | Italpreziosi | Italy | ||||||
Gold | SAXONIA Edelmetalle GmbH | Germany | ||||||
Gold | WIELAND Edelmetalle GmbH | Germany | ||||||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||||||
Gold | AU Traders and Refiners | South Africa | ||||||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | ||||||
Gold | Sai Refinery | India | ||||||
Gold | Bangalore Refinery | India | ||||||
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | ||||||
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
20
Gold | Pease & Curren | United States Of America | ||||||
Gold | JALAN & Company | India | ||||||
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | ||||||
Gold | Planta Recuperadora de Metales SpA | Chile | ||||||
Gold | Safimet S.p.A | Italy | ||||||
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | ||||||
Gold | QG Refining, LLC | United States Of America | ||||||
Gold | CGR Metalloys Pvt Ltd. | India | ||||||
Gold | Sovereign Metals | India | ||||||
Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | ||||||
Gold | Augmont Enterprises Private Limited | India | ||||||
Gold | Kundan Care Products Ltd. | India | ||||||
Gold | Emerald Jewel Industry India Limited (Unit 1) | India | ||||||
Gold | Emerald Jewel Industry India Limited (Unit 2) | India | ||||||
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | ||||||
Gold | Emerald Jewel Industry India Limited (Unit 4) | India | ||||||
Gold | K.A. Rasmussen | Norway | ||||||
Gold | Alexy Metals | United States Of America | ||||||
Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | ||||||
Gold | Sellem Industries Ltd. | Mauritania | ||||||
Gold | MD Overseas | India | ||||||
Gold | Metallix Refining Inc. | United States Of America | ||||||
Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | ||||||
Gold | Kazakhmys Smelting LLC | Kazakhstan | ||||||
Gold | SAFINA A.S. | Czechia | ||||||
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | ||||||
Gold | International Precious Metal Refiners | United Arab Emirates | ||||||
Gold | NH Recytech Company | Korea, Republic Of | ||||||
Gold | C.I Metales Procesados Industriales SAS | Colombia | ||||||
Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | ||||||
Gold | WEEEREFINING | France |
21
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||||||
Gold | Caridad | Mexico | ||||||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | ||||||
Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | ||||||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||||||
Gold | L'azurde Company For Jewelry | Saudi Arabia | ||||||
Gold | Samwon Metals Corp. | Korea, Republic Of | ||||||
Gold | Morris and Watson | New Zealand | ||||||
Gold | Abington Reldan Metals, LLC | United States Of America | ||||||
Gold | Modeltech Sdn Bhd | Malaysia | ||||||
Gold | Super Dragon Technology Co., Ltd. | China | ||||||
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||||||
Gold | Kaloti Precious Metals | United Arab Emirates | ||||||
Gold | Sudan Gold Refinery | Sudan | ||||||
Gold | Fujairah Gold FZC | United Arab Emirates | ||||||
Gold | Industrial Refining Company | Belgium | ||||||
Gold | African Gold Refinery | Uganda | ||||||
Gold | Gold Coast Refinery | Ghana | ||||||
Gold | Dijllah Gold Refinery FZC | United Arab Emirates | ||||||
Gold | Value Trading | Belgium | ||||||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | ||||||
Tantalum | Exotech Inc. | United States Of America | ||||||
Tantalum | F&X Electro-Materials Ltd. | China | ||||||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | ||||||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||||||
Tantalum | Jiujiang Tanbre Co., Ltd. | China | ||||||
Tantalum | LSM Brasil S.A. | Brazil | ||||||
Tantalum | Metallurgical Products India Pvt., Ltd. | India | ||||||
Tantalum | Mineracao Taboca S.A. | Brazil | ||||||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | ||||||
Tantalum | NPM Silmet AS | Estonia |
22
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||||||
Tantalum | QuantumClean | United States Of America | ||||||
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||||||
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||||||
Tantalum | Taki Chemical Co., Ltd. | Japan | ||||||
Tantalum | Telex Metals | United States Of America | ||||||
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||||||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||||||
Tantalum | D Block Metals, LLC | United States Of America | ||||||
Tantalum | FIR Metals & Resource Ltd. | China | ||||||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||||||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | ||||||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||||||
Tantalum | KEMET Blue Metals | Mexico | ||||||
Tantalum | H.C. Starck Co., Ltd. | Thailand | ||||||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | ||||||
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | ||||||
Tantalum | H.C. Starck Inc. | United States Of America | ||||||
Tantalum | H.C. Starck Ltd. | Japan | ||||||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | ||||||
Tantalum | Global Advanced Metals Boyertown | United States Of America | ||||||
Tantalum | Global Advanced Metals Aizu | Japan | ||||||
Tantalum | Resind Industria e Comercio Ltda. | Brazil | ||||||
Tantalum | Jiangxi Tuohong New Raw Material | China | ||||||
Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | China | ||||||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||||||
Tin | Alpha | United States Of America | ||||||
Tin | Dowa | Japan | ||||||
Tin | EM Vinto | Bolivia (Plurinational State Of) | ||||||
Tin | Fenix Metals | Poland | ||||||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
23
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | ||||||
Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||||||
Tin | China Tin Group Co., Ltd. | China | ||||||
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||||||
Tin | Metallic Resources, Inc. | United States Of America | ||||||
Tin | Mineracao Taboca S.A. | Brazil | ||||||
Tin | Minsur | Peru | ||||||
Tin | Mitsubishi Materials Corporation | Japan | ||||||
Tin | Jiangxi New Nanshan Technology Ltd. | China | ||||||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||||||
Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | ||||||
Tin | PT Mitra Stania Prima | Indonesia | ||||||
Tin | PT Refined Bangka Tin | Indonesia | ||||||
Tin | PT Timah Tbk Kundur | Indonesia | ||||||
Tin | PT Timah Tbk Mentok | Indonesia | ||||||
Tin | Rui Da Hung | Taiwan, Province Of China | ||||||
Tin | Soft Metais Ltda. | Brazil | ||||||
Tin | Thaisarco | Thailand | ||||||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | ||||||
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | ||||||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | ||||||
Tin | Yunnan Tin Company Limited | China | ||||||
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | ||||||
Tin | Melt Metais e Ligas S.A. | Brazil | ||||||
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||||||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||||||
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | ||||||
Tin | Resind Industria e Comercio Ltda. | Brazil | ||||||
Tin | Super Ligas | Brazil | ||||||
Tin | Metallo Belgium N.V. | Belgium |
24
Tin | Metallo Spain S.L.U. | Spain | ||||||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | ||||||
Tin | HuiChang Hill Tin Industry Co., Ltd. | China | ||||||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||||||
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||||||
Tin | PT Bangka Serumpun | Indonesia | ||||||
Tin | Pongpipat Company Limited | Myanmar | ||||||
Tin | Tin Technology & Refining | United States Of America | ||||||
Tin | Ma'anshan Weitai Tin Co., Ltd. | China | ||||||
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | ||||||
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | ||||||
Tin | CRM Synergies | Spain | ||||||
Tin | PT Stanindo Inti Perkasa | Indonesia | ||||||
Tin | PT Tinindo Inter Nusa | Indonesia | ||||||
Tin | PT Artha Cipta Langgeng | Indonesia | ||||||
Tin | PT Babel Surya Alam Lestari | Indonesia | ||||||
Tin | PT Prima Timah Utama | Indonesia | ||||||
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||||||
Tin | PT Menara Cipta Mulia | Indonesia | ||||||
Tin | PT Rajawali Rimba Perkasa | Indonesia | ||||||
Tin | Luna Smelter, Ltd. | Rwanda | ||||||
Tin | PT Aries Kencana Sejahtera | Indonesia | ||||||
Tin | Estanho de Rondonia S.A. | Brazil | ||||||
Tin | Novosibirsk Processing Plant Ltd. | Russian Federation | ||||||
Tin | PT Babel Inti Perkasa | Indonesia | ||||||
Tin | PT Bukit Timah | Indonesia | ||||||
Tin | PT Sariwiguna Binasentosa | Indonesia | ||||||
Tin | PT Timah Nusantara | Indonesia | ||||||
Tin | CV Venus Inti Perkasa | Indonesia | ||||||
Tin | PT Sukses Inti Makmur | Indonesia | ||||||
Tin | PT Mitra Sukses Globalindo | Indonesia |
25
Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | ||||||
Tin | PT Belitung Industri Sejahtera | Indonesia | ||||||
Tin | PT Panca Mega Persada | Indonesia | ||||||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||||||
Tin | Modeltech Sdn Bhd | Malaysia | ||||||
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | ||||||
Tin | Precious Minerals and Smelting Limited | India | ||||||
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | ||||||
Tin | PT Tommy Utama | Indonesia | ||||||
Tin | VQB Mineral and Trading Group JSC | Viet Nam | ||||||
Tin | PT Tirus Putra Mandiri | Indonesia | ||||||
Tin | PT Cipta Persada Mulia | Indonesia | ||||||
Tin | PT Masbro Alam Stania | Indonesia | ||||||
Tungsten | A.L.M.T. Corp. | Japan | ||||||
Tungsten | Kennametal Huntsville | United States Of America | ||||||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||||||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||||||
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | ||||||
Tungsten | Global Tungsten & Powders Corp. | United States Of America | ||||||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | ||||||
Tungsten | Japan New Metals Co., Ltd. | Japan | ||||||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | ||||||
Tungsten | Kennametal Fallon | United States Of America | ||||||
Tungsten | Wolfram Bergbau und Hutten AG | Austria | ||||||
Tungsten | Xiamen Tungsten Co., Ltd. | China | ||||||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||||||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||||||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||||||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||||||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
26
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||||||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||||||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | ||||||
Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | ||||||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | ||||||
Tungsten | H.C. Starck Tungsten GmbH | Germany | ||||||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | ||||||
Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | ||||||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||||||
Tungsten | Niagara Refining LLC | United States Of America | ||||||
Tungsten | China Molybdenum Co., Ltd. | China | ||||||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | ||||||
Tungsten | Hydrometallurg, JSC | Russian Federation | ||||||
Tungsten | Unecha Refractory metals plant | Russian Federation | ||||||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | ||||||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | ||||||
Tungsten | ACL Metais Eireli | Brazil | ||||||
Tungsten | Moliren Ltd. | Russian Federation | ||||||
Tungsten | KGETS Co., Ltd. | Korea, Republic Of | ||||||
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | ||||||
Tungsten | Cronimet Brasil Ltda | Brazil | ||||||
Tungsten | Artek LLC | Russian Federation | ||||||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | ||||||
Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | ||||||
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | ||||||
Tungsten | NPP Tyazhmetprom LLC | Russian Federation | ||||||
Tungsten | GEM Co., Ltd. | China | ||||||
Tungsten | Fujian Xinlu Tungsten | China | ||||||
Tungsten | OOO “Technolom” 2 | Russian Federation | ||||||
Tungsten | OOO “Technolom” 1 | Russian Federation | ||||||
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
27
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 any country that shares an internationally recognized border with the DRC
OECD Organisation 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
SORs of Interest Smelters or Refiners that present significant risk to supply chains, as per the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
28