EXHIBIT 1.01
BABCOCK & WILCOX ENTERPRISES, INC.
CONFLICT MINERALS REPORT
YEAR ENDED DECEMBER 31, 2021
Introduction
This Conflict Minerals Report (this "Report") has been prepared by management of Babcock & Wilcox Enterprises, Inc. In this Report, unless the context otherwise indicates, "B&W," "we," "us," the "Company" and "our" mean Babcock & Wilcox Enterprises, Inc. and its consolidated subsidiaries. This Report for the year ended December 31, 2021 (the “Reporting Period”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TG”) as necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this Report, B&W has reason to believe that some of the 3TG present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TG in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we cannot rule out the possibility that we may have some suppliers that sourced 3TG from the Covered Countries and proceeded to conduct due diligence on our in scope suppliers.
Forward looking statements
Statements we make in this Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward- looking statements, including statements relating to our compliance efforts and expected actions identified under the “Steps to be taken” section of this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our ability to implement improvements in our conflict minerals program and identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (“SEC”), including our Annual Report on Form 10-K for the year ended December 31, 2021. B&W cautions not to place undue reliance on these forward-looking statements, which speak only as of the date of this Report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.
Overview
B&W is a growing, globally-focused renewable, environmental and thermal technologies provider with over 150 years of experience providing diversified energy and emissions control solutions to a broad range of industrial, electrical utility, municipal and other customers. B&W’s innovative products and services are organized into three market-facing segments. Our reportable segments are as follows:
• Babcock & Wilcox Renewable: Cost-effective technologies for efficient and environmentally sustainable power and heat generation, including waste-to-energy, solar construction and installation, biomass energy and black liquor systems for the pulp and paper industry. B&W’s leading technologies support a circular economy by diverting waste from landfills to use for power generation and replacing fossil fuels while recovering metals and reducing emissions.
• Babcock & Wilcox Environmental: A full suite of best-in-class emissions control and environmental technology solutions for utility, waste to energy, biomass, carbon black and industrial steam generation applications around the world. B&W’s broad experience includes systems for cooling, ash handling, particulate control, nitrogen oxides and sulfur dioxides removal, chemical looping for carbon control, and mercury control.
• Babcock & Wilcox Thermal: Steam generation equipment, aftermarket parts, construction, maintenance and field services for plants in the power generation, oil and gas, and industrial sectors. B&W has an extensive global base of installed equipment for utilities and general industrial applications including refining, petrochemical, food processing, metals and others.
Our business depends significantly on the capital, operations and maintenance expenditures of global electric power generating companies, including renewable and thermal powered heat generation industries and industrial facilities with environmental compliance policy requirements. Several factors may influence these expenditures, including:
•climate change initiatives promoting environmental policies which include renewable energy options utilizing waste-to-energy or biomass to meet legislative requirements and clean energy portfolio standards in the United States, European, Middle East and Asian markets;
•requirements for environmental improvements in various global markets;
•expectation of future governmental requirements to further limit or reduce greenhouse gas and other emissions in the United States, Europe and other international climate change sensitive countries;
•prices for electricity, along with the cost of production and distribution including the cost of fuels within the United States, Europe, Middle East and Asian based countries;
•demand for electricity and other end products of steam-generating facilities;
•level of capacity utilization at operating power plants and other industrial uses of steam production;
•requirements for maintenance and upkeep at operating power plants to combat the accumulated effects of usage;
•prices of and access to materials, particularly as a result of rising inflation and the impact of the Russian invasion of Ukraine;
•overall strength of the industrial industry; and
•ability of electric power generating companies and other steam users to raise capital.
Customer demand is heavily affected by the variations in our customers' business cycles and by the overall economies and energy, environmental and noise abatement needs of the countries in which they operate.
Our products
We conducted an analysis of our products to determine which of our products were likely to contain 3TG. We have identified 3TG in products within each of our business segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period.
Conflict minerals policy
We have adopted a conflict minerals policy, as follows, which is also publicly available on our website at “ http://s22.q4cdn.com/178702546/files/doc_downloads/gov_doc/Conflict-Minerals-Policy.pdf ”. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
We support sourcing components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. We are committed to complying with the SEC disclosure requirements and are working with our suppliers to perform reasonable country of origin inquiries and due diligence in determining the potential for conflict minerals in our supply chain and products.
We expect our suppliers to partner with us in our commitment to compliance and have designed our efforts to align with conflict minerals reporting rules.
Description of RCOI
Our operations use materials, such as carbon and alloy steels in various forms and components and accessories for assembly, which are available from numerous sources. We generally purchase materials and components as needed for individual contracts.
As noted above, we manufacture a variety of products for which materials included in those products may differ from year to year. These products are highly complex, typically containing thousands of parts from many suppliers throughout the world. We may purchase the same materials from multiple different suppliers and distributors. These suppliers and distributors often obtain their materials from lower tier suppliers. Accordingly, our supply chain is deep and identifying the ultimate source of materials supplied to us is difficult. We rely on our direct suppliers to work with their suppliers to provide information on the smelters and origin of the 3TG contained in components and materials supplied to us.
During the Reporting Period, our compliance efforts included both our domestic and our international locations. For each of the products (or subassemblies) that we identified as containing 3TG necessary to their functionality or production, we identified the suppliers that provided the materials comprising each of these products. We specifically identified each supplier that provided the materials containing the 3TG that we identified, as the 3TG in these products and related supplier base was limited.
To determine whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), our third party service provider, to assist us in reviewing our supply chain and identifying risks. We provided a list composed of suppliers associated with the covered products to Assent for upload to the Assent Compliance Manager tool (“ACM”).
B&W utilized the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) version 6.0 or higher to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM, a software-as-a-service (SaaS) platform provided by Assent that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question 1 of the CMRT asks suppliers whether any of the 3TGs are intentionally added or used in the products or in the production process. Question 2 also asks if any 3TGs remain in their products. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. We conducted this analysis based on the following criteria:
•The company supplies packaging only (excluding labels)
•The company supplies us with items that do not end up in our products (including equipment used to make our products)
•The company is a test lab
•The company is a service provider only
•The company is in active litigation with B&W
Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. B&W directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested such suppliers to complete the CMRT form and submit such form to Assent.
Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT.
All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to submit a valid form. Suppliers are also provided with
guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. As of May 9th, 2022, there were 13 invalid supplier submissions that could not be corrected.
Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the Responsible Mineral Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total of 337 smelters and refiners that appear on the lists maintained by RMI. Of these 337 smelters and refiners, 231 are validated as conflict free by RMI or a cross-recognized initiative.
Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products.
Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the conflict minerals in question.
As of May 9th, 2022, there were 1453 suppliers in scope of the conflict minerals program and 691 provided a completed CMRT. B&W’s total response rate for this reporting year was 48%. These metrics are summarized in the table below in order to assess progress over time:
| | | | | | | | | | | |
| Year | Suppliers in Scope | % Responded | %Invalid |
| RY 2019 | 787 | 44% | 0.38% |
| RY 2020 | 1358 | 55% | 1.24% |
| RY 2021 | 1453 | 48% | 0.89% |
Due diligence
Design of due diligence
We designed our due diligence measures to conform, in all material respects, with the framework in The Organization 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.Reporting annually on our supply chain due diligence
Due diligence requires B&W’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as we cannot fully own this process. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.
We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, B&W does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.
The Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the 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 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.
Due diligence performed
1. Establish strong company management systems
Conflict minerals policy
We established a Conflict Minerals Policy related to our sourcing of 3TG as described in full in the “Conflict Minerals Policy” section above and posted this policy on our website at “http://s22.q4cdn.com/178702546/files/doc_downloads/gov_doc/Conflict-Minerals-Policy.pdf ” within the “Investors” section under “Corporate Governance.” The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Internal team
We commissioned a Conflict Minerals Steering Committee comprised of individuals in management positions across the procurement, legal and finance functions. The Conflict Minerals Steering Committee is led by members of our senior management. The Conflict Minerals Steering Committee governs our conflict minerals compliance effort and is responsible for providing guidance and direction for the implementation of our conflict minerals program.
We also use a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regards to conflict minerals. The use of Assent and its tools has allowed us to assist our suppliers in understanding our expectations and requirements with respect to conflict minerals compliance.
We leverage Assent’s Managed Services in order to work with dedicated program specialists who support B&W’s conflict minerals program. We communicate regularly with the Assent team in order to receive updates on program status.
Control systems and grievance mechanism
We do not typically have a direct relationship with smelters and refiners. However, we have controls in place designed to uphold our core values and ethical standards in all interactions with customers, vendors, suppliers, shareholders, fellow employees and others. These controls include a Code of Business Conduct and a Supplier Code of Conduct that outline expected behaviors for all employees, vendors and independent contractors. These Codes are publicly available on our website within the “Company” section under “Ethics.” To this end, anyone can utilize our Integrity Line as detailed in the Codes to proactively report a violation of our Code or policies, including our conflict minerals policy and related program efforts.
Maintain records
We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of ten years.
In addition, we implemented a document retention policy through Assent to retain conflict minerals related documents for five years, including supplier responses to CMRTs. We store all the information and findings from this process in a database that can be audited by internal or external parties.
Supplier engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 6.0 or higher and Assent’s web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.
We continue to emphasize supplier education and training. To accomplish this, we utilized Assent’s learning management system and provided all in-scope suppliers access to many conflict minerals training and support resources. This training was tracked and evaluated based on completion. B&W has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, B&W through Assent has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. B&W suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.
We believe that the combination of the Supplier Code of Conduct, our Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and requests constitute a strong program when it comes to supplier engagement.
2. Identify and assess risks in the supply chain
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 identified automatically in the Assent Compliance Manager system based on criteria established for supplier responses in the System. These risks are addressed by Assent Compliance Supply Chain staff and members of our supply chain team internally who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TGs in the components supplied to B&W. Additionally, some 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.
In accordance with the Guidance, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2021 calendar year.
To assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed the RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.
Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
•Geographic proximity to the DRC and Covered Countries;
•Known mineral source country of origin;
•RMAP audit status;
•Credible evidence of unethical or conflict sourcing;
•Peer Assessments conducted by credible third-party sources.
As part of our risk management plan under the Guidance, when facilities of interest were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent Compliance, submissions that include any facilities of interest immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to B&W, and escalating up to removal of these smelters of interest from their supply chain.
As per the Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent’s learning management system to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
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 Guidance 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?
When suppliers meet or exceed those criteria (Yes to at least A, E, G, 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 May 9th, 2022, a total of 73 of our responsive suppliers have been identified as having a weak program.
3. Design and implement a strategy to respond to risks
We report our findings annually to the Conflict Minerals Steering Committee prior to the issuance of Form SD and this Report. We also report any significant due diligence findings to the Conflict Minerals Steering Committee as they arise. For example, if we find that we source 3TG that directly or indirectly finances or benefits armed groups, in the Covered Countries, B&W will assess the supplier relationship and encourage the supplier in question to
establish an alternative source of 3TG that does not support such conflict. We have found no instance where it was necessary to implement risk mitigation efforts as a result of a supplier’s response to our information request.
As per the Guidance, risk mitigation will depend on the supplier’s specific context. Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. We engage suppliers believed to be supplying 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the Guidance. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.
4. Carry-out independent third-party audit of supply chain due diligence at identified points in the supply chain
We do not typically have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.
Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.
5. Public reporting on supply chain due diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at “http://investors.babcock.com/financials-information/sec-filings/default.aspx ” within the “Investors” section under “Financial Information” and “SEC Filings” and is filed with the SEC. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Results of due diligence
Survey results
As described above, B&W actively surveys our supply chain and reviews the responses against criteria developed to determine whether further engagement is required. These criteria include: untimely responses, incomplete responses and inconsistencies within the data reported in the CMRT.
As of May 9th 2022 we received responses from over 48% of our 1453 surveyed suppliers for the Reporting Period. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. A total of 13 suppliers were unable to correct their CMRTs and as such, are still listed as invalid submissions. Additionally, no suppliers were deemed out of scope.
SUPPLY CHAIN OUTREACH METRICS
| | | | | | | | | | | |
Number of In-Scope Suppliers for 2021 | Change in Number of In-Scope Suppliers From 2020 |
Response Rate |
Valid Response Rate |
| 1453 | 95 | 49% | 48% |
Efforts to determine mine or location of origin
Given that we do not have established relationships with the ultimate smelters and refiners from which the 3TG in our products is sourced, we have determined that requesting our suppliers to complete the CMRT represents our good faith effort to determine the mines or locations of origin of 3TG in our supply chain.
Smelters and refiners
Of the suppliers surveyed, many completed the CMRT at the company, business unit or entity level and are unable to represent that 3TG from the processing facilities they listed had actually been included in components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continues to be varied. Many of the responses provided by suppliers via the CMRT included the names of facilities listed by the suppliers as smelters or refiners ("SORs"). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and Assent follows up on these, urging suppliers to resubmit the form and include smelter information. Any CMRTs submitted by suppliers unable to provide SORs used for the materials supplied to us are deemed invalid.
For all responses that indicated a smelter, Assent compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as "Conflict-Free," Assent confirmed that the name was listed by the RMI as a certified smelter. As of May 9th, 2022, we have identified 337 smelters or refiners that were reported by our suppliers via the CMRT. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. All smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. Appendix B includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 231 smelters that are deemed RMAP Conformant - this indicates these smelters or refiners are compliant with the Conflict Free Smelter Program assessment protocols. There are 18 more smelters or refiners that are deemed RMAP Active - Smelters and refiners on the Active list have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 71 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. As mentioned above, there are 20 smelters or refiners that we consider “High Risk
Smelters”, and 81 of the CMRTs submitted by B&W suppliers reported at least one of these twenty smelters of concern.
Risk mitigation activities were initiated on the suppliers submitting these entries in their CMRT. Through Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions including removal of these red-flag smelters from their supply chain. The submission of these smelters by B&W suppliers does not guarantee that these smelters or refiners are present in the B&W supply chain as these B&W suppliers were only able to provide company-level CMRTs and not able to provide product-level CMRTs directly linking those smelters or refiners to the products they provide to B&W.
As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to make any determinations regarding the 3TG included in our products during the Reporting Period or to provide additional smelter and refiner names and country of origin of the necessary 3TGs at this time.
| | | | | |
| Status | Number of Identified Smelters and Refiners |
| RMAP Conformant | 231 |
| RMAP Active | 18 |
| Not Enrolled | 71 |
| Non-Conformant | 17 |
Countries of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively
source 3TGs, based on information provided through the CMRT data collection process, from direct smelter
outreach and the RMAP. As mentioned in the above section, it is understood that many responses may
provide more data than can be directly linked to products sold by our company, therefore, Appendix B may
contain more countries than those that the Company’s products are being sourced from.
Steps to be taken
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our conflict minerals program and related due diligence. Our next steps may include, but are not limited to the following:
•Engage with suppliers and direct them to training resources, including increasing the number who utilize Assent’s learning management system. This will encourage supplier participation and improve the overall efficiency of our Conflict Minerals Due Diligence Program.
•Increase the emphasis on clean and validated smelter and refiner information from our supply chain through Assent as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the RMAP program.
•Encourage our suppliers through Assent to develop and strengthen their internal policies to include due diligence procedures for their supply chains to improve the quality of the responses from such suppliers.
•Update and maintain the supplier list and contact information for subsequent supplier engagement.
•Further document procedures and timelines for administering the conflict mineral program.
Smelter & Refiner Risk Evaluation
Understanding the risks associated with the smelters and refiners potentially providing material into our supply chain is an important part of the due diligence process. Through Assent, comprehensive and ongoing analysis is conducted by Assent’s smelter library manager to assess sourcing risk. This information is used to:
•Provide supplier feedback.
•Determine the health of the Company’s overall program.
•Conduct outreach to smelters, refiners and their respective associations.
•Provide detailed analysis in this report.
The following risk categories are used for smelter evaluation and risk determination:
Geo-Risk: Did the mineral originate from or has been transported through a conflict-affected area as defined by Section 1502 of the Dodd-Frank Act (the DRC and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia)?
Audit Status: Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD Guidance? Assent relies on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance.
Sourcing risk: Has evidence of any other risk characteristic is supported by credible sources been identified?
Appendix A:
The following smelters and refiners were reported by our suppliers as being in their supply chains. Facilities that have been certified as conflict-free by an internationally-recognized validation scheme for 3TG smelters and refiners are designated below in the sixth column.
| | | | | | | | | | | | | | | | | | | | | | | |
| Metal | Smelter Name | | Smelter Facility Location | | Smelter ID | RMAP Audit Status | Conflict Free? |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | | China | | CID000211 | Conformant | Yes |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | | China | | CID000258 | Conformant | Yes |
| Tantalum | F&X Electro-Materials Ltd. | | China | | CID000460 | Conformant | Yes |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | | China | | CID000875 | Conformant | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | | China | | CID000917 | Conformant | Yes |
| Tantalum | NPM Silmet AS | | Estonia | | CID001200 | Conformant | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | | China | | CID001277 | Conformant | Yes |
| Tantalum | Ulba Metallurgical Plant JSC | | Kazakhstan | | CID001969 | Conformant | Yes |
| Tungsten | Wolfram Bergbau und Hutten AG | | Austria | | CID002044 | Conformant | Yes |
| Tungsten | Xiamen Tungsten Co., Ltd. | | China | | CID002082 | Conformant | Yes |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | | China | | CID002316 | Conformant | Yes |
| Tantalum | D Block Metals, LLC | | United States Of America | | CID002504 | Conformant | Yes |
| Tantalum | FIR Metals & Resource Ltd. | | China | | CID002505 | Conformant |
Yes |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | | Germany | | CID002542 | Conformant | Yes |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | | Germany | | CID002545 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tantalum | Global Advanced Metals Boyertown | | United States Of America | | CID002557 | Conformant | Yes |
| Tin | EM Vinto | | Bolivia (Plurinational State Of) | | CID000438 | Conformant | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | | Malaysia | | CID001105 | Conformant | Yes |
| Tin | Mineracao Taboca S.A. | | Brazil | | CID001173 | Conformant | Yes |
| Tin | Minsur | | Peru | | CID001182 | Conformant | Yes |
| Tin | PT Timah Tbk Mentok | | Indonesia | | CID001482 | Conformant | Yes |
| Tin | Thaisarco | | Thailand | | CID001898 | Conformant | Yes |
| Gold | Advanced Chemical Company | | United States Of America | | CID000015 | Conformant | Yes |
| Gold | Aida Chemical Industries Co., Ltd. | | Japan | | CID000019 | Conformant | Yes |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | | Germany | | CID000035 | Conformant | Yes |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | | Uzbekistan | | CID000041 | Conformant | Yes |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | | Brazil | | CID000058 | Conformant | Yes |
| Gold | Argor-Heraeus S.A. | | Switzerland | | CID000077 | Conformant | Yes |
| Gold | Asahi Pretec Corp. | | Japan | | CID000082 | Conformant | Yes |
| Gold | Asaka Riken Co., Ltd. | | Japan | | CID000090 | Conformant | Yes |
| Gold | Aurubis AG | | Germany | | CID000113 | Conformant | Yes |
| Gold | Boliden AB | | Sweden | | CID000157 | Conformant | Yes |
| Gold | C. Hafner GmbH + Co. KG | | Germany | | CID000176 | Conformant | Yes |
| Gold | CCR Refinery - Glencore Canada Corporation | | Canada | | CID000185 | Conformant | Yes |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | | China | | CID000218 | Conformant | Yes |
| Gold | Chimet S.p.A. | | Italy | | CID000233 | Conformant | Yes |
| Gold | Chugai Mining | | Japan | | CID000264 | Conformant | Yes |
| Tin | Alpha | | United States Of America | | CID000292 | Conformant | Yes |
| Gold | DSC (Do Sung Corporation) | | Korea, Republic Of | | CID000359 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tin | Dowa | | Japan | | CID000402 | Conformant | Yes |
| Tin | Estanho de Rondonia S.A. | | Brazil | | CID000448 | Conformant | Yes |
| Tin | Fenix Metals | | Poland | | CID000468 | Conformant | Yes |
| Gold | OJSC Novosibirsk Refinery | | Russian Federation | | CID000493 | Non Conformant | No |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | China | | CID000538 | Conformant | Yes |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | | China | | CID000555 | Conformant | Yes |
| Tungsten | Global Tungsten & Powders Corp. | | United States Of America | | CID000568 | Conformant | Yes |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | | China | | CID000616 | Conformant | Yes |
| Gold | LT Metal Ltd. | | Korea, Republic Of | | CID000689 | Conformant | Yes |
| Gold | Heimerle + Meule GmbH | | Germany | | CID000694 | Conformant | Yes |
| Gold | Heraeus Metals Hong Kong Ltd. | | China | | CID000707 | Conformant | Yes |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | China | | CID000801 | Conformant | Yes |
| Gold | Ishifuku Metal Industry Co., Ltd. | | Japan | | CID000807 | Conformant | Yes |
| Gold | Istanbul Gold Refinery | | Turkey | | CID000814 | Conformant | Yes |
| Gold | Japan Mint | | Japan | | CID000823 | Conformant | Yes |
| Tungsten | Japan New Metals Co., Ltd. | | Japan | | CID000825 | Conformant | Yes |
| Gold | Jiangxi Copper Co., Ltd. | | China | | CID000855 | Conformant | Yes |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | China | | CID000914 | Conformant | Yes |
| Gold | Asahi Refining USA Inc. | | United States Of America | | CID000920 | Conformant | Yes |
| Gold | Asahi Refining Canada Ltd. | | Canada | | CID000924 | Conformant | Yes |
| Gold | JSC Uralelectromed | | Russian Federation | | CID000929 | Non Conformant | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | JX Nippon Mining & Metals Co., Ltd. | | Japan | | CID000937 | Conformant | Yes |
| Gold | Kazzinc | | Kazakhstan | | CID000957 | Conformant | Yes |
| Gold | Kennecott Utah Copper LLC | | United States Of America | | CID000969 | Conformant | Yes |
| Gold | Kojima Chemicals Co., Ltd. | | Japan | | CID000981 | Conformant | Yes |
| Tantalum | LSM Brasil S.A. | | Brazil | | CID001076 | Conformant | Yes |
| Gold | LS-NIKKO Copper Inc. | | Korea, Republic Of | | CID001078 | Conformant | Yes |
| Gold | Matsuda Sangyo Co., Ltd. | | Japan | | CID001119 | Conformant | Yes |
| Tin | Metallic Resources, Inc. | | United States Of America | | CID001142 | Conformant | Yes |
| Gold | Metalor Technologies (Suzhou) Ltd. | | China | | CID001147 | Conformant | Yes |
| Gold | Metalor Technologies (Hong Kong) Ltd. | | China | | CID001149 | Conformant | Yes |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | | Singapore | | CID001152 | Conformant | Yes |
| Gold | Metalor Technologies S.A. | | Switzerland | | CID001153 | Conformant | Yes |
| Gold | Metalor USA Refining Corporation | | United States Of America | | CID001157 | Conformant | Yes |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | | Mexico | | CID001161 | Conformant | Yes |
| Tantalum | Metallurgical Products India Pvt., Ltd. | | India | | CID001163 | Conformant | Yes |
| Tantalum | Mineracao Taboca S.A. | | Brazil | | CID001175 | Conformant | Yes |
| Gold | Mitsubishi Materials Corporation | | Japan | | CID001188 | Conformant | Yes |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | | Japan | | CID001192 | Conformant | Yes |
| Gold | Mitsui Mining and Smelting Co., Ltd. | | Japan | | CID001193 | Conformant | Yes |
| Gold | Moscow Special Alloys Processing Plant | | Russian Federation | | CID001204 | Non Conformant | No |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | | Turkey | | CID001220 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tin | Jiangxi New Nanshan Technology Ltd. | | China | | CID001231 | Conformant | Yes |
| Gold | Nihon Material Co., Ltd. | | Japan | | CID001259 | Conformant | Yes |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | | Thailand | | CID001314 | Conformant | Yes |
| Gold | Ohura Precious Metal Industry Co., Ltd. | | Japan | | CID001325 | Conformant | Yes |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | | Russian Federation | | CID001326 | Non Conformant | No |
| Gold | PAMP S.A. | | Switzerland | | CID001352 | Conformant | Yes |
| Gold | Prioksky Plant of Non-Ferrous Metals | | Russian Federation | | CID001386 | Non Conformant | No |
| Gold | PT Aneka Tambang (Persero) Tbk | | Indonesia | | CID001397 | Conformant | Yes |
| Tin | PT Artha Cipta Langgeng | | Indonesia | | CID001399 | Conformant | Yes |
| Tin | PT Babel Surya Alam Lestari | | Indonesia | | CID001406 | Conformant | Yes |
| Tin | PT Mitra Stania Prima | | Indonesia | | CID001453 | Conformant | Yes |
| Tin | PT Prima Timah Utama | | Indonesia | | CID001458 | Conformant | Yes |
| Tin | PT Refined Bangka Tin | | Indonesia | | CID001460 | Conformant | Yes |
| Tin | PT Timah Nusantara | | Indonesia | | CID001486 | Active | No |
| Gold | PX Precinox S.A. | | Switzerland | | CID001498 | Conformant | Yes |
| Tantalum | QuantumClean | | United States Of America | | CID001508 | Conformant | Yes |
| Gold | Rand Refinery (Pty) Ltd. | | South Africa | | CID001512 | Conformant | Yes |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | China | | CID001522 | Conformant | Yes |
| Gold | Royal Canadian Mint | | Canada | | CID001534 | Conformant | Yes |
| Tin | Rui Da Hung | | Taiwan, Province Of China | | CID001539 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Samduck Precious Metals | | Korea, Republic Of | | CID001555 | Conformant | Yes |
| Gold | SEMPSA Joyeria Plateria S.A. | | Spain | | CID001585 | Conformant | Yes |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | China | | CID001622 | Conformant | Yes |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | | China | | CID001736 | Conformant | Yes |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | | Russian Federation | | CID001756 | Non Conformant | No |
| Tin | Soft Metais Ltda. | | Brazil | | CID001758 | Conformant | Yes |
| Gold | Solar Applied Materials Technology Corp. | | Taiwan, Province Of China | | CID001761 | Conformant | Yes |
| Tantalum | Solikamsk Magnesium Works OAO | | Russian Federation | | CID001769 | Conformant | Yes |
| Gold | Sumitomo Metal Mining Co., Ltd. | | Japan | | CID001798 | Conformant | Yes |
| Gold | Tanaka Kikinzoku Kogyo K.K. | | Japan | | CID001875 | Conformant | Yes |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | China | | CID001908 | Conformant | Yes |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | | China | | CID001916 | Conformant | Yes |
| Gold | Tokuriki Honten Co., Ltd. | | Japan | | CID001938 | Conformant | Yes |
| Gold | Torecom | | Korea, Republic Of | | CID001955 | Conformant | Yes |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | | Belgium | | CID001980 | Conformant | Yes |
| Gold | Valcambi S.A. | | Switzerland | | CID002003 | Conformant | Yes |
| Gold | Western Australian Mint (T/a The Perth Mint) | | Australia | | CID002030 | Conformant | Yes |
| Tin | White Solder Metalurgia e Mineracao Ltda. | | Brazil | | CID002036 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Yamakin Co., Ltd. | | Japan | | CID002100 | Conformant | Yes |
| Gold | Yokohama Metal Co., Ltd. | | Japan | | CID002129 | Conformant | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | China | | CID002158 | Conformant | Yes |
| Tin | Yunnan Tin Company Limited | | China | | CID002180 | Conformant | Yes |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | China | | CID002224 | Conformant | Yes |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | | China | | CID002243 | Conformant | Yes |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | China | | CID002315 | Conformant | Yes |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | China | | CID002317 | Conformant | Yes |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | China | | CID002318 | Conformant | Yes |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | | China | | CID002319 | Conformant | Yes |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | | China | | CID002320 | Conformant | Yes |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | | China | | CID002321 | Conformant | Yes |
| Gold | Geib Refining Corporation | | United States Of America | | CID002459 | Conformant | Yes |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | | China | | CID002492 | Conformant | Yes |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | | China | | CID002494 | Conformant | Yes |
| Tin | PT ATD Makmur Mandiri Jaya | | Indonesia | | CID002503 | Conformant | Yes |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | China | | CID002506 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | MMTC-PAMP India Pvt., Ltd. | | India | | CID002509 | Conformant | Yes |
| Gold | KGHM Polska Miedz Spolka Akcyjna | | Poland | | CID002511 | Conformant | Yes |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | | China | | CID002513 | Conformant | Yes |
| Tin | O.M. Manufacturing Philippines, Inc. | | Philippines | | CID002517 | Conformant | Yes |
| Tantalum | KEMET Blue Metals | | Mexico | | CID002539 | Conformant | Yes |
| Tungsten | H.C. Starck Tungsten GmbH | | Germany | | CID002541 | Conformant | Yes |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | | Viet Nam | | CID002543 | Conformant | Yes |
| Tantalum | H.C. Starck Co., Ltd. | | Thailand | | CID002544 | Conformant | Yes |
| Tantalum | H.C. Starck Inc. | | United States Of America | | CID002548 | Conformant | Yes |
| Tantalum | H.C. Starck Ltd. | | Japan | | CID002549 | Conformant | Yes |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | | Germany | | CID002550 | Conformant | Yes |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | China | | CID002551 | Conformant | Yes |
| Tantalum | Global Advanced Metals Aizu | | Japan | | CID002558 | Conformant | Yes |
| Gold | Al Etihad Gold Refinery DMCC | | United Arab Emirates | | CID002560 | Conformant | Yes |
| Gold | Emirates Gold DMCC | | United Arab Emirates | | CID002561 | Conformant | Yes |
| Gold | T.C.A S.p.A | | Italy | | CID002580 | Conformant | Yes |
| Gold | REMONDIS PMR B.V. | | Netherlands | | CID002582 | Conformant | Yes |
| Tungsten | Niagara Refining LLC | | United States Of America | | CID002589 | Conformant | Yes |
| Gold | Korea Zinc Co., Ltd. | | Korea, Republic Of | | CID002605 | Conformant | Yes |
| Gold | TOO Tau-Ken-Altyn | | Kazakhstan | | CID002615 | Conformant | Yes |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | | China | | CID002645 | Conformant | Yes |
| Tungsten | Hydrometallurg, JSC | | Russian Federation | | CID002649 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tin | Resind Industria e Comercio Ltda. | | Brazil | | CID002706 | Conformant | Yes |
| Tantalum | Resind Industria e Comercio Ltda. | | Brazil | | CID002707 | Conformant | Yes |
| Tungsten | Unecha Refractory metals plant | | Russian Federation | | CID002724 | Conformant | Yes |
| Gold | L'Orfebre S.A. | | Andorra | | CID002762 | Conformant | Yes |
| Gold | Italpreziosi | | Italy | | CID002765 | Conformant | Yes |
| Tin | Metallo Belgium N.V. | | Belgium | | CID002773 | Conformant | Yes |
| Tin | Metallo Spain S.L.U. | | Spain | | CID002774 | Conformant | Yes |
| Gold | WIELAND Edelmetalle GmbH | | Germany | | CID002778 | Conformant | Yes |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | Austria | | CID002779 | Conformant | Yes |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | | Philippines | | CID002827 | Conformant | Yes |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | China | | CID002830 | Conformant | Yes |
| Tungsten | ACL Metais Eireli | | Brazil | | CID002833 | Conformant | Yes |
| Tin | PT Menara Cipta Mulia | | Indonesia | | CID002835 | Conformant | Yes |
| Tungsten | Moliren Ltd. | | Russian Federation | | CID002845 | Conformant | Yes |
| Gold | SungEel HiMetal Co., Ltd. | | Korea, Republic Of | | CID002918 | Conformant | Yes |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | China | | CID003116 | Conformant | Yes |
| Tin | PT Bangka Serumpun | | Indonesia | | CID003205 | Conformant | Yes |
| Tin | Tin Technology & Refining | | United States Of America | | CID003325 | Conformant | Yes |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | | China | | CID003379 | Conformant | Yes |
| Tin | PT Masbro Alam Stania | | Indonesia | | CID003380 | Active | No |
| Tin | PT Rajawali Rimba Perkasa | | Indonesia | | CID003381 | Conformant | Yes |
| Tin | Luna Smelter, Ltd. | | Rwanda | | CID003387 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | | China | | CID003401 | Conformant | Yes |
| Tungsten | Lianyou Metals Co., Ltd. | | Taiwan, Province Of China | | CID003407 | Conformant | Yes |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | | Russian Federation | | CID003408 | Conformant | Yes |
| Tungsten | NPP Tyazhmetprom LLC | | Russian Federation | | CID003416 | Active | No |
| Tungsten | GEM Co., Ltd. | | China | | CID003417 | Conformant | Yes |
| Gold | C.I Metales Procesados Industriales SAS | | Colombia | | CID003421 | Active | No |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | | Brazil | | CID003427 | Active | No |
| Tin | PT Mitra Sukses Globalindo | | Indonesia | | CID003449 | Active | No |
| Gold | Augmont Enterprises Private Limited | | India | | CID003461 | Active | No |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | | Brazil | | CID003486 | Active | No |
| Gold | Alexy Metals | | United States Of America | | CID003500 | Active | No |
| Tin | CRM Synergies | | Spain | | CID003524 | Conformant | Yes |
| Gold | Sancus ZFS (L’Orfebre, SA) | | Colombia | | CID003529 | Active | No |
| Gold | Metal Concentrators SA (Pty) Ltd. | | South Africa | | CID003575 | Conformant | Yes |
| Tungsten | A.L.M.T. Corp. | | Japan | | CID000004 | Conformant | Yes |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | Turkey | | CID000103 | Outreach Required | No |
| Tungsten | Kennametal Huntsville | | United States Of America | | CID000105 | Conformant | Yes |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | Philippines | | CID000128 | Conformant | Yes |
| Gold | Caridad | | Mexico | | CID000180 | Outreach Required | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Cendres + Metaux S.A. | | Switzerland | | CID000189 | Conformant | Yes |
| Gold | Yunnan Copper Industry Co., Ltd. | | China | | CID000197 | Outreach Required | No |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | China | | CID000228 | Conformant | Yes |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | | China | | CID000281 | Outreach Required | No |
| Tin | PT Aries Kencana Sejahtera | | Indonesia | | CID000309 | Active | No |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | | China | | CID000343 | In Communication | No |
| Gold | Dowa | | Japan | | CID000401 | Conformant | Yes |
| Gold | Eco-System Recycling Co., Ltd. East Plant | | Japan | | CID000425 | Conformant | Yes |
| Gold | Refinery of Seemine Gold Co., Ltd. | | China | | CID000522 | Outreach Required | No |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | China | | CID000651 | Outreach Required | No |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | | China | | CID000671 | Outreach Required | No |
| Gold | Heraeus Precious Metals GmbH & Co. KG | | Germany | | CID000711 | Conformant | Yes |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | | China | | CID000766 | Conformant | Yes |
| Gold | Hunan Chenzhou Mining Co., Ltd. | | China | | CID000767 | Outreach Required | No |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | | China | | CID000769 | Conformant | Yes |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | | China | | CID000773 | Outreach Required | No |
| Gold | HwaSeong CJ CO., LTD. | | Korea, Republic Of | | CID000778 | Communication Suspended - Not Interested | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | Russian Federation | | CID000927 | RMI Due Diligence Review - Unable to Proceed | No |
| Tin | Gejiu Kai Meng Industry and Trade LLC | | China | | CID000942 | Non Conformant | No |
| Gold | Kazakhmys Smelting LLC | | Kazakhstan | | CID000956 | In Communication | Yes |
| Tungsten | Kennametal Fallon | | United States Of America | | CID000966 | Conformant | Yes |
| Gold | Kyrgyzaltyn JSC | | Kyrgyzstan | | CID001029 | Non Conformant | No |
| Gold | L'azurde Company For Jewelry | | Saudi Arabia | | CID001032 | RMI Due Diligence Review - Unable to Proceed | No |
| Gold | Lingbao Gold Co., Ltd. | | China | | CID001056 | Outreach Required | No |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | China | | CID001058 | Outreach Required | No |
| Tin | China Tin Group Co., Ltd. | | China | | CID001070 | Conformant | Yes |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | China | | CID001093 | Outreach Required | No |
| Gold | Materion | | United States Of America | | CID001113 | Conformant | Yes |
| Tin | Mitsubishi Materials Corporation | | Japan | | CID001191 | Conformant | Yes |
| Gold | Navoi Mining and Metallurgical Combinat | | Uzbekistan | | CID001236 | Conformant | Yes |
| Tin | Novosibirsk Processing Plant Ltd. | | Russian Federation | | CID001305 | Conformant | Yes |
| Tin | Operaciones Metalurgicas S.A. | | Bolivia (Plurinational State Of) | | CID001337 | Conformant | Yes |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | | China | | CID001362 | Outreach Required | No |
| Tin | PT Babel Inti Perkasa | | Indonesia | | CID001402 | Conformant | Yes |
| Tin | PT Belitung Industri Sejahtera | | Indonesia | | CID001421 | Outreach Required | No |
| Tin | PT Bukit Timah | | Indonesia | | CID001428 | Conformant | Yes |
| Tin | PT Panca Mega Persada | | Indonesia | | CID001457 | Outreach Required | No |
| Tin | PT Sariwiguna Binasentosa | | Indonesia | | CID001463 | Conformant | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tin | PT Stanindo Inti Perkasa | | Indonesia | | CID001468 | Conformant | Yes |
| Tin | PT Timah Tbk Kundur | | Indonesia | | CID001477 | Conformant | Yes |
| Tin | PT Tinindo Inter Nusa | | Indonesia | | CID001490 | Conformant | Yes |
| Tin | PT Tommy Utama | | Indonesia | | CID001493 | In Communication | No |
| Gold | Sabin Metal Corp. | | United States Of America | | CID001546 | Communication Suspended - Not Interested | No |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | China | | CID001619 | Outreach Required | No |
| Tantalum | Taki Chemical Co., Ltd. | | Japan | | CID001869 | Conformant | Yes |
| Tantalum | Telex Metals | | United States Of America | | CID001891 | Conformant | Yes |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | | China | | CID001909 | Outreach Required | No |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | | China | | CID001947 | Outreach Required | No |
| Gold | United Precious Metal Refining, Inc. | | United States Of America | | CID001993 | Conformant | Yes |
| Tin | VQB Mineral and Trading Group JSC | | Viet Nam | | CID002015 | Outreach Required | No |
| Gold | Morris and Watson | | New Zealand | | CID002282 | In Communication | Yes |
| Gold | SAFINA A.S. | | Czechia | | CID002290 | Conformant | Yes |
| Gold | Guangdong Jinding Gold Limited | | China | | CID002312 | Outreach Required | No |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | China | | CID002313 | Communication Suspended - Not Interested | No |
| Gold | Umicore Precious Metals Thailand | | Thailand | | CID002314 | Conformant | Yes |
| Tin | CV Venus Inti Perkasa | | Indonesia | | CID002455 | Active | No |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | | Brazil | | CID002468 | Conformant | Yes |
| Tin | PT Tirus Putra Mandiri | | Indonesia | | CID002478 | Outreach Required | No |
| Tin | Melt Metais e Ligas S.A. | | Brazil | | CID002500 | Outreach Required | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | | Viet Nam | | CID002502 | Conformant | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | | China | | CID002508 | Conformant | Yes |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | China | | CID002512 | Conformant | Yes |
| Gold | Fidelity Printers and Refiners Ltd. | | Zimbabwe | | CID002515 | RMI Due Diligence Review - Unable to Proceed | No |
| Gold | Singway Technology Co., Ltd. | | Taiwan, Province Of China | | CID002516 | Conformant | Yes |
| Gold | Shandong Humon Smelting Co., Ltd. | | China | | CID002525 | Outreach Required | No |
| Tantalum | H.C. Starck Hermsdorf GmbH | | Germany | | CID002547 | Conformant | Yes |
| Gold | International Precious Metal Refiners | | United Arab Emirates | | CID002562 | In Communication | No |
| Gold | Kaloti Precious Metals | | United Arab Emirates | | CID002563 | RMI Due Diligence Review - Unable to Proceed | No |
| Gold | Sudan Gold Refinery | | Sudan | | CID002567 | Outreach Required | No |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | Viet Nam | | CID002572 | Non Conformant | No |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | Viet Nam | | CID002573 | Outreach Required | No |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | Viet Nam | | CID002574 | Outreach Required | No |
| Gold | Fujairah Gold FZC | | United Arab Emirates | | CID002584 | Outreach Required | No |
| Gold | Industrial Refining Company | | Belgium | | CID002587 | Non Conformant | No |
| Gold | Marsam Metals | | Brazil | | CID002606 | Conformant | Yes |
| Tin | PT Cipta Persada Mulia | | Indonesia | | CID002696 | Conformant | Yes |
| Tin | An Vinh Joint Stock Mineral Processing Company | | Viet Nam | | CID002703 | Outreach Required | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Abington Reldan Metals, LLC | | United States Of America | | CID002708 | Non Conformant | No |
| Tin | Super Ligas | | Brazil | | CID002756 | Active | No |
| Gold | SAAMP | | France | | CID002761 | Conformant | Yes |
| Gold | 8853 S.p.A. | | Italy | | CID002763 | Conformant | Yes |
| Tin | PT Sukses Inti Makmur | | Indonesia | | CID002816 | Active | No |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | | Viet Nam | | CID002834 | Conformant | Yes |
| Tantalum | Jiangxi Tuohong New Raw Material | | China | | CID002842 | Conformant | Yes |
| Gold | AU Traders and Refiners | | South Africa | | CID002850 | Non Conformant | No |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | | India | | CID002852 | Active | No |
| Gold | Sai Refinery | | India | | CID002853 | Outreach Required | No |
| Gold | Modeltech Sdn Bhd | | Malaysia | | CID002857 | Non Conformant | No |
| Tin | Modeltech Sdn Bhd | | Malaysia | | CID002858 | Non Conformant | No |
| Gold | Bangalore Refinery | | India | | CID002863 | Conformant | Yes |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | | Russian Federation | | CID002865 | Outreach Required | No |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | | Germany | | CID002867 | Outreach Required | No |
| Gold | Pease & Curren | | United States Of America | | CID002872 | Communication Suspended - Not Interested | No |
| Gold | Planta Recuperadora de Metales SpA | | Chile | | CID002919 | Conformant | Yes |
| Gold | Safimet S.p.A | | Italy | | CID002973 | Conformant | Yes |
| Gold | State Research Institute Center for Physical Sciences and Technology | | Lithuania | | CID003153 | Outreach Required | No |
| Gold | African Gold Refinery | | Uganda | | CID003185 | Outreach Required | No |
| Gold | NH Recytech Company | | Korea, Republic Of | | CID003189 | Conformant | Yes |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | | China | | CID003190 | Conformant | Yes |
| Tin | Pongpipat Company Limited | | Myanmar | | CID003208 | Outreach Required | No |
| Gold | QG Refining, LLC | | United States Of America | | CID003324 | Outreach Required | No |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Dijllah Gold Refinery FZC | | United Arab Emirates | | CID003348 | Outreach Required | No |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | China | | CID003356 | Non Conformant | No |
| Gold | CGR Metalloys Pvt Ltd. | | India | | CID003382 | Outreach Required | No |
| Gold | Sovereign Metals | | India | | CID003383 | Outreach Required | No |
| Tungsten | KGETS Co., Ltd. | | Korea, Republic Of | | CID003388 | Conformant | Yes |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | | China | | CID003397 | Non Conformant | No |
| Tin | Precious Minerals and Smelting Limited | | India | | CID003409 | Non Conformant | No |
| Gold | Eco-System Recycling Co., Ltd. North Plant | | Japan | | CID003424 | Conformant | Yes |
| Gold | Eco-System Recycling Co., Ltd. West Plant | | Japan | | CID003425 | Conformant | Yes |
| Tungsten | China Molybdenum Co., Ltd. | | China | | CID002641 | Conformant | Yes |
| Gold | Super Dragon Technology Co., Ltd. | | China | | CID001810 | Outreach Required | No |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | | China | | CID002527 | Outreach Required | No |
| Gold | Shirpur Gold Refinery Ltd. | | India | | CID002588 | Outreach Required | No |
| Gold | JALAN & Company | | India | | CID002893 | Outreach Required | No |
| Gold | Gold Coast Refinery | | Ghana | | CID003186 | Outreach Required | No |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | | China | | CID003410 | Outreach Required | No |
| Gold | Kundan Care Products Ltd. | | India | | CID003463 | In Communication | Yes |
| Tungsten | Cronimet Brasil Ltda | | Brazil | | CID003468 | Conformant | Yes |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | | India | | CID003487 | In Communication | Yes |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | | India | | CID003488 | In Communication | Yes |
| | | | | | | | | | | | | | | | | | | | | | | |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | | India | | CID003489 | In Communication | Yes |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | | India | | CID003490 | In Communication | Yes |
| Gold | K.A. Rasmussen | | Norway | | CID003497 | Outreach Required | No |
| Gold | Sellem Industries Ltd. | | Mauritania | | CID003540 | Communication Suspended - Not Interested | No |
| Gold | MD Overseas | | India | | CID003548 | In Communication | No |
| Tungsten | Artek LLC | | Russian Federation | | CID003553 | Outreach Required | No |
| Gold | Metallix Refining Inc. | | United States Of America | | CID003557 | In Communication | No |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | | Brazil | | CID003582 | Conformant | Yes |
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | | China | | CID003583 | Conformant | Yes |
| Tungsten | Fujian Xinlu Tungsten | | China | | CID003609 | Conformant | Yes |
| Tungsten | OOO “Technolom” 2 | | Russian Federation | | CID003612 | Active | No |
| Tungsten | OOO “Technolom” 1 | | Russian Federation | | CID003614 | Active | No |
| Gold | WEEEREFINING | | France | | CID003615 | Active | No |
| Gold | Value Trading | | Belgium | | CID003617 | In Communication | No |
| Gold | Samwon Metals Corp. | | Korea, Republic Of | | CID001562 | Communication Suspended - Not Interested | No |
| Gold | ABC Refinery Pty Ltd. | | Australia | | CID002920 | Outreach Required | No |
| Tungsten | LLC Volstok | | Russian Federation | | CID003643 | Outreach Required | No |
Appendix B:
Countries of origin:
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.
Afghanistan, Åland Islands, Albania, American Samoa, Andorra, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Democratic Republic of Congo, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, Zimbabwe
