CONFLICT MINERALS REPORT OF HEWLETT PACKARD ENTERPRISE
PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
Hewlett Packard Enterprise Company (“HPE”) presents this Conflict Minerals Report for the reporting period of January 1, 2018 to December 31, 2018 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission.
We are a global technology leader focused on developing intelligent solutions that allow customers to capture, analyze and act upon data seamlessly from edge to cloud. We enable customers to accelerate business outcomes by driving new business models, creating new customer and employee experiences, and increasing operational efficiency today and into the future. Our legacy dates back to a partnership founded in 1939 by William R. Hewlett and David Packard, and we strive every day to uphold and enhance that legacy through our dedication to providing innovative technological solutions to our customers.
Unless otherwise specified or unless the context otherwise requires, references to “we,” “us,” or “our” refer to HPE and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear in this report have the meanings given in Item 1.01 of Form SD.
Overview of our Conflict Minerals Program
As part of HPE’s commitment to sustainability, HPE’s suppliers are expected to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HPE’s Supply Chain Social and Environmental Responsibility Policy and HPE’s General Specification for the Environment Standards (available at https://h20195.www2.hpe.com/v2/Getdocument.aspx?docname=c04797673 and https://h20195.www2.hpe.com/v2/Getdocument.aspx?docname=c04862211&ENW respectively). Both policies contain a section on conflict minerals. HPE’s Supplier Social and Environmental Responsibility requirements, which include conflict minerals due diligence and reporting obligations, are incorporated into contracts with direct suppliers. HPE engages in ongoing supplier outreach and communications, addressing in particular the substance of our conflict minerals policy and our expectations and objectives with respect to conflict minerals.
HPE has been recognized as an industry leader for the company’s efforts to advance the use of responsibly sourced minerals, including those from the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”). Our goal is to improve the transparency of mineral sourcing within our supply chain while striving to achieve DRC conflict free sourcing for our products. Ultimately, we aim to improve conditions in the DRC, its adjoining countries, and other conflict-affected and high-risk areas. Because we believe it is important to avoid the economic and humanitarian impacts associated with an embargo of the DRC region, we continue to source – and do not prohibit our suppliers from sourcing – from the Covered Countries.
HPE is a member of the Responsible Minerals Initiative (“RMI”), which is instrumental in developing and advancing programs and tools such as the Responsible Minerals Assurance Program (“RMAP”) and the Conflict Minerals Reporting Template (the “Template”). Consistent with past years, HPE also participates in RMI’s Smelter Engagement team and Multi-Stakeholder group. In 2018, we facilitated direct outreach to more than 40 smelters and refiners (“SORs”) of gold or the derivatives tin, tantalum, or tungsten (collectively “3TG”) to encourage their involvement in RMAP and we began participating in RMI’s Single Point of Contact Program (“SPOC”). Through SPOC, HPE works closely with an eligible SOR, encouraging their participation in RMAP and supporting them through the pre-audit and audit process should they decide to participate. To increase SORs’ accessibility to, and participation in RMI’s RMAP audit program, in 2018, HPE made a financial contribution to RMI’s Initial Audit Fund for Participating Smelters, a fund that supports SORs with the costs of RMAP audits.
HPE continues to contribute financially to KEMET Corporation’s (“KEMET”) closed-loop tantalum supply chain by purchasing “conflict-free” tantalum capacitors. In 2018, HPE became one of the first donors outside of the DRC region to make a financial contribution to KEMET’s Friends of Kisengo Foundation, a nonprofit dedicated to effectively and sustainably improving the lives of people in the DRC through an integrated rural development program focusing on infrastructure, health, education, and environmental development. HPE’s contribution facilitated support for the educational needs of over 1500 children in the mining village of Kisengo, DRC for a
month. Consistent with our disclosure for calendar year 2017, all tantalum smelters reported to be in the supply chain were conformant with RMAP1 in 2018.
HPE Products
Conflict minerals in the form of 3TG were necessary to the functionality or production of our products (i.e., were “necessary conflict minerals”). The products containing necessary conflict minerals that HPE manufactured or contracted to manufacture during 2018 are: 1) server, storage, and networking products and 2) certain accessories.
Design of Our Due Diligence Measures
We designed our due diligence measures to conform with applicable portions of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition, OECD 2016) and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures reflects our individual facts and circumstances, our downstream position in the minerals supply chain, and the OECD recommendations for downstream actors with no direct relationships to SORs2. This design also includes the use of independent assessment programs to provide information about SORs.
Consistent with the OECD Guidance, the design of our due diligence has the following features:
| |
| (1) | Establishment of strong internal company management systems, including a conflict minerals policy3; a Conflict Minerals Program team with senior management support; a Supply Chain Transparency System4; engagement with 3TG Direct Suppliers5 to communicate and reinforce our expectations with respect to necessary conflict minerals; a requirement that 3TG Direct Suppliers immediately begin transitioning all 3TG supply chains to SORs listed as participating in or successfully completing an independent assessment program (“Conflict-Free Smelters”) or encouraging their known smelters to participate in the RMAP; integration of supplier conflict minerals performance into sourcing decisions through the use of supplier scorecards and business unit reviews with key suppliers; use of internal performance metrics such as the number of supplier responses received and our progress toward internal goals; and a corporate grievance mechanism that is available internally and externally to report concerns, including those related to conflict minerals. |
1 RMAP is an RMI program that uses an independent third-party audit of smelter and refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The audit employs a risk-based approach to validate smelters’ company level management processes for responsible mineral procurement.
2 The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HPE; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
3 HPE’s Supply Chain Social and Environmental Responsibility Policy and HPE’s General Specification for the Environment Standards both contain sections on conflict minerals.
4 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition 37-39 (2016). Specific recommendations for all downstream companies to establish a system of controls and transparency over the mineral supply chain: “Introduce a supply chain transparency system that allows the identification of the smelters/refiners in the company’s mineral supply chain through which the following information on the supply chain of minerals from “red flag locations of mineral origin and transit” should be obtained: the identification of all countries of origin, transport and transit for the minerals in the supply chains of each smelter/refiner.”
5 3TG Direct Suppliers are direct suppliers of materials, parts, components or products containing necessary conflict minerals.
| |
| (2) | Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Conflict Minerals Program team in systematically surveying, collecting, and analyzing information relating to 3TG facilities6. In 2018, we developed a database to aid in the analysis of supplier reported data and to better understand where further attention is necessary. |
| |
| (3) | Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on facilities’ due diligence practices, formulation of a risk management plan, and reporting to senior management. We directly contact smelters and refiners to request their participation in the RMAP. |
| |
| (4) | Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership and active participation in RMI (member ID HPE), the industry initiative that conducts audits and assessments of facilities’ due diligence activities. We rely on the RMI program to determine if smelters and refiners reported by our suppliers are conformant with audit standards. To support the work of RMI, HPE contributes to RMI’s Initial Audit Fund for Participating Smelters, a fund that supports SORs with the costs of RMAP audits. |
| |
| (5) | Annual reporting through this Conflict Minerals Report and in our annual Living Progress Report. |
Description of Due Diligence Measures Performed
We undertook the following due diligence measures with respect to the source and chain of custody of necessary conflict minerals contained in our products:
| |
| • | compared reported 3TG facilities to the facilities that are listed by RMI as either RMAP Conformant or Active7; |
| |
| • | reached out (either directly or through a third party) to 3TG facilities with unknown sourcing to provide conflict minerals education, collect information (such as country of origin of necessary conflict minerals related to the supply chain for HPE’s products), or encourage participation in RMAP; |
| |
| • | if any 3TG Direct Supplier reported to us a facility for which we had information that identified a relevant concern, then we asked the supplier to investigate whether or not that facility contributed 3TG to our products, and, if so, to take steps to remove the facility from our supply chain; |
| |
| • | supported RMAP through our membership and participation in RMI; |
| |
| • | encouraged 3TG facilities to join RMAP; and |
| |
| • | asked HPE’s 3TG Direct Suppliers to encourage the facilities in their supply chain to join RMAP. |
We reviewed the results of our due diligence with senior management, including the Senior Vice President & Chief Ethics and Compliance Officer.
Results
Below we set forth the results of our due diligence as well as our progress toward DRC conflict free products. We provide both a snapshot of our total progress as well as our progress with respect to each 3TG metal. Of the 302 3TG
6 3TG facilities are those entities reported by our 3TG Direct Suppliers that are also identified by RMI to be smelters, refiners, recyclers or scrap processors of conflict minerals.7 RMI defines “active” as smelter or refiner facilities that are engaged in RMAP but not yet conformant.
facilities reported to us in 2018, as of April 5, 20198 (the “2019 Cut-Off Date”), 284, or 94% are now conformant, active, and/or are reasonably believed to provide only conflict minerals from recycled or scrap sources, or to source conflict minerals from outside the Covered Countries.
Due Diligence Results for 3TG Facilities
Our approach prioritizes smelter engagement and outreach, and when we learn of smelters that are not yet participating in an industry assessment program, we seek out and consider other credible sources of information on these smelters. Due to our position as a downstream company several tiers removed from smelters, our direct suppliers often cannot provide information on 3TG sourcing that is specific to HPE products; therefore, our ability to trace 3TG in our products to the smelter or mine level has limits; conversely, as further explained in Attachment B, the reported presence of a smelter in our suppliers’ supply chain does not necessarily mean that 3TG from that smelter was used in HPE products. Our results, accordingly, may fluctuate depending on the resources and abilities of our suppliers (and their suppliers), the economic leverage we can exercise in a particular scenario, and the quality of information available to us, among other factors.
We measure our results in part based on the number of all 3TG facilities reported to us by our supply chain that are listed as participating in, or that have successfully completed an independent assessment program. Because participation in an independent assessment program, such as RMAP, provides us (a downstream company) with a level of assurance of an upstream facility’s sourcing practices, we track and report on this participation. Where additional information is available to us as a result of our due diligence or RCOI efforts, we also consider whether any of the 3TG facilities not yet participating in an independent assessment program may nonetheless be providing minerals that are DRC conflict free because they are sourced from outside the Covered Countries or are exclusively derived from recycled or scrap sources.
Our suppliers reported 302 total 3TG facilities in 2018, 94% (284) of which (as of the 2019 Cut-Off Date) are conformant with or active with an independent assessment program, are believed to source from outside the Covered Countries, or are exclusively providing conflict minerals from recycled or scrap sources. Only 6% (18) of the supplier-reported 3TG facilities are facilities for which we have limited or no information on the sourcing of necessary conflict minerals (both because they are not yet participating in an independent assessment program and because we found no information giving us reason to believe they were sourcing from outside the Covered Countries or exclusively from recycled or scrap sources).
We received information identifying a potential concern with respect to six of the 3TG facilities that were reported by one 3TG Direct Supplier. Even though the information we received did not indicate that the facilities in question have any connection to armed conflict in the Covered Countries, we requested the supplier reporting these facilities to investigate the likelihood that the facilities contributed 3TG to our products. In parallel, we sought to either encourage the facilities’ participation in RMAP or to have the facilities removed from our supply chain, where applicable. While the supplier has so far been unable to rule out the possibility that these facilities contributed 3TG to HPE products, we understand that the facilities have been or are in the process of being removed from the supply chain.
Additional information on the status of individual 3TG facilities is provided in Attachment B.
Attachment A to this Conflict Minerals Report includes (to the extent information was available) the countries from which the supplier-reported 3TG facilities may have sourced necessary conflict minerals.
Attachment B to this Conflict Minerals Report sets forth the name and status of the supplier-reported 3TG facilities.
8 The “2019 Cut-Off Date” is the date by which HPE stops accepting new conflict minerals data from its 3TG Direct Suppliers and for purposes of identifying the RMAP status of smelters that have been identified in our supply chain.
Progress toward DRC Conflict Free by Metal
We also measure our progress toward DRC conflict free products by metal. Chart 1 further expands on our results by providing for each metal the number and percentage (as of the 2019 Cut-Off Date) of all supplier-reported 3TG facilities that were either RMAP conformant or active, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries. Again in 2018, all of the tantalum smelters reported to be in our supply chain are conformant with RMAP.
Chart 1 Progress toward DRC Conflict Free by Metal
|
| | | |
| | Supplier-Reported | Progress toward DRC Conflict | Percentage |
| 3TG Facilities | Free | |
| Tantalum Facilities | 40 | 40 | 100% |
| Tin Facilities | 78 | 76 | 97% |
| Tungsten Facilities | 42 | 41 | 98% |
| Gold Facilities | 142 | 127 | 89% |
| Total | 302 | 284 | 94% |
Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity
As a downstream actor, we rely upon independent assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for a downstream actor like us, our efforts to facilitate upstream mine or location of origin determinations were focused on support of independent assessment programs such as RMAP.
To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by independent assessment programs, we:
| |
| • | surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the Template (which included questions about the mine or location of origin) and required those suppliers to make similar efforts to survey their supply chains using the Template; |
| |
| • | reviewed information obtained through those surveys on 3TG facilities, and any mine or location of origin information if it was provided; and |
| |
| • | assessed any information on countries of origin available through our membership in RMI for 3TG facilities. (As part of the RMAP audit protocol, the independent auditor makes an examination of the countries of origin and the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to RMI members). |
Steps to Further Mitigate Risk and Improve Due Diligence in 2019
We plan to continue the activities described in “Design of Our Due Diligence Measures” and “Description of Due Diligence Measures Performed” in our journey to achieve DRC conflict free status for our products. This includes the following steps to mitigate further any risk that necessary conflict minerals in our products finance or benefit an armed group:
| |
| • | engage with 3TG Direct Suppliers to update information provided to us; |
| |
| • | repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the RMAP; and |
| |
| • | support the development of RMAP, including outreach efforts to encourage participation in the program. |
Attachment A
Countries of Origin
Based on information available from RMI as of the 2019 Cut-Off Date and additional research by our external
expert consultant, we believe that the countries of origin of the necessary conflict minerals from supplier-reported
3TG facilities may include the following countries.
|
| | |
| |
| Covered Countries | | Outside Covered Countries |
| Burundi | | Argentina |
| Congo, Democratic Republic of the | | Armenia |
| Rwanda | | Australia |
| Tanzania | | Austria |
| Uganda | | Azerbaijan |
| Zambia | | Bahamas |
| | | Barbados |
| | | Belarus |
| | | Belgium |
| | | Benin |
| | | Bolivia |
| | | Bosnia and Herzegovina |
| | | Botswana |
| | | Brazil |
| | | Bulgaria |
| | | Burkina Faso |
| | | Cambodia |
| | | Cameroon |
| | | Canada |
| | | Chile |
| | | China |
| | | Colombia |
| | | Croatia |
| | | Curacao (Dutch Antilles) |
| | | Cyprus |
| | | Czech Republic |
| | | Denmark |
| | | Dominican Republic |
| | | Ecuador |
| | | Egypt |
| | | El Salvador |
| | | Eritrea |
| | | Estonia |
| | | Ethiopia |
| | | Fiji |
| | | Finland |
| | | France |
|
| | |
| | | Gabon |
| | | Gambia, The |
| | | Georgia |
| | | Germany |
| | | Ghana |
| | | Greece |
| | | Guatemala |
| | | Guinea |
| | | Guyana |
| | | Honduras |
| | | Hong Kong |
| | | Hungary |
| | | Iceland |
| | | India |
| | | Indonesia |
| | | Iran9 |
| | | Ireland |
| | | Israel |
| | | Italy |
| | | Ivory Coast |
| | | Japan |
| | | Jordan |
| | | Kazakhstan |
| | | Kenya |
| | | Korea, Republic of |
| | | Kosovo |
| | | Kuwait |
| | | Kyrgyzstan |
| | | Laos |
| | | Latvia |
| | | Lebanon |
| | | Liberia |
| | | Libya |
| | | Liechtenstein |
| | | Lithuania
|
| | | Luxembourg
|
| | | Macau |
| | | Madagascar |
| | | Malaysia |
| | | Mali |
| | | Malta |
| | | Mauritania |
9 Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person. |
|
| | |
| | | |
| | | Mauritius |
| | | Mexico |
| | | Mongolia |
| | | Morocco |
| | | Mozambique |
| | | Myanmar |
| | | Namibia |
| | | Netherlands |
| | | New Caledonia |
| | | New Zealand |
| | | Nicaragua |
| | | Niger |
| | | Nigeria |
| | | Norway |
| | | Pakistan |
| | | Panama |
| | | Papua New Guinea |
| | | Peru |
| | | Philippines |
| | | Poland |
| | | Portugal |
| | | Puerto Rico |
| | | Romania |
| | | Russian Federation |
| | | San Marino |
| | | Saudi Arabia |
| | | Senegal |
| | | Serbia |
| | | Sierra Leone |
| | | Singapore |
| | | Slovakia |
| | | Slovenia |
| | | Solomon Islands |
| | | South Africa |
| | | Spain |
| | | Suriname |
| | | Swaziland |
| | | Sweden |
| | | Switzerland |
| | | Taiwan |
| | | Tajikistan |
| | | Thailand |
| | | Togo |
| | | Trinidad and Tobago |
| | | Tunisia |
| | | Turkey |
| | | Ukraine |
|
| | |
| | | United Arab Emirates |
| | | United Kingdom of Great Britain |
| | | United Kingdom of Great Britain and Northern Ireland |
| | | United States of America |
| | | Uruguay |
| | | Uzbekistan |
| | | Vatican City |
| | | Venezuela |
| | | Vietnam |
| | | Yemen |
| | | Zimbabwe |
Attachment B
3TG Facility List
This 3TG Facility List sets forth the name, location and status of all of the 302 3TG facilities our suppliers reported to us. It is the result of our review of data from several sources, including information reported to us by 3TG Direct Suppliers, obtained through supplemental engagement with certain 3TG facilities, and from RMI. Inclusion on this list is not necessarily an indication that any particular facility supplies materials that are ultimately incorporated into HPE products. In many cases facility information was provided to us for the entire supply chain of 3TG Direct Suppliers, and did not identify with specificity those 3TG facilities believed to contribute necessary conflict minerals to any of our products.
|
| | | |
| Metal | Facility Name10 | Facility Location11 | Status12 |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Non Conformant |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
| Gold | Aurubis AG | GERMANY | Conformant |
| Gold | Bangalore Refinery | INDIA | Active |
10 Entities that have been reported to us by our 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by RMI (as of the 2019 Cut-Off Date) to be smelters, refiners, recyclers or scrap processors of conflict minerals (i.e., the “3TG facilities”). The facility names are listed as they appear on the RMI Smelter Database. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler or scrap processor) that is processing different types of minerals or metals. 11 The facility locations are listed as they appear for each of the 3TG facilities on the RMI Smelter Database. 12 Conformant refers to 3TG facilities that are listed by RMI (as of the 2019 Cut-Off Date) as (a) conformant with RMAP protocols or (b) certified or accredited by a similar independent assessment program such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme. Active refers to smelter or refiner facilities that are engaged in RMAP but not yet conformant (as of the 2019 Cut-Off Date). Non Conformant refers to facilities that are non conformant to the RMAP standard (as of the 2019 Cut-Off Date). We have reason to believe that none of the non conformant facilities source from the Covered Countries; two of the four non conformant facilities are 100% recyclers. Not yet participating refers to 3TG facilities that are not engaged with an independent assessment program.
|
|
| | | |
| | | | |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | Boliden AB | SWEDEN | Conformant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | Caridad | MEXICO | Not yet participating |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not yet participating |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Active |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not yet participating |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
| Gold | Dowa | JAPAN | Conformant |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not yet participating |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not yet participating |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not yet participating* |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Not yet participating |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| Gold | Italpreziosi | ITALY | Conformant |
| Gold | Japan Mint | JAPAN | Conformant |
|
| | | |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not yet participating |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not yet participating |
| Gold | Kazzinc | KAZAKHSTAN | Conformant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not yet participating |
| Gold | Guangdong Jinding Gold Limited | CHINA | Not yet participating |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not yet participating |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | Marsam Metals | BRAZIL | Conformant |
| Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | Modeltech Sdn Bhd | MALAYSIA | Non Conformant |
| Gold | Morris and Watson | NEW ZEALAND | Not yet participating |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
|
| | | |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not yet participating |
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant |
| Gold | PAMP S.A. | SWITZERLAND | Conformant |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | Not yet participating |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not yet participating |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | SAAMP | FRANCE | Conformant |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Not yet participating |
| Gold | Safimet S.p.A | ITALY | Conformant |
| Gold | SAFINA A.S. | CZECH REPUBLIC | Not yet participating* |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Not yet participating |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not yet participating |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | T.C.A S.p.A | ITALY | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
|
| | | |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| Gold | Umicore Brasil Ltda. | BRAZIL | Conformant |
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Not yet participating* |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not yet participating* |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| Gold | Yamakin Co., Ltd. | JAPAN | Conformant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not yet participating |
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not yet participating |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not yet participating |
| Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not yet participating |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Active |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not yet participating |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant |
| Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not yet participating |
| Gold | Sai Refinery | INDIA | Not yet participating |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not yet participating |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| Gold | Sudan Gold Refinery | SUDAN | Not yet participating* |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
|
| | | |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not yet participating |
| Gold | Tony Goetz NV | BELGIUM | Non Conformant* |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not yet participating |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not yet participating |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
|
| | | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | KEMET Blue Metals | MEXICO | Conformant |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | Conformant |
| Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| Tantalum | NPM Silmet AS | ESTONIA | Conformant |
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Conformant |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not yet participating |
| Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Non Conformant |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Active |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Non Conformant |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not yet participating |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
|
| | | |
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| Tin | CV Ayi Jaya | INDONESIA | Conformant |
| Tin | CV Dua Sekawan | INDONESIA | Conformant |
| Tin | CV Gita Pesona | INDONESIA | Conformant |
| Tin | CV United Smelting | INDONESIA | Conformant |
| Tin | Dowa | JAPAN | Conformant |
| Tin | Pongpipat Company Limited | MYANMAR | Not yet participating |
| Tin | Estanho de Rondonia S.A. | BRAZIL | Not yet participating |
| Tin | Fenix Metals | POLAND | Conformant |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
| Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tin | Minsur | PERU | Conformant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | Modeltech Sdn Bhd | MALAYSIA | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
|
| | | |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
| Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
| Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| Tin | PT Bangka Tin Industry | INDONESIA | Conformant |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant |
| Tin | PT Bukit Timah | INDONESIA | Conformant |
| Tin | PT DS Jaya Abadi | INDONESIA | Conformant |
| Tin | PT Inti Stania Prima | INDONESIA | Conformant |
| Tin | PT Karimun Mining | INDONESIA | Conformant |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant |
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| Tin | PT Panca Mega Persada | INDONESIA | Conformant |
| Tin | PT Premium Tin Indonesia | INDONESIA | Conformant |
| Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| Tin | PT Rajehan Ariq | INDONESIA | Conformant |
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
| Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
| Tin | PT Sumber Jaya Indah | INDONESIA | Conformant |
| Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
| Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
| Tin | PT Tommy Utama | INDONESIA | Conformant |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| Tin | Super Ligas | BRAZIL | Not yet participating |
| Tin | Thaisarco | THAILAND | Conformant |
|
| | | |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | Yunnan Tin Company Limited | CHINA | Conformant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not yet participating |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not yet participating |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not yet participating |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant |
| Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Active |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
|
| | | |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | Conformant |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
* Denotes facilities that have been or are in the process of being removed from the supply chain
