Exhibit 1.01
Adient plc
Conflict Minerals Report
For the Calendar Year Ended December 31, 2020
| I. Background | ||
The Securities and Exchange Commission (the “SEC”), through Section 13(p) of the Securities Exchange Act of 1934, imposes reporting requirements (the “Rule”) on SEC issuers concerning the use of Conflict Minerals and the metals derived from such minerals, as described below, that originate in the Democratic Republic of the Congo (the “DRC”) or the adjoining countries (collectively, the “Covered Countries”).
The term “Conflict Mineral” is defined to include cassiterite, columbite-tantalite, gold, and wolframite and their derivatives, including tantalum, tin and tungsten (“3TG”) regardless of their source.
This is the Conflict Minerals Report (“Report”) of Adient plc (“Adient”) for reporting year (“RY”) 2020 and covers all activities conducted for the calendar year ended December 31, 2020.
| II. Adient Overview | ||
Adient is one of the world’s largest automotive seating suppliers and has relationships with the largest global auto manufacturers. Adient designs, manufactures and markets a full range of seating systems and components for passenger cars, commercial vehicles and light trucks, including vans, pick-up trucks and sport/crossover utility vehicles. Adient’s proprietary technologies extend into virtually every area of automotive seating solutions, including complete seating systems, frames, mechanisms, foam, head restraints, armrests, trim covers and fabrics.
As used in this Report, and except where the context otherwise requires, “we” and “our” refer to Adient and its majority-owned subsidiaries and variable interest entities that are required to be consolidated.
| III. Product Overview | ||
As noted above, our products include complete seating systems, frames, mechanisms, foam, head restraints, armrests, and trim covers. Adient’s products previously included automotive seating fabrics, but during the course of RY 2020, Adient subsequently sold its fabrics business.
| IV. Supply Chain Description | ||
Adient is committed to the responsible sourcing of Conflict Minerals and is a member of the Responsible Minerals Initiative (“RMI”). RMI was founded by members of the Responsible Business Alliance (“RBA”). Adient encourages its suppliers to conduct conflict-free sourcing from RMI certified smelters.
As a large multinational company, Adient has a complex, multi-tiered supply chain. The products that Adient manufactures are typically highly engineered, complex and contain thousands of parts from a vast network of globally dispersed suppliers.
As a downstream consumer with many tiers in its supply chain, Adient generally does not have a direct relationship with smelters and refiners. In most instances, Adient obtains products containing 3TG from unrelated third-party suppliers with their own independent supply chains. Accordingly, Adient must rely on its direct suppliers to provide
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information regarding the origin of any Conflict Minerals contained in the components and parts they supply to Adient.
| V. Reasonable Country of Origin Inquiry (“RCOI”) | ||
A.Process Summary
Adient designed and implemented a compliance framework that follows the process steps set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected Areas and High-Risk Areas (“OECD Guidance”) issued by the Organization for Economic Co-operation and Development (“OECD”).
Due to the complexity of Adient’s supply chain, Adient relied on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in components and parts supplied to Adient. In addition, Adient sent the RMI Conflict Minerals Reporting Template (the “CMRT”) to these suppliers to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.
Adient elected to utilize, without alteration, the CMRT, as well as a survey tool to facilitate its RCOI. The questions on the CMRT include, but are not limited to, the use of Conflict Minerals and their necessity to product functionality or production, the origin of such Conflict Minerals, and whether smelters have been validated as compliant in accordance with the RMI. Adient communicated with In-Scope Suppliers (as defined below), notifying them of the RCOI and Adient’s expectations, and also provided such suppliers with instructions to assist with the completion of the CMRT.
In addition to the RCOI efforts described above, Adient undertook the following measures to determine the mine or country of origin of any Conflict Minerals:
▪As part of its global scoping exercise, Adient considered the following supply base categories as the scope universe for RCOI purposes: manufactured products, products contracted to be manufactured, and spare parts. Identification of suppliers that were subject to the RCOI (“In-Scope Suppliers”) was closely linked not only to the presence of 3TG in the products but also to contractual agreements to determine the amount of influence that Adient has on In-Scope Suppliers regarding the sourcing decisions taken in the supply chain.
▪A risk level of “High,” “Low” or “None” based on the likelihood of the presence of Conflict Minerals in each component was assigned to each In-Scope Supplier as result of the joint effort between our Procurement and Engineering Departments. Suppliers providing components with risk rankings of High and Low were considered in-scope for RCOI procedures. The risk level is used during escalation activities for non-responding suppliers to prioritize activities by the Procurement Department.
▪Adient required each In-Scope Supplier to provide information regarding the use of Conflict Minerals from their suppliers, who, in turn, were expected to solicit that information from their next tier of suppliers. The Conflict Minerals Supplier Letter that was sent to each In-Scope Supplier can be found on Adient’s website at:
https://www.adient.com/suppliers/corporate-responsibility.
▪In addition to the online training course available on https://www.adient.com/suppliers/corporate-responsibility, Adient provided support to its suppliers during the RY, including explanations regarding the relevant requirements of the Rule and their obligations under the Rule, and reiterated Adient’s expectation that suppliers cooperate to support Adient’s compliance efforts. Refer to “Supplier Engagement and Training” below for more information.
▪The responses received from the In-Scope Suppliers about the country of origin of any Conflict Minerals necessary for product functionality or production of products supplied to Adient were reviewed for accuracy and completeness, and, if necessary, were flagged for additional follow-up and/or due diligence.
▪In-Scope Suppliers who sent incomplete or inconsistent responses were asked to review their responses and resubmit their surveys.
▪Adient implemented the following escalation process for In-Scope Suppliers that did not respond:
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◦Step 1: For suppliers with risk ratings of High that did not respond, an escalation letter was sent.
◦Step 2: Adient commodity managers/buyers contacted the suppliers with risk ratings of High that did not respond to the escalation letter (either by phone or in written form) to request survey completion.
◦Step 3: If the supplier still did not respond, the relevant Vice President(s) of the Procurement Department sent a written letter to the supplier requesting completion of the survey.
Adient revised its approach to supplier scoping in 2020 based on experience developed during earlier reporting years. Suppliers identified as “High” risk based on the entries in the International Material Data System database are now subject to additional checks to ensure that only those who have active business during the reporting year will be included. This may exclude former in-scope prototype suppliers, spare part suppliers with no active purchase orders and suppliers of serial parts that were not ordered during the reporting year. Together with the enhanced escalation processes implemented during RY 2019, these changes increased the supplier response rate from 57% in 2019 to 63% in 2020. Many of the supplier escalation activities were still pending at the end of RY 2020. Based on the results available in February and March 2021 we currently anticipate a further increase in the RY 2021 response rate. We believe these changes continued to improve our reporting quality, and we will continue to review our processes and consider further adjustments in the future to continue refining and improving our reporting.
B.RCOI Results
Adient determined there were 939 In-Scope Suppliers for calendar year 2020, which represented 31% of Adient’s total direct suppliers. Adient sent communications to its In-Scope Suppliers notifying them of the RCOI and received delivery confirmation receipts from 93% of those In-Scope Suppliers.
The overall response rate among the In-Scope Suppliers surveyed was 63%, including 374 responses that were received and accepted (representing 43% of the suppliers who confirmed receipt of the survey). Adient considers a response as received and accepted when a completed CMRT has been returned to Adient and the CMRT has been validated as accurate by its compliance specialists. Below are the results of the RCOI survey:
| RCOI Survey Results | |||||
| No 3TG | 75 | % | |||
| Acknowledged 3TG Sourced from the Covered Countries | 14 | % | |||
| Acknowledged 3TG Not Sourced from the Covered Countries | 6 | % | |||
| 3TG Origin Uncertain or Unknown | 5 | % | |||
C.Improvement Measures to be Taken
Adient experienced an increased response rate of 63% for In-Scope Suppliers in RY 2020. The COVID-19 pandemic negatively impacted the supplier communication, which resulted in unforeseen delays in connection with supplier escalation communications. As an example, seven of our In-Scope Suppliers could not be contacted in time. Ninety-five In-Scope Suppliers sent responses for RY 2020 in the beginning of 2021. Given these delays Adient was not able to fully evaluate the results of its RY 2020 improvement measures. We also note that some of the RY 2020 process improvements regarding supplier escalation are still pending and certain RY 2020 process improvements have not yet been fully implemented. These ongoing activities and other anticipated changes for RY 2021 include the following:
•Enhancing the collaboration between Adient controlled suppliers and our Procurement Department to improve the compliance with our Conflict Minerals program by engaging Adient commodity buyers in the escalation process;
•Incorporating feedback from suppliers into the supplier communication letters to improve content and language for ease of understanding and simplification of response requirements; and
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•Reconsidering supply arrangements and potentially implementing remedies for suppliers that refuse to cooperate with Adient’s compliance efforts.
| VI. Conflict Minerals Due Diligence | ||
A.Compliance Framework
i.Framework Design and Overview
Adient designed and implemented a compliance framework that conforms to the primary principles of the OECD Guidance, which is the internationally recognized due diligence framework developed by the OECD. Our compliance framework includes elements drawn from those principles and the corresponding supplements for each of the four conflict minerals. These include: 1) establishing strong company management systems; 2) identifying and assessing risk in the supply chain; 3) designing and implementing a strategy to respond to identified risks; 4) carrying out an independent third-party audit of smelters’/refiners’ due diligence practices; and 5) reporting annually on supply chain due diligence. We described each of these elements further below.
ii.Establish Strong Company Management Systems
Conflict Minerals Policy
Adient is committed to the responsible sourcing of Conflict Minerals and it supports the humanitarian goal of ending violent conflict in the Covered Countries. Our Conflict Minerals Policy Statement expresses that we continue to promote and encourage suppliers to conduct conflict-free sourcing from the Covered Countries, and to use responsible sourcing practices. We expect our suppliers to conduct due diligence on their respective supply chains and to assist us with our compliance efforts. To the extent that a supplier refuses to cooperate with our compliance efforts or does not conduct conflict-free sourcing from the Covered Countries, we may reconsider our supply arrangement and/or implement remedies available to us. Our Conflict Minerals Policy Statement is publicly available on Adient’s website at: https://www.adient.com/-/media/adient/shared/suppliers/corporate-responsibility/conflict-minerals/adientconflictmineralspolicystatement2021.pdf.
Internal Management System
Adient maintains an internal management system where senior management with the necessary expertise, knowledge, and experience oversee the RCOI and due diligence process. These managers continuously seek new ways to evaluate and address potential risk in our supply chain process through initiatives that often involve stakeholder engagement or consultation with outside experts.
Adient also maintains a Conflict Minerals Executive Steering Committee (“Steering Committee”) comprised of leaders from the company’s Procurement, Legal, Engineering, Communications and Finance Departments. The Steering Committee oversees and supports Adient’s Conflict Minerals compliance program. The Steering Committee meets to develop and monitor plans to comply with the reporting requirements of the Rule.
This Report was also shared with Adient’s Disclosure Committee, which is comprised of Adient’s Chief Executive Officer; Chief Financial Officer; General Counsel; Chief Accounting Officer; Vice President and General Counsel, Commercial Transactions; Vice President, Finance; Vice President, Tax; Vice President, Internal Audit; Vice President, Treasurer and Investor Relations; Vice Presidents and Executive Directors, Regional Finance; and Vice President, Global Financial, Planning and Analysis.
System of Controls and Transparency
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Due to the complexity of Adient’s global supply chain, Adient relies on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in materials supplied to Adient. Adient’s RCOI and due diligence processes are designed to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.
Supplier Engagement and Training
Adient provides an online training for suppliers as part of the initial communication package to the In-Scope Suppliers that explains the relevant requirements of the Rule, Adient’s obligations under the Rule, and Adient’s expectation that our suppliers support our Conflict Minerals compliance efforts. The training is posted on our website at: https://www.adient.com/suppliers/corporate-responsibility. Suppliers are encouraged to ask questions to our compliance specialists to enhance their understanding of the Rule and our expectations. Additional training is also provided to suppliers on request.
Adient also provides the In-Scope Suppliers with instructions for responding to the survey, and our compliance specialists have scripts to help explain our requests and the reason behind the requests. Communications sent to suppliers also contain reference links to the Rule and additional guidance from the SEC, Automotive Industry Action Group (“AIAG”), RMI, and OECD. To help suppliers identify and address smelters of concern, Adient provides links to other non-governmental organization (“NGO”) resources such as Global Witness or Amnesty International for smelter information.
Adient publicly shares its position on responsible sourcing of Conflict Minerals through its Conflict Minerals Policy Statement. Where appropriate, Adient also includes a Conflict Minerals compliance provision when it renews or enters into new agreements with suppliers. The provision requires suppliers to conduct and document inquiries of smelters and refiners of any Conflict Minerals incorporated into the products supplied to Adient, including inquiries into the country of origin. Adient’s Global Supplier Standards Manual further reflects and reinforces these expectations.
Internal Training
Adient maintains a web-based training module designed specifically for employees within its Sales, Procurement and Engineering Departments. This training educates employees about the relevant requirements of the Rule, Adient’s obligations under the Rule, and the processes Adient uses to evaluate and respond to related supply chain risks. Training sessions are mandatory for new employees at Adient facilities that perform engineering and design activities related to the use of Conflict Minerals.
Records Management
Adient retains relevant Conflict Minerals documentation in accordance with its existing corporate retention policy and procedures.
Grievance Mechanism
Adient maintains a web- and telephone-based, 24-hour Integrity Helpline (information is available at: https://adient.ethicspoint.com). The Integrity Helpline provides any interested party (e.g., employees, customers, suppliers, or other external third parties) with a confidential mechanism to report potential violations of the law, regulations, professional standards, and policies (including Adient's Ethics Policy and its Conflict Minerals Policy Statement), as well as concerns regarding Adient’s supply chain. Credible reports follow Adient’s internal investigations protocol, whereby incoming reports are either investigated by Adient’s Legal Department or transferred to another
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responsible group inside Adient for investigation. The Legal Department monitors these internal investigations and the resolution of cases escalated through other channels.
iii.Identify and Assess Risk in the Supply Chain
Adient’s RCOI was designed to determine whether the Conflict Minerals necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by Adient originated in the Covered Countries or were from recycled or scrap sources. Through communications with the In-Scope Suppliers, Adient attempted to identify smelters and refiners of Conflict Minerals that may be used in its products.
Adient followed-up, and continues to follow-up, with suppliers who indicated that they might be sourcing Conflict Minerals from the Covered Countries or non-certified smelters in order to exercise due diligence on the source and chain of custody of the Conflict Minerals, inquiring of such suppliers whether they:
•provided information on all smelters and the country of origin of the Conflict Minerals;
•performed due diligence procedures for non-certified smelters; and
•were able to determine if the Conflict Minerals financed or benefited armed groups in the Covered Countries.
iv.Design and Implement a Strategy to Respond to Identified Risks
Adient has established due diligence guidelines to be followed if it identifies information indicating that a supplier may have sourced Conflict Minerals from the Covered Countries through a review of the received CMRT.
Once an In-Scope Supplier indicates that it might be sourcing Conflict Minerals from the Covered Countries, Adient initiates due diligence procedures to collect more detailed information from that supplier. This included engaging with such supplier and validating information with other reliable sources. Suppliers reporting RMI-certified smelters from the Covered Countries were generally exempt from further due diligence as long as there were no incident reports available from NGOs or other reliable sources regarding the listed smelter(s) or refiner(s).
Any findings from the due diligence procedures are discussed with Adient’s Procurement Department. Based on this information, Adient created a list of suppliers identified as using Conflict Minerals from a Covered Country as well as the indicated smelters. This list was then compared to the RMI smelter listing to verify the accuracy of the supplier responses as well as the source of the Conflict Minerals, and then shared with the responsible procurement team.
In addition to these measures, Adient engaged and actively cooperated with industry groups, including RMI and AIAG. Adient also intensified its activities to manage risk identified in its supply chain by supporting the RMI Smelter Engagement Team.
v.Carry Out Independent Third-Party Audit of Smelters’/Refiners’ Due Diligence Practices
Adient does not purchase raw ore or unrefined Conflict Minerals, and, to the best of its knowledge, conducts no purchasing activities directly in the Covered Countries. Instead, Adient is a downstream consumer of Conflict Minerals and is many steps removed from the mining of Conflict Minerals. In order to meet its obligations under the Rule, Adient supports independent third-party audits by being a member of the RMI and relies on the RMI’s Conflict-Free Smelter Program in connection with our due diligence efforts.
This program helps Adient to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. Adient evaluates the supplier reports it receives using the RMI smelter database and then reports any unknown smelter or smelters that have not been certified to the RMI for further investigation and inclusion in the smelter certification scheme.
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vi.Report Annually on Supply Chain Due Diligence
This Report (and the related Form SD) was filed with the SEC and is available on our website at: https://www.adient.com/suppliers/corporate-responsibility.
B.Due Diligence Results
i.Facilities Used to Process Necessary 3TG Originating from Covered Countries
Each of the measures described above was designed to provide Adient with information on the smelters and refiners that the In-Scope Suppliers used to process Conflict Minerals incorporated into the products they supply to Adient. As previously discussed, Adient is a downstream consumer of 3TG and generally does not have a direct relationship with smelters and refiners. Consequently, it must rely on responses from its suppliers in order to determine the facilities used to process Conflict Minerals. Much like Adient, our suppliers generally do not have a direct relationship with the facilities used to process Conflict Minerals.
In RY 2020, 10 suppliers responded they were unable to provide smelter and refiner information – an amount that accounts for 1% of our In-Scope Suppliers. Given this response and the low response rate for this reporting period, Adient does not know all of the countries of origin or the facilities used to process all the Conflict Minerals incorporated into its products.
Another 6% of the suppliers indicated that they did not source from the Covered Countries, while 14% acknowledged that they sourced 3TG from one or more Covered Countries. The suppliers sourcing from the Covered Countries indicated that they only sourced from smelters that the RMI identifies as DRC conflict free. None of the responses acknowledged that 3TG was sourced from smelters or mines that financed or benefited armed groups, after reviewing information from NGOs and other sources.
ii.Smelter Lists (Appendix A)
As explained above, Adient compared the smelter lists provided in responses from its In-Scope Suppliers with the RMI list of compliant smelters to determine which smelters the RMI identifies as DRC conflict free. The information provided by our suppliers was used to conduct our due diligence, including assessing reports for completeness and consistency.
Appendix A includes a list of the smelters identified by our In-Scope Suppliers as part of our RCOI and due diligence efforts. A total of 393 smelters were identified by our suppliers and 267, or approximately 68%, are RMI certified. The percentage of certified smelters decreased by 2 percentage points as compared to 2019. Five smelters indicated that they were not interested in participating in a smelter registration and audit scheme. Fifty-eight smelters have not yet been contacted by the respective upstream supplier to participate in the RMI certification scheme and were not certified during the reporting year. Four smelters are currently undergoing certification and 10 smelters are not conformant to the RMI audit scheme. We learned that 48 smelters ceased operations during the reporting year. One smelter is not yet RMI listed and was brought to the attention of RMI.
C.Risk Mitigation Measures
Adient’s current processes and procedures for mitigating Conflict Minerals supply chain risks include the following:
•Membership in the RMI, which has allowed for the comparison of all supplier responses to the RMI smelter listing to confirm the accuracy of supplier responses;
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•Updating and adapting our scoping and due diligence guidelines as well as the escalation process to reflect organizational changes inside Adient;
•Reviewing and utilizing our inhouse information technology systems and tools to increase process reliability and apply best business practices; and
•Identifying other unrelated risks during the Conflict Minerals reporting process and addressing them through the responsible Adient departments.
According to reports from NGOs, such as Global Witness, responsible sourcing initiatives still need to improve their processes to reduce illicit sanctions, mainly of gold mined in the DRC. Since the number of active and compliant gold smelters and refiners in the RMI certification program is low when compared to Tin, Tantalum and Tungsten, the RMI encourages smelters to participate in the Responsible Minerals Assurance Process and undergo third party audits. The goal is to encourage smelters to make responsible sourcing decisions, and to reduce the likelihood that the sale of these Conflict Minerals will benefit armed groups in the Covered Countries.
Adient is committed to promoting these same objectives by complying with the OECD Guidance and the Rule in a manner consistent with our Conflict Minerals Policy Statement. To that end, Adient will continue its efforts with its In-Scope Suppliers to improve the response rate and the completeness of the surveys. These efforts include:
•Directing suppliers to Adient’s Conflict Minerals Policy Statement, which emphasizes the responsible sourcing of Conflict Minerals;
•Striving to improve supplier awareness to identify potential risks at an early stage by improving our supplier training and sending out detailed feedback related to information received from suppliers;
•Following-up with suppliers that source Conflict Minerals from, or were identified as potentially sourcing from, smelters and refiners not participating in certification schemes;
•Striving to improve the effectiveness of the escalation process to enhance supplier communications and the quality of responses by addressing concerns related to customer buy arrangements to the affected customer;
•Enhancing our RCOI and due diligence measures, as well as the review process for existing and new suppliers included in the scoping guidelines;
•Working with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance; and
•Working with the RMI smelter engagement team to support their engagement and certification efforts.
| VII. Determination | ||
For RY 2020, Adient is unable to determine the mine or country of origin of its necessary Conflict Minerals or the facilities used to process Conflict Minerals in its supply chain with the greatest possible specificity due to either a lack of survey responses or inconclusive survey responses from its In-Scope Suppliers. As such, Adient is currently unable to determine whether products manufactured, or contracted to be manufactured, by Adient in RY 2020 have been found to be free of necessary Conflict Minerals that directly or indirectly financed or benefited armed groups in the Covered Countries. These products include those identified in “Part III. Product Overview” above. See Appendix A for a list of smelters for each of the Conflict Minerals identified as part of Adient’s efforts and country of origin information.
Cautionary Statement Regarding Forward-Looking Statements:
Adient has made statements in this Report that are forward-looking and, therefore, are subject to risks and uncertainties. All statements in this Report other than statements of historical fact are statements that are, or could be, deemed “forward looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. In this document, statements regarding Adient’s future plans, objectives, outlook, targets, guidance or goals are forward-looking statements. Words such as “may,” “will,” “expect,” “intend,” “estimate,” “anticipate,”
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“believe,” “should,” “forecast,” “project” or “plan” or terms of similar meaning are also generally intended to identify forward-looking statements. Adient cautions that these statements are subject to numerous important risks, uncertainties, assumptions and other factors, some of which are beyond Adient’s control, that could cause Adient’s actual results to differ materially from those expressed or implied by such forward-looking statements. These risks and uncertainties are difficult to predict accurately and may include (but are not limited to) regulatory changes and other developments relating to Conflict Minerals disclosures, changes in or developments related to Adient’s products or Adient’s supply chain, changes to Adient’s supplier base and industry developments relating to supply chain diligence, disclosure and other practices. A detailed discussion of risks related to Adient’s business is included in the section entitled “Risk Factors” in Adient’s Annual Report on Form 10-K for the fiscal year ended September 30, 2020 and in its quarterly reports on Form 10-Q as well as other filings with the SEC, available at www.sec.gov. The forward-looking statements included in this Report are made only as of the date of this Report and, except as required by law, Adient assumes no obligation, and disclaims any obligation, to update such statements.
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Appendix A - Smelters by Mineral
The attached smelter information refers to data available in the RMI smelter database in March 2021. Any changes to the RMI smelter database that took place after March 2021 are not covered.
List 1: Smelters and Refiners reported to have been included in Adient’s supply chain as of December 31, 2020
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tantalum (Ta) | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Tantalum (Ta) | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | F&X Electro-Materials Ltd. | CHINA | ||||||
| Tantalum (Ta) | FIR Metals & Resource Ltd. | CHINA | ||||||
| Tantalum (Ta) | Global Advanced Metals Aizu | JAPAN | ||||||
| Tantalum (Ta) | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | ||||||
| Tantalum (Ta) | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | H.C. Starck Co., Ltd. | THAILAND | ||||||
| Tantalum (Ta) | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
| Tantalum (Ta) | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | H.C. Starck Ltd. | JAPAN | ||||||
| Tantalum (Ta) | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||||||
| Tantalum (Ta) | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||||||
| Tantalum (Ta) | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | Jiangxi Tuohong New Raw Material | CHINA | ||||||
| Tantalum (Ta) | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | KEMET Blue Metals | MEXICO | ||||||
| Tantalum (Ta) | LSM Brasil S.A. | BRAZIL | ||||||
| Tantalum (Ta) | Metallurgical Products India Pvt., Ltd. | INDIA | ||||||
| Tantalum (Ta) | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tantalum (Ta) | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Tantalum (Ta) | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | NPM Silmet AS | ESTONIA | ||||||
| Tantalum (Ta) | Power Resources Ltd. | NORTH MACEDONIA | ||||||
| Tantalum (Ta) | QuantumClean | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tantalum (Ta) | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||||||
| Tantalum (Ta) | Taki Chemical Co., Ltd. | JAPAN | ||||||
| Tantalum (Ta) | Telex Metals | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
Appendix A
1
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tantalum (Ta) | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||||||
| Tantalum (Ta) | PRG Dooel | NORTH MACEDONIA | ||||||
| Tantalum (Ta) | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Alpha | UNITED STATES OF AMERICA | ||||||
| Tin (Sn) | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||||||
| Tin (Sn) | China Tin Group Co., Ltd. | CHINA | ||||||
| Tin (Sn) | CV Venus Inti Perkasa | INDONESIA | ||||||
| Tin (Sn) | Dowa | JAPAN | ||||||
| Tin (Sn) | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin (Sn) | Estanho de Rondonia S.A. | BRAZIL | ||||||
| Tin (Sn) | Fenix Metals | POLAND | ||||||
| Tin (Sn) | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||||||
| Tin (Sn) | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
| Tin (Sn) | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||||||
| Tin (Sn) | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
| Tin (Sn) | Luna Smelter, Ltd. | RWANDA | ||||||
| Tin (Sn) | Ma'anshan Weitai Tin Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
| Tin (Sn) | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
| Tin (Sn) | Melt Metais e Ligas S.A. | BRAZIL | ||||||
| Tin (Sn) | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
| Tin (Sn) | Metallo Belgium N.V. | BELGIUM | ||||||
| Tin (Sn) | Metallo Spain S.L.U. | SPAIN | ||||||
| Tin (Sn) | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tin (Sn) | Minsur | PERU | ||||||
| Tin (Sn) | Mitsubishi Materials Corporation | JAPAN | ||||||
| Tin (Sn) | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
| Tin (Sn) | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
| Tin (Sn) | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin (Sn) | PT Aries Kencana Sejahtera | INDONESIA | ||||||
| Tin (Sn) | PT Artha Cipta Langgeng | INDONESIA | ||||||
| Tin (Sn) | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
| Tin (Sn) | PT Babel Surya Alam Lestari | INDONESIA | ||||||
| Tin (Sn) | PT Bangka Serumpun | INDONESIA | ||||||
| Tin (Sn) | PT Lautan Harmonis Sejahtera | INDONESIA | ||||||
| Tin (Sn) | PT Menara Cipta Mulia | INDONESIA | ||||||
| Tin (Sn) | PT Mitra Stania Prima | INDONESIA | ||||||
Appendix A
2
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tin (Sn) | PT Prima Timah Utama | INDONESIA | ||||||
| Tin (Sn) | PT Rajawali Rimba Perkasa | INDONESIA | ||||||
| Tin (Sn) | PT Rajehan Ariq | INDONESIA | ||||||
| Tin (Sn) | PT Refined Bangka Tin | INDONESIA | ||||||
| Tin (Sn) | PT Stanindo Inti Perkasa | INDONESIA | ||||||
| Tin (Sn) | PT Timah Tbk Kundur | INDONESIA | ||||||
| Tin (Sn) | PT Timah Tbk Mentok | INDONESIA | ||||||
| Tin (Sn) | PT Tinindo Inter Nusa | INDONESIA | ||||||
| Tin (Sn) | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin (Sn) | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
| Tin (Sn) | Soft Metais Ltda. | BRAZIL | ||||||
| Tin (Sn) | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
| Tin (Sn) | Thaisarco | THAILAND | ||||||
| Tin (Sn) | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
| Tin (Sn) | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
| Tin (Sn) | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Yunnan Tin Company Limited | CHINA | ||||||
| Tin (Sn) | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin (Sn) | CV Tiga Sekawan | INDONESIA | ||||||
| Tin (Sn) | Malaysia Smelting Corporation | MALAYSIA | ||||||
| Tin (Sn) | Mineracao Taboca SA | BRAZIL | ||||||
| Tin (Sn) | PT Timah (Persero) Tbk Kundur | INDONESIA | ||||||
| Tin (Sn) | PT Timah (Persero) Tbk Mentok | INDONESIA | ||||||
| Tin (Sn) | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||||||
| Tin (Sn) | CRM Synergies | SPAIN | ||||||
| Tin (Sn) | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||||||
| Tin (Sn) | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||||||
| Tin (Sn) | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||||||
| Tin (Sn) | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Tin (Sn) | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin (Sn) | Pongpipat Company Limited | MYANMAR | ||||||
| Tin (Sn) | Precious Minerals and Smelting Limited | INDIA | ||||||
| Tin (Sn) | PT Mitra Sukses Globalindo | INDONESIA | ||||||
| Tin (Sn) | PT Timah Nusantara | INDONESIA | ||||||
| Tin (Sn) | Super Ligas | BRAZIL | ||||||
| Tin (Sn) | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin (Sn) | Jin Zhi Dao Tin Co. Ltd. | CHINA | ||||||
| Tungsten (W) | A.L.M.T Corp. | JAPAN | ||||||
| Tungsten (W) | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten (W) | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
Appendix A
3
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tungsten (W) | Asia Tungsten Products VIET NAM Ltd. | VIET NAM | ||||||
| Tungsten (W) | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten (W) | China Molybdenum Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
| Tungsten (W) | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||||||
| Tungsten (W) | H.C. Starck Tungsten GmbH | GERMANY | ||||||
| Tungsten (W) | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||||||
| Tungsten (W) | Japan New Metals Co., Ltd. | JAPAN | ||||||
| Tungsten (W) | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
| Tungsten (W) | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
| Tungsten (W) | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
| Tungsten (W) | KGETS CO., LTD. | KOREA, REPUBLIC OF | ||||||
| Tungsten (W) | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Tungsten (W) | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||||||
| Tungsten (W) | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
| Tungsten (W) | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
| Tungsten (W) | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||||||
| Tungsten (W) | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten (W) | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
| Tungsten (W) | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
| Tungsten (W) | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten (W) | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Artek LLC | RUSSIAN FEDERATION | ||||||
| Tungsten (W) | Cronimet Brasil Ltda | BRAZIL | ||||||
Appendix A
4
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tungsten (W) | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten (W) | GEM Co., Ltd. | CHINA | ||||||
| Tungsten (W) | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||||
| Gold (Au) | 8853 S.p.A. | ITALY | ||||||
| Gold (Au) | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
| Gold (Au) | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
| Gold (Au) | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
| Gold (Au) | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
| Gold (Au) | Argor-Heraeus S.A. | SWITZERLAND | ||||||
| Gold (Au) | Asahi Pretec Corp. | JAPAN | ||||||
| Gold (Au) | Asahi Refining Canada Ltd. | CANADA | ||||||
| Gold (Au) | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Gold (Au) | AU Traders and Refiners | SOUTH AFRICA | ||||||
| Gold (Au) | Aurubis AG | GERMANY | ||||||
| Gold (Au) | Bangalore Refinery | INDIA | ||||||
| Gold (Au) | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
| Gold (Au) | Boliden AB | SWEDEN | ||||||
| Gold (Au) | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold (Au) | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
| Gold (Au) | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
| Gold (Au) | Cendres + Metaux S.A. | SWITZERLAND | ||||||
| Gold (Au) | Chimet S.p.A. | ITALY | ||||||
| Gold (Au) | Chugai Mining | JAPAN | ||||||
| Gold (Au) | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
| Gold (Au) | Dowa | JAPAN | ||||||
| Gold (Au) | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Eco-System Recycling Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
| Gold (Au) | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
| Gold (Au) | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
| Gold (Au) | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
| Gold (Au) | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold (Au) | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
| Gold (Au) | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||||||
| Gold (Au) | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
| Gold (Au) | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Istanbul Gold Refinery | TURKEY | ||||||
| Gold (Au) | Italpreziosi | ITALY | ||||||
Appendix A
5
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold (Au) | Japan Mint | JAPAN | ||||||
| Gold (Au) | Jiangxi Copper Co., Ltd. | CHINA | ||||||
| Gold (Au) | JSC Uralelectromed | RUSSIAN FEDERATION | ||||||
| Gold (Au) | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Kazzinc | KAZAKHSTAN | ||||||
| Gold (Au) | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
| Gold (Au) | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
| Gold (Au) | L'Orfebre S.A. | ANDORRA | ||||||
| Gold (Au) | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Marsam Metals | BRAZIL | ||||||
| Gold (Au) | Materion | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
| Gold (Au) | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
| Gold (Au) | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
| Gold (Au) | Metalor Technologies S.A. | SWITZERLAND | ||||||
| Gold (Au) | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
| Gold (Au) | Mitsubishi Materials Corporation | JAPAN | ||||||
| Gold (Au) | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Gold (Au) | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
| Gold (Au) | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold (Au) | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
| Gold (Au) | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
| Gold (Au) | Nihon Material Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
| Gold (Au) | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold (Au) | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||||||
| Gold (Au) | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||||||
| Gold (Au) | PAMP S.A. | SWITZERLAND | ||||||
| Gold (Au) | Planta Recuperadora de Metales SpA | CHILE | ||||||
| Gold (Au) | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||||||
| Gold (Au) | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
| Gold (Au) | PX Precinox S.A. | SWITZERLAND | ||||||
| Gold (Au) | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold (Au) | REMONDIS PMR B.V. | NETHERLANDS | ||||||
| Gold (Au) | Royal Canadian Mint | CANADA | ||||||
| Gold (Au) | SAAMP | FRANCE | ||||||
| Gold (Au) | Safimet S.p.A | ITALY | ||||||
Appendix A
6
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold (Au) | SAFINA A.S. | CZECH REPUBLIC | ||||||
| Gold (Au) | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
| Gold (Au) | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
| Gold (Au) | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
| Gold (Au) | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
| Gold (Au) | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold (Au) | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||||||
| Gold (Au) | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold (Au) | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||||||
| Gold (Au) | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | T.C.A S.p.A | ITALY | ||||||
| Gold (Au) | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
| Gold (Au) | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||||||
| Gold (Au) | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
| Gold (Au) | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
| Gold (Au) | Torecom | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | TSK Pretech | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Umicore Precious Metals Thailand | THAILAND | ||||||
| Gold (Au) | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
| Gold (Au) | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Valcambi S.A. | SWITZERLAND | ||||||
| Gold (Au) | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
| Gold (Au) | WIELAND Edelmetalle GmbH | GERMANY | ||||||
| Gold (Au) | YAMAKIN CO., LTD. | JAPAN | ||||||
| Gold (Au) | Yokohama Metal Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
| Gold (Au) | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
| Gold (Au) | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Metalor Technologies(Suzhou) Ltd | CHINA | ||||||
| Gold (Au) | SAXONIA Edelmetalle | GERMANY | ||||||
| Gold (Au) | Yamamoto Precious Co., Ltd. | JAPAN | ||||||
| Gold (Au) | Augmont Enterprises Private Limited | INDIA | ||||||
| Gold (Au) | Alexy Metals | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold (Au) | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | African Gold Refinery | UGANDA | ||||||
| Gold (Au) | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||||
| Gold (Au) | Caridad | MEXICO | ||||||
| Gold (Au) | CGR Metalloys Pvt Ltd. | INDIA | ||||||
| Gold (Au) | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
| Gold (Au) | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||||||
| Gold (Au) | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||||||
| Gold (Au) | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||||
Appendix A
7
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold (Au) | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||||||
| Gold (Au) | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
| Gold (Au) | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
| Gold (Au) | Guangdong Jinding Gold Limited | CHINA | ||||||
| Gold (Au) | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||||||
| Gold (Au) | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||||||
| Gold (Au) | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Gold (Au) | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||||||
| Gold (Au) | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||||||
| Gold (Au) | JALAN & Company | INDIA | ||||||
| Gold (Au) | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||||
| Gold (Au) | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||||
| Gold (Au) | Kundan Care Products Ltd. | INDIA | ||||||
| Gold (Au) | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||||||
| Gold (Au) | L'azurde Company For Jewelry | SAUDI ARABIA | ||||||
| Gold (Au) | Lingbao Gold Co., Ltd. | CHINA | ||||||
| Gold (Au) | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||||
| Gold (Au) | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||||
| Gold (Au) | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Gold (Au) | Morris and Watson | NEW ZEALAND | ||||||
| Gold (Au) | NH Recytech Company | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Pease & Curren | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||||
| Gold (Au) | QG Refining, LLC | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Refinery of Seemine Gold Co., Ltd. | CHINA | ||||||
| Gold (Au) | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Sai Refinery | INDIA | ||||||
| Gold (Au) | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Shandong Humon Smelting Co., Ltd. | CHINA | ||||||
| Gold (Au) | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||||
| Gold (Au) | Shirpur Gold Refinery Ltd. | INDIA | ||||||
| Gold (Au) | Sovereign Metals | INDIA | ||||||
| Gold (Au) | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||||||
| Gold (Au) | Sudan Gold Refinery | SUDAN | ||||||
| Gold (Au) | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||||
| Gold (Au) | Tony Goetz NV | BELGIUM | ||||||
| Gold (Au) | Yunnan Copper Industry Co., Ltd. | CHINA | ||||||
| Gold (Au) | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | ||||||
| Gold (Au) | Gold Coast Refinery | GHANA | ||||||
| Gold (Au) | K.A. Rasmussen | NORWAY | ||||||
| Gold (Au) | MD Overseas | INDIA | ||||||
| Gold (Au) | Emerald Jewel Industry India Limited (Unit 1) | INDIA | ||||||
Appendix A
8
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold (Au) | Emerald Jewel Industry India Limited (Unit 2) | INDIA | ||||||
| Gold (Au) | Emerald Jewel Industry India Limited (Unit 3) | INDIA | ||||||
| Gold (Au) | Emerald Jewel Industry India Limited (Unit 4) | INDIA | ||||||
| Gold (Au) | Sellem Industries Ltd. | MAURITANIA | ||||||
| Gold (Au) | Metallix Refining Inc. | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | ||||||
| Gold (Au) | Gold Coast Refinery | GHANA | ||||||
| Gold (Au) | Henan Yuguang Gold & Lead Co., Ltd. | CHINA | ||||||
| Gold (Au) | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | ||||||
| Gold (Au) | Zhongkuang Gold Industry Co., Ltd. | CHINA | ||||||
* Country names according to ISO 3166-1
Appendix A
9
List 2: Smelters and Refiners reported to have been included in Adient’s supply chain but identified as having ceased operation prior to December 31, 2020
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tantalum (Ta) | Duoluoshan | CHINA | ||||||
| Tantalum (Ta) | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum (Ta) | KEMET Blue Powder | UNITED STATES OF AMERICA | ||||||
| Tin (Sn) | Cooperativa Metalurgica de Rondonia Ltda. | BRAZIL | ||||||
| Tin (Sn) | CV Ayi Jaya | INDONESIA | ||||||
| Tin (Sn) | CV Dua Sekawan | INDONESIA | ||||||
| Tin (Sn) | CV Gita Pesona | INDONESIA | ||||||
| Tin (Sn) | CV United Smelting | INDONESIA | ||||||
| Tin (Sn) | Gejiu Jinye Mineral Company | CHINA | ||||||
| Tin (Sn) | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||||||
| Tin (Sn) | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||||
| Tin (Sn) | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | ||||||
| Tin (Sn) | PT Babel Inti Perkasa | INDONESIA | ||||||
| Tin (Sn) | PT Bangka Prima Tin | INDONESIA | ||||||
| Tin (Sn) | PT Bangka Tin Industry | INDONESIA | ||||||
| Tin (Sn) | PT Belitung Industri Sejahtera | INDONESIA | ||||||
| Tin (Sn) | PT BilliTin Makmur Lestari | INDONESIA | ||||||
| Tin (Sn) | PT Bukit Timah | INDONESIA | ||||||
| Tin (Sn) | PT DS Jaya Abadi | INDONESIA | ||||||
| Tin (Sn) | PT Eunindo Usaha Mandiri | INDONESIA | ||||||
| Tin (Sn) | PT Inti Stania Prima | INDONESIA | ||||||
| Tin (Sn) | PT Justindo | INDONESIA | ||||||
| Tin (Sn) | PT Karimun Mining | INDONESIA | ||||||
| Tin (Sn) | PT Kijang Jaya Mandiri | INDONESIA | ||||||
| Tin (Sn) | PT Panca Mega Persada | INDONESIA | ||||||
| Tin (Sn) | PT Premium Tin Indonesia | INDONESIA | ||||||
| Tin (Sn) | PT Sariwiguna Binasentosa | INDONESIA | ||||||
| Tin (Sn) | PT Sukses Inti Makmur | INDONESIA | ||||||
| Tin (Sn) | PT Sumber Jaya Indah | INDONESIA | ||||||
| Tin (Sn) | PT Tirus Putra Mandiri | INDONESIA | ||||||
| Tin (Sn) | PT Tommy Utama | INDONESIA | ||||||
| Tin (Sn) | PT Wahana Perkit Jaya | INDONESIA | ||||||
| Tin (Sn) | CV United Smeiting | INDONESIA | ||||||
| Tin (Sn) | PT Bangka Putra Karya | INDONESIA | ||||||
| Tungsten (W) | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||||||
| Tungsten (W) | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||||||
| Tungsten (W) | Tejing (VIET NAM) Tungsten Co., Ltd. | VIET NAM | ||||||
| Tungsten (W) | VIET NAM Youngsun Tungsten Industry Co., Ltd. | VIET NAM | ||||||
Appendix A
10
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tungsten (W) | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten (W) | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||||
| Gold (Au) | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold (Au) | Elemetal Refining, LLC | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Morris and Watson Gold Coast | AUSTRALIA | ||||||
| Gold (Au) | Republic Metals Corporation | UNITED STATES OF AMERICA | ||||||
| Gold (Au) | Schone Edelmetaal B.V. | NETHERLANDS | ||||||
| Gold (Au) | Umicore Brasil Ltda. | BRAZIL | ||||||
Appendix A
11
Potential Countries of Origin of Conflict Minerals:
| Argentina | India | Eswatini | ||||||
| Australia | Indonesia | Taiwan, Province of China | ||||||
| Austria | Japan | Tanzania* | ||||||
| Benin | Laos | Thailand | ||||||
| Bolivia | Madagascar | Uganda* | ||||||
| Bolivia (Plurinational State of) | Malaysia | United Kingdom of Great Britain and Northern Ireland | ||||||
| Brazil | Mexico | United States of America | ||||||
| Burundi* | Mongolia | Uzbekistan | ||||||
| Canada | Mozambique | Venezuela (Bolivarian Republic of)*** | ||||||
| China | Myanmar | Viet Nam | ||||||
| Colombia | Namibia | Zambia* | ||||||
| Congo, Democratic Republic of the* | Niger | Zimbabwe | ||||||
| Ecuador | Nigeria | |||||||
| Eritrea | Peru | |||||||
| Ethiopia | Portugal | |||||||
| France | Russian Federation** | |||||||
| Germany | Rwanda* | |||||||
| Ghana | Sierra Leone | |||||||
| Guinea | South Africa | |||||||
| Guyana | Spain | |||||||
| * | DRC and adjoining countries | ||||
| ** | Information from suppliers CMRTs identified JSC Ekaterinburg Non-Ferrous Metal Processing Plant (“JSC Ekaterinburg”) as a potential source of metals used by Adient’s third-party suppliers. JSC Ekaterinburg is owned by a sanctioned Russian party. Adient prohibits suppliers from sourcing materials from JSC Ekaterinburg, and none of the completed and accepted conflict minerals surveys returned by our suppliers indicated that they did so during this reporting period. As explained above, Adient does not knowingly source metals directly or indirectly from sanctioned countries or parties, does not conduct transactions with sanctioned countries or parties, and has robust economic sanctions screening procedures designed to prevent business with sanctioned countries or parties before it occurs. To the extent that Adient might have unknowingly received metals from JSC Ekaterinburg, these materials would have been substantially transformed before being sold to Adient or otherwise incorporated into finished products. | ||||
| *** | Adient includes Venezuela in this list of potential countries of origin based on information obtained from RMI’s smelter database. RMI obtains the information appearing in that database from third-party sources that rely on information obtained from other, unrelated parties participating in highly-attenuated, multi-tiered global supply chains. It is also important to note that the information appearing in RMI’s smelter database identifies Venezuela within the “L1” risk-rating category, which includes over 120 jurisdictions including the United States. | ||||
Appendix A
12