Exhibit 1.01
Adient plc
Conflict Minerals Report
For the Calendar Year Ended December 31, 2022
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”) 2022 and covers all activities conducted for the calendar year ended December 31, 2022.
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 and 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, and trim covers.
Adient operates more than 200 wholly-owned and majority-owned manufacturing or assembly facilities in 30 countries, and employs approximately 70,000 employees worldwide.
As used in this Report, and except where the context otherwise requires, the terms “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, Adient’s products include complete automotive seating systems, as well as automotive seating frames, mechanisms, foam, head restraints, armrests, and trim covers.
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. 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 sourced from a vast network of globally dispersed suppliers.
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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 relies on its first-tier suppliers to provide 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 first-tier suppliers to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.
Adient elected to use the unaltered CMRT and 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 additional 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 relevant 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.
■Adient then assigned a risk level of “High,” “Low” or “None” based on the likelihood of the presence of Conflict Minerals in each component to each In-Scope Supplier as determined by a joint assessment of 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/online-resources/, 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.
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■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.
■Adient asked the In-Scope Suppliers who provided incomplete or inconsistent responses to review their responses and resubmit their information.
■Adient enhanced its escalation process for In-Scope Suppliers in 2022 to allow for earlier updates from the supplier’s side. The changes included:
■early identification of affected suppliers by using information from previous reporting years;
■informing affected suppliers at an earlier stage through the Adient Supplier Portal (https://www.adient.com/suppliers/corporate-responsibility/), the supplier training and individual communication; and
■additional reminders and follow-ups from Adient’s Procurement team for controlled suppliers and the Commercial groups for customer directed suppliers.
As part of the process described above, Adient also works to identify smelters that may be located in countries targeted under U.S. economic sanctions programs, as well as smelters who may be sanctioned parties. If Adient identifies potential economic sanctions risk as part of the CMRT review process, then it works with the relevant suppliers to evaluate and remediate such risks in a manner consistent with applicable sanctions-program requirements.
B.RCOI Results
Adient determined there were 941 In-Scope Suppliers for RY 2022. Adient sent communications to its In-Scope Suppliers notifying them of the RCOI and received delivery confirmation receipts from 97% of those In-Scope Suppliers.
The overall response rate among the In-Scope Suppliers surveyed was 72%, including 529 responses that were received and accepted (representing 81% 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 our compliance specialists. Below are the results of the RCOI survey:
RCOI Survey Results* | |||||
No 3TG | 72 | % | |||
Acknowledged 3TG Sourced from the Covered Countries | 5 | % | |||
Acknowledged 3TG Not Sourced from the Covered Countries | 4 | % | |||
3TG Origin Uncertain or Unknown | 19 | % |
*results based on the number of received and accepted CMRTs
C.Improvement Measures to be Taken
Adient has succeeded in increasing the supplier response rate for four consecutive years, but continues to work on continuous improvement of its processes. For example, Adient's due diligence efforts will be extended to include cobalt and mica during 2023 to fulfill the demands of the automotive industry for responsible supply chain management.
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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. Each of these elements is further described 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. Adient’s Sustainability Report and its Conflict Minerals Policy Statement express 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 reserve the right to 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/wp-content/uploads/2023/05/AdientConflictMineralsPolicyStatement2023.pdf
Internal Management System
Adient maintains an internal management system in which 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 processes through initiatives that often involve stakeholder engagement or consultation with outside experts.
Adient’s Conflict Minerals Executive Steering Committee (“Steering Committee”), comprised of leaders from the company’s Procurement, Legal, Engineering, Communications and Finance Departments, meets several times a year. The Steering Committee oversees and supports the development of the Conflict Minerals compliance program and monitors plans to comply with all requirements.
This Report was also reviewed by Adient’s Chief Executive Officer as well as Adient’s Disclosure Committee, which includes its Chief Financial Officer, Chief Legal and Human Resources Officer, Chief Accounting Officer, and other senior Adient managers with relevant oversight roles.
System of Controls and Transparency
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.
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Supplier Engagement and Training
Adient provides 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 Adient's website at: https://www.adient.com/suppliers/corporate-responsibility. Adient encourages its suppliers to confer with Adient's compliance team and strengthen their understanding of the Rule and our expectations. Adient also provides additional training to suppliers on request.
Adient also provides the In-Scope Suppliers with instructions for responding to the survey, and our Conflict Minerals 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.
Where appropriate, Adient 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 (available at https://www.adient.com/suppliers/supplier-expectations/).
Internal Training
Adient maintains a web-based training module designed specifically for employees within its Procurement and Engineering Departments. This training is updated at least annually and 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. Special emphasis is given to new and upcoming supply chain risks related to smelter management. 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 records retention procedures.
Complaint Mechanism
Adient maintains a web- and telephone-based, 24-hour Integrity Helpline (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 and anonymous 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. All good-faith reports submitted to the Integrity Helpline are investigated. The Legal Department is responsible for evaluating concerns reported through this reporting mechanism, conducting internal investigations where appropriate, and resolving cases that may require remedial or corrective action.
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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 exercises ongoing due diligence and escalation processes of its suppliers to remove Covered Countries, comprehensively sanctioned countries, and non-certified smelters from their supply chain. Adient asks 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 or embargoed 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 includes engaging with such supplier and validating information with other reliable sources. Suppliers reporting RMI-certified smelters from the Covered Countries are 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 maintains a list of suppliers identified as potentially using Conflict Minerals from a Covered Country as well as the indicated smelters. This list is then compared to the RMI smelter listing to verify the accuracy of the supplier responses as well as the source of the Conflict Minerals, which is then shared with the responsible procurement team.
In addition to these measures, Adient engages and actively cooperates with industry groups, including RMI and AIAG. Adient also provides its smelter list to the RMI to support RMI’s risk assessments.
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 have their own highly attenuated global supply chains and do not have direct relationships with the smelters or other facilities that process Conflict Minerals.
Adient’s CMRT evaluation process allows for the rejection of CMRTs that appear to be incorrect or that do not provide RCOI information about listed smelters that are uncertified. The Conflict Minerals team categorizes these CMRTs as “3TG origin uncertain or unknown” and includes data received from suppliers providing these CMRTs into the Report as noted.
In RY 2022, none of the supplier responses (based on total responses received) stated that they were unable to provide smelter and refiner information. Only 23 suppliers (4%) stated that they do not source from the Covered Countries. Another 6% 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.
In addition, 125 suppliers (24%) reported uncertified smelters and were consequently rated as “3TG uncertain or unknown”. These suppliers received information that their CMRT was rejected after closure of the reporting period in January 2023. 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.
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.
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Appendix A includes a list of the smelters identified in the CMRTs Adient received and accepted from Adient's In-Scope Suppliers as part of Adient's RCOI and due diligence efforts. A total of 288 RMI certified smelters were identified by our suppliers. Out of these, 20 smelters have been reported to have ceased operations during the reporting year. One smelter (African Gold Refinery) that is owned by a party sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) was reported by 25 suppliers. Adient subjected each of these suppliers to our escalation process. As a result, 7 suppliers removed this problematic smelter from their supply chains. The escalation process is still under way for the remaining 18 suppliers, and Adient reserves the right to reconsider the supply arrangement for controlled suppliers who do not remove this smelter from their supply chain.
In addition to African Gold Refinery, Adient is following a similar process with respect to Russian smelters Hydrometallurg JSC and Kyrovgrad Hard Alloys Plant JSC, which are owned by sanctioned parties.
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;
■Updating and adapting our scoping, due diligence and escalation guidelines;
■Reviewing and utilizing our internal 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.
The purpose of these processes 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 and training, 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.
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VII. Determination |
For RY 2022, Adient is unable to determine the mine or country of origin for each 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 conclusively whether all products manufactured, or contracted to be manufactured, by Adient in RY 2022 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,” “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, 2022 filed with the SEC on November 22, 2022, and in subsequent reports filed with or furnished to 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. In addition, Adient is not including the information contained on, or that can be accessed through, its website as part of, or incorporating it by reference into, this Report.
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Appendix A - Smelters by Mineral
The below smelter information refers to data available in the RMI smelter database as of January 2023. Any changes to the RMI smelter database that took place after January 2023 are not covered.
List 1: Smelters and Refiners identified in the CMRTs Adient received and accepted that were included in Adient's supply chain as of December 31, 2022:
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 |
Appendix A
1
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Tantalum (Ta) | Telex Metals | UNITED STATES OF AMERICA | ||||||
Tantalum (Ta) | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
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 | Alpha | UNITED STATES OF AMERICA | ||||||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||||||
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||||||
Tin | China Tin Group Co., Ltd. | CHINA | ||||||
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||||||
Tin | CRM Synergies | SPAIN | ||||||
Tin | CV Tiga Sekawan | INDONESIA | ||||||
Tin | CV Venus Inti Perkasa | INDONESIA | ||||||
Tin | Dowa | JAPAN | ||||||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
Tin | Fenix Metals | POLAND | ||||||
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||||||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||||||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||||
Tin | Gejiu Zili Mining and Metallurgy Co., Ltd. | CHINA | ||||||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||||||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
Tin | Luna Smelter, Ltd. | RWANDA | ||||||
Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | ||||||
Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
Tin | Malaysia Smelting Corporation | MALAYSIA | ||||||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
Tin | Melt Metais e Ligas S.A. | BRAZIL | ||||||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
Tin | Metallo Belgium N.V. | BELGIUM | ||||||
Tin | Metallo Spain S.L.U. | SPAIN | ||||||
Tin | Mineracao Taboca S.A. | BRAZIL | ||||||
Tin | Mineracao Taboca SA | BRAZIL | ||||||
Tin | Minsur | PERU | ||||||
Tin | Mitsubishi Materials Corporation | JAPAN | ||||||
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION** | ||||||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
Appendix A
2
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
Tin | PT Babel Surya Alam Lestari | INDONESIA | ||||||
Tin | PT Bangka Serumpun | INDONESIA | ||||||
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | ||||||
Tin | PT Menara Cipta Mulia | INDONESIA | ||||||
Tin | PT Mitra Stania Prima | INDONESIA | ||||||
Tin | PT Prima Timah Utama | INDONESIA | ||||||
Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||||||
Tin | PT Rajehan Ariq | INDONESIA | ||||||
Tin | PT Refined Bangka Tin | INDONESIA | ||||||
Tin | PT Stanindo Inti Perkasa | INDONESIA | ||||||
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | ||||||
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | ||||||
Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
Tin | PT Tinindo Inter Nusa | INDONESIA | ||||||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
Tin | Soft Metais Ltda. | BRAZIL | ||||||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
Tin | Thaisarco | THAILAND | ||||||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
Tin | Yunnan Tin Company Limited | CHINA | ||||||
Tungsten | A.L.M.T Corp. | JAPAN | ||||||
Tungsten | ACL Metais Eireli | BRAZIL | ||||||
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
Tungsten | Artek LLC | RUSSIAN FEDERATION** | ||||||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||||||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Cronimet Brasil Ltda | BRAZIL | ||||||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Appendix A
3
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||||||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION** | ||||||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||||||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION** | ||||||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
Tungsten | KGETS CO., LTD. | KOREA, REPUBLIC OF | ||||||
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||||||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION** | ||||||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION** | ||||||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION** | ||||||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||
Gold | 8853 S.p.A. | ITALY | ||||||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
Gold | Alexy Metals | UNITED STATES OF AMERICA | ||||||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
Gold | Argor-Heraeus S.A. | SWITZERLAND | ||||||
Gold | Asahi Pretec Corp. | JAPAN | ||||||
Gold | Asahi Refining Canada Ltd. | CANADA | ||||||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
Gold | Asaka Riken Co., Ltd. | JAPAN | ||||||
Gold | AU Traders and Refiners | SOUTH AFRICA |
Appendix A
4
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Gold | Augmont Enterprises Private Limited | INDIA | ||||||
Gold | Aurubis AG | GERMANY | ||||||
Gold | Bangalore Refinery | INDIA | ||||||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
Gold | Boliden AB | SWEDEN | ||||||
Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
Gold | Chimet S.p.A. | ITALY | ||||||
Gold | Chugai Mining | JAPAN | ||||||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
Gold | Dowa | JAPAN | ||||||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
Gold | Eco-System Recycling Co., Ltd. | JAPAN | ||||||
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | Heimerle + Meule GmbH | GERMANY | ||||||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
Gold | Istanbul Gold Refinery | TURKEY | ||||||
Gold | Italpreziosi | ITALY | ||||||
Gold | Japan Mint | JAPAN | ||||||
Gold | Jiangxi Copper Co., Ltd. | CHINA | ||||||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION** | ||||||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
Gold | Kazzinc | KAZAKHSTAN | ||||||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
Gold | L’Orfebre S.A. | ANDORRA | ||||||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | Marsam Metals | BRAZIL |
Appendix A
5
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Gold | Materion | UNITED STATES OF AMERICA | ||||||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||||||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
Gold | Metalor Technologies S.A. | SWITZERLAND | ||||||
Gold | Metalor Technologies (Suzhou) Ltd | CHINA | ||||||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
Gold | Mitsubishi Materials Corporation | JAPAN | ||||||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION** | ||||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
Gold | Nihon Material Co., Ltd. | JAPAN | ||||||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION** | ||||||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION** | ||||||
Gold | PAMP S.A. | SWITZERLAND | ||||||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||||||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION** | ||||||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
Gold | PX Precinox S.A. | SWITZERLAND | ||||||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
Gold | REMONDIS PMR B.V. | NETHERLANDS | ||||||
Gold | Royal Canadian Mint | CANADA | ||||||
Gold | SAAMP | FRANCE | ||||||
Gold | Safimet S.p.A | ITALY | ||||||
Gold | SAFINA A.S. | CZECHIA | ||||||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
Gold | SAXONIA Edelmetalle | GERMANY | ||||||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION** | ||||||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Appendix A
6
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | T.C.A S.p.A | ITALY | ||||||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||||||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
Gold | Torecom | KOREA, REPUBLIC OF | ||||||
Gold | TSK Pretech | KOREA, REPUBLIC OF | ||||||
Gold | Umicore Precious Metals Thailand | THAILAND | ||||||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
Gold | Valcambi S.A. | SWITZERLAND | ||||||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||||
Gold | YAMAKIN CO., LTD. | JAPAN | ||||||
Gold | Yamamoto Precious Co., Ltd. | JAPAN | ||||||
Gold | Yokohama Metal Co., Ltd. | JAPAN | ||||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
* Country names according to ISO 3166-1
Appendix A
7
List 2: Smelters and Refiners identified in the CMRTs received and accepted that were included in Adient's supply chain but identified as having ceased operation prior to December 31, 2022:
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | ||||||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | ||||||
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | ||||||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||||||
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||||||
Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | ||||||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||||||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||||||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | ||||||
Appendix A
8
Potential Countries of Origin of Conflict Minerals:
Andorra | Guinea | Russian Federation** | ||||||
Angola* | Guyana | Rwanda* | ||||||
Antigua and Barbuda | Honduras | Saint Kitts and Nevis | ||||||
Argentina | Hong Kong | Saudi Arabia | ||||||
Australia | Hungary | Senegal | ||||||
Austria | India | Serbia | ||||||
Bahamas | Indonesia | Sierra Leone | ||||||
Bahrain | Ireland | Singapore | ||||||
Bangladesh | Israel | Sint Maarten | ||||||
Barbados | Italy | Slovakia | ||||||
Belarus | Japan | Slovenia | ||||||
Belgium | Jordan | South Africa | ||||||
Benin | Kazakhstan | South Korea | ||||||
Bolivia (Plurinational State of) | Kenya | Spain | ||||||
Brazil | Kuwait | St Vincent and Grenadines | ||||||
Bulgaria | Laos | Sudan | ||||||
Burundi* | Latvia | Swaziland | ||||||
Canada | Lebanon | Sweden | ||||||
Cayman Islands | Liberia | Switzerland | ||||||
Chile | Lithuania | Taiwan, Province of China | ||||||
China | Luxembourg | Tanzania* | ||||||
Colombia | Malaysia | Thailand | ||||||
Congo, Democratic Republic of the* | Malta | Togo | ||||||
Croatia | Mexico | Trinidad and Tobago | ||||||
Curacao | Morocco | Tunisia | ||||||
Czech Republic | Mozambique | Turkey | ||||||
Denmark | Myanmar | Turks and Caicos | ||||||
Dominican Republic | Namibia | Uganda* | ||||||
Ecuador | Netherlands | Ukraine | ||||||
Egypt | New Zealand | United Arab Emirates | ||||||
El Salvador | Niger | United Kingdom of Great Britain and Northern Ireland | ||||||
Eritrea | Nigeria | United States of America | ||||||
Estonia | Norway | Uruguay | ||||||
Ethiopia | Pakistan | Uzbekistan | ||||||
Finland | Panama | Venezuela (Bolivarian Republic of)*** | ||||||
France | Peru | Vietnam | ||||||
Germany | Philippines | Yemen | ||||||
Ghana | Poland | Zambia* | ||||||
Greece | Portugal | Zimbabwe | ||||||
Grenada | Puerto Rico | |||||||
Guatemala | Romania | |||||||
Appendix A
9
* | DRC and adjoining countries | ||||
** | Information from supplier CMRTs identified smelters located in the Russian Federation as a potential source of metals used by Adient’s third-party suppliers. These smelters lost their certification during the Reporting Year. As they were part of Adient’s supply chain prior to change in status they are still listed. | ||||
*** | As explained above, Adient does not knowingly source directly or indirectly from sanctioned countries or parties. Nonetheless, we include 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. These facts further diminish the potential conflict minerals risks associated with the RMI smelter data used to prepare this summary. |
Appendix A
10