Exhibit 1.01
Conflict Minerals Report
For Calendar Year 2018
This is The Walt Disney Company’s 2018 (January 1 to December 31, 2018) Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”).
Background
The Walt Disney Company, together with its subsidiaries, is a diversified worldwide entertainment company. The Company operates under four business segments: Media Networks, Parks, Experiences and Products, Studio Entertainment and Direct-to-Consumer & International. For convenience, the terms “Company,” “Disney” and “we” are used in this CMR to refer collectively to the parent company and its consolidated subsidiaries through which our various businesses were conducted during calendar 2018.
The Company derives the vast majority of its revenues from the licensing of intellectual property, the sale of advertising time, and charges for entertainment, lodging and associated food and beverage sales at its theme parks, resorts, and cruise lines. We also derive revenue from the sales of physical products (such as physical copies of films and music) that we have determined do not include columbite-tantalite, cassiterite, gold, wolframite or their derivatives (collectively, the “Subject Minerals”) as necessary to the products’ functionality or production (“necessary Subject Minerals”).
The products we sell that may include necessary Subject Minerals are items such as clothing, accessories, electronic toys, jewelry, and other consumer goods. We classify these items together as retail merchandise, and that is the product category covered by this CMR. We sell many of these items directly through Disney Stores throughout the world, including our online stores, and at our entertainment venues, including our parks and resorts. We also sell retail merchandise wholesale to other retailers.
The sale of retail merchandise constituted less than 10% of our revenue in calendar 2018. The number of individual items sold is, however, large. We estimate that we sold retail merchandise with approximately 160,000 stock-keeping units (SKUs) in calendar 2018. Moreover, due to the dynamic nature of our business, the items we sell change rapidly, with many items sold for only a few months, and then replaced by other items sourced from other suppliers.
The Company does not manufacture any of the retail merchandise it sells, sourcing the specific merchandise items that may contain Subject Minerals from over 800 suppliers in calendar 2018. Many of our suppliers themselves source components of these items from numerous other suppliers, and our direct suppliers are often many steps removed from the source of the raw materials contained in the items. In addition, in many cases the items we acquire from a supplier represent a small portion of the supplier’s total production.
The number, diversity and frequent turnover of the retail merchandise we sell, the number and turnover of suppliers, and our remote position in the supply chain make it difficult for us to determine and track the source of individual items, the nature of the raw materials included in the items, and the source of
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those raw materials. Nevertheless, our Conflict Minerals Compliance Program (the “Program”) is designed to gain relevant information about the sources of raw materials in our products that is as complete as reasonably possible given the large number and diversity of products we sell and in light of our position in the supply chain.
Our Program is focused on identifying suppliers of retail merchandise that may contain necessary Subject Minerals and gathering information about the supply chain practices of those suppliers. The Program conforms to the elements of the guidance set forth in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD Guidance) that are required by the Conflict Minerals Rule, and thus includes:
• | strong company management systems (including a Conflict Minerals Policy and an established internal management structure); |
• | identification and assessment of risk in the supply chain through a reasonable country of origin inquiry; |
• | a strategy to respond to identified risks through due diligence procedures that include follow up with suppliers who either provide insufficient information to identify sources of necessary Subject Minerals or who provide information indicating that they may source necessary Subject Minerals that may have originated in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”); and |
• | reporting on results of the Program. |
These elements of the Program, and the results of the Program for calendar 2018, are described below.
Company Management Systems
1. | Conflict Minerals Policy. The Company’s Conflict Minerals Policy sets forth the steps we are taking to comply with the Conflict Minerals Rule. These steps include: the establishment of the internal management structure described below; engagement with suppliers as described in this report; reporting required by the Conflict Minerals Rule; and monitoring developments relating to conflict minerals with an eye to enhancing the Program. Our policy was distributed to suppliers who may supply us with products covered by the rule and is posted on our website at https://www.thewaltdisneycompany.com/wp-content/uploads/2019/05/Conflict-Minerals-Policy.pdf. The policy includes a mechanism for reporting concerns or asking questions regarding the policy. |
2. | Internal Management Structure. A management oversight structure that includes input from executive-level representatives of Legal, Investor Relations, Controllership, Corporate Communications, Global Public Policy, and Global Product & Labor Standards. These executives are responsible for providing governance and oversight over the execution of the Program and for monitoring the Program’s compliance with regulatory requirements and satisfaction of enterprise goals. The day-to-day implementation of the Program is conducted by a Conflict Minerals Compliance Program Team within our Global Product & Labor Standards organization, which reports to an executive officer of the Company. |
3. | Chain of Custody and Traceability. Support for and engagement with the Responsible Minerals Initiative (RMI). The data on which we relied for certain statements in this report was obtained through our membership in RMI, using the Reasonable Country of Origin Inquiry report for member DISN. |
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Identification and Assessment of Risk Through Reasonable Country of Origin Inquiry
Based on lists of historic suppliers of retail merchandise updated through interviews with sourcing executives, we compile a list each year of the suppliers we are able to identify as supplying retail merchandise in the prior calendar year that may contain necessary Subject Minerals.
Each year, we distribute a survey to these suppliers regarding their supply chain practices relating to Subject Minerals. The 2018 survey was based on RMI’s Conflict Minerals Reporting Template (CMRT), revision 5.0 or higher. We supplemented this template with additional multi-language questions designed to provide visibility into our suppliers’ sourcing activities, including the basis for their responses regarding the source of Subject Minerals in the retail merchandise they supplied to us. We also provided suppliers with access to a live technical support specialist via chat during the survey phase, provided multi-language training documents highlighting Frequently Asked Questions on Conflict Minerals and Section 1502 of the Dodd-Frank Wall-Street Reform and Consumer Protection Act, as well as instructions on how to complete the CMRT. Our communications included our expectations for response and noted that the Conflict Minerals Rule was not intended to stop companies and their suppliers from sourcing from the Covered Countries and that such an embargo would be contrary to the intent of the Conflict Minerals Rule.
In 2018, we continued to refine the method of identifying suppliers that are within the scope of the Conflict Minerals Rule and surveyed 810 suppliers of retail merchandise that we sell to our customers. We received survey responses from 661, or 82%, compared to a response rate of 72% for calendar 2017. We received survey responses from, or otherwise corresponded with, 96% of our 100 largest suppliers by spend of merchandise for resale and 100% of the suppliers we initially identified as most likely to be supplying us with products that contained Subject Minerals. Our response rate since 2015 is shown in Figure 1 below.
1 For Calendar Year 2018, due to improved systems and processes, we were better able to identify in-scope suppliers thereby resulting in a reduction in the survey population.
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The vast majority of the suppliers who completed the survey responded that the merchandise they supplied to us did not contain any necessary Subject Minerals. Based on survey responses, interviews, and our further review of the retail merchandise supplied, we identified 36 suppliers who manufactured retail merchandise for us that most likely contained necessary Subject Minerals. Of these suppliers:
• | One supplier responded that the Subject Minerals in all the products it supplied to us did not originate in the Covered Countries, and they provided sufficient information regarding their supply chain program for us to determine that this response was reliable; |
• | Three suppliers responded that the Subject Minerals in at least some of the products it supplied to us originated in the Covered Countries. As noted below, we determined that these suppliers only sourced Subject Minerals in the Covered Countries from smelters and refiners that are compliant with the RMI’s Responsible Minerals Assurance Process (RMAP). |
• | The remaining suppliers could not determine the country of origin of all of the necessary Subject Minerals in products supplied to us for resale by us or could not provide sufficient information regarding the materials used to manufacture our products for us to determine the country of origin. |
Due Diligence Measures Performed
Based on our assessment of survey responses for calendar 2018, we implemented due diligence measures with respect to suppliers who (1) may have manufactured retail merchandise for us containing Subject Minerals and (2) had not reliably demonstrated that the Subject Minerals were not sourced from Covered Countries. These measures included:
• | Performance of targeted follow-up with suppliers who did not initially respond to the survey. |
• | Verification of information regarding smelters and refiners provided by our suppliers with the RMI’s list of conformant smelters and refiners and other lists provided by accredited organizations such as London Bullion Market Association (LBMA) or Responsible Jewelry Council (RJC). Through this effort, we validated one supplier’s response that the Subject Minerals in all the products it supplied to us did not originate in the Covered Countries, and we determined that the smelters and refiners in the Covered Countries that were identified by three of our suppliers were all compliant with the RMI’s RMAP. |
• | Requests for additional information (e.g., certificate of material analysis and bill of materials) from suppliers whom we determined supplied items containing Subject Minerals and who provided information that was insufficient for us to determine reliably the source of Subject Minerals in retail merchandise manufactured for us. Through this effort, we were able to obtain more reliable information about the presence of Subject Minerals in items supplied to us and obtain additional smelter and refiner information. |
• | Encouragement of suppliers who provided insufficient information regarding their supply chain to develop more robust supply chain information programs and policies. |
• | Encouragement of suppliers who may have sourced Subject Minerals (or product components from sub-suppliers who may have sourced Subject Minerals) from non-compliant smelters or refiners to source from smelters and refiners who are compliant with the relevant RMAP assessment protocols of the RMI, or from another accredited organization. |
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Smelters, Refiners, and Countries of Origin Information
The suppliers who manufactured retail merchandise for us that we determined contained necessary Subject Minerals identified 267 smelters or refiners that supplied them with Subject Minerals. Although we cannot determine whether retail merchandise manufactured for us contained Subject Minerals from each of these 267 smelters and refiners, we have listed each of them in Attachment A. All but 53 of these smelters and refiners are compliant, or conformant, with the relevant RMAP assessment protocols of RMI and/or another accredited organizations. Figure 2 shows compliance by mineral.2
Based on the information provided by our suppliers, we have been able to determine that:
• | of the 267 smelters and refiners identified in Attachment A, 19 are identified by RMI as sourcing Subject Minerals from Covered Countries; |
• | each of these 19 smelters and refiners were determined by RMI to be conformant with the relevant RMAP assessment protocols of the RMI; and |
• | the countries of origin of the Subject Minerals supplied by the smelters and refiners included in Attachment A are listed in Attachment B. |
However, we cannot determine: whether the 53 smelters and refiners who are not conformant with the relevant RMAP assessment protocols of the RMI, or another accredited organization, sourced from Covered Countries; whether gold smelters certified by the RJC or LBMA sourced from the Covered Countries; and whether the suppliers who provided us with insufficient information regarding the source of Subject Minerals sourced Subject Minerals from the Covered Countries. Therefore, we are unable to determine either the facilities used to process or the source (country, mine or other location) of necessary Subject Minerals for all of the retail merchandise we sell.
2 Of the 101 gold conformant smelters, 70 were also found to be certified by the LBMA and/or RJC.
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Further Development of Disney’s Conflict Minerals Compliance Program
Our efforts with respect to calendar 2018 were devoted to managing the response rate to our supplier survey, improving our conflict minerals survey tool, and implementing internal process efficiencies. We achieved these goals by enhancing our third-party conflict minerals solution and developing our internal capabilities. We continued to encourage suppliers to improve their supply chain policies, source responsibly, and to source Subject Minerals from (or from sub-suppliers who source from) smelters and refiners who are compliant with the relevant RMAP assessment protocols of RMI or any other accredited organization. In calendar 2018 we saw year-over-year improvement from existing suppliers in providing information regarding their supply chain policies and in efforts to identify smelters in their supply chain. Each year we also encourage new suppliers in our supply chain to provide us with this information and to source from compliant smelters and refiners.
We continue to focus on refining our systems for identifying relevant suppliers and the product categories associated with each supplier, and on obtaining additional and more reliable information on each supplier’s own supply chain. We also continue to evaluate the overall quality of supply chain practices of our suppliers, the impact of encouraging adoption of robust supply chain practices in light of developing supply chain certification programs, the practices of our suppliers, and whether it is helpful and feasible to give them further incentives to strengthen their supply chain programs.
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Attachment A
Smelters and Refiners
Identified by Suppliers
The following table identifies each of the smelters and refiners identified by our suppliers as sources of Subject Minerals in retail merchandise manufactured by the supplier. The table includes the name of the smelter or refiner, the Subject Minerals supplied by the smelter or refiner, the location of the smelter or refiner, the certification obtained by the smelter or refiner and whether certification had been obtained. Our suppliers could not confirm whether each smelter or refiner they used supplied Subject Minerals in retail merchandise manufactured for the Company. All but 53 of the smelters and refiners identified below are currently conformant with RMAP assessment protocols of the RMI or other accredited organizations. Disney has encouraged its suppliers to work with the non-conformant smelters to gain certification from RMI or other accredited organizations, or to source from certified smelters or refiners.
Mineral | Smelter or Refiner Name | ISO* Country Code | Certification | Certified |
Gold | Abington Reldan Metals, LLC | US | NO | |
Gold | Advanced Chemical Company | US | † | YES |
Gold | African Gold Refinery | UG | NO | |
Gold | Aida Chemical Industries Co., Ltd. | JP | † | YES |
Gold | Al Etihad Gold Refinery DMCC | AE | † | YES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | DE | *, ‡, † | YES |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZ | *, † | YES |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BR | *, † | YES |
Gold | Argor-Heraeus S.A. | CH | *, † | YES |
Gold | Asahi Pretec Corp. | JP | *, † | YES |
Gold | Asahi Refining Canada Ltd. | CA | *, † | YES |
Gold | Asahi Refining USA Inc. | US | *, † | YES |
Gold | Asaka Riken Co., Ltd. | JP | † | YES |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TR | NO | |
Gold | AU Traders and Refiners | ZA | ‡, † | YES |
Gold | Aurubis AG | DE | *, † | YES |
Gold | Bangalore Refinery | IN | ** | NO |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PH | *, † | YES |
Gold | Boliden AB | SE | *, † | YES |
Gold | C. Hafner GmbH + Co. KG | DE | *, ‡, † | YES |
Gold | Caridad | MX | NO | |
Gold | CCR Refinery - Glencore Canada Corporation | CA | *, † | YES |
Gold | Cendres + Metaux S.A. | CH | † | YES |
Gold | Chimet S.p.A. | IT | *, † | YES |
Gold | Chugai Mining | JP | ** | NO |
Gold | Daejin Indus Co., Ltd. | KR | † | YES |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CN | NO | |
Gold | Degussa Sonne / Mond Goldhandel GmbH | DE | NO | |
Gold | DODUCO Contacts and Refining GmbH | DE | † | YES |
Gold | Dowa | JP | † | YES |
* International Standards Organization
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Gold | DS PRETECH Co., Ltd. | KR | † | YES |
Gold | DSC (Do Sung Corporation) | KR | † | YES |
Gold | Eco-System Recycling Co., Ltd. | JP | † | YES |
Gold | Emirates Gold DMCC | AE | *, † | YES |
Gold | Fidelity Printers and Refiners Ltd. | ZW | NO | |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | IN | NO | |
Gold | Geib Refining Corporation | US | † | YES |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CN | *, † | YES |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CN | NO | |
Gold | Guangdong Jinding Gold Limited | CN | NO | |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CN | NO | |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CN | NO | |
Gold | HeeSung Metal Ltd. | KR | † | YES |
Gold | Heimerle + Meule GmbH | DE | *, † | YES |
Gold | Heraeus Metals Hong Kong Ltd. | CN | *, ‡, † | YES |
Gold | Heraeus Precious Metals GmbH & Co. KG | DE | *, † | YES |
Gold | Hunan Chenzhou Mining Co., Ltd. | CN | NO | |
Gold | HwaSeong CJ CO., LTD. | KR | NO | |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co. | CN | *, † | YES |
Gold | Ishifuku Metal Industry Co., Ltd. | JP | *, † | YES |
Gold | Istanbul Gold Refinery | TR | *, † | YES |
Gold | Italpreziosi | IT | ‡, † | YES |
Gold | Japan Mint | JP | *, † | YES |
Gold | Jiangxi Copper Co., Ltd. | CN | *, † | YES |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RU | NO | |
Gold | JSC Uralelectromed | RU | *, † | YES |
Gold | JX Nippon Mining & Metals Co., Ltd. | JP | *, † | YES |
Gold | Kaloti Precious Metals | AE | NO | |
Gold | Kazakhmys Smelting LLC | KZ | NO | |
Gold | Kazzinc | KZ | *, † | YES |
Gold | Kennecott Utah Copper LLC | US | *, † | YES |
Gold | KGHM Polska Miedz Spolka Akcyjna | PL | ** | NO |
Gold | Kojima Chemicals Co., Ltd. | JP | † | YES |
Gold | Korea Zinc Co., Ltd. | KR | † | YES |
Gold | Kyrgyzaltyn JSC | KG | *, † | YES |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RU | NO | |
Gold | L'azurde Company For Jewelry | SA | NO | |
Gold | L'Orfebre S.A. | CN | † | YES |
Gold | Lingbao Gold Co., Ltd. | CN | NO | |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | AD | NO | |
Gold | LS-NIKKO Copper Inc. | KR | *, † | YES |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CN | NO | |
Gold | Marsam Metals | BR | † | YES |
Gold | Materion | US | † | YES |
Gold | Matsuda Sangyo Co., Ltd. | JP | *, † | YES |
Gold | Metalor Technologies (Hong Kong) Ltd. | CN | *, ‡, † | YES |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SG | *, ‡, † | YES |
Gold | Metalor Technologies (Suzhou) Ltd. | CN | ‡, † | YES |
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Gold | Metalor Technologies S.A. | CH | *, ‡, † | YES |
Gold | Metalor USA Refining Corporation | US | *, ‡, † | YES |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MX | *, † | YES |
Gold | Mitsubishi Materials Corporation | JP | *, † | YES |
Gold | Mitsui Mining and Smelting Co., Ltd. | JP | *, † | YES |
Gold | MMTC-PAMP India Pvt., Ltd. | IN | *, † | YES |
Gold | Modeltech Sdn Bhd | MY | NO | |
Gold | Morris and Watson | NZ | NO | |
Gold | Morris and Watson Gold Coast | AU | NO | |
Gold | Moscow Special Alloys Processing Plant | RU | *, † | YES |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TR | *, † | YES |
Gold | Navoi Mining and Metallurgical Combinat | UZ | NO | |
Gold | NH Recytech Company | KR | ** | NO |
Gold | Nihon Material Co., Ltd. | JP | *, † | YES |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt | AT | ‡, † | YES |
Gold | Ohura Precious Metal Industry Co., Ltd. | JP | † | YES |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RU | *, † | YES |
Gold | OJSC Novosibirsk Refinery | RU | *, † | YES |
Gold | PAMP S.A. | CH | *, † | YES |
Gold | Pease & Curren | US | NO | |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CN | NO | |
Gold | Planta Recuperadora de Metales SpA | CL | † | YES |
Gold | Prioksky Plant of Non-Ferrous Metals | RU | *, † | YES |
Gold | PT Aneka Tambang (Persero) Tbk | ID | *, † | YES |
Gold | PX Precinox S.A. | CH | *, † | YES |
Gold | Rand Refinery (Pty) Ltd. | ZA | *, † | YES |
Gold | Refinery of Seemine Gold Co., Ltd. | CN | NO | |
Gold | REMONDIS PMR B.V. | NL | † | YES |
Gold | Royal Canadian Mint | CA | *, † | YES |
Gold | SAAMP | FR | ‡, † | YES |
Gold | Sabin Metal Corp. | US | NO | |
Gold | Safimet S.p.A | IT | † | YES |
Gold | SAFINA A.S. | CZ | NO | |
Gold | Sai Refinery | IN | NO | |
Gold | Samduck Precious Metals | KR | † | YES |
Gold | SAMWON METALS Corp. | KR | NO | |
Gold | SAXONIA Edelmetalle GmbH | DE | † | YES |
Gold | SEMPSA Joyeria Plateria S.A. | ES | *, † | YES |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CN | NO | |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CN | *, † | YES |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CN | *, † | YES |
Gold | Singway Technology Co., Ltd. | TW | † | YES |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RU | *, † | YES |
Gold | Solar Applied Materials Technology Corp. | TW | *, † | YES |
Gold | State Research Institute Center for Physical Sciences and Technology | LT | NO | |
Gold | Sudan Gold Refinery | SD | NO | |
Gold | Sumitomo Metal Mining Co., Ltd. | JP | *, † | YES |
Gold | SungEel HiMetal Co., Ltd. | KR | † | YES |
Gold | T.C.A S.p.A | IT | *, † | YES |
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Gold | Tanaka Kikinzoku Kogyo K.K. | JP | *, † | YES |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CN | *, † | YES |
Gold | Tokuriki Honten Co., Ltd. | JP | *, † | YES |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CN | NO | |
Gold | Tony Goetz NV | BE | NO | |
Gold | TOO Tau-Ken-Altyn | KZ | NO | |
Gold | Torecom | KR | † | YES |
Gold | Umicore Brasil Ltda. | BR | *, † | YES |
Gold | Umicore Precious Metals Thailand | TH | ‡, † | YES |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BE | *, † | YES |
Gold | United Precious Metal Refining, Inc. | US | † | YES |
Gold | Universal Precious Metals Refining Zambia | ZM | NO | |
Gold | Valcambi S.A. | CH | *, ‡, † | YES |
Gold | Western Australian Mint (T/a The Perth Mint) | AU | *, † | YES |
Gold | WIELAND Edelmetalle GmbH | DE | † | YES |
Gold | Yamakin Co., Ltd. | JP | † | YES |
Gold | Yokohama Metal Co., Ltd. | JP | † | YES |
Gold | Yunnan Copper Industry Co., Ltd. | CN | NO | |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CN | *, † | YES |
Tantalum | Asaka Riken Co., Ltd. | JP | † | YES |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CN | † | YES |
Tantalum | D Block Metals, LLC | US | † | YES |
Tantalum | Exotech Inc. | US | † | YES |
Tantalum | F&X Electro-Materials Ltd. | CN | † | YES |
Tantalum | FIR Metals & Resource Ltd. | CN | † | YES |
Tantalum | Global Advanced Metals Aizu | JP | † | YES |
Tantalum | Global Advanced Metals Boyertown | US | † | YES |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CN | † | YES |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CN | † | YES |
Tantalum | H.C. Starck Co., Ltd. | TH | † | YES |
Tantalum | H.C. Starck Hermsdorf GmbH | DE | † | YES |
Tantalum | H.C. Starck Inc. | US | † | YES |
Tantalum | H.C. Starck Ltd. | JP | † | YES |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | DE | † | YES |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | DE | † | YES |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CN | † | YES |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CN | † | YES |
Tantalum | Jiangxi Tuohong New Raw Material | CN | † | YES |
Tantalum | Jiujiang Janny New Material Co., Ltd. | CN | † | YES |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CN | † | YES |
Tantalum | Jiujiang Tanbre Co., Ltd. | CN | † | YES |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CN | † | YES |
Tantalum | KEMET Blue Metals | MX | † | YES |
Tantalum | Kemet Blue Powder | US | † | YES |
Tantalum | LSM Brasil S.A. | BR | † | YES |
Tantalum | Metallurgical Products India Pvt., Ltd. | IN | † | YES |
Tantalum | Mineracao Taboca S.A. | BR | † | YES |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JP | † | YES |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CN | † | YES |
Tantalum | NPM Silmet AS | EE | † | YES |
Tantalum | Power Resources Ltd. | MK | † | YES |
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Tantalum | QuantumClean | US | † | YES |
Tantalum | Resind Industria e Comercio Ltda. | BR | † | YES |
Tantalum | Solikamsk Magnesium Works OAO | RU | † | YES |
Tantalum | Taki Chemical Co., Ltd. | JP | † | YES |
Tantalum | Telex Metals | US | † | YES |
Tantalum | Ulba Metallurgical Plant JSC | KZ | † | YES |
Tantalum | XinXing Haorong Electronic Material Co., Ltd. | CN | † | YES |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CN | † | YES |
Tin | Alpha | US | † | YES |
Tin | An Vinh Joint Stock Mineral Processing Company | VN | NO | |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CN | † | YES |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CN | † | YES |
Tin | China Tin Group Co., Ltd. | CN | † | YES |
Tin | CV Ayi Jaya | ID | † | YES |
Tin | CV Dua Sekawan | ID | † | YES |
Tin | CV Gita Pesona | ID | † | YES |
Tin | CV United Smelting | ID | † | YES |
Tin | CV Venus Inti Perkasa | ID | † | YES |
Tin | Dowa | JP | † | YES |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VN | NO | |
Tin | EM Vinto | BO | † | YES |
Tin | Estanho de Rondonia S.A. | BR | NO | |
Tin | Fenix Metals | PL | † | YES |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CN | † | YES |
Tin | Gejiu Kai Meng Industry and Trade LLC | CN | † | YES |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CN | † | YES |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CN | † | YES |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CN | † | YES |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CN | † | YES |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CN | † | YES |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CN | NO | |
Tin | Huichang Jinshunda Tin Co., Ltd. | CN | † | YES |
Tin | Jiangxi New Nanshan Technology Ltd. | CN | † | YES |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BR | † | YES |
Tin | Malaysia Smelting Corporation (MSC) | MY | † | YES |
Tin | Melt Metais e Ligas S.A. | BR | † | YES |
Tin | Metallic Resources, Inc. | US | † | YES |
Tin | Metallo Belgium N.V. | BE | † | YES |
Tin | Metallo Spain S.L.U. | ES | † | YES |
Tin | Mineracao Taboca S.A. | BR | † | YES |
Tin | Minsur | PE | † | YES |
Tin | Mitsubishi Materials Corporation | JP | † | YES |
Tin | Modeltech Sdn Bhd | MY | † | YES |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VN | NO | |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | TH | † | YES |
Tin | O.M. Manufacturing Philippines, Inc. | PH | † | YES |
Tin | Operaciones Metalurgical S.A. | BO | † | YES |
Tin | Pongpipat Company Limited | MM | NO | |
Tin | PT Aries Kencana Sejahtera | ID | † | YES |
Tin | PT Artha Cipta Langgeng | ID | † | YES |
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Tin | PT ATD Makmur Mandiri Jaya | ID | † | YES |
Tin | PT Babel Inti Perkasa | ID | † | YES |
Tin | PT Bangka Prima Tin | ID | † | YES |
Tin | PT Bangka Serumpun | ID | † | YES |
Tin | PT Bangka Tin Industry | ID | † | YES |
Tin | PT Belitung Industri Sejahtera | ID | † | YES |
Tin | PT Bukit Timah | ID | † | YES |
Tin | PT DS Jaya Abadi | ID | † | YES |
Tin | PT Inti Stania Prima | ID | † | YES |
Tin | PT Karimun Mining | ID | † | YES |
Tin | PT Kijang Jaya Mandiri | ID | † | YES |
Tin | PT Menara Cipta Mulia | ID | † | YES |
Tin | PT Mitra Stania Prima | ID | † | YES |
Tin | PT Panca Mega Persada | ID | † | YES |
Tin | PT Premium Tin Indonesia | ID | † | YES |
Tin | PT Prima Timah Utama | ID | † | YES |
Tin | PT Rajehan Ariq | ID | † | YES |
Tin | PT Refined Bangka Tin | ID | † | YES |
Tin | PT Sariwiguna Binasentosa | ID | † | YES |
Tin | PT Stanindo Inti Perkasa | ID | † | YES |
Tin | PT Sukses Inti Makmur | ID | † | YES |
Tin | PT Sumber Jaya Indah | ID | † | YES |
Tin | PT Timah (Persero) Tbk Kundur | ID | † | YES |
Tin | PT Timah (Persero) Tbk Mentok | ID | † | YES |
Tin | PT Tinindo Inter Nusa | ID | † | YES |
Tin | PT Tommy Utama | ID | † | YES |
Tin | Resind Industria e Comercio Ltda. | BR | † | YES |
Tin | Rui Da Hung | TW | † | YES |
Tin | Soft Metais Ltda. | BR | † | YES |
Tin | Super Ligas | BR | NO | |
Tin | Thaisarco | TH | † | YES |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VN | NO | |
Tin | White Solder Metalurgia e Mineracao Ltda. | BR | † | YES |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CN | † | YES |
Tin | Yunnan Tin Company Limited | CN | † | YES |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CN | † | YES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CN | † | YES |
Tungsten | Wolfram Bergbau und Hutten AG | AT | † | YES |
Tungsten | Xiamen Tungsten Co., Ltd. | CN | † | YES |
* | LBMA |
‡ | RJC |
† | RMAP |
** | RMAP - Active |
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Attachment B
Countries of Origin
The following table identifies the countries of origin of the smelters and refiners identified in Attachment A and is based on the smelters and refiners provided by our suppliers.
Argentina | Italy | Russian Federation |
Armenia | Ivory Coast | Rwanda |
Australia | Japan | Saudi Arabia |
Austria | Kazakhstan | Sierra Leone |
Bolivia | Korea, Republic of | Slovakia |
Brazil | Kyrgyzstan | South Africa |
Burundi | Laos | Spain |
Canada | Madagascar | Suriname |
Chile | Malaysia | Sweden |
China | Mali | Taiwan |
Colombia | Mexico | Tajikistan |
Congo (Brazzaville) | Mongolia | Tanzania |
DRC- Congo (Kinshasa) | Mozambique | Thailand |
Ecuador | Myanmar | Turkey |
Egypt | Namibia | Uganda |
Ethiopia | New Zealand | United Kingdom |
Finland | Niger | United States |
France | Nigeria | Uzbekistan |
Ghana | Papua New Guinea | Vietnam |
Guinea | Peru | Zambia |
Guyana | Philippines | Zimbabwe |
India | Poland | |
Indonesia | Portugal |
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