INTRODUCTION & SUMMARY
COMPANY OVERVIEW
This report has been prepared by the management of Lyft, Inc. (herein referred to as the “Lyft”, “Company”, “we”, “us”, or “our”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated.
Lyft is a ridesharing marketplace that connects drivers with riders via the Lyft mobile application in cities across the United States and in select cities in Canada. To complement its software offering, Lyft designs and contracts to manufacture equipment in Lyft’s micro-mobility network including bicycles, e-bicycles, scooters, bike stations, and vehicle accessories (Lyft Glow in-car emblem and Halo vehicle rooftop digital screens).
FORWARD LOOKING STATEMENTS
This Conflict Minerals Report contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lyft’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to conflict minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and Lyft assumes no obligation to update such statements.
INTRODUCTION
For the 2021 calendar year, Lyft determined that tin, tungsten, tantalum and/or gold (“3TGs”) were necessary to the functionality or production of products that were manufactured or contracted to be manufactured by Lyft. Therefore, Lyft conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs in Covered Products (as defined below) originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, Lyft believes that its Covered Products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), performed due diligence on the source and chain of custody of the 3TGs in question to determine whether its Covered Products are “DRC Conflict Free.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework in The Organization for Economic Co-Operation and Development
(“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).
Lyft is committed to upholding responsible sourcing practices. As such, the Company has implemented a Supplier Code of Conduct (the “Supplier Code”) to formalize its efforts to uphold human rights and responsible practices across the supply chain. Lyft’s Supplier Code encompasses regulatory, compliance, and ethical requirements and covers human rights and labor, health and safety, environmental, ethics (which covers responsible sourcing of minerals), and intellectual property categories and also provides for an audit, investigations and reporting mechanism.
CONFLICT MINERALS PROGRAM
Lyft’s requirement for responsible sourcing of minerals is incorporated into our Supplier Code, and is available online at https://www.lyft.com/suppliers/code-of-conduct. Lyft has adopted additional practices and procedures to implement the standard set forth in our Supplier Code, including pre-onboarding due diligence of higher-risk suppliers.
To determine Lyft’s products that may contain 3TGs, we screened our Enterprise Resource Planning (“ERP”) database for metal parts and printed circuit board assemblies (“PCBAs”). As required under the Rule, these are the products that Lyft manufactured or contracted others to manufacture and that are covered in this Report (collectively, the “Covered Products”).
REASONABLE COUNTRY OF ORIGIN INQUIRY
To determine whether necessary 3TGs in Covered Products originated in Covered Countries, Lyft contracted Assent, a third-party service provider, to assist us in reviewing the supply chain and identifying risks. We provided a list of suppliers and parts associated with the Covered Products to Assent for upload to the Assent Compliance Manager (“ACM”).
To collect data on the materials’ sources of origin procured by the supply chain, Lyft utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.10 to conduct a survey of all suppliers that provide Covered Products to Lyft since only those parts could contain 3TGs (“in-scope suppliers”).
During the supplier survey, we contacted suppliers via the ACM, a platform provided by Assent that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.
Via the ACM and Assent team, we requested that all in-scope suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency.
Our program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the suppliers who sell parts directly to Lyft (“Tier 1 suppliers”). The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.
All submitted forms are accepted and classified as valid or invalid so that data is retained. Invalid CMRTs include non-responsive, incomplete or contradicting answers. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Lyft tracks program gaps to account for future improvement opportunities. As of May 20, 2022, there were 0 invalid supplier submissions that could not be corrected.
As of May 20, 2022, there were 34 in-scope suppliers and 13 provided a completed CMRT. Lyft’s total response rate for this reporting year was 38%. These metrics are summarized in the table below:
| | | | | | | | | | | |
| Year | In Scope Suppliers | % of In-Scope Suppliers that Responded with Valid Submissions | % of In-Scope Suppliers that Provided Invalid Submissions |
| 2021 | 34 | 38% | 0% |
DESIGN OF DUE DILIGENCE
Lyft designed its due diligence measures to conform, in all material respects, with the framework
in the OECD Guidance. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to assess opportunities for improvement.
Due diligence requires our necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be controlled by Lyft. However, Lyft’s due diligence process, including the outreach and process validation conducted by Assent, conforms with the OECD’s guidance as it relates to Lyft’s position as a downstream purchaser.
DUE DILIGENCE PERFORMED
1)ESTABLISH STRONG COMPANY MANAGEMENT SYSTEMS
•Internal Compliance Team
Lyft established a cross-functional Conflict Minerals Compliance Team led by our Legal Team.
The Conflict Minerals Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.
Lyft also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company undertakes with suppliers in regards to conflict minerals.
We leverage Assent’s Managed Services in order to work with dedicated program specialists
who support Lyft’s conflict minerals program. We communicate regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team
is trained in conflict minerals compliance and the relevant OECD requirements, and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.
•Control Systems
Lyft expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Lyft are DRC Conflict Free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. The Company relies on direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.
Lyft’s Supplier Code applies to all direct suppliers and outlines certain expected behaviors and practices. The Supplier Code is based on industry and internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. Lyft’s Supplier Code is available on our website to all suppliers. We have the right to terminate relationships with the suppliers who do not meet Lyft’s requirements. The Supplier Code is reviewed regularly to ensure it continues to align with industry best practices.
•Supplier Engagement
Lyft has a strong relationship with Tier 1 suppliers. We have leveraged processes and educational opportunities to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. Lyft’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.
With respect to the OECD requirement to strengthen engagement with suppliers, we
have developed an internal procedure that includes steps of supplier engagement escalation including establishing a designated conflict mineral compliance communications channel, conflict mineral reporting questionnaire follow-up and in person meetings, as appropriate.
In addition, in our supplier contracts and in purchase orders, we require suppliers to comply with our Supplier Code, which includes an obligation to supply DRC Conflict-Free minerals. Acceptance of these terms is a condition of doing business with Lyft.
Lyft places a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to Assent’s library of conflict minerals training and support resources.
We believe that the combination of the Supplier Code and engagement with suppliers for conflict minerals training and requests constitute a strong supplier engagement program.
•Grievance Mechanisms
Lyft has established a mechanism whereby employees and suppliers can report violations of our policies, including with respect to conflict minerals. Suppliers and others outside of Lyft may contact Lyft’s Compliance team to report grievances or other issues by making a submission through Lyft’s Compliance & Ethics Hotline (the “Hotline”). A link to the Hotline is included in Lyft’s Supplier Code. The Hotline also includes toll-free telephone contact numbers and operators who speak the languages of the jurisdictions in which we operate.
Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (“RMI”) directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.
•Maintain Records
Lyft has adopted a policy to retain relevant conflict minerals documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. We store all of the information and findings from this process in a database that can be audited by internal or external parties.
2)IDENTIFY & ASSESS RISK IN THE SUPPLY CHAIN
Risks associated with supplier CMRT content are identified automatically in the ACM based on Assent’s acceptance criteria for a valid supplier response. These risks are addressed by Assent staff and members of Lyft’s internal Conflict Minerals Compliance Team, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at the company level. In those cases where a company-level CMRT (such as when a company declares there are 3TGs in some of its products) is submitted, we are unable to determine if all of the specified smelters and refiners were used for 3TGs in the products supplied to us.
Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2021 calendar year.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance such as the Responsible Minerals Assurance Process (“RMAP”). Lyft does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters that have completed an RMAP audit are considered to be DRC Conflict Free.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to redflag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
•Geographic proximity to the Covered Countries;
•Known mineral source country of origin;
•RMAP audit status;
•Credible evidence of unethical or conflict sourcing; and
•Peer assessments conducted by credible third-party sources.
Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent’s automated email receipts, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Lyft. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
3) DESIGN & IMPLEMENT A STRATEGY TO RESPOND TO RISKS
Together with Assent, Lyft has developed processes to assess and respond to the conflict minerals risk identified in the supply chain. Escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance with the conflict minerals rules and the Company’s expectations. Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs.
In cases where suppliers have been non-responsive or are not committed to corrective action plans, Lyft will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Compliance Team and Lyft’s Leadership Team to ensure transparency within the Company.
4)CARRY OUT INDEPENDENT THIRD-PARTY AUDIT OF SUPPLY CHAIN DUE DILIGENCE AT IDENTIFIED POINTS IN THE SUPPLY CHAIN
Lyft does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.
5)REPORT ANNUALLY ON SUPPLY CHAIN DUE DILIGENCE
Lyft has published the Form SD for the year ended December 31, 2021. This report is available on the Company’s website at https://investor.lyft.com/financials-and-reports/esg/default.aspx. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. Lyft has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission. This year we have also considered the impacts from the European Union Conflict Minerals Rule when disclosing details with regard to due diligence efforts. We will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public report.
•Due Diligence Results
Supply chain outreach is required to identify the upstream sources of origin of 3TGs. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Lyft for the 2021 reporting year.
•Supply Chain Outreach Metrics
| | | | | | | | |
| Number of In-Scope Suppliers | Response rate | Valid response Rate |
| 34 | 38% | 38% |
•Upstream Data Transparency
All smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which of Lyft’s product lines the materials may end up in. As a result, those providing the smelters and refiners may list all smelters and refiners they may purchase from within the reporting period. Therefore, the smelters or refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters or refiners which actually processed the 3TGs contained in our products.
Although the potential for over-reporting is understood, Lyft has taken measures to validate these sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners. From the gathered responses, 6 smelters out of 214 surveyed potentially posed a risk due to the presence of some red flag. 207 smelters were RMAP-conformant, 6 non-conformant, and 1 not enrolled into RMAP.
•Countries of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by Lyft, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.
•Risk Mitigation Plan
As of the date of this filing, Lyft has taken, or intends to take, the following steps to improve the due diligence conducted to further mitigate risk that the necessary 3TGs in the Company’s products could benefit armed groups in the Covered Countries:
•Through Assent, continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to using a comprehensive smelter and refiner library with detailed status and notes for each listing; scanning for credible information on each smelter and refiner to flag risk issues; and comparing the list of smelters and refiners against government watch and denied parties lists.
•Engage with suppliers more closely, and provide more information and training resources regarding responsible sourcing of 3TGs.
•Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
•Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.
•Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis.
APPENDIX A: SMELTER LIST
Includes: Mineral, smelter/refinery name, location
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | Smelter ID |
| Gold | 8853 S.p.A. | Italy | CID002763 |
| Gold | Advanced Chemical Company | U.S.A. | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 |
| Gold | Argor-Heraeus S.A. | Switzerland | CID000077 |
| Gold | Asahi Pretec Corp. | Japan | CID000082 |
| Gold | Asahi Refining Canada Ltd. | Canada | CID000924 |
| Gold | Asahi Refining USA Inc. | U.S.A. | CID000920 |
| Gold | Asaka Riken Co., Ltd. | Japan | CID000090 |
| Gold | Aurubis AG | Germany | CID000113 |
| Gold | Bangalore Refinery | India | CID002863 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 |
| Gold | Boliden AB | Sweden | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 |
| Gold | Cendres + Metaux S.A. | Switzerland | CID000189 |
| Gold | Chimet S.p.A. | Italy | CID000233 |
| Gold | Chugai Mining | Japan | CID000264 |
| Gold | Dowa | Japan | CID000401 |
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359 |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 |
| Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 |
| Gold | Geib Refining Corporation | U.S.A. | CID002459 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 |
| Gold | Heimerle + Meule GmbH | Germany | CID000694 |
| Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | CID000711 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 |
| Gold | Istanbul Gold Refinery | Turkey | CID000814 |
| Gold | Italpreziosi | Italy | CID002765 |
| | | | | | | | | | | |
| Gold | Japan Mint | Japan | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | China | CID000855 |
| Gold | JSC Uralelectromed | Russian Federation | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 |
| Gold | Kazzinc | Kazakhstan | CID000957 |
| Gold | Kennecott Utah Copper LLC | U.S.A. | CID000969 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 |
| Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 |
| Gold | L'Orfebre S.A. | Andorra | CID002762 |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078 |
| Gold | LT Metal Ltd. | Korea, Republic Of | CID000689 |
| Gold | Marsam Metals | Brazil | CID002606 |
| Gold | Materion | U.S.A. | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 |
| Gold | Metalor Technologies S.A. | Switzerland | CID001153 |
| Gold | Metalor USA Refining Corporation | U.S.A. | CID001157 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 |
| Gold | Mitsubishi Materials Corporation | Japan | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236 |
| Gold | Nihon Material Co., Ltd. | Japan | CID001259 |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 |
| Gold | OJSC Novosibirsk Refinery | Russian Federation | CID000493 |
| Gold | PAMP S.A. | Switzerland | CID001352 |
| Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 |
| Gold | PX Precinox S.A. | Switzerland | CID001498 |
| | | | | | | | | | | |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 |
| Gold | REMONDIS PMR B.V. | Netherlands | CID002582 |
| Gold | Royal Canadian Mint | Canada | CID001534 |
| Gold | SAAMP | France | CID002761 |
| Gold | Safimet S.p.A | Italy | CID002973 |
| Gold | SAFINA A.S. | Czechia | CID002290 |
| Gold | Samduck Precious Metals | Korea, Republic Of | CID001555 |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918 |
| Gold | T.C.A S.p.A | Italy | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615 |
| Gold | Torecom | Korea, Republic Of | CID001955 |
| Gold | Umicore Precious Metals Thailand | Thailand | CID002314 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 |
| Gold | United Precious Metal Refining, Inc. | U.S.A. | CID001993 |
| Gold | Valcambi S.A. | Switzerland | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 |
| Gold | Yamakin Co., Ltd. | Japan | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | CID000211 |
| Tantalum | D Block Metals, LLC | U.S.A. | CID002504 |
| Tantalum | F&X Electro-Materials Ltd. | China | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | China | CID002505 |
| Tantalum | Global Advanced Metals Aizu | Japan | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | U.S.A. | CID002557 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | CID000616 |
| Tantalum | H.C. Starck Co., Ltd. | Thailand | CID002544 |
| | | | | | | | | | | |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | CID002547 |
| Tantalum | H.C. Starck Inc. | U.S.A. | CID002548 |
| Tantalum | H.C. Starck Ltd. | Japan | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | CID002550 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 |
| Tantalum | KEMET Blue Metals | Mexico | CID002539 |
| Tantalum | LSM Brasil S.A. | Brazil | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 |
| Tantalum | Mineracao Taboca S.A. | Brazil | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 |
| Tantalum | NPM Silmet AS | Estonia | CID001200 |
| Tantalum | QuantumClean | U.S.A. | CID001508 |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707 |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 |
| Tantalum | Telex Metals | U.S.A. | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 |
| Tin | Alpha | U.S.A. | CID000292 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 |
| Tin | China Tin Group Co., Ltd. | China | CID001070 |
| Tin | Dowa | Japan | CID000402 |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 |
| Tin | Fenix Metals | Poland | CID000468 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | CID003379 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 |
| Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 |
| Tin | Metallic Resources, Inc. | U.S.A. | CID001142 |
| | | | | | | | | | | |
| Tin | Metallo Belgium N.V. | Belgium | CID002773 |
| Tin | Metallo Spain S.L.U. | Spain | CID002774 |
| Tin | Mineracao Taboca S.A. | Brazil | CID001173 |
| Tin | Minsur | Peru | CID001182 |
| Tin | Mitsubishi Materials Corporation | Japan | CID001191 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337 |
| Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 |
| Tin | PT Menara Cipta Mulia | Indonesia | CID002835 |
| Tin | PT Mitra Stania Prima | Indonesia | CID001453 |
| Tin | PT Prima Timah Utama | Indonesia | CID001458 |
| Tin | PT Refined Bangka Tin | Indonesia | CID001460 |
| Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 |
| Tin | PT Timah Tbk Kundur | Indonesia | CID001477 |
| Tin | PT Timah Tbk Mentok | Indonesia | CID001482 |
| Tin | PT Tinindo Inter Nusa | Indonesia | CID001490 |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 |
| Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 |
| Tin | Soft Metais Ltda. | Brazil | CID001758 |
| Tin | Thaisarco | Thailand | CID001898 |
| Tin | Tin Technology & Refining | U.S.A. | CID003325 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 |
| Tin | Yunnan Tin Company Limited | China | CID002180 |
| Tungsten | A.L.M.T. Corp. | Japan | CID000004 |
| Tungsten | ACL Metais Eireli | Brazil | CID002833 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | CID002645 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 |
| Tungsten | Global Tungsten & Powders Corp. | U.S.A. | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | CID000769 |
| | | | | | | | | | | |
| Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 |
| Tungsten | Kennametal Fallon | U.S.A. | CID000966 |
| Tungsten | Kennametal Huntsville | U.S.A. | CID000105 |
| Tungsten | KGETS Co., Ltd. | Korea, Republic Of | CID003388 |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | CID003407 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | CID002543 |
| Tungsten | Moliren Ltd. | Russian Federation | CID002845 |
| Tungsten | Niagara Refining LLC | U.S.A. | CID002589 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 |
| Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | CID002830 |
APPENDIX B: COUNTRIES OF ORIGIN
Includes: List of countries that declared smelters are known to source from.
| | |
| Country List |
| Afghanistan |
| Åland Islands |
| Albania |
| American Samoa |
| Andorra |
| Angola |
| Argentina |
| Armenia |
| Australia |
| Austria |
| Belarus |
| Belgium |
| Bermuda |
| Bolivia (Plurinational State of) |
| Brazil |
| Bulgaria |
| Burundi |
| Cambodia |
| Canada |
| Central African Republic |
| Chile |
| China |
| Colombia |
| Congo |
| Democratic Republic of Congo |
| Djibouti |
| Dominica |
| Dominican Republic |
| Ecuador |
| Egypt |
| Eritrea |
| Estonia |
| Ethiopia |
| Finland |
| France |
| Germany |
| Ghana |
| Guinea |
| Guyana |
| Hong Kong |
| Hungary |
| | |
| India |
| Indonesia |
| Ireland |
| Israel |
| Italy |
| Japan |
| Kazakhstan |
| Kenya |
| Korea |
| Kyrgyzstan |
| Liberia |
| Luxembourg |
| Madagascar |
| Malaysia |
| Mali |
| Mauritania |
| Mexico |
| Mongolia |
| Morocco |
| Mozambique |
| Myanmar |
| Namibia |
| Netherlands |
| New Zealand |
| Niger |
| Nigeria |
| Panama |
| Papua New Guinea |
| Peru |
| Philippines |
| Poland |
| Portugal |
| Russian Federation |
| Rwanda |
| Saudi Arabia |
| Sierra Leone |
| Singapore |
| Slovakia |
| Slovenia |
| South Africa |
| South Sudan |
| Spain |
| Sudan |
| Suriname |
| Sweden |
| | |
| Switzerland |
| Taiwan |
| Tajikistan |
| Tanzania |
| Thailand |
| Turkey |
| Uganda |
| United Arab Emirates |
| United Kingdom |
| United States |
| Uzbekistan |
| Viet Nam |
| Zambia |
| Zimbabwe |
