Exhibit 1.01
Corning Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2020
This Conflict Minerals Report (CMR) for the year ended December 31, 2020 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (3TG).
This report is available on the Investor Relations page of Corning’s website (see http://www.corning.com/investor_relations/index.aspx and click on “View All Filings”).
| 1. | Company Overview |
This report has been prepared by management of Corning Incorporated (herein referred to as “Corning,” the “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 in accordance with US Generally Accepted Accounting Principles. It does not include the activities of subsidiaries or variable interest entities that are not required to be consolidated.
Corning is a world leader in the manufacture of specialty glass and ceramics. Drawing on nearly 170 years of materials science and process engineering knowledge, Corning creates and makes keystone components that enable high-technology systems for consumer electronics, mobile emissions control, telecommunications and life sciences. Corning operates in five reportable segments: Display Technologies, Optical Communications, Environmental Technologies, Specialty Materials and Life Sciences. Corning manufactures products at 122 plants in 15 countries.
| 2. | Products Overview |
Corning’s principal products, by segment, are as follows:
Corning’s Display Technologies segment manufactures glass substrates for flat panel displays, including liquid crystal displays (LCDs) and organic light-emitting diode (OLEDs) that are used primarily in televisions, notebook computers, desktop monitors, tablets and handheld devices.
Corning’s Optical Communications segment is classified into two main product groupings – carrier network and enterprise network. The carrier network product group consists primarily of products and solutions for optical-based communications infrastructure for services such as video, data and voice communications. The enterprise network product group consists primarily of optical-based communication networks sold to businesses, governments and individuals for their own use.
Corning’s Environmental Technologies segment manufactures ceramic substrates and filter products for emissions control in mobile applications around the world.
The Specialty Materials segment manufactures products that provide more than 150 material formulations for glass, glass ceramics and crystals, as well as precision metrology instruments and software to meet requirements for unique customer needs. Consequently, this segment operates in a wide variety of commercial and industrial markets that include materials optimized for mobile consumer electronics, semiconductor equipment optics and consumables, aerospace and defense optics, radiation shielding products, sunglasses, and telecommunications components.
Corning’s Life Sciences segment is a leading developer, manufacturer and global supplier of laboratory products, including consumables, such as plastic vessels, liquid handling plastics, specialty surfaces, cell culture media and serum, as well as general labware and equipment.
All other segments at Corning that do not meet the quantitative threshold for separate reporting have been grouped as “All Other.” This group is primarily comprised of the results of the pharmaceutical technologies business, auto glass, new product lines and development projects, as well as other businesses and certain corporate investments. The Company obtained a controlling interest in Hemlock Semiconductor Group (“HSG”) during the third quarter of 2020 and has consolidated results in “All Other” as of September 9, 2020.
| 3. | Supply Chain Overview |
Corning maintains complex and diverse supply chains across its reported segments, involving thousands of suppliers to the Company. We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three years or more and we cannot unilaterally impose new contract terms and flow-down requirements. Corning has incorporated a clause to relevant agreements that requires suppliers to provide information about the source of conflict minerals and smelters. Based upon these contractual requirements and our supplier relationships, we work annually with selected suppliers to ensure they provide us the 3TG sourcing information required.
Based upon technical knowledge regarding our products, as well as the results of the prior supplier surveys regarding conflict minerals, relevant personnel in each of our reported segments identified the suppliers to survey regarding whether the components or materials supplied to Corning by such suppliers contain 3TG. We relied upon these suppliers, approximately 163 in total, to provide us with information about whether the components or materials supplied to Corning contain 3TG; and if so, the source of such 3TG. Our direct suppliers are similarly reliant upon information provided by their suppliers, or in the case of distributors from whom we purchase components or materials, reliant upon the manufacturers of such items. Many of our larger suppliers are also SEC registrants and subject to the Rule.
| 4. | Reasonable Country of Origin Inquiry (RCOI) and RCOI Conclusion | |
| 4.1 | Requests for Information | |
| We surveyed those suppliers described above using version 6.01 of the conflict minerals reporting template developed by the Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Responsible Minerals Initiative (“RMI”) Reporting Template (or the “CMRT”). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on Responsible Business Alliance’s website. The CMRT is being used by many companies in their due diligence processes related to 3TG. | ||
| To determine whether any 3TG necessary to our products originated in the Covered Countries, we retained a third-party service provider, Assent Compliance (“Assent”) to assist us in surveying our supply chain. During our supplier survey, we contacted suppliers via the Assent Compliance Manager (“ACM”), a SaaS platform provided by Assent that enables its users to complete and track supplier communications as well as allows suppliers to upload completed CMRTs directly to the platform for assessment and management. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question one of the CMRT asks suppliers whether any 3TGs are necessary to the functionality or production of their products. We also reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process (e.g., the removal of suppliers who provided only packaging to Corning). | ||
| Assent requested that all in-scope suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of the template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Corning directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that such suppliers complete and submit the CMRT to Assent. | ||
| 4.2 | Survey Responses | |
Where the CMRT responses included the names of entities listed by our suppliers as smelters or refiners, we consulted the RMI publicly-available information to determine whether such entities had been identified as certified Conflict-Free. In some cases, the CMRT responses did not provide smelter information; this was one of the items that we typically requested in follow-up communications with suppliers. Ultimately, some suppliers were unable to provide us with smelter information because they were engaged in their own efforts to obtain that information from their suppliers. Through Assent’s platform automated data validation was performed 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 logical sequencing and required correlations between the CMRT questions (for example, if a supplier does not report having received information from 100% of its 3TG sources, it cannot logically offer definitive statements in response to certain other questions). All submitted CMRTs are first accepted and then classified as valid or invalid so that their data is still retained. Suppliers are contacted in regard to invalid forms and are encouraged to resubmit a valid form. As of May 10, 2021, there were four (4) invalid supplier submissions in Corning’s supplier survey that could not be corrected. Many of the responses we received provided data at a company or divisional level or, as described above, were unable to specify with certainty all of the smelters or refiners used for components supplied to Corning. In some instances, we engaged in follow-up communications with suppliers to request that they provide a CMRT response specific to the components or materials supplied to Corning; however, in many cases, the suppliers were unable to do so because they were unable to obtain detailed information from their own suppliers. | ||
| 4.3 | RCOI Conclusion | |
Based upon the results of our RCOI, we were able to determine that no 3TGs are contained in the products sold by Corning’s Environmental Technologies segment. In Corning’s Display Technologies segment, our RCOI determined that tin contained in the products sold by this segment is sourced from the Covered Countries, but only from RMI compliant smelters. For Corning’s Optical Communications, Specialty Materials, and Life Sciences segments, we were unable to conclusively determine whether the 3TG in the products for such segments originated in the Covered Countries because of the incomplete information received from our supply chain. Based on RCOI responses we have received from certain suppliers, we believe that certain of the 3TG contained in the products for our Optical Communications, Specialty Materials, and/or Life Sciences segments may have originated in the Democratic Republic of the Congo or an adjoining country (the Covered Countries). Thus, we are required under the Rule to conduct due diligence on the source and chain of custody of those minerals as well as those in the supply chain for our Display Technologies segment and submit to the SEC a Conflict Minerals Report as an Exhibit to Form SD. | ||
5. | Due Diligence Program | |
5.1 | Design of Due Diligence | |
Our due diligence measures have been designed to conform, in all material respects, with the 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, Second Edition, 2013 (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely: | ||
| 1. | Establishing strong company management systems regarding conflict minerals; |
| 2. | Identifying and assessing risks in our supply chain; | |
| 3. | Designing and implementing a strategy to respond to identified risks in our supply chain; | |
| 4. | Utilizing independent third-party audits of supply chain diligence; and | |
| 5. | Publicly reporting on our supply chain due diligence |
We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, we do not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries directly. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure. | |||
| 5.2 | Establish Strong Company Management Systems | ||
| 5.2.1 | Conflict Minerals Policy | ||
We have adopted the following revised conflict minerals policy, effective March 2019: Background on Conflict Minerals Conflict minerals refer to the mineral precursors of the metals tantalum, tin, tungsten, and gold (3TG), which are found in small amounts in virtually all electronic products. Revenue from mining these minerals in the Democratic Republic of Congo (DRC) and nine neighboring countries has been linked to funding for groups engaged in extreme violence and human rights atrocities. Pursuant to the Dodd–Frank Wall Street Reform and Consumer Protection Act, public companies in the US that make products for which 3TG metals (tantalum, tin, tungsten & gold) are necessary to the functionality or production of that product are required to assess their supply chains and report on the source of these materials. Corning Incorporated (“Corning”) is a public company, and therefore is committed to complying with this law. Corning Incorporated’s Corporate Position on Conflict Minerals At Corning, corporate social responsibility is a proactive commitment to preserving the trust of our stakeholders. The commitment contributes to sustainable economic and environmental development through all our business activities – how we operate, what we sell, how we give, and how we support our people, the communities in which we operate, and society at large. Any connection between the materials used in Corning products and armed violence or human rights abuses is unacceptable. Corporate social responsibility is intrinsic to Corning’s heritage and it is integral to how we build value and trust in our company. It is also a demonstration of how we live our Values which represent the unchanging moral and ethical compass that guides everything we do. More information about Sustainability at Corning can be found here. The 3TG supply chain is complex, typically including many stages between Corning and the smelters that purchase and process the ore into metals. The greatest risk of conflict minerals entering our supply chain is through these smelters’ ore purchasing practices. We require our suppliers to source 3TG for Corning products only from smelters that comply with the Responsible Minerals Initiative 's (RMI, formerly the Conflict Free Sourcing Initiative) Responsible Minerals Assurance Process (RMAP, formerly the Conflict-Free Smelter Program), which requires a third-party sourcing audit. To monitor 3TG suppliers’ performance, we assess their responses to the RMI’s Conflict Minerals Reporting Template, and request corrective action where needed, including the removal from our supply chain of smelters that pose a risk. | |||
More information about the Responsible Minerals Initiative can be found here. Our due diligence measures implemented as part of our conflict minerals program have been designed to conform, in all material respects, with the 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. Corning requires our suppliers to comply with our requests to provide complete and accurate Conflict Minerals Reporting Templates, and to perform further due diligence as required about the source of any conflict minerals in their products which are provided to us in order to ensure alignment throughout the supply chain. Failure to provide this information to Corning when requested may result in removal from active status as a Corning supplier. Our conflict minerals policy is publicly available on our website at the following link: |
| 5.2.2 | Internal Team | ||
Corning has established a cross-functional Conflict Minerals Compliance Team for managing our conflict minerals program. Our Conflict Minerals Compliance Team includes a steering team sponsored by the Senior Vice President, Global Supply Chain as well as executive-level representatives from the company’s finance and legal functions. Reporting to the steering team is a core working team, which is led by our Global Supply Management organization. This core team, which includes subject matter experts from relevant functions such as finance, legal, and global supply management, is responsible for implementing our conflict minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on an annual basis. Corning also uses a third-party service provider, Assent, to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers regarding conflict minerals. Corning leverages Assent’s Managed Services in order to work with dedicated program specialists who support Corning’s conflict minerals program. Corning communicates 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 understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act. | |||
| 5.2.3 | Control Systems | ||
As we do not typically have a direct relationship with 3TG smelters and refiners, we have relied upon industry-wide initiatives to disclose upstream actors in the supply chain. Specifically, as part of our due diligence efforts we have utilized the smelter information provided by the Responsible Minerals Initiative. In addition, with the assistance of personnel from Corning’s accounting, compliance and reporting function, we previously developed a detailed risk control matrix through which Corning’s conflict minerals program can be evaluated and monitored. | |||
| 5.2.4 | Supplier Engagement | ||
With respect to the OECD requirement to strengthen engagement with suppliers, we have added a conflict minerals clause to our purchase order terms and conditions and relevant contract templates in order to communicate to suppliers our expectations and requirements regarding the sourcing of and disclosure of conflict minerals. We also include our Supplier Code of Conduct in our supplier contracts, which contains Corning’s expectations for suppliers with respect to humane labor conditions, health and safety, and environmental factors, among others. Further, Corning’s suppliers are required to flow down these expectations from Corning’s Supplier Code of Conduct to their own supply chains. | |||
A copy of our Supplier Code of Conduct is available at http://www.corning.com/worldwide/en/sustainability/articles/processes/supply-chain-management/supplier-code-of-conduct.html. |
| 5.2.5 | Grievance Mechanism | ||
Corning’s Supplier Code of Conduct, referenced in 5.2.4 above, instructs suppliers that questions or concerns may be submitted to Corning’s third-party telephone and web hotline service. This hotline is also described in Corning’s Code of Conduct, as referenced above. These phone or web services can be used to make an anonymous report and are available on a 24/7 basis. Corning maintains a robust internal compliance and ethics program under the oversight of a Vice President and Chief Compliance Officer to ensure that all such reports are properly investigated, reported and remediated as required. Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. |
| 5.2.6 | Maintain Records | ||
Corning has an existing document retention policy which governs the retention of documentation relevant to our due diligence efforts. We also implemented a document retention policy through Assent to retain conflict minerals related documents, including supplier responses to CMRTs. Assent stores all of the information and findings from this process in a database that can be audited by internal or external parties. | |||
| 5.3 | Identify and Assess Risks in the Supply Chain | ||
Because of our size, the complexity of our products, and the depth and breadth of our supply chain, it is difficult to identify actors upstream from our direct suppliers. One method for identifying risks in our supply chain is through automatic checks in the ACM system based on criteria established by Assent for supplier responses as outlined above. Another method Corning uses specifically for minerals supply chain risk management is an internal risk mapping of all mineral suppliers to Corning based on four criteria (supplier reputation, material risk, country risk, and sustainability compliance). More generally, Corning monitors risk across all of its suppliers using a third-party tool, riskmethods, and its standard set of 49 risk indicators. In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters or refiners not being certified DRC-Conflict Free pose a significant risk to the supply chain. Certain of the responses provided by our suppliers via the CMRT included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by RMI. As of May 10, 2021, of the 333 legitimate smelters and refiners identified by our suppliers, we have validated 237 smelters or refiners as Responsible Minerals Assurance Process (“RMAP”) conformant. Due to the provision of a mix of company-level, product-level and user defined CMRTs, we cannot definitively determine the connection of any smelters or refiners listed in them to our in-scope products. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent determines the level of risk that each smelter poses to the supply chain by identifying the following red flags: | |||
| ● | Geographic proximity to the DRC and Covered Countries; |
| ● | Responsible Minerals Assurance Process (RMAP) audit status; |
| ● | Credible evidence of unethical or conflict sourcing; |
| ● | Known mineral source country of origin; and |
| ● | Peer Assessments conducted by credible third-party sources. |
Based on these criteria the following facilities have been identified as being of highest concern to the supply chain: |
| ● | Tony Goetz NV - CID002587 |
| ● | Kaloti Precious Metals - CID002563 |
| ● | African Gold Refinery Limited - CID003185 |
| ● | Fidelity Printers and Refiners Ltd. - CID002515 |
| ● | Sudan Gold Refinery - CID002567 |
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers we surveyed, risk mitigation activities were initiated. Through our third-party vendor, Assent Compliance, submissions that included any of the above facilities immediately produced a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Corning, and escalating up to removal of these high-risk smelters from their supply chain. As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain. Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT: A. Have you established a conflict minerals sourcing policy? When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. At this time, eight (8) of our responsive suppliers have been identified as having a weak program. | ||
| 5.4 | Design and Implement a Strategy to Respond to Risks | |
Corning has developed processes to assess and respond to the risks identified in the supply chain. Corning has a responsible minerals sourcing program through which its conflict minerals program is implemented, managed and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and Corning’s expectations. As described in our conflict minerals policy, we intend to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to appropriately address the situation, which may include establishing an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. The result and timing will depend upon factors such as the criticality of the specific part and the availability of alternate suppliers. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, Corning 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 the leadership of Corning’s Global Supply Management function to ensure transparency within the company. | ||
As of the date of this filing, we have found no instances where it was necessary to terminate a contract or find a replacement supplier due to 3TG sourced from the Covered Countries. | |||
| 5.5 | Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain | ||
Corning does not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities within our supply chain. However, we do rely 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. In early 2020, Corning became a member of the Responsible Minerals Initiative, enabling us to expand our industry collaborative efforts through RMI membership and to utilize RMI’s flagship Responsible Minerals Assurance Process (RMAP) through our supply chain as described above. Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. Corning is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance. Through the company’s membership with the RMI, smelters or refiners have been encouraged to participate in the RMAP. Any smelters or refiners that were reported by suppliers who were not part of the RMAP were also contacted directly by Assent to encourage them to participate in the RMAP. | |||
| 5.6 | Report on Supply Chain Due Diligence | ||
In addition to this report, see our website at http://www.corning.com/worldwide/en/about-us/suppliers.html for further information about Corning’s commercial relationships with and expectations of its suppliers. | |||
| 5.6.1 | Due Diligence Process | ||
Corning conducted a survey of its relevant suppliers (as described above) using the template originally developed jointly by the Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Responsible Minerals Initiative Reporting Template (the “CMRT”). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on RMI’s website and via the website of Assent Compliance, our third-party provider. | |||
| 5.6.2 | Survey Responses | ||
Corning surveyed approximately 163 suppliers based upon the likelihood that such suppliers supplied materials or components to Corning that contained one or more 3TG, and we received responses from 99% of the suppliers we surveyed. Corning’s response rate for 2020 was approximately 24% higher than the previous year. A total of six (6) suppliers indicated in their survey responses that they sourced 3TG from the Covered Countries, but those 3TG were “conflict free.” Nineteen (19) of the suppliers surveyed stated that the 3TG they sourced came from outside of the Covered Countries, and 22 suppliers reported as “undeterminable” in regard to sourcing 3TGs from the Covered Countries. | |||
| 5.6.3 | Efforts to Determine Country of Origin of Mine or 3TG | ||
We have determined that seeking information about 3TG smelters and refiners in our supply chain through the use of the CMRT with our relevant suppliers represents the most reasonable effort we are able to make to determine the mines or locations of origin of the 3TG in our supply chain. | |||
| 5.6.4 | Efforts to Identify Smelters or Refiners | ||
Because of the incomplete information provided to us by our suppliers in response to our surveys, or the receipt of company-level responses that do not provide information specific to materials or components supplied to Corning, in many cases the smelters and refiners we have identified to date cannot be tied to specific Corning products. However, in certain instances, our suppliers did provide CMRTs specific to the products supplied to Corning. We have reported all legitimate smelter or refiner information included in the CMRTs we received on Appendix A to this report, recognizing as stated above that not all such smelters or refiners can definitively be tied to Corning products. Of the 333 legitimate smelters identified on the CMRTs we received, as of May 10, 2021 237 were identified as RMAP Conformant and 23 were actively working toward a “conflict free” designation. As noted, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that processed the conflict minerals actually contained in our products. | |||
| 5.6.5 | Countries of Origin | ||
Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI. As mentioned in the above section, many responses were provided at the company level, therefore, Appendix B may contain more countries than those that the conflict minerals used in our products are sourced from. | |||
| 6. | Steps to be taken to mitigate risk | ||
We have taken and/or intend to continue to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries: | |||
| A. | Include a conflict minerals flow-down clause in relevant new or renewed supplier contracts. | ||
| B. | Include a step to our new supplier enrollment process to directly identify new suppliers who could potentially supply Corning with products or materials containing 3TG. | ||
| C. | Partner with a third-party company, Assent Compliance, which specializes in conducting conflict minerals compliance programs, to improve the accuracy and efficiency of our supplier survey and reporting process. | ||
| D. | Engage with suppliers to attempt to increase the response rate and improve the content of the supplier survey responses. | ||
| E. | Engage any of our suppliers found to be supplying us with 3TG from sources that support conflict in the DRC or any adjoining country to address the situation, which will include establishing an alternative source of 3TG that does not support such conflict, with timing depending on factors such as the criticality of the specific part and the availability of alternate suppliers. | ||
| F. | Maintain Corning’s membership in the Responsible Minerals Initiative, enabling us to expand our industry collaborative efforts through RMI membership and to utilize RMI’s flagship Responsible Minerals Assurance Process (RMAP) through our supply chain. |
FORWARD-LOOKING STATEMENTS
The statements in this Form SD and related comments by management that are not historical facts or information and contain words such as “will,” “believe,” “anticipate,” “expect,” “intend,” “plan,” “seek,” “see,” “would,” and “target” and similar expressions are forward-looking statements. Such statements relate to future events that by their nature address matters that are, to different degrees, uncertain. These forward-looking statements relate to, among other things, the company’s future operating performance, the company's share of new and existing markets, the company's revenue and earnings growth rates, the company’s ability to innovate and commercialize new products, and the company’s implementation of cost-reduction initiatives and measures to improve pricing, including the optimization of the company’s manufacturing capacity.
Appendix A
RMI Smelter List1
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | 8853 S.p.A. | ITALY | CID002763 | Conformant | Yes | Unknown |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 | Non Conformant | Unknown | Unknown |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 | Conformant | Yes | No |
| Gold | African Gold Refinery | UGANDA | CID003185 | Outreach Required | Unknown | Unknown |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | Conformant | Yes | No |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | Conformant | Yes | Yes |
| Gold | Alexy Metals | UNITED STATES OF AMERICA | CID003500 | Active | Unknown | Unknown |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | Conformant | Yes | Unknown |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | Conformant | Yes | Unknown |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 | Conformant | Yes | Unknown |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Conformant | Yes | Unknown |
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 | Conformant | Yes | Unknown |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Conformant | Yes | Unknown |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | Conformant | Yes | Unknown |
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | Conformant | Yes | No |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | Due Diligence Vetting Process | Unknown | Unknown |
| Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | Conformant | Yes | Unknown |
| Gold | Augmont Enterprises Private Limited | INDIA | CID003461 | Active | Unknown | Unknown |
| Gold | Aurubis AG | GERMANY | CID000113 | Conformant | Yes | Unknown |
| Gold | Bangalore Refinery | INDIA | CID002863 | Conformant | Yes | No |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Conformant | Yes | Unknown |
| Gold | Boliden AB | SWEDEN | CID000157 | Conformant | Yes | Unknown |
1 This Exhibit contains all legitimate smelter or refiner information we received on the CMRTs provided by our suppliers in response to our survey requests. Because these CMRTs in some instances contained incomplete information, or were not specific to the products supplied to Corning, many of these smelters and refiners cannot be tied to specific Corning products.
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Conformant | Yes | Unknown |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | CID003421 | Active | Unknown | Unknown |
| Gold | Caridad | MEXICO | CID000180 | Communication Suspended - Not Interested | Unknown | Unknown |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Conformant | Yes | Unknown |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 | Conformant | Yes | Unknown |
| Gold | CGR Metalloys Pvt Ltd. | INDIA | CID003382 | Outreach Required | Unknown | Unknown |
| Gold | Chimet S.p.A. | ITALY | CID000233 | Conformant | Yes | Unknown |
| Gold | Chugai Mining | JAPAN | CID000264 | Conformant | Yes | No |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | In Communication | Unknown | Unknown |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | Outreach Required | Unknown | Unknown |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 | In Communication | Unknown | Unknown |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 | Conformant | Yes | No |
| Gold | Dowa | JAPAN | CID000401 | Conformant | Yes | No |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 | Conformant | Yes | No |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | Conformant | Yes | No |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 | Conformant | Yes | No |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 | Conformant | Yes | No |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 | Conformant | Yes | No |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | CID003487 | In Communication | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | CID003488 | In Communication | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | CID003489 | In Communication | Unknown | Unknown |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | CID003490 | In Communication | Unknown | Unknown |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | Conformant | Yes | Yes |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | RMI Due Diligence Review - Unable to Proceed | Unknown | Unknown |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 | Outreach Required | Unknown | Unknown |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 | In Communication | Unknown | Unknown |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 | Conformant | Yes | No |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | Gold Coast Refinery | GHANA | CID003186 | Outreach Required | Unknown | Unknown |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | Conformant | Yes | Unknown |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | Outreach Required | Unknown | Unknown |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | Outreach Required | Unknown | Unknown |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | Outreach Required | Unknown | Unknown |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | Outreach Required | Unknown | Unknown |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | Conformant | Yes | Unknown |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | Conformant | Yes | Unknown |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | Active | Unknown | Unknown |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | Outreach Required | Unknown | Unknown |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 | Outreach Required | Unknown | Unknown |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 | Communication Suspended - Not Interested | Unknown | Unknown |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Conformant | Yes | Unknown |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 | Active | Unknown | Unknown |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Conformant | Yes | Unknown |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Conformant | Yes | Unknown |
| Gold | Italpreziosi | ITALY | CID002765 | Conformant | Yes | Unknown |
| Gold | JALAN & Company | INDIA | CID002893 | Outreach Required | Unknown | Unknown |
| Gold | Japan Mint | JAPAN | CID000823 | Conformant | Yes | Unknown |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Conformant | Yes | Unknown |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | RMI Due Diligence Review - Unable to Proceed | Unknown | Unknown |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Conformant | Yes | Unknown |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Conformant | Yes | Unknown |
| Gold | K.A. Rasmussen | NORWAY | CID003497 | Outreach Required | Unknown | Unknown |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | RMI Due Diligence Review - Unable to Proceed | Unknown | Unknown |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | In Communication | Unknown | Unknown |
| Gold | Kazzinc | KAZAKHSTAN | CID000957 | Conformant | Yes | Unknown |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | Conformant | Yes | Unknown |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | Conformant | Yes | Unknown |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | Conformant | Yes | No |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | Conformant | Yes | No |
| Gold | Kundan Care Products Ltd. | INDIA | CID003463 | In Communication | Unknown | Unknown |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Conformant | Yes | Unknown |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 | Outreach Required | Unknown | Unknown |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 | RMI Due Diligence Review - Unable to Proceed | Unknown | Unknown |
| Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | Outreach Required | Unknown | Unknown |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | Outreach Required | Unknown | Unknown |
| Gold | L'Orfebre S.A. | ANDORRA | CID002762 | Conformant | Yes | Yes |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Conformant | Yes | Unknown |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 | Conformant | Yes | No |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | Outreach Required | Unknown | Unknown |
| Gold | Marsam Metals | BRAZIL | CID002606 | Conformant | Yes | No |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 | Conformant | Yes | No |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Conformant | Yes | Unknown |
| Gold | MD Overseas | INDIA | CID003548 | In Communication | Unknown | Unknown |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 | Conformant | Yes | Unknown |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | CID003557 | Active | Unknown | Unknown |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Conformant | Yes | Unknown |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Conformant | Yes | Unknown |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | Conformant | Yes | Unknown |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Conformant | Yes | Unknown |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 | Conformant | Yes | Unknown |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 | Conformant | Yes | Unknown |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Conformant | Yes | Unknown |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Conformant | Yes | Unknown |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Conformant | Yes | Unknown |
| Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Non Conformant | Unknown | Unknown |
| Gold | Morris and Watson | NEW ZEALAND | CID002282 | Communication Suspended - Not Interested | Unknown | Unknown |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Conformant | Yes | Unknown |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | Conformant | Yes | Unknown |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | Conformant | Yes | Unknown |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | Non Conformant | Unknown | Unknown |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Conformant | Yes | Unknown |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Conformant | Yes | Unknown |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | Conformant | Yes | No |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | Conformant | Yes | Unknown |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Conformant | Yes | Unknown |
| Gold | PAMP S.A. | SWITZERLAND | CID001352 | Conformant | Yes | Unknown |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 | Outreach Required | Unknown | Unknown |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | Outreach Required | Unknown | Unknown |
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 | Conformant | Yes | No |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Conformant | Yes | Unknown |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Conformant | Yes | Unknown |
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | Conformant | Yes | Unknown |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 | Outreach Required | Unknown | Unknown |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Conformant | Yes | Unknown |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 | Outreach Required | Unknown | Unknown |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 | Conformant | Yes | No |
| Gold | Royal Canadian Mint | CANADA | CID001534 | Conformant | Yes | Unknown |
| Gold | SAAMP | FRANCE | CID002761 | Conformant | Yes | Unknown |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 | Outreach Required | Unknown | Unknown |
| Gold | Safimet S.p.A | ITALY | CID002973 | Conformant | Yes | Unknown |
| Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | Conformant | Yes | No |
| Gold | Sai Refinery | INDIA | CID002853 | Outreach Required | Unknown | Unknown |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Conformant | Yes | No |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 | Communication Suspended - Not Interested | Unknown | Unknown |
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | CID003529 | In Communication | Unknown | Unknown |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | Conformant | Yes | No |
| Gold | Sellem Industries Ltd. | MAURITANIA | CID003540 | Outreach Required | Unknown | Unknown |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | Conformant | Yes | Unknown |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 | Outreach Required | Unknown | Unknown |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | Outreach Required | Unknown | Unknown |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Conformant | Yes | Unknown |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | CID002527 | Outreach Required | Unknown | Unknown |
| Gold | Shirpur Gold Refinery Ltd. | INDIA | CID002588 | Outreach Required | Unknown | Unknown |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Conformant | Yes | Unknown |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 | Conformant | Yes | No |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Conformant | Yes | Unknown |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | Conformant | Yes | Unknown |
| Gold | Sovereign Metals | INDIA | CID003383 | Outreach Required | Unknown | Unknown |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 | Outreach Required | Unknown | Unknown |
| Gold | Sudan Gold Refinery | SUDAN | CID002567 | Outreach Required | Unknown | Unknown |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Conformant | Yes | Unknown |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 | Conformant | Yes | No |
| Gold | Super Dragon Technology Co., Ltd | TAIWAN, PROVINCE OF CHINA | CID001810 | Outreach Required | Unknown | Unknown |
| Gold | T.C.A S.p.A | ITALY | CID002580 | Conformant | Yes | Unknown |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Conformant | Yes | Unknown |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Conformant | Yes | Unknown |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Conformant | Yes | Unknown |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | Outreach Required | Unknown | Unknown |
| Gold | Tony Goetz NV | BELGIUM | CID002587 | Non Conformant | Unknown | Unknown |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Conformant | Yes | Unknown |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | Conformant | Yes | No |
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | Conformant | Yes | Unknown |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Conformant | Yes | Unknown |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 | Conformant | Yes | No |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Conformant | Yes | Unknown |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | Conformant | Yes | Unknown |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | Conformant | Yes | Unknown |
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 | Conformant | Yes | No |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | Conformant | Yes | No |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | Outreach Required | Unknown | Unknown |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Conformant | Yes | Unknown |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 | Conformant | Yes | No |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Conformant | Yes | No |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | Conformant | Yes | No |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 | Conformant | Yes | No |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Conformant | Yes | Yes |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Conformant | Yes | No |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Conformant | Yes | No |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | Conformant | Yes | Yes |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | Conformant | Yes | Yes |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | Conformant | Yes | Yes |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | Conformant | Yes | No |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 | Conformant | Yes | No |
| Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | Conformant | Yes | No |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | Conformant | Yes | Yes |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | Conformant | Yes | Yes |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Conformant | Yes | Yes |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | Conformant | Yes | No |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Conformant | Yes | No |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Conformant | Yes | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Conformant | Yes | Yes |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | Conformant | Yes | No |
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 | Conformant | Yes | No |
| Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 | Conformant | Yes | No |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | Conformant | Yes | No |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 | Conformant | Yes | No |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 | Conformant | Yes | No |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Conformant | Yes | Yes |
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 | Conformant | Yes | Yes |
| Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | CID002847 | Conformant | Yes | No |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 | Conformant | Yes | No |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 | Conformant | Yes | No |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | Conformant | Yes | No |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 | Conformant | Yes | No |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 | Conformant | Yes | No |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Conformant | Yes | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Conformant | Yes | Yes |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | Conformant | Yes | Yes |
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 | Conformant | Yes | No |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | Outreach Required | Unknown | Unknown |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | Conformant | Yes | No |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | Conformant | Yes | No |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | Conformant | Yes | No |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 | Active | Unknown | Unknown |
| Tin | CRM Synergies | SPAIN | CID003524 | Active | Unknown | Unknown |
| Tin | CV Ayi Jaya | INDONESIA | CID002570 | Active | Unknown | Unknown |
| Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | Active | Unknown | Unknown |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 | Non Conformant | Unknown | Unknown |
| Tin | Dowa | JAPAN | CID000402 | Conformant | Yes | No |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | Non Conformant | Unknown | Unknown |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 | Conformant | Yes | No |
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 | Active | Unknown | Unknown |
| Tin | Fenix Metals | POLAND | CID000468 | Conformant | Yes | No |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | CID003410 | Outreach Required | Unknown | Unknown |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 | Conformant | Yes | No |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | Conformant | Yes | No |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | Conformant | Yes | No |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | Conformant | Yes | No |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | Conformant | Yes | No |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 | Conformant | Yes | No |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | Conformant | Yes | No |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 | Conformant | Yes | No |
| Tin | Luna Smelter, Ltd. | RWANDA | CID003387 | Conformant | Yes | Yes |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 | Conformant | Yes | No |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | Conformant | Yes | No |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Conformant | Yes | Yes |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | Conformant | Yes | No |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 | Conformant | Yes | No |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Tin | Metallo Belgium N.V. | BELGIUM | CID002773 | Conformant | Yes | No |
| Tin | Metallo Spain S.L.U. | SPAIN | CID002774 | Conformant | Yes | No |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | Conformant | Yes | No |
| Tin | Minsur | PERU | CID001182 | Conformant | Yes | No |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | Conformant | Yes | No |
| Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | Non Conformant | Unknown | Unknown |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | Outreach Required | Unknown | Unknown |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | CID001305 | Active | Unknown | Unknown |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | Conformant | Yes | No |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | Conformant | Yes | No |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 | Conformant | Yes | No |
| Tin | Pongpipat Company Limited | MYANMAR | CID003208 | Outreach Required | Unknown | Unknown |
| Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 | Non Conformant | Unknown | Unknown |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | Active | Unknown | Unknown |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Conformant | Yes | No |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Conformant | Yes | No |
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 | Conformant | Yes | No |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 | Conformant | Yes | No |
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 | Conformant | Yes | No |
| Tin | PT Bukit Timah | INDONESIA | CID001428 | Active | Unknown | Unknown |
| Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 | In Communication | Unknown | Unknown |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 | Active | Unknown | Unknown |
| Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 | Conformant | Yes | No |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | Conformant | Yes | No |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 | In Communication | Unknown | Unknown |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 | Conformant | Yes | No |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | CID003381 | Conformant | Yes | No |
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 | Conformant | Yes | No |
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | Conformant | Yes | No |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | Conformant | Yes | No |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 | Active | Unknown | Unknown |
| Tin | PT Timah Nusantara | INDONESIA | CID001486 | Active | Unknown | Unknown |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 | Conformant | Yes | No |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 | Conformant | Yes | No |
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | Conformant | Yes | Unknown |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 | Conformant | Yes | No |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 | Conformant | Yes | No |
| Tin | Soft Metais Ltda. | BRAZIL | CID001758 | Conformant | Yes | No |
| Tin | Super Ligas | BRAZIL | CID002756 | Active | Unknown | Unknown |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | CID002834 | Conformant | Yes | No |
| Tin | Thaisarco | THAILAND | CID001898 | Conformant | Yes | Yes |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | Conformant | Yes | No |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | Outreach Required | Unknown | Unknown |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 | Outreach Required | Unknown | Unknown |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 | Conformant | Yes | No |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | Conformant | Yes | No |
| Tin | Yunnan Tin Company Limited | CHINA | CID002180 | Conformant | Yes | No |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 | Conformant | Yes | No |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 | Conformant | Yes | Unknown |
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | Conformant | Yes | No |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 | Active | Unknown | Unknown |
| Tungsten | Artek LLC | RUSSIAN FEDERATION | CID003553 | Outreach Required | Unknown | Unknown |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Conformant | Yes | Yes |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | Conformant | Yes | Unknown |
| Tungsten | China Molybdenum Co., Ltd. | CHINA | CID002641 | Conformant | Yes | Unknown |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | Conformant | Yes | Unknown |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 | Outreach Required | Unknown | Unknown |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 | Active | Unknown | Unknown |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 | Conformant | Yes | No |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 | Conformant | Yes | No |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | Conformant | Yes | Unknown |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | Conformant | Yes | No |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | Conformant | Yes | Unknown |
| Tungsten | GEM Co., Ltd. | CHINA | CID003417 | Active | Unknown | Unknown |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | Conformant | Yes | Yes |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | Conformant | Yes | Unknown |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 | Conformant | Yes | Unknown |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | Conformant | Yes | Unknown |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | Conformant | Yes | No |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | Conformant | Yes | Unknown |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | Conformant | Yes | Unknown |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Conformant | Yes | Unknown |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | Conformant | Yes | Unknown |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | Conformant | Yes | Unknown |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | Communication Suspended - Not Interested | Unknown | Unknown |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | Conformant | Yes | Unknown |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | Conformant | Yes | Unknown |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | Conformant | Yes | Unknown |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 | Active | Unknown | Unknown |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 | Conformant | Yes | Unknown |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 | Conformant | Yes | Unknown |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | CID003388 | Conformant | Yes | No |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 | Conformant | Yes | No |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | Conformant | Yes | Unknown |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 | Conformant | Yes | Yes |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 | Conformant | Yes | Unknown |
| Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMAP Status | Conflict Free? | Source from DRC? |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | Conformant | Yes | Unknown |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 | Active | Unknown | Unknown |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | Conformant | Yes | No |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | Conformant | Yes | No |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | Conformant | Yes | Yes |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Conformant | Yes | Yes |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | Conformant | Yes | Unknown |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | Conformant | Yes | Unknown |
Appendix B
Country of Origin Information
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be specifically linked to our products.
Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Congo, Democratic Republic of the, Djibouti, Dominican Republic, Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic of Korea, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe.
