Exhibit 1.01
CONFLICT MINERALS REPORT FOR CALENDAR YEAR 2020
Part I: Introduction
This document constitutes Merck & Co., Inc.’s Conflict Minerals Report (the “Report” or “CMR”) for the year ended December 31, 2020. We have prepared this Report and are issuing it in accordance with the requirements of Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and in connection with Merck & Co., Inc.’s disclosure filed on the specialized disclosure form (“Form SD”). Any references to “Merck,” the “Company,” “we,” “us,” and “our” refer to Merck & Co., Inc. and its consolidated subsidiaries.
In August 2012, the U.S. Securities and Exchange Commission (“SEC”) issued rules implementing the “Conflict Minerals” disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “SEC Conflict Minerals Reporting Rule” or the “Rule”). If an SEC registrant manufactures (or contracts to have manufactured) products containing columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (collectively, “3TG” or “Conflict Minerals”), and the 3TG is necessary to such products’ functionality or production, the Rule requires that registrant to undertake a Reasonable Country of Origin Inquiry (“RCOI”). If, as a result of a RCOI, the Company knows or has reason to believe that any 3TG contained in such products originated in the Democratic Republic of Congo or an adjoining country as defined in the Rule (the “Covered Countries”), and is not from recycled or scrap sources, the registrant must exercise due diligence on the source and chain of custody of such minerals. Specifically, registrants must determine whether: (a) any 3TG which is necessary to the functionality or production of a product manufactured or contracted to be manufactured by the registrant originated in the Covered Countries; and (b) any such 3TG directly or indirectly financed or benefitted armed groups in the Covered Countries.
Overview
Merck & Co., Inc. (“Merck” or the “Company”) is a global health care company that delivers innovative health solutions through its prescription medicines, vaccines, biologic therapies and animal health products. The Company’s operations are principally managed on a products basis and include four operating segments, which are the Pharmaceutical, Healthcare Services, Alliances, and Animal Health segments. The scope of Merck’s Conflict Minerals due diligence and reporting activities has grown as a result of an acquisition made by the Animal Health segment in 2019.
The Pharmaceutical segment includes human health pharmaceutical and vaccine products. Human health pharmaceutical products consist of therapeutic and preventive agents, generally sold by prescription, for the treatment of human disorders. The Company sells these human health pharmaceutical products primarily to drug wholesalers and retailers, hospitals, government agencies and managed health care
providers such as health maintenance organizations, pharmacy benefit managers and other institutions. Human health vaccine products consist of preventive pediatric, adolescent and adult vaccines, primarily administered at physician offices. The Company sells these human health vaccines primarily to physicians, wholesalers, physician distributors and government entities.
The Healthcare Services segment provides services and solutions that focus on engagement, health analytics and clinical services to improve the value of care delivered to patients. The Company has recently sold certain businesses in the Healthcare Services segment and is in the process of divesting the remaining businesses. While the Company continues to look for investment opportunities in this area of health care, the approach to these investments has shifted toward venture capital investments in third parties as opposed to wholly owned businesses.
The Alliances segment primarily includes activity from the Company’s relationship with AstraZeneca LP related to sales of Nexium and Prilosec, which concluded in 2018.
The Animal Health segment develops, manufactures and markets a broad range of veterinary medicines and services, including pharmaceutical and vaccine products and health management solutions and services. In 2019, Merck acquired a privately held animal health intelligence company called Antelliq Corporation, which became the Merck Animal Health Intelligence (“MAHI”) business unit after the transaction was completed. MAHI offers a suite of digitally connected identification, traceability and monitoring technologies for livestock, veterinarian, pet owner, wildlife research, and animal producer customers through its affiliated brands. MAHI’s products are designed to improve the quality of life of animals, protect the human food chain, and assist in aquaculture conservation efforts. MAHI’s suite of products is largely digital, meaning that such products inherently involve a greater potential use of 3TG. Because Antelliq was privately held, it was not previously subject to the SEC Conflict Minerals Reporting Rule, and many of its suppliers had not previously been required to engage in 3TG due diligence. Therefore, while 100% of in-scope suppliers responded to Merck’s due diligence inquiries in 2019, the response rate was 22% in 2020, and for that reason and in order to continue to strengthen its Conflict Mineral due diligence activities, Merck will take the actions described further in Part VI below.
Merck has thousands of direct material suppliers and an extensive internal and external network of manufacturing sites around the world. Given the size and complexity of Merck’s supply chain, Merck is several tiers removed from smelters/refiners and has no direct business relationship with them. As a result, Merck must rely on its direct material suppliers to provide information on their upstream supplier sourcing; this includes country of origin determinations for Conflict Minerals that may go into the materials or product provided by those direct material suppliers to Merck. In addition, the amount of reliable information available globally on the traceability and sourcing of Conflict Minerals is limited, which presents another challenge to our ability to precisely track any Conflict Minerals back to their source and origin, thereby making us more reliant on the information provided by our direct material suppliers and industrial initiatives such as the Responsible Materials Initiative (“RMI”).
Our Conflict Minerals Policy
Merck has established a Conflict Minerals Policy governing its position and commitment on managing the use of Conflict Minerals in its supply chain.
Our Conflict Minerals Policy can be found on our website: https://www.merck.com/about/views-and-positions/Policy_2019_Conflict-Minerals_MERCK.pdf
Our Scoping Assessment
Merck completed scoping assessment activities to determine which materials and products in our supply chain for this reporting period contain any Conflict Minerals that may be necessary to the functionality or production of our products, including those made by contract manufacturers or that Merck manufactures along with its joint ventures. Consistent with the Company’s last filing, Merck has determined that none of our Pharmaceutical or Animal Health medicines, vaccines or biologic products contains 3TG. Merck does, however, have reason to believe that 3TG may be necessary to the functionality or production of certain MAHI products, including electronic identification and monitoring tags and collars for livestock and companion animals, home pet products that monitor key animal health and wellbeing indicators, and electronic and radiofrequency identification products and other technology products for fish conservation and aquaculture (collectively, the “Covered MAHI Products”). Merck also has reason to believe that 3TG may be necessary to the functionality or production of a small number of its product delivery systems and ancillary devices to support the use of our products (collectively with the Covered MAHI Products, the “in-scope products”). As a result, Merck is taking the actions described in Part II and conducting a RCOI of these in-scope products.
Part II. Reasonable Country of Origin Inquiry
For the 2020 reporting period, Merck continued to use the Conflict Minerals Reporting Template (“CMRT”) published by the RMI for the RCOI survey to obtain countries of origin information for any Conflict Mineral smelters/refiners that may exist upstream in our supply chain. Merck performed a Conflict Minerals applicability scoping assessment to determine which of our suppliers sell products to Merck that may contain 3TG in their materials or products, or for which 3TG is necessary to the functionality or production of the materials or products. Our scoping assessment confirmed that approximately 171 direct material suppliers (including contract manufacturers) were in scope for the RCOI survey. Accordingly, we sent the RCOI survey to these suppliers. We requested our direct material suppliers to identify the smelters/refiners and countries of origin of the Conflict Minerals in products or materials they supply to us. Each direct material supplier received an introductory email that provided each supplier with information on the SEC Conflict Minerals Reporting Rule and the reasons why we contacted them. We also provided these suppliers with information on how to complete the Conflict Minerals Reporting Template (CMRT). Following the initial survey request, reminder emails were sent asking suppliers to complete the RCOI survey.
We received responses from 38 direct material suppliers that were in the RCOI survey. Of these, 25 stated that some 3TG is used in their materials or products or is necessary to the functionality or production of the materials or products purchased by Merck. A number of the direct material suppliers that responded to our survey identified specific smelters or refiners. Based on the RCOI survey responses received and subsequent smelter/refiner information verification, we have reason to believe that some smelters/refiners identified by our direct material suppliers may be sourcing 3TG from the Covered Countries and that the 3TG does not completely come from recycled or scrap sources; however, we cannot be certain that the identified smelters and refiners supplied 3TG for parts and components supplied to Merck rather than to other customers, and we are continuing to conduct due diligence activities, as described further in Part VI below.
Part III. Design of Conflict Minerals Program
We have designed our due diligence process to conform, in all material respects, with the Organization for Economic Co-Operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”), and related supplements for tin, tantalum, tungsten and gold. Summarized below are the design components of our Conflict Minerals Program as they relate to the five-step framework from the OECD Guidance. We note at the outset that the integration of the MAHI supplier network into Merck’s overall procurement practices, including its Conflict Minerals control systems, is ongoing. While the general procurement practices described below have not yet been implemented throughout the MAHI supplier network, Merck will continue its efforts to integrate MAHI into the larger Merck procurement ecosystem in 2021, including the Conflict Minerals program described below. Those efforts are described further in Part VI below.
OECD Step 1: Establish strong company management systems
Conflict Minerals Policy: We have an established Conflict Minerals Policy. Our Conflict Minerals Policy is posted on our Company website and is distributed to the direct material suppliers in the survey.
Conflict Minerals Expectations: We define and communicate our expectations for the responsible sourcing of minerals in our Company’s Business Partner Code of Conduct. All business partners that engage in the manufacture of our products or that supply direct materials are expected to maintain procedures to ensure the responsible sourcing of minerals.
Conflict Minerals Team: We maintain a cross-functional team consisting of Compliance, Supplier Management, Business Development, and Technical Experts that supervise and manage our Conflict Minerals Program. This team provides program status updates to senior management of Procurement and the Executive Vice President and President of Merck Manufacturing Division periodically.
Conflict Minerals Training: We train staff that have responsibility for sourcing direct materials on the processes and procedures that must be followed when sourcing materials, including those that may potentially contain Conflict Minerals.
Conflict Minerals Information: We provide information and training materials on Conflict Minerals to direct materials suppliers identified as in-scope to receive an RCOI survey to help inform and educate them.
Conflict Minerals Control System: We maintain a Conflict Minerals Program that is linked to our supplier sourcing decision-making process. We apply a conflict minerals supply chain system of controls and transparency through the use of the CMRT which is created and maintained by the Responsible Minerals Initiative (RMI) to identify the smelters/refiners that process the necessary Conflict Minerals potentially contained in our products.
Conflict Minerals Recordkeeping: We keep business records that relate to our Conflict Minerals Program, including the results of RCOI surveys and smelter/refiner due diligence activities, and retain them for at least 5 years.
Conflict Minerals Contract Clause: We maintain a Conflict Minerals compliance clause for inclusion in future contracts with direct material suppliers whose materials or products are known to contain Conflict Minerals and for which Conflict Minerals are necessary to the functionality or production of the products.
Grievance Mechanism: We maintain a mechanism to allow employees, suppliers, business partners and other stakeholders to report concerns, including those that relate to our Conflict Minerals Program. Concerns may be reported confidentially and anonymously at msdethics.com.
OECD Step 2: Identify and assess risks in our supply chain
Identify: We identify all direct material suppliers, including contract manufacturers and joint venture partners that supply materials and products to our Company which may potentially contain Conflict Minerals and that are considered in-scope.
Survey: For all direct material suppliers whose materials or products are considered likely to contain Conflict Minerals and for which Conflict Minerals are necessary to the production or functionality of the materials or products, we survey these suppliers using the CMRT developed by RMI, requesting them to identify smelters/refiners and countries of origin of the Conflict Minerals in the materials and products they provide to us.
Follow-Up: When direct material suppliers fail to provide complete and consistent responses to our RCOI survey request in a timely manner, the sourcing managers and representatives from our Conflict Minerals Team follow up to obtain the requested information. We sent up to five follow-up
communication to each MAHI supplier who had not responded throughout the duration of the campaign.
Compare and Research: Upon receipt of the RCOI survey response, we compare each supplier’s reported list of smelters/refiners against the list of facilities that have received “conformant” or “active” designation from the Responsible Minerals Assurance Program (“RMAP”) or other independent third party audit programs to identify their “conflict-free” status. We rely on RMI member data to ascertain the countries of origin of the Conflict Minerals processed by these facilities and, additionally, we leverage the research capabilities of a third-party service provider to attempt to identify the countries of origin for supplier identified smelters/refiners that are not disclosed by the RMI.
Document: At the conclusion of the process, we document the smelters/refiners and related countries of origin information for supplier identified smelters/refiners.
OECD Step 3: Execute a strategy to respond to identified risks
We develop and implement Conflict Minerals risk mitigation plans for all direct material suppliers identified as not meeting our Company expectations for responsible sourcing of minerals (e.g., suppliers with no smelters/refiners identified, suppliers with Conflict Minerals sourced from non-conformant smelters/refiners, etc.).
Our Conflict Minerals Team meets with relevant business sourcing managers to discuss and agree upon the actions Merck will take to maintain conformance with our Conflict Minerals Policy. We document and track the implementation of risk mitigation plans for each direct material supplier and present our progress annually to senior management.
OECD Step 4: Carry out independent third-party audits
Merck supports the independent third-party audits of smelters/refiners through our membership contribution to RMI. Merck’s RMI member ID No. is MERK.
OECD Step 5: Report annually on Supply Chain Due Diligence
Merck reports its annual Conflict Minerals due diligence results to the SEC and makes the report available on the Company website at https://www.merck.com/about/how-we-operate/conflict_minerals_report.pdf. The information on this website is not incorporated by reference into this CMR and does not constitute a part of this CMR.
Part IV: Due Diligence Performed
Below is a summary of the due diligence activities Merck performed for this reporting period:
•Continued to use our Conflict Minerals Program which is integrated in our Company’s sourcing and decision-making processes to evaluate any new suppliers and new products and materials.
•Continued to roll out the training to new staff involved in direct material sourcing activities.
•Issued requests to all in-scope direct material suppliers to complete and return a CMRT survey form to obtain smelters/refiners information and countries of origin information for the materials/ products they provided to Merck in 2020.
•Reviewed CMRT survey responses received to identify potential red flags based on criteria defined in our Company’s Conflict Minerals compliance program. For direct material suppliers surveyed in the previous reporting period, we compared the responses received this reporting period against their prior submission to monitor progress and consistency of reporting.
•Performed verification activities to determine if any of the smelters/refiners disclosed by suppliers are Conflict Minerals processing facilities, using the Standard Smelter List published by RMI. Where a supplier-identified smelter/refiner was confirmed as a Conflict Minerals processing facility, we evaluated whether or not that smelter/refiner was certified as “conformant” or “active” using the RMAP, or other equivalent validation program.
•Communicated the results of Conflict Minerals surveys, smelter due diligence outcomes and ongoing risk mitigation efforts to senior management, including those responsible for global supply chain management and oversight of our Conflict Minerals Program. Presented the program status to the Executive Vice President and President of Merck Manufacturing Division.
•Financially supported Conflict Minerals initiatives through our continued membership to the RMI. Merck’s RMI member ID No. is MERK.
Part V: Results of Due Diligence
During this reporting period, we confirmed that none of our Pharmaceutical or Animal Health medicines, vaccines or biologic products contain any 3TG; however, Merck does have reason to believe 3TG may be necessary to the functionality or production of the Covered MAHI Products, as well as a small number of its product delivery systems and ancillary devices to support the use of our products (collectively, the “in-scope products”). Merck cannot at this time draw any definitive conclusions about the countries of origin for, or the conformant status of, all identified smelters/refiners that may be necessary to its in-scope products’ functionality or production. A majority of the smelters/refiners identified by our suppliers were at company-level of their upstream suppliers and therefore potentially not relevant to the materials or products they supply to us. Although the information in Appendix I and Appendix II below ultimately may not be completely relevant to any Merck product, given the aforementioned reasons, Merck has chosen to aggregate the smelter/refiner data for all responding in-scope suppliers that identified smelters/refiners and report it in the Appendices below. In addition, our direct material suppliers were not able to provide a
complete list of smelters/refiners, nor were they able to provide the countries of origin for the ore that the smelters/refiners were processing. Our efforts to determine the countries of origin for supplier identified smelters/refiners is, as described in this report, reliant on the “conformant” smelter/refiner information provided by RMI, internationally recognized industry associations and research of publicly available information on other smelters/refiners whose countries of origin information was not provided by RMI (e.g., various government databases and industry/trade organization lists).
| | | | | | | | | | | |
| Metal | Total Number of Smelters/Refiners Identified By our Direct Material Suppliers | Number of Confirmed Smelters/Refiners | Number of “Conformant” Smelters/Refiners |
| Total | 575 | 323 | 243 |
Note:
“Confirmed” means smelters/refiners appear on the Standard Smelter List of the RMI’s CMRT.
“Conformant” means smelters/refiners are conformant with the RMAP assessment protocols. The compliance status reflected in the table is based solely on information published by RMI.
Part VI: Future Due Diligence Measures
Merck is continuing to execute the activities described in the Part III “Design of Conflict Minerals Program” and Part IV “Due Diligence Performed” for the next reporting period. Merck will continue to encourage our direct material suppliers to influence their upstream suppliers to participate in the RMAP or other equivalent program to become conformant smelters/refiners.
For the 2021 reporting period, Merck is focused on strengthening its Conflict Minerals due diligence activities with respect to MAHI-related direct material suppliers. Merck will work with suppliers to provide education on both general issues related to Conflict Minerals, as well as Merck’s own due diligence process. Through these outreach and education activities, Merck’s goal is to bring more suppliers into its Conflict Minerals due diligence process, and in turn increase the number of responses to its Conflict Minerals survey. By receiving more robust information in response to the survey, Merck will be able to more thoroughly assess smelters/refiners against the list of facilities that have received “conformant” or “active” designation from the RMAP, which will in turn allow Merck to determine whether additional risk response activities are needed.
Appendix I: Smelter or Refiner Information
The information provided in the list below is an aggregation of data received from our direct material suppliers and not a confirmation of Conflict Minerals contained in our products. Since many of the identified smelters/refiners were disclosed at the company-level by our direct material suppliers, Merck is unable to confirm which specific smelters/refiners were actually linked to our products. Therefore, there may be some smelters/refiners in the list below that do not relate directly to our products. Only the smelters/refiners whose facility names and locations were verified against the RMI’s Standard Smelter List are reported below.
| | | | | | | | | | | |
| | Smelter/Refiner Facility Name | Identification # | Location |
| Gold |
| * | 8853 S.p.A. | CID002763 | Italy |
| * | Abington Reldan Metals, LLC | CID002708 | United States |
| * | Advanced Chemical Company | CID000015 | United States |
| * | Aida Chemical Industries Co., Ltd. | CID000019 | Japan |
| * | Al Etihad Gold Refinery DMCC | CID002560 | United Arab Emirates |
| * | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | Germany |
| * | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | Uzbekistan |
| * | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 | Brazil |
| * | Argor-Heraeus S.A. | CID000077 | Switzerland |
| * | Asahi Pretec Corp. | CID000082 | Japan |
| * | Asahi Refining Canada Ltd. | CID000924 | Canada |
| * | Asahi Refining USA Inc. | CID000920 | United States |
| * | Asaka Riken Co., Ltd. | CID000090 | Japan |
| * | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | Turkey |
| * | AU Traders and Refiners | CID002850 | South Africa |
| * | Augmont Enterprises Private Limited | CID003461 | India |
| * | Aurubis AG | CID000113 | Germany |
| * | Bangalore Refinery | CID002863 | India |
| * | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | Philippines |
| * | Boliden AB | CID000157 | Sweden |
| * | C. Hafner GmbH + Co. KG | CID000176 | Germany |
| * | C.I Metales Procesados Industriales SAS | CID003421 | Colombia |
| * | Caridad | CID000180 | Mexico |
| * | CCR Refinery - Glencore Canada Corporation | CID000185 | Canada |
| * | Cendres + Metaux S.A. | CID000189 | Switzerland |
| * | CGR Metalloys Pvt Ltd. | CID003382 | India |
| * | Chimet S.p.A. | CID000233 | Italy |
| * | Chugai Mining | CID000264 | Japan |
| * | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | China |
| * | Degussa Sonne / Mond Goldhandel GmbH | CID002867 | Germany |
| * | Dijllah Gold Refinery FZC | CID003348 | United Arab Emirates |
| * | DODUCO Contacts and Refining GmbH | CID000362 | Germany |
| * | Dowa | CID000401 | Japan |
| * | DS PRETECH Co., Ltd. | CID003195 | Korea, Republic of |
| * | DSC (Do Sung Corporation) | CID000359 | Korea, Republic of |
| * | Eco-System Recycling Co., Ltd. East Plant | CID000425 | Japan |
| * | Eco-System Recycling Co., Ltd. North Plant | CID003424 | Japan |
| | | | | | | | | | | |
| * | Eco-System Recycling Co., Ltd. West Plant | CID003425 | Japan |
| * | Emirates Gold DMCC | CID002561 | United Arab Emirates |
| * | Fidelity Printers and Refiners Ltd. | CID002515 | Zimbabwe |
| * | Fujairah Gold FZC | CID002584 | United Arab Emirates |
| * | GCC Gujrat Gold Centre Pvt. Ltd. | CID002852 | India |
| * | Geib Refining Corporation | CID002459 | United States |
| * | Gold Coast Refinery | CID003186 | Ghana |
| * | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 | China |
| * | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | China |
| * | Guangdong Jinding Gold Limited | CID002312 | China |
| * | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | China |
| * | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | China |
| * | Heimerle + Meule GmbH | CID000694 | Germany |
| * | Heraeus Metals Hong Kong Ltd. | CID000707 | China |
| * | Heraeus Precious Metals GmbH & Co. KG | CID000711 | Germany |
| * | Hunan Chenzhou Mining Co., Ltd. | CID000767 | China |
| * | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 | China |
| * | HwaSeong CJ CO., LTD. | CID000778 | Korea, Republic of |
| * | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | China |
| * | International Precious Metal Refiners | CID002562 | United Arab Emirates |
| * | Ishifuku Metal Industry Co., Ltd. | CID000807 | Japan |
| * | Istanbul Gold Refinery | CID000814 | Turkey |
| * | Italpreziosi | CID002765 | Italy |
| * | JALAN & Company | CID002893 | India |
| * | Japan Mint | CID000823 | Japan |
| * | Jiangxi Copper Co., Ltd. | CID000855 | China |
| * | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | Russian Federation |
| * | JSC Uralelectromed | CID000929 | Russian Federation |
| * | JX Nippon Mining & Metals Co., Ltd. | CID000937 | Japan |
| * | Kaloti Precious Metals | CID002563 | United Arab Emirates |
| * | Kazakhmys Smelting LLC | CID000956 | Kazakhstan |
| * | Kazzinc | CID000957 | Kazakhstan |
| * | Kennecott Utah Copper LLC | CID000969 | United States |
| * | KGHM Polska Miedz Spolka Akcyjna | CID002511 | Poland |
| * | Kojima Chemicals Co., Ltd. | CID000981 | Japan |
| * | Korea Zinc Co., Ltd. | CID002605 | Korea, Republic of |
| * | Kundan Care Products Ltd. | CID003463 | India |
| * | Kyrgyzaltyn JSC | CID001029 | Kyrgyzstan |
| * | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 | Russian Federation |
| * | L'azurde Company For Jewelry | CID001032 | Saudi Arabia |
| * | L'Orfebre S.A. | CID002762 | Andorra |
| * | Lingbao Gold Co., Ltd. | CID001056 | China |
| * | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | China |
| * | LS-NIKKO Copper Inc. | CID001078 | Korea, Republic of |
| * | LT Metal Ltd. | CID000689 | Korea, Republic of |
| * | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | China |
| * | Marsam Metals | CID002606 | Brazil |
| * | Materion | CID001113 | United States |
| * | Matsuda Sangyo Co., Ltd. | CID001119 | Japan |
| * | Metalor Technologies (Hong Kong) Ltd. | CID001149 | China |
| * | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | Singapore |
| | | | | | | | | | | |
| * | Metalor Technologies (Suzhou) Ltd. | CID001147 | China |
| * | Metalor Technologies S.A. | CID001153 | Switzerland |
| * | Metalor USA Refining Corporation | CID001157 | United States |
| * | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 | Mexico |
| * | Mitsubishi Materials Corporation | CID001188 | Japan |
| * | Mitsui Mining and Smelting Co., Ltd. | CID001193 | Japan |
| * | MMTC-PAMP India Pvt., Ltd. | CID002509 | India |
| * | Modeltech Sdn Bhd | CID002857 | Malaysia |
| * | Morris and Watson | CID002282 | New Zealand |
| * | Moscow Special Alloys Processing Plant | CID001204 | Russian Federation |
| * | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 | Turkey |
| * | Navoi Mining and Metallurgical Combinat | CID001236 | Uzbekistan |
| * | NH Recytech Company | CID003189 | Korea, Republic of |
| * | Nihon Material Co., Ltd. | CID001259 | Japan |
| * | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | Austria |
| * | Ohura Precious Metal Industry Co., Ltd. | CID001325 | Japan |
| * | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | Russian Federation |
| * | OJSC Novosibirsk Refinery | CID000493 | Russian Federation |
| * | PAMP S.A. | CID001352 | Switzerland |
| * | Pease & Curren | CID002872 | United States |
| * | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | China |
| * | Planta Recuperadora de Metales SpA | CID002919 | Chile |
| * | Prioksky Plant of Non-Ferrous Metals | CID001386 | Russian Federation |
| * | PT Aneka Tambang (Persero) Tbk | CID001397 | Indonesia |
| * | PX Precinox S.A. | CID001498 | Switzerland |
| * | QG Refining, LLC | CID003324 | United States |
| * | Rand Refinery (Pty) Ltd. | CID001512 | South Africa |
| * | Refinery of Seemine Gold Co., Ltd. | CID000522 | China |
| * | REMONDIS PMR B.V. | CID002582 | Netherlands |
| * | Royal Canadian Mint | CID001534 | Canada |
| * | SAAMP | CID002761 | France |
| * | Sabin Metal Corp. | CID001546 | United States |
| * | Safimet S.p.A | CID002973 | Italy |
| * | SAFINA A.S. | CID002290 | Czech Republic |
| * | Sai Refinery | CID002853 | India |
| * | Samduck Precious Metals | CID001555 | Korea, Republic of |
| * | SAMWON METALS Corp. | CID001562 | Korea, Republic of |
| * | SAXONIA Edelmetalle GmbH | CID002777 | Germany |
| * | SEMPSA Joyeria Plateria S.A. | CID001585 | Spain |
| * | Shandong Humon Smelting Co., Ltd. | CID002525 | China |
| * | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | China |
| * | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | China |
| * | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 | China |
| * | Shirpur Gold Refinery Ltd. | CID002588 | India |
| * | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | China |
| * | Singway Technology Co., Ltd. | CID002516 | Taiwan |
| * | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | Russian Federation |
| * | Solar Applied Materials Technology Corp. | CID001761 | Taiwan |
| * | Sovereign Metals | CID003383 | India |
| | | | | | | | | | | |
| * | State Research Institute Center for Physical Sciences and Technology | CID003153 | Lithuania |
| * | Sudan Gold Refinery | CID002567 | Sudan |
| * | Sumitomo Metal Mining Co., Ltd. | CID001798 | Japan |
| * | SungEel HiMetal Co., Ltd. | CID002918 | Korea, Republic of |
| * | T.C.A S.p.A | CID002580 | Italy |
| * | Tanaka Kikinzoku Kogyo K.K. | CID001875 | Japan |
| * | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | China |
| * | Tokuriki Honten Co., Ltd. | CID001938 | Japan |
| * | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | China |
| * | Tony Goetz NV | CID002587 | Belgium |
| * | TOO Tau-Ken-Altyn | CID002615 | Kazakhstan |
| * | Torecom | CID001955 | Korea, Republic of |
| * | Umicore Brasil Ltda. | CID001977 | Brazil |
| * | Umicore Precious Metals Thailand | CID002314 | Thailand |
| * | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | Belgium |
| * | United Precious Metal Refining, Inc. | CID001993 | United States |
| * | Valcambi S.A. | CID002003 | Switzerland |
| * | Western Australian Mint (T/a The Perth Mint) | CID002030 | Australia |
| * | WIELAND Edelmetalle GmbH | CID002778 | Germany |
| * | Yamakin Co., Ltd. | CID002100 | Japan |
| * | Yokohama Metal Co., Ltd. | CID002129 | Japan |
| * | Yunnan Copper Industry Co., Ltd. | CID000197 | China |
| * | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | China |
| Tantalum |
| * | Asaka Riken Co., Ltd. | CID000092 | Japan |
| * | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | China |
| * | D Block Metals, LLC | CID002504 | United States |
| * | Exotech Inc. | CID000456 | United States |
| * | F&X Electro-Materials Ltd. | CID000460 | China |
| * | FIR Metals & Resource Ltd. | CID002505 | China |
| * | Global Advanced Metals Aizu | CID002558 | Japan |
| * | Global Advanced Metals Boyertown | CID002557 | United States |
| * | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 | China |
| * | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | China |
| * | H.C. Starck Hermsdorf GmbH | CID002547 | Germany |
| * | H.C. Starck Inc. | CID002548 | United States |
| * | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | China |
| * | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | China |
| * | Jiangxi Tuohong New Raw Material | CID002842 | China |
| * | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | China |
| * | Jiujiang Tanbre Co., Ltd. | CID000917 | China |
| * | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | China |
| * | KEMET Blue Metals | CID002539 | Mexico |
| * | LSM Brasil S.A. | CID001076 | Brazil |
| * | Meta Materials | CID002847 | Macedonia, The Former Yugoslav Republic Of |
| * | Metallurgical Products India Pvt., Ltd. | CID001163 | India |
| * | Mineracao Taboca S.A. | CID001175 | Brazil |
| * | Mitsui Mining and Smelting Co., Ltd. | CID001192 | Japan |
| * | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | China |
| | | | | | | | | | | |
| * | NPM Silmet AS | CID001200 | Estonia |
| * | QuantumClean | CID001508 | United States |
| * | Resind Industria e Comercio Ltda. | CID002707 | Brazil |
| * | Solikamsk Magnesium Works OAO | CID001769 | Russian Federation |
| * | Taki Chemical Co., Ltd. | CID001869 | Japan |
| * | TANIOBIS Co., Ltd. | CID002544 | Thailand |
| * | TANIOBIS GmbH | CID002545 | Germany |
| * | TANIOBIS Japan Co., Ltd. | CID002549 | Japan |
| * | TANIOBIS Smelting GmbH & Co. KG | CID002550 | Germany |
| * | Telex Metals | CID001891 | United States |
| * | Ulba Metallurgical Plant JSC | CID001969 | Kazakhstan |
| * | XinXing Haorong Electronic Material Co., Ltd. | CID002508 | China |
| * | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | China |
| Tin |
| * | Alpha | CID000292 | United States |
| * | An Vinh Joint Stock Mineral Processing Company | CID002703 | Viet Nam |
| * | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | China |
| * | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 | China |
| * | China Tin Group Co., Ltd. | CID001070 | China |
| * | CV Ayi Jaya | CID002570 | Indonesia |
| * | CV Venus Inti Perkasa | CID002455 | Indonesia |
| * | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 | China |
| * | Dowa | CID000402 | Japan |
| * | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | Viet Nam |
| * | EM Vinto | CID000438 | Bolivia |
| * | Estanho de Rondonia S.A. | CID000448 | Brazil |
| * | Fenix Metals | CID000468 | Poland |
| * | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 | China |
| * | Gejiu Fengming Metallurgy Chemical Plant | CID002848 | China |
| * | Gejiu Kai Meng Industry and Trade LLC | CID000942 | China |
| * | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | China |
| * | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | China |
| * | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | China |
| * | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 | China |
| * | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 | China |
| * | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | China |
| * | Huichang Jinshunda Tin Co., Ltd. | CID000760 | China |
| * | Jiangxi New Nanshan Technology Ltd. | CID001231 | China |
| * | Luna Smelter, Ltd. | CID003387 | Rwanda |
| * | Ma'anshan Weitai Tin Co., Ltd. | CID003379 | China |
| * | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | Brazil |
| * | Malaysia Smelting Corporation (MSC) | CID001105 | Malaysia |
| * | Melt Metais e Ligas S.A. | CID002500 | Brazil |
| * | Metallic Resources, Inc. | CID001142 | United States |
| * | Metallo Belgium N.V. | CID002773 | Belgium |
| * | Metallo Spain S.L.U. | CID002774 | Spain |
| * | Mineracao Taboca S.A. | CID001173 | Brazil |
| * | Minsur | CID001182 | Peru |
| * | Mitsubishi Materials Corporation | CID001191 | Japan |
| * | Modeltech Sdn Bhd | CID002858 | Malaysia |
| | | | | | | | | | | |
| * | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | Viet Nam |
| * | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | Thailand |
| * | O.M. Manufacturing Philippines, Inc. | CID002517 | Philippines |
| * | Operaciones Metalurgicas S.A. | CID001337 | Bolivia |
| * | Precious Minerals and Smelting Limited | CID003409 | India |
| * | PT Aries Kencana Sejahtera | CID000309 | Indonesia |
| * | PT Artha Cipta Langgeng | CID001399 | Indonesia |
| * | PT ATD Makmur Mandiri Jaya | CID002503 | Indonesia |
| * | PT Babel Inti Perkasa | CID001402 | Indonesia |
| * | PT Babel Surya Alam Lestari | CID001406 | Indonesia |
| * | PT Bangka Serumpun | CID003205 | Indonesia |
| * | PT Bukit Timah | CID001428 | Indonesia |
| * | PT Lautan Harmonis Sejahtera | CID002870 | Indonesia |
| * | PT Menara Cipta Mulia | CID002835 | Indonesia |
| * | PT Mitra Stania Prima | CID001453 | Indonesia |
| * | PT Mitra Sukses Globalindo | CID003449 | Indonesia |
| * | PT Prima Timah Utama | CID001458 | Indonesia |
| * | PT Rajawali Rimba Perkasa | CID003381 | Indonesia |
| * | PT Rajehan Ariq | CID002593 | Indonesia |
| * | PT Refined Bangka Tin | CID001460 | Indonesia |
| * | PT Stanindo Inti Perkasa | CID001468 | Indonesia |
| * | PT Timah Tbk Kundur | CID001477 | Indonesia |
| * | PT Timah Tbk Mentok | CID001482 | Indonesia |
| * | PT Tinindo Inter Nusa | CID001490 | Indonesia |
| * | Resind Industria e Comercio Ltda. | CID002706 | Brazil |
| * | Rui Da Hung | CID001539 | Taiwan |
| * | Soft Metais Ltda. | CID001758 | Brazil |
| * | Super Ligas | CID002756 | Brazil |
| * | Thai Nguyen Mining and Metallurgy Co., Ltd. | CID002834 | Viet Nam |
| * | Thaisarco | CID001898 | Thailand |
| * | Tin Technology & Refining | CID003325 | United States |
| * | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | Viet Nam |
| * | VQB Mineral and Trading Group JSC | CID002015 | Viet Nam |
| * | White Solder Metalurgia e Mineracao Ltda. | CID002036 | Brazil |
| * | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | China |
| * | Yunnan Tin Company Limited | CID002180 | China |
| * | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | China |
| Tungsten |
| * | A.L.M.T. TUNGSTEN Corp. | CID000004 | Japan |
| * | ACL Metais Eireli | CID002833 | Brazil |
| * | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 | Brazil |
| * | Asia Tungsten Products Vietnam Ltd. | CID002502 | Viet Nam |
| * | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | China |
| * | China Molybdenum Co., Ltd. | CID002641 | China |
| * | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | China |
| * | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 | China |
| * | Fujian Ganmin RareMetal Co., Ltd. | CID003401 | China |
| * | Fujian Jinxin Tungsten Co., Ltd. | CID000499 | China |
| * | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 | China |
| * | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | China |
| * | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | China |
| | | | | | | | | | | |
| * | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | China |
| * | GEM Co., Ltd. | CID003417 | China |
| * | Global Tungsten & Powders Corp. | CID000568 | United States |
| * | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | China |
| * | H.C. Starck Tungsten GmbH | CID002541 | Germany |
| * | Hunan Chenzhou Mining Co., Ltd. | CID000766 | China |
| * | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 | China |
| * | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | China |
| * | Hunan Litian Tungsten Industry Co., Ltd. | CID003182 | China |
| * | Hydrometallurg, JSC | CID002649 | Russian Federation |
| * | Japan New Metals Co., Ltd. | CID000825 | Japan |
| * | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | China |
| * | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | China |
| * | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | China |
| * | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | China |
| * | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | China |
| * | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | China |
| * | JSC "Kirovgrad Hard Alloys Plant" | CID003408 | Russian Federation |
| * | Kennametal Fallon | CID000966 | United States |
| * | Kennametal Huntsville | CID000105 | United States |
| * | KGETS CO., LTD. | CID003388 | Korea, Republic of |
| * | Lianyou Metals Co., Ltd. | CID003407 | Taiwan |
| * | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | China |
| * | Masan Tungsten Chemical LLC (MTC) | CID002543 | Viet Nam |
| * | Moliren Ltd. | CID002845 | Russian Federation |
| * | Niagara Refining LLC | CID002589 | United States |
| * | NPP Tyazhmetprom LLC | CID003416 | Russian Federation |
| * | Philippine Chuangxin Industrial Co., Inc. | CID002827 | Philippines |
| * | TANIOBIS Smelting GmbH & Co. KG | CID002542 | Germany |
| * | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | Viet Nam |
| * | Unecha Refractory Metals Plant | CID002724 | Russian Federation |
| * | Wolfram Bergbau und Hutten AG | CID002044 | Austria |
| * | Woltech Korea Co., Ltd. | CID002843 | Korea, Republic of |
| * | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | China |
| * | Xiamen Tungsten Co., Ltd. | CID002082 | China |
| * | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 | China |
| * | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 | China |
Note: As used in the table, the terms “conformant” and “active” have the meanings defined by the RMI. The compliance status reflected in the table is based solely on information made publicly available by the RMI without independent verification by us.
* Conformant smelter/refiner – Conformant with the Responsible Minerals Assurance Process (RAMP) Standards.
# Smelter/refiner with no RAMP conformant certification.
Appendix II: Country of Origin Information
The countries of origin of the Conflict Minerals processed by the smelters/refiners listed above may have included the countries listed below, based on information provided by the RMI to its members for the
“conformant” smelters/refiners and our independent research of all other smelters/refiners disclosed. Because the RMI generally does not indicate individual country of origin of the Conflict Minerals processed by “conformant” smelters/refiners, we were not able to determine the countries of origin of the Conflict Minerals processed by the listed “conformant” smelters/ refiners with greater specificity. In addition, for some of the listed “conformant” smelters/refiners, the country of origin information is not disclosed by RMI.
| | |
L1 - Level 1 countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. Argentina, Armenia, Australia, Austria, Azerbaijan, Bahamas, Barbados, Belarus, Belgium, Benin, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Cameroon, Canada, Cayman Islands, Chile, China, Colombia, Croatia, Curacao, Cyprus, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Fiji, Finland, France, Gabon, Gambia, Georgia, Germany, Ghana, Greece, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Iran, Ireland, Israel, Italy, Ivory Coast, Japan, Jordan, Kazakhstan, Kenya, Korea, Republic of, Kosovo, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Libya, Liechtenstein, Lithuania, Luxembourg, Macau, Madagascar, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Myanmar, Namibia, Netherlands, New Caledonia, New Zealand, Nicaragua, Niger, Nigeria, Norway, Pakistan, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russian Federation, San Marino, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, Spain, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Vatican City, Venezuela, Vietnam, Yemen and Zimbabwe. |
L2 - Level 2 countries that are known or plausible countries for smuggling, exporting out of region or transit of materials containing tantalum, tin, tungsten or gold: Mozambique and South Africa. |
CC – Covered counties are the 9 countries adjoining the Democratic Republic of Congo: Burundi, Rwanda, Uganda, Zambia and Tanzania. |
DRC - The Democratic Republic of the Congo. |
