Exhibit 1.01
CONFLICT MINERALS REPORT OF 2017
TO
FORM SD SPECIALIZED DISCLOSURE REPORT
OF
ECOLAB INC.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of the future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG (as such term is defined below) benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, (3) the accuracy and validity of the audits conducted under the Responsible Minerals Assurance Process (“RMAP”) assessment protocols and analogous audit programs with which the Responsible Minerals Initiative (“RMI”) has a mutual recognition agreement and (4) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of the filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of the filing of this document or to reflect the occurrence of unanticipated events.
I.Introduction
Except where the context otherwise requires, references in this Conflict Minerals Report to “Ecolab,” “Company,” “we” and “our” are to Ecolab Inc. and its subsidiaries, collectively. As used herein and consistent with the Conflict Minerals Rule (as such term is defined below), (1) “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold and wolframite, and their metallic-form derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals, and (2) the “Conflict Minerals Rule” is, collectively, Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD.
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Applicability of the Conflict Minerals Rule to Our Company
We are the global leader in water, hygiene and energy technologies and services that protect people and vital resources. We deliver comprehensive programs, products and services to promote safe food, maintain clean environments, optimize water and energy use, and improve operational efficiencies for customers in the food, healthcare, energy, hospitality and industrial markets in more than 170 countries around the world. Our cleaning and sanitizing programs and products, and pest elimination services support customers in the foodservice, food and beverage processing, hospitality, healthcare, government and education, retail, textile care and commercial facilities management sectors. Our products and technologies are also used in water treatment, pollution control, energy conservation, oil production and refining, steelmaking, papermaking, mining and other industrial processes.
We are required to make filings pursuant to the Conflict Minerals Rule because some of the products that we manufacture or contract to manufacture, in particular certain components of our control and dispensing equipment and healthcare product offerings, contain metallic forms of 3TG that are necessary to the functionality or production of the products. Not all of our products contain 3TG. The 3TG content in our products accounts for only a small percentage of the total materials content and our products with 3TG content accounted for less than 1% of our 2017 total sales. Our in-scope products taken together as a whole include all four 3TG, though each in-scope product does not include all four 3TG.
We do not directly source 3TG from mines, smelters or refiners, and we believe that we are in most cases many levels removed from these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy described below.
Reasonable Country of Origin Information
As required by the Conflict Minerals Rule, for 2017, we conducted a “reasonable country of origin inquiry” (“RCOI”) of the direct suppliers of the components, parts or products believed by us to contain 3TG. Our RCOI was reasonably designed to determine in good faith whether any of the 3TG in our in-scope products may have originated or did originate in the DRC or an adjoining country or from recycled or scrap sources. For our RCOI, we utilized the processes and procedures contemplated by Steps 1 and 2 of the OECD Guidance (as defined below). These steps of the OECD Guidance are described under “Design of Due Diligence Measures” and “Due Diligence Measures Performed by Ecolab.”
In connection with our RCOI, product-level supplier surveys identified to us 313 smelters and refiners that processed the necessary 3TG contained in our in-scope products. The percentage of these smelters and refiners that were listed as “conformant” by the RMI with applicable RMAP assessment protocols, “active” with respect to progressing to compliance with such protocols, and not conformant or active as of May 16, 2018 are set forth in the table below. These smelters and refiners and their compliance status are listed on Annexes I and II.
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Smelter or |
| Conflict Minerals |
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Refiner |
| Gold |
| Tantalum |
| Tin |
| Tungsten |
| Total |
| ||||||||||
Status |
| No. |
| % |
| No. |
| % |
| No. |
| % |
| No. |
| % |
| No. |
| % |
|
Conformant |
| 99 |
| 69.7 | % | 40 |
| 97.6 | % | 73 |
| 86.9 | % | 40 |
| 87.0 | % | 252 |
| 80.5 | % |
Active |
| 8 |
| 5.6 | % | 0 |
| 0.0 | % | 2 |
| 2.4 | % | 1 |
| 2.2 | % | 11 |
| 3.5 | % |
Not Conformant or Active |
| 35 |
| 24.6 | % | 1 |
| 2.4 | % | 9 |
| 10.7 | % | 5 |
| 10.9 | % | 50 |
| 16.0 | % |
To help achieve a greater level of specificity in determining the countries of origin of the 3TG processed by the smelters and refiners identified by our suppliers, we continued our practice of enlisting the services of a third-party service provider (the “Reviewer”) to review the smelters and refiners identified to us and provide us with a list of the related countries of origin and plausible countries of origin known to it. The identified countries of origin are listed below under “Product, Smelter and Refiner and Country of Origin Information.” Our country of origin and plausibility determinations are derived from information known to us as an RMI member and information provided to us by the Reviewer. This information is based on, among other things, RMAP audits, smelter and refiner disclosures, other information known to the Reviewer and RMI through their work in this subject area and mineral origin information in reports published by the U.S. Geological Survey. Certain of the other compliance activities described in this Conflict Minerals Report also were performed on our behalf by the Reviewer.
Based on the information provided by the Reviewer and our own analysis of that information, we had reason to believe that some of the identified smelters and refiners sourced from the DRC and its adjoining countries. Based on the results of our RCOI, we conducted due diligence for 2017. These due diligence efforts are discussed below.
II.Design of Due Diligence Measures
We designed our 3TG compliance procedures based on, and in conformity in all material respects with, the applicable portions of the five step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016 Third Edition), including the supplements on tin, tantalum and tungsten and gold (the “OECD Guidance”). Selected elements of our program design are discussed below. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2017 are discussed below under “Due Diligence Measures Performed by Ecolab.”
1.Establish strong company management systems
a. We have a team of responsible personnel from our regulatory affairs, global supply chain, legal, and research and development functions for the management and continued implementation of our 3TG compliance strategy. We also utilize specialist outside counsel and other advisors to assist us with our compliance efforts. |
b. We have adopted and communicate to our suppliers and the public a company policy regarding 3TG (the “Conflict Minerals Policy”) for our supply chain. Among other things, the Conflict Minerals Policy contains our expectations that our suppliers: (i) supply materials to Ecolab that are “DRC Conflict-Free”; (ii) adopt policies and management systems with respect to 3TG and require their suppliers to adopt similar policies and systems; (iii) establish their own due diligence program to ensure conflict-free supply chains; and (iv) respond to survey requests |
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in a timely manner, and with full disclosure, following the specific instructions provided. The Conflict Minerals Policy indicates that, in the event Ecolab determines that a supplier’s efforts to comply with the Conflict Minerals Policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Ecolab reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier. Our policy is available on our website at https://www.ecolab.com/about/suppliers/conflict-mineral-policy. |
Through our procurement policies and industry association membership and participation we support responsible sourcing from the DRC region. We do not support embargoes of the region.
c. We utilize the Conflict Minerals Reporting Template (the “Conflict Minerals Reporting Template”) developed by the RMI to identify smelters and refiners in our supply chain. The Conflict Minerals Reporting Template requests suppliers to provide information concerning the usage and source of 3TG in the products they provide Ecolab, as well as information concerning their related compliance efforts. |
d. We are a member of the RMI. Company personnel on our Conflict Minerals practices team are members of the RMI due diligence practices team. Additionally, we participate as a member of the Conflict Minerals Task Force in the Twin Cities (Minneapolis-St. Paul) for the purpose of aligning our approach and establishing best practices with other firms with respect to compliance with the Conflict Minerals Rule. |
e. We have implemented an IT solution managed by a third party to engage our direct suppliers and to maintain responses relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, in an electronic format for at least five years. |
f. Our procurement terms and conditions contain provisions relating to the sourcing of 3TG to be contained in our products. |
g. We include as a part of our supplier quality review process inquiries concerning the supplier’s policies and procedures relating to 3TG sourcing. |
h. In addition to other reporting methods set forth on our website and in our Code of Conduct and Supplier Code of Conduct, which is available on our website, we have a dedicated email address, conflictminerals@ecolab.com, which can be used by interested internal and external parties to contact Ecolab with respect to its supplier surveys, Conflict Minerals Policy and related matters such as grievances, concerns and other possibly relevant information. This email serves as our grievance mechanism. |
2.Identify and assess risk in the supply chain
a. We request that suppliers provide us with information concerning the usage and source of 3TG in the parts that they sell to us and their related compliance efforts through the completion of a Conflict Minerals Reporting Template. We |
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follow up by email with suppliers that do not respond to the request within a specified time frame. |
b. Our IT solution utilizes programming logic to review the Conflict Minerals Reporting Templates that we receive from suppliers and flags responses not conforming to specified criteria. |
c. Smelter and refiner data is reviewed for us through the IT solution and by the Reviewer to verify, to the extent known by the Reviewer based on its research and other information as described earlier in this Conflict Minerals Report, (a) the validity of the smelters and refiners identified to us by the suppliers, (b) the audit status of such smelters and refiners, (c) the country of origin of the 3TG processed by such smelters and refiners, (d) the plausibility of the identified countries of origin having 3TG reserves or mines, and (e) whether such smelters and refiners obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. |
3.Design and implement a strategy to respond to identified risks
We have procedures for monitoring and reporting on risk to designated senior management, including our Executive Vice President, General Counsel and Secretary, on an ongoing basis. Pursuant to these procedures, our 3TG compliance team also reports the findings of its compliance efforts to a steering committee comprised of management personnel from our global supply chain, regulatory affairs, legal, and research and development functions.
We utilize a risk mitigation framework that allows for a flexible response commensurate with the risks identified. Under the framework, actions range from supplier education and follow-up to discontinuing purchases from a supplier.
In addition, to the extent that identified smelters and refiners are not listed as conformant, we seek to exercise leverage over these smelters and refiners to become so through our participation in and support of the RMI. We also utilize information provided by the RMI to its members to monitor smelter and refiner improvement.
4.Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
We support the RMAP through our membership in the RMI. The RMAP uses an independent third-party audit of smelter and refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The audit employs a risk-based approach to validate smelters’ and refiners’ company level management processes for responsible mineral procurement.
In connection with our due diligence, we utilize and rely on information made available by the RMI concerning RMAP audits to assess smelter and refiner due diligence and to determine whether a smelter or refiner is conformant.
The data on which we relied for certain statements in this Conflict Minerals Report was obtained through our membership in the RMI.
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5.Report on supply chain due diligence
We file a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission and make these documents available on our website at https://www.ecolab.com/about/suppliers/conflict-mineral-policy.
III.Due Diligence Measures Performed by Ecolab
Ecolab has performed the due diligence and related measures set forth below in respect of 2017. These are not all of the measures that we took in respect of 2017 in furtherance of our Conflict Minerals Policy and 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance.
We continued to refine and improve our product scoping processes. These process improvements led to a 40% reduction in the number of our in-scope suppliers, thereby enabling us to better focus our risk mitigation efforts.
We sent requests to our in-scope suppliers to provide us with a completed Conflict Minerals Reporting Template. We made repeated follow-up requests with the suppliers that did not provide a response within the specified time frame.
We reviewed the completed responses received from the suppliers based on our approved review criteria to identify incomplete responses and specified sourcing risks and sent follow-up emails to suppliers providing incomplete or non-conforming responses.
This year we implemented a new IT solution managed by a third party. This IT solution provided better functionality and processes for validating data. We utilized the IT solution and the Reviewer to verify, to the extent known by the Reviewer based on its research and other information as described in this Conflict Minerals Report, (a) the validity of the smelters and refiners identified to us by the suppliers, (b) the audit status of such smelters and refiners, (c) the country of origin of the 3TG processed by such smelters and refiners, (d) the plausibility of the identified countries of origin having 3TG reserves or mines, and (e) whether such smelters and refiners obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country.
Our 3TG compliance team reported the findings of its compliance efforts in respect of 2017 to our management steering committee, which is described earlier in this Conflict Minerals Report.
We participated in independent third-party audits of smelters and refiners through our membership in the RMI. In addition, our Conflict Minerals practices team personnel were members of the RMI due diligence practices team.
IV.Product, Smelter and Refiner and Country of Origin Information
In-Scope Product Categories
For 2017, our in-scope products were in the following product categories:
A. Equipment used for the control and dispensing of chemical products.
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B. Healthcare patient management systems and other miscellaneous components related to our Healthcare products.
Identified Smelters and Refiners
In connection with our due diligence, the suppliers identified to us the verified smelters and refiners listed in Annex I and Annex II below as having processed the necessary 3TG contained in our in-scope products in 2017. However, not all of the included smelters and refiners may have processed the necessary 3TG contained in our in-scope products. In some cases, suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners listed in the Annexes may not be all of the smelters and refiners in our supply chain, since the suppliers may have been unable to identify the smelters and refiners of some of the necessary 3TG content contained in our in-scope products and because not all suppliers responded to our inquiries.
Annex I provides a list of smelters and refiners reported by the RMI as conformant with applicable RMAP assessment protocols or active with respect to progressing to compliance with such protocols. Annex II provides a list of verified smelters and refiners that were not conformant or active.
Potential Countries of Origin
In addition to sourcing from recycled and scrap sources, based on information received from the Reviewer, Ecolab believes the country of origin of the 3TG sourced by the smelters and refiners in the Annexes may include the following: Angola, Argentina, Australia, Austria, Bolivia, Brazil, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Republic of the Congo, Czech Republic, the DRC, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, India, Indonesia, Ireland, Ivory Coast, Japan, Kazakhstan, Kyrgyzstan, Laos, Madagascar, Malaysia, Mexico, Mongolia, Mozambique, New Zealand, Nigeria, Peru, Philippines, Poland, Portugal, Republic of Korea, Russian Federation, Rwanda, South Africa, Spain, Switzerland, Taiwan, Thailand, Turkey, United States, Viet Nam, and Zimbabwe.
For 2017, notwithstanding our compliance efforts, we may not have been able to determine the facilities at which at least a portion of the necessary 3TG contained in each of our in-scope products were processed. We also may not have been able to determine the country of origin for at least a portion of the necessary 3TG contained in each of our in-scope products. None of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
We endeavored to determine the mine or location of origin of the necessary 3TG contained in our in-scope products by requesting that the suppliers provide us with a completed Conflict Minerals Reporting Template and through the other measures described in this Conflict Minerals Report. Additionally, information made available by the RMI to its members and the Reviewer assisted us in determining whether the smelters and refiners identified to us by our suppliers obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country to the extent known by the Reviewer from its research.
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V.Steps to Improve Due Diligence
We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:
· | Continue to refine scoping efforts to reduce the number of suppliers that we believe supply us with components, parts or products containing 3TG. |
· | Increase engagement with suppliers that were unresponsive or provided non-conforming responses. |
· | Utilize the improved functionality provided by our IT solution to increase the number of product-level responses received from our suppliers. |
· | Continue our membership in the RMI. |
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ANNEX I
List of Facilities Conformant with RMAP Protocols or on RMI Active List
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
Advanced Chemical Company | Gold | Conformant | United States |
Aida Chemical Industries Co., Ltd. | Gold | Conformant | Japan |
Al Etihad Gold LLC | Gold | Conformant | United Arab Emirates |
Allgemeine Gold-und Silberscheideanstalt A.G. | Gold | Conformant | Germany |
Almalyk Mining and Metallurgical Complex (AMMC) | Gold | Conformant | Uzbekistan |
AngloGold Ashanti Corrego do Sitio Mineracao | Gold | Conformant | Brazil |
Argor-Heraeus S.A. | Gold | Conformant | Switzerland |
Asahi Pretec Corp. | Gold | Conformant | Japan |
Asahi Refining Canada Ltd. | Gold | Conformant | Canada |
Asahi Refining USA Inc. | Gold | Conformant | United States |
Asaka Riken Co., Ltd. | Gold | Conformant | Japan |
AU Traders and Refiners | Gold | Conformant | South Africa |
Aurubis AG | Gold | Conformant | Germany |
Bangalore Refinery | Gold | Active | India |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Gold | Conformant | Philippines |
Boliden AB | Gold | Conformant | Sweden |
C. Hafner GmbH + Co. KG | Gold | Conformant | Germany |
Cendres + Metaux S.A. | Gold | Conformant | Switzerland |
Chimet S.p.A. | Gold | Conformant | Italy |
Daejin Indus Co., Ltd. | Gold | Conformant | Republic of Korea |
DODUCO Contacts and Refining GmbH | Gold | Conformant | Germany |
Dowa | Gold | Conformant | Japan |
DS PRETECH Co., Ltd. | Gold | Active | Republic of Korea |
DSC (Do Sung Corporation) | Gold | Conformant | Republic of Korea |
Eco-System Recycling Co., Ltd. | Gold | Conformant | Japan |
Emirates Gold DMCC | Gold | Conformant | United Arab Emirates |
Geib Refining Corporation | Gold | Conformant | United States |
Gold Refinery of Zijin Mining Group Co., Ltd. | Gold | Conformant | China |
HeeSung Metal Ltd. | Gold | Conformant | Republic of Korea |
Heimerle + Meule GmbH | Gold | Conformant | Germany |
Heraeus Metals Hong Kong Ltd. | Gold | Conformant | China |
Heraeus Precious Metals GmbH & Co. KG | Gold | Conformant | Germany |
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | Gold | Conformant | China |
Ishifuku Metal Industry Co., Ltd. | Gold | Conformant | Japan |
Istanbul Gold Refinery | Gold | Conformant | Turkey |
Italpreziosi | Gold | Conformant | Italy |
Japan Mint | Gold | Conformant | Japan |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold | Conformant | Russian Federation |
JSC Uralelectromed | Gold | Conformant | Russian Federation |
JX Nippon Mining & Metals Co., Ltd. | Gold | Conformant | Japan |
Kazzinc | Gold | Conformant | Kazakhstan |
Kennecott Utah Copper LLC | Gold | Conformant | United States |
KGHM Polska Miedz Spolka Akcyjna | Gold | Active | Poland |
Kojima Chemicals Co., Ltd. | Gold | Conformant | Japan |
Korea Zinc Co., Ltd. | Gold | Conformant | Republic of Korea |
Kyrgyzaltyn JSC | Gold | Conformant | Kyrgyzstan |
L’Orfebre S.A. | Gold | Active | Andorra |
LS-NIKKO Copper Inc. | Gold | Conformant | Republic of Korea |
Marsam Metals | Gold | Conformant | Brazil |
Materion | Gold | Conformant | United States |
Matsuda Sangyo Co., Ltd. | Gold | Conformant | Japan |
Metalor Technologies (Hong Kong) Ltd. | Gold | Conformant | China |
Metalor Technologies (Singapore) Pte., Ltd. | Gold | Conformant | Singapore |
Metalor Technologies (Suzhou) Ltd. | Gold | Conformant | China |
Metalor Technologies S.A. | Gold | Conformant | Switzerland |
Metalor USA Refining Corporation | Gold | Conformant | United States |
Metalurgica Met-Mex Penoles S.A. De C.V. | Gold | Conformant | Mexico |
Mitsubishi Materials Corporation | Gold | Conformant | Japan |
Mitsui Mining and Smelting Co., Ltd. | Gold | Conformant | Japan |
MMTC-PAMP India Pvt., Ltd. | Gold | Conformant | India |
Modeltech Sdn Bhd | Gold | Active | Malaysia |
Moscow Special Alloys Processing Plant | Gold | Conformant | Russian Federation |
Nadir Metal Rafineri San. Ve Tic. A.S. | Gold | Conformant | Turkey |
NH Recytech Company | Gold | Active | Republic of Korea |
Nihon Material Co., Ltd. | Gold | Conformant | Japan |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Gold | Conformant | Austria |
Ohura Precious Metal Industry Co., Ltd. | Gold | Conformant | Japan |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold | Conformant | Russian Federation |
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
OJSC Novosibirsk Refinery | Gold | Conformant | Russian Federation |
PAMP S.A. | Gold | Conformant | Switzerland |
Planta Recuperadora de Metales SpA | Gold | Conformant | Chile |
Prioksky Plant of Non-Ferrous Metals | Gold | Conformant | Russian Federation |
PT Aneka Tambang (Persero) Tbk | Gold | Conformant | Indonesia |
PX Precinox S.A. | Gold | Conformant | Switzerland |
Rand Refinery (Pty) Ltd. | Gold | Conformant | South Africa |
Remondis Argentia B.V. | Gold | Active | Netherlands |
Republic Metals Corporation | Gold | Conformant | United States |
Royal Canadian Mint | Gold | Conformant | Canada |
SAAMP | Gold | Conformant | France |
Safimet S.p.A. | Gold | Conformant | Italy |
SAFINA A.S. | Gold | Active | Czech Republic |
Samduck Precious Metals | Gold | Conformant | Republic of Korea |
SAMWON METALS Corp. | Gold | Conformant | Republic of Korea |
SAXONIA Edelmetalle GmbH | Gold | Conformant | Germany |
SEMPSA Joyeria Plateria S.A. | Gold | Conformant | Spain |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Gold | Conformant | China |
Sichuan Tianze Precious Metals Co., Ltd. | Gold | Conformant | China |
Singway Technology Co., Ltd. | Gold | Conformant | Taiwan |
SOE Shyolkovsky Factory of Secondary Precious Metals | Gold | Conformant | Russian Federation |
Solar Applied Materials Technology Corp. | Gold | Conformant | Taiwan |
Sumitomo Metal Mining Co., Ltd. | Gold | Conformant | Japan |
SungEel HiMetal Co., Ltd. | Gold | Conformant | Republic of Korea |
T.C.A. S.p.A. | Gold | Conformant | Italy |
Tanaka Kikinzoku Kogyo K.K. | Gold | Conformant | Japan |
The Refinery of Shandong Gold Mining Co., Ltd. | Gold | Conformant | China |
Tokuriki Honten Co., Ltd. | Gold | Conformant | Japan |
Torecom | Gold | Conformant | Republic of Korea |
Umicore Brasil Ltda. | Gold | Conformant | Brazil |
Umicore Precious Metals Thailand | Gold | Conformant | Thailand |
Umicore S.A. Business Unit Precious Metals Refining | Gold | Conformant | Belgium |
United Precious Metal Refining, Inc. | Gold | Conformant | United States |
Valcambi S.A. | Gold | Conformant | Switzerland |
Western Australian Mint (T/a The Perth Mint) | Gold | Conformant | Australia |
WIELAND Edelmetalle GmbH | Gold | Conformant | Germany |
Yamakin Co., Ltd. | Gold | Conformant | Japan |
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
Yokohama Metal Co., Ltd. | Gold | Conformant | Japan |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Gold | Conformant | China |
Asaka Riken Co., Ltd. | Tantalum | Conformant | Japan |
Changsha South Tantalum Niobium Co., Ltd. | Tantalum | Conformant | China |
D Block Metals, LLC | Tantalum | Conformant | United States |
Exotech Inc. | Tantalum | Conformant | United States |
F&X Electro-Materials Ltd. | Tantalum | Conformant | China |
FIR Metals & Resource Ltd. | Tantalum | Conformant | China |
Global Advanced Metals Aizu | Tantalum | Conformant | Japan |
Global Advanced Metals Boyertown | Tantalum | Conformant | United States |
Guangdong Rising Rare Metals-EO Materials Ltd. | Tantalum | Conformant | China |
Guangdong Zhiyuan New Material Co., Ltd. | Tantalum | Conformant | China |
H.C. Starck Co., Ltd. | Tantalum | Conformant | Thailand |
H.C. Starck Hermsdorf GmbH | Tantalum | Conformant | Germany |
H.C. Starck Inc. | Tantalum | Conformant | United States |
H.C. Starck Ltd. | Tantalum | Conformant | Japan |
H.C. Starck Smelting GmbH & Co. KG | Tantalum | Conformant | Germany |
H.C. Starck Tantalum and Niobium GmbH | Tantalum | Conformant | Germany |
Hengyang King Xing Lifeng New Materials Co., Ltd. | Tantalum | Conformant | China |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Tantalum | Conformant | China |
Jiangxi Tuohong New Raw Material | Tantalum | Conformant | China |
JiuJiang Janny New Material Co., Ltd. | Tantalum | Conformant | China |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tantalum | Conformant | China |
Jiujiang Tanbre Co., Ltd. | Tantalum | Conformant | China |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Tantalum | Conformant | China |
KEMET Blue Metals | Tantalum | Conformant | Mexico |
Kemet Blue Powder | Tantalum | Conformant | United States |
LSM Brasil S.A. | Tantalum | Conformant | Brazil |
Metallurgical Products India Pvt., Ltd. | Tantalum | Conformant | India |
Mineracao Taboca S.A. | Tantalum | Conformant | Brazil |
Mitsui Mining and Smelting Co., Ltd. | Tantalum | Conformant | Japan |
Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum | Conformant | China |
NPM Silmet AS | Tantalum | Conformant | Estonia |
Power Resources Ltd. | Tantalum | Conformant | Macedonia |
QuantumClean | Tantalum | Conformant | United States |
Resind Industria e Comercio Ltda. | Tantalum | Conformant | Brazil |
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | Tantalum | Conformant | China |
12
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
Solikamsk Magnesium Works OAO | Tantalum | Conformant | Russian Federation |
Taki Chemical Co., Ltd. | Tantalum | Conformant | Japan |
Telex Metals | Tantalum | Conformant | United States |
Ulba Metallurgical Plant JSC | Tantalum | Conformant | Kazakhstan |
XinXing Haorong Electronic Material Co., Ltd. | Tantalum | Conformant | China |
Alpha | Tin | Conformant | United States |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | Tin | Conformant | China |
Chifeng Dajingzi Tin Industry Co., Ltd. | Tin | Conformant | China |
China Tin Group Co., Ltd. | Tin | Conformant | China |
CNMC (Guangxi) PGMA Co., Ltd. | Tin | Conformant | China |
CV Ayi Jaya | Tin | Conformant | Indonesia |
CV Dua Sekawan | Tin | Conformant | Indonesia |
CV Gita Pesona | Tin | Conformant | Indonesia |
CV United Smelting | Tin | Conformant | Indonesia |
CV Venus Inti Perkasa | Tin | Conformant | Indonesia |
Dowa | Tin | Conformant | Japan |
EM Vinto | Tin | Conformant | Bolivia |
Fenix Metals | Tin | Conformant | Poland |
Gejiu Fengming Metallurgy Chemical Plant | Tin | Conformant | China |
Gejiu Jinye Mineral Company | Tin | Conformant | China |
Gejiu Kai Meng Industry and Trade LLC | Tin | Conformant | China |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | Tin | Conformant | China |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | Tin | Conformant | China |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | Tin | Conformant | China |
Guanyang Guida Nonferrous Metal Smelting Plant | Tin | Conformant | China |
HuiChang Hill Tin Industry Co., Ltd. | Tin | Conformant | China |
Huichang Jinshunda Tin Co., Ltd. | Tin | Conformant | China |
Jiangxi Ketai Advanced Material Co., Ltd. | Tin | Conformant | China |
Jiangxi New Nanshan Technology Ltd. | Tin | Conformant | China |
Magnu's Minerais Metais e Ligas Ltda. | Tin | Conformant | Brazil |
Malaysia Smelting Corporation (MSC) | Tin | Conformant | Malaysia |
Melt Metais e Ligas S.A. | Tin | Conformant | Brazil |
Metallic Resources, Inc. | Tin | Conformant | United States |
Metallo Belgium N.V. | Tin | Conformant | Belgium |
Metallo Spain S.L.U. | Tin | Conformant | Spain |
Mineracao Taboca S.A. | Tin | Conformant | Brazil |
Minsur | Tin | Conformant | Peru |
Mitsubishi Materials Corporation | Tin | Conformant | Japan |
Modeltech Sdn Bhd | Tin | Active | Malaysia |
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
O.M. Manufacturing (Thailand) Co., Ltd. | Tin | Conformant | Thailand |
O.M. Manufacturing Philippines, Inc. | Tin | Conformant | Philippines |
Operaciones Metalurgical S.A. | Tin | Conformant | Bolivia |
PT Aries Kencana Sejahtera | Tin | Conformant | Indonesia |
PT Artha Cipta Langgeng | Tin | Conformant | Indonesia |
PT ATD Makmur Mandiri Jaya | Tin | Conformant | Indonesia |
PT Babel Inti Perkasa | Tin | Conformant | Indonesia |
PT Babel Surya Alam Lestari | Tin | Active | Indonesia |
PT Bangka Prima Tin | Tin | Conformant | Indonesia |
PT Bangka Serumpun | Tin | Conformant | Indonesia |
PT Bangka Tin Industry | Tin | Conformant | Indonesia |
PT Belitung Industri Sejahtera | Tin | Conformant | Indonesia |
PT Bukit Timah | Tin | Conformant | Indonesia |
PT DS Jaya Abadi | Tin | Conformant | Indonesia |
PT Eunindo Usaha Mandiri | Tin | Conformant | Indonesia |
PT Inti Stania Prima | Tin | Conformant | Indonesia |
PT Karimun Mining | Tin | Conformant | Indonesia |
PT Kijang Jaya Mandiri | Tin | Conformant | Indonesia |
PT Lautan Harmonis Sejahtera | Tin | Conformant | Indonesia |
PT Menara Cipta Mulia | Tin | Conformant | Indonesia |
PT Mitra Stania Prima | Tin | Conformant | Indonesia |
PT Panca Mega Persada | Tin | Conformant | Indonesia |
PT Premium Tin Indonesia | Tin | Conformant | Indonesia |
PT Prima Timah Utama | Tin | Conformant | Indonesia |
PT Rajehan Ariq | Tin | Conformant | Indonesia |
PT Refined Bangka Tin | Tin | Conformant | Indonesia |
PT Sariwiguna Binasentosa | Tin | Conformant | Indonesia |
PT Stanindo Inti Perkasa | Tin | Conformant | Indonesia |
PT Sukses Inti Makmur | Tin | Conformant | Indonesia |
PT Sumber Jaya Indah | Tin | Conformant | Indonesia |
PT Timah (Persero) Tbk Kundur | Tin | Conformant | Indonesia |
PT Timah (Persero) Tbk Mentok | Tin | Conformant | Indonesia |
PT Tinindo Inter Nusa | Tin | Conformant | Indonesia |
PT Tommy Utama | Tin | Conformant | Indonesia |
Resind Industria e Comercio Ltda. | Tin | Conformant | Brazil |
Rui Da Hung | Tin | Conformant | Taiwan |
Soft Metais Ltda. | Tin | Conformant | Brazil |
Thaisarco | Tin | Conformant | Thailand |
White Solder Metalurgia e Mineracao Ltda. | Tin | Conformant | Brazil |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | Tin | Conformant | China |
Yunnan Tin Company Limited | Tin | Conformant | China |
14
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
A.L.M.T. TUNGSTEN Corp. | Tungsten | Conformant | Japan |
ACL Metais Eireli | Tungsten | Conformant | Brazil |
Asia Tungsten Products Vietnam Ltd. | Tungsten | Conformant | Viet Nam |
Chenzhou Diamond Tungsten Products Co., Ltd. | Tungsten | Conformant | China |
Chongyi Zhangyuan Tungsten Co., Ltd. | Tungsten | Conformant | China |
Fujian Jinxin Tungsten Co., Ltd. | Tungsten | Conformant | China |
Ganzhou Haichuang Tungsten Industry Co., Ltd. | Tungsten | Active | China |
Ganzhou Huaxing Tungsten Products Co., Ltd. | Tungsten | Conformant | China |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Tungsten | Conformant | China |
Ganzhou Seadragon W & Mo Co., Ltd. | Tungsten | Conformant | China |
Global Tungsten & Powders Corp. | Tungsten | Conformant | United States |
Guangdong Xianglu Tungsten Co., Ltd. | Tungsten | Conformant | China |
H.C. Starck Smelting GmbH & Co. KG | Tungsten | Conformant | Germany |
H.C. Starck Tungsten GmbH | Tungsten | Conformant | Germany |
Hunan Chenzhou Mining Co., Ltd. | Tungsten | Conformant | China |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | Tungsten | Conformant | China |
Hunan Chunchang Nonferrous Metals Co., Ltd. | Tungsten | Conformant | China |
Hydrometallurg, JSC | Tungsten | Conformant | Russian Federation |
Japan New Metals Co., Ltd. | Tungsten | Conformant | Japan |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Tungsten | Conformant | China |
Jiangxi Gan Bei Tungsten Co., Ltd. | Tungsten | Conformant | China |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Tungsten | Conformant | China |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Tungsten | Conformant | China |
Jiangxi Yaosheng Tungsten Co., Ltd. | Tungsten | Conformant | China |
Kennametal Fallon | Tungsten | Conformant | United States |
Kennametal Huntsville | Tungsten | Conformant | United States |
Malipo Haiyu Tungsten Co., Ltd. | Tungsten | Conformant | China |
Moliren Ltd. | Tungsten | Conformant | Russian Federation |
Niagara Refining LLC | Tungsten | Conformant | United States |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Tungsten | Conformant | Viet Nam |
Philippine Chuangxin Industrial Co., Inc. | Tungsten | Conformant | Philippines |
South-East Nonferrous Metal Company Limited of Hengyang City | Tungsten | Conformant | China |
Tejing (Vietnam) Tungsten Co., Ltd. | Tungsten | Conformant | Viet Nam |
15
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Smelter or Refiner Name | Mineral | Smelter or | Smelter or |
Unecha Refractory Metals Plant | Tungsten | Conformant | Russian Federation |
Vietnam Youngsun Tungsten Industry Co., Ltd. | Tungsten | Conformant | Viet Nam |
Wolfram Bergbau und Hutten AG | Tungsten | Conformant | Austria |
Woltech Korea Co., Ltd. | Tungsten | Conformant | Republic of Korea |
Xiamen Tungsten (H.C.) Co., Ltd. | Tungsten | Conformant | China |
Xiamen Tungsten Co., Ltd. | Tungsten | Conformant | China |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | Tungsten | Conformant | China |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Tungsten | Conformant | China |
The following notes apply to Annex I above:
(1) | “Conformant” means that a smelter or refiner was conformant with the Responsible Minerals Assurance Process (“RMAP”) assessment protocols. Smelters and refiners with a “re-audit in progress” are still considered to be RMAP conformant |
(2) | “Active” means that the smelter or refiner is a participant in the RMAP and has committed to undergo an audit or is participating in a cross-recognized certification program. |
(3) | The designations of Conformant and Active and the smelter or refiner location reflected in the table are based solely on information made publicly available by the RMI, without independent verification by us. |
16
ANNEX II
List of Verified Facilities Not Otherwise Listed as Conformant or Active
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Smelter or Refiner Name | Mineral | Smelter or |
Abington Reldan Metals, LLC | Gold | United States |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Gold | Turkey |
Caridad | Gold | Mexico |
Chugai Mining | Gold | Japan |
Daye Non-Ferrous Metals Mining Ltd. | Gold | China |
Degussa Sonne / Mond Goldhandel GmbH | Gold | Germany |
GCC Gurjat Gold Centre Pvt. Ltd. | Gold | India |
Great Wall Precious Metals Co., Ltd. of CBPM | Gold | China |
Guangdong Jinding Gold Limited | Gold | China |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. | Gold | China |
Hangzhou Fuchunjiang Smelting Co., Ltd. | Gold | China |
Hunan Chenzhou Mining Co., Ltd. | Gold | China |
HwaSeong CJ CO., LTD. | Gold | Republic of Korea |
Kazakhmys Smelting LLC | Gold | Kazakhstan |
Kyshtym Copper-Electrolytic Plant ZAO | Gold | Russian Federation |
L'azurde Company For Jewelry | Gold | Saudi Arabia |
Lingbao Gold Co., Ltd. | Gold | China |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Gold | China |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | Gold | China |
Morris and Watson | Gold | New Zealand |
Morris and Watson Gold Coast | Gold | Australia |
Navoi Mining and Metallurgical Combinat | Gold | Uzbekistan |
Pease & Curren | Gold | United States |
Penglai Penggang Gold Industry Co., Ltd. | Gold | China |
Refinery of Seemine Gold Co., Ltd. | Gold | China |
Sabin Metal Corp. | Gold | United States |
Sai Refinery | Gold | India |
SAMWON Metals Corp. | Gold | Republic of Korea |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Gold | China |
State Research Institute Center for Physical Sciences and Technology | Gold | Lithuania |
Tongling Nonferrous Metals Group Co., Ltd. | Gold | China |
Tony Goetz NV | Gold | Belgium |
TOO Tau-Ken-Altyn | Gold | Kazakhstan |
Universal Precious Metals Refining Zambia | Gold | Zambia |
Yunnan Copper Industry Co., Ltd. | Gold | China |
Duoluoshan | Tantalum | China |
17
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Smelter or Refiner Name | Mineral | Smelter or |
An Vinh Joint Stock Mineral Processing Company | Tin | Viet Nam |
CNMC (Guangxi) PGMA Co., Ltd. | Tin | China |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Tin | Viet Nam |
Estanho de Rondonia S.A. | Tin | Brazil |
Gejiu Zili Mining And Metallurgy Co., Ltd. | Tin | China |
Nghe Tinh Non-Ferrous Metals Joint Stock Company | Tin | Viet Nam |
Pongpipat Company Limited | Tin | Myanmar |
Super Ligas | Tin | Brazil |
Tuyen Quang Non-Ferrous Metals Joint Stock Company | Tin | Viet Nam |
Ganzhou Yatai Tungsten Co., Ltd. | Tungsten | China |
Hunan Litian Tungsten Industry Co., Ltd. | Tungsten | China |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. | Tungsten | China |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Tungsten | China |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Tungsten | China |
18
