Exhibit 1.01
H.B. FULLER COMPANY
Conflict Minerals Report
For the reporting period from January 1, 2021 to December 31, 2021
This Conflict Minerals Report (the “Report”) of H.B. Fuller Company (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities and Exchange Act of 1934, as amended, for the reporting period from January 1, 2021 to December 31, 2021.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products, and the Conflict Minerals are necessary to the functionality of those products.
If a registrant has reason to believe that any of the Conflict Minerals necessary to the functionality or production of their products may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the source of the Conflict Minerals. The registrant must annually submit a report, Conflict Minerals Report (a “CMR”), to the U.S. Securities and Exchange Commission (the “SEC”) that includes a description of those due diligence measures.
1. | Introduction. |
a. | Company Overview. The Company is a leading worldwide formulator, manufacturer and marketer of adhesives, sealants and other specialty chemical products. Sales operations span 35 countries in North America, Europe, Latin America, the Asia Pacific region, India, the Middle East and Africa. Industrial adhesives represent our core product offering. Customers use our adhesives products in manufacturing common consumer and industrial goods, including food and beverage containers, disposable diapers, windows, doors, flooring, roofing, appliances, sportswear, footwear, multi-wall bags, water filtration products, insulation, textiles, automobiles, recreational vehicles, buses, trucks and trailers, marine products, solar energy systems, electronics and products for the aerospace and defense industries. Our adhesives help improve the performance of our customers’ products or improve their manufacturing processes. We also provide our customers with technical support and unique solutions designed to address their specific needs. In addition, we have established a variety of product offerings for residential construction markets, such as tile-setting adhesives, grout, sealants and related products. |
b. | Conflict Minerals Compliance Program (CMCP) Description. The SEC Final Conflict Minerals Rule (the “SEC Final Rule”) requires a three-step compliance process: the first step is determining the applicability of the Rule; the second step is conducting a “reasonable country of origin inquiry” (RCOI) to determine whether or not there is reason to believe that tin, tantalum, tungsten, or gold (3TG), also referred to as Conflict Minerals, from the Democratic Republic of the Congo or adjoining countries are present in the company’s products; and if so, the third step is conducting due diligence to determine the source and origin of those Conflict Minerals based on the facilities (smelter or refiners, “SORs”) in which they were processed. Companies requiring due diligence must use a nationally or internationally recognized standard such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance1) to meet the SEC regulatory requirements. The sections below describe our approach to meet each of the three steps in the SEC Final Rule compliance process; these activities were completed in concert with a third party vendor. |
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
2. | Applicability of the Conflict Minerals Rule. |
a. | Product Overview. This report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2021. These products (referred to collectively as “Covered Products” in this Report) are the following: |
• | Certain equipment used or sold in our Adhesive Coated Products business, which the Company manufactures or contracts to manufacture, which contain electronic components and materials. |
• | Certain products manufactured or assembled by Engent, Inc. ("Engent"), a wholly owned subsidiary of the Company, for its customers which contain electronic components and materials. Engent, Inc. is a wholly owned subsidiary of the Company and is a provider of manufacturing, research and development services to the electronics industry. |
• | Certain equipment manufactured or assembled by Tonsan Adhesive, Inc. ("Tonsan"), a majority owned subsidiary of the Company, for its customers which contain electronic components and materials. Tonsan, which is based in Beijing, China, manufactures engineering adhesives across numerous industries including photovoltaic, electronics, automotive, heavy machinery and transportation. |
3. Reasonable Country of Origin Inquiry (RCOI). The Company has conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap resources. |
To complete the RCOI required by the SEC Final Rule, we engaged the Company’s applicable suppliers to collect information about the presence and sourcing of tantalum, tin, tungsten and gold (3TG) used in the products and components supplied to H.B. Fuller. The program utilized the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (CMRT). Only CMRT version 5.0 or higher was accepted. Suppliers were offered two options to submit the required information: either by uploading the CMRT in MS Excel format or by completing an online survey version of this template directly in the vendor platform. In certain cases, if a supplier was unable to complete on the platform, H.B. Fuller or its third-party vendor uploaded the CMRT on their behalf.
The RCOI began with an introduction email sent by H.B. Fuller to its relevant suppliers describing the Conflict Minerals Compliance Program (CMCP) and identifying our vendor as a partner in the process. Following that, our vendor sent a subsequent email to suppliers containing a registration and survey request link for the on-line data collection platform.
Subsequent engagement followed these steps:
• | Following the initial introductions to the program and information request, up to four reminder emails were sent to each non-responsive supplier requesting survey completion. |
• | For suppliers who remained non-responsive to these email reminders, an escalation process was initiated. The Company contacted the non-responsive suppliers to request their participation in the program. |
Suppliers were asked to provide information regarding the sourcing of their materials with the goal of identifying the 3TG smelters or refiners (“SORs”) and associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT were asked to upload this document into the vendor system or to provide this information in the online survey version.
The Company gave its suppliers the ability to share information at a level with which they were most comfortable (i.e. company, product or user-defined), but the declaration scope had to be specified.
Suppliers were requested to provide an electronic signature before submitting their data to the Company to verify that all answers submitted were accurate to the best of the supplier’s knowledge, but the suppliers were not required to provide an electronic signature to submit their data.
Supplier responses were evaluated for plausibility, consistency, and gaps. If any of the following “quality control” (QC) flags were raised, suppliers were contacted by the vendor on a bi-weekly basis up to three times.
• | One or more smelter or refiners (SORs) were listed for an unused metal; |
• | SOR information was not provided for a used metal, or SOR information provided was not a verified metal processor; |
• | Supplier answered yes to sourcing from the Democratic Republic of the Congo or adjoining countries (“DRC”), but none of the SORs listed are known to source from the region; |
• | Supplier indicated that they have not received Conflict Minerals data for each metal from all relevant suppliers; | |
| ||
• | Supplier indicated they have not identified all of the SORs used for the products included in the declaration scope; |
• | Supplier indicated they have not provided all applicable SOR information received; and; |
• | Supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more SORs listed are not known to be exclusive recyclers. |
In response to our RCOI, most suppliers confirmed that their products originated from countries other than Covered Countries. Some suppliers indicated that their products included Conflict Minerals which originated from the Covered Countries. The majority of those suppliers indicated that such Conflict Minerals were from smelters that were certified as noted on Schedule 1.
4. Design of Due Diligence Framework. The Company’s due diligence measures have been designed to conform to the framework in the OECD Guidance in all material respects.
5. Due Diligence Measures Performed. The Company has adopted a policy relating to the Conflict Minerals (the “Company Policy”), incorporating the standards set forth in the OECD Guidance. The policy generally states that the Company is committed to ethical practices and compliance with applicable laws and regulations, including the SEC’s regulations and the Conflict Minerals Rules. The Company does not generally source Conflict Minerals directly from the source of supply (mines, smelters, refiners) and the Company is therefore generally removed by several levels from sources of supply of Conflict Minerals. The Company Policy commits the Company to diligently work with its global supply chain partners to identify the origin of any Conflict Minerals they may supply to the Company. The Company is committed to compliance with the Conflict Minerals Rules, including understanding the Conflict Minerals Rules, communicating and educating our personnel, suppliers and customers regarding the Conflict Minerals Rules and to create processes and procedures to conduct supply chain due diligence and comply with reporting requirements. The Company values its supplier and customer relationships and will work with our suppliers over time to ensure our compliance with the Conflict Minerals Rules.
The Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and has therefore asked its suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. Most of the suppliers who provided information regarding smelters provided this information on a company level versus a product level. Therefore, we do not know if the materials from the smelters we have included in this Conflict Minerals Report are in our products. It is possible that we may not get product level information.
The Company has a steering committee which oversees the activities of a multi-functional group of personnel who have worked on due diligence and compliance related to Conflict Minerals. The composition of the steering committee includes two executive level officers. The multi-functional group includes employees from the Company covering areas such as regulatory, sourcing, finance, legal, and operations.
In general, in our initial compliance efforts, a review of products and raw materials contained therein (including chemical composition) or components (for equipment) was completed and a list of suppliers of raw materials or components where Conflict Minerals were determined to be potentially present was assembled. New products and the raw materials used in those products are reviewed as such products are developed. The focus has been on top-tier suppliers of these raw materials or components. For these top-tier suppliers, the Company used a third-party vendor to send out questionnaires including the EICC®-GeSI form (“Supplier Questionnaire”) to inquire about the country of origin of Conflict Minerals potentially included in the Company’s Covered Products. This template 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 supplier’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the supplier and its suppliers use. In addition, the template 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 EICC’s website. Responses to these questionnaires were monitored and follow-up communication was sent if a response was not received. The Company has not had any direct contact with mines, smelters or refiners.
The Company has undertaken an internal education process to ensure that relevant personnel are aware of the Conflict Minerals Rules and it has conducted training of several employee groups since the inception of due diligence efforts. In addition, it has designated personnel to respond to customer and supplier inquiries regarding the Conflict Minerals Rules. These personnel are part of the multi-functional group working on due diligence and compliance efforts.
The Company will review any suppliers who are materially non-compliant with our Conflict Minerals Policy and communicate the Company’s expectation regarding compliance with our Conflict Minerals Policy. The Company will make reasonable efforts to find suppliers who comply with our Conflict Minerals Policy and who will meet our needs. The products that we manufacture that are subject to the reporting obligations of the Rule contain 3TG of unknown origin. We have not been able to determine whether the 3TG used in our products came from recycled or scrap sources, or if not, whether the 3TG originated from a Covered Country, or the specific facilities used to process these minerals, or their specific country, location or mine of origin.
Facilities That May Have Been Used to Process Necessary Conflict Minerals, if Known, for H.B. Fuller Products.
Schedule 1 to this Conflict Minerals Report includes a list of facilities that may have been used to process necessary Conflict Minerals for Company products. This list is based on our due diligence for 2021. Most of the information was provided to us on a company level versus a product level, and the suppliers did not generally limit their responses to facility information for Conflict Minerals in products they supply to us specifically.
Countries of Origin of the Conflict Minerals Processed by These Facilities.
Schedule 2 to this Conflict Minerals Report includes a list of potential countries of origin for each facility noted on the Schedule to the extent identified by the applicable smelter. Conflict Minerals contained in our Covered Products did not necessarily originate in the countries listed on Schedule 2. This is because our suppliers and manufacturers generally provided smelter and country of origin information in the survey responses at the company level (representing the suppliers’ and manufacturers’ entire product lines), and generally did not limit their responses to countries of origin for products they supply to us specifically.
As set forth above, the Company will continue to engage with its suppliers to obtain complete and accurate information about its supply chain as it relates to Conflict Minerals and their origins.
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk about the sourcing of our Conflict Minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; or lack of progress by smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities). In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in our most recently submitted Annual and Quarterly Reports on Form 10-K and Form 10-Q, respectively. Except as required by law, we disclaim any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.
Schedule 1
Metal | Standard Smelter or Refiner Name | Facility Location (Country) | Certified Smelter* |
Tin | Melt Metais e Ligas S.A. | Brazil | NO |
Tin | Soft Metais Ltda. | Brazil | YES |
Tin | Metallic Resources, Inc. | United States | YES |
Tin | Metallo Belgium N.V. | Belgium | YES |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | YES |
Tin | HuiChang Hill Tin Industry Co., Ltd. | China | YES |
Tin | Gejiu Kai Meng Industry and Trade LLC | China | NO |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | YES |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | YES |
Tin | Mineracao Taboca S.A. | Brazil | YES |
Tin | Minsur | Peru | YES |
Tin | Alpha | United States | YES |
Tin | Mitsubishi Materials Corporation | Japan | YES |
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | NO |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | YES |
Tin | Jiangxi New Nanshan Technology Ltd. | China | YES |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | NO |
Tin | Thaisarco | Thailand | YES |
Tin | PT Bangka Serumpun | Indonesia | YES |
Tin | Pongpipat Company Limited | Myanmar | NO |
Tin | Tin Technology & Refining | United States | YES |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | NO |
Tin | PT Rajawali Rimba Perkasa | Indonesia | YES |
Tin | Novosibirsk Processing Plant Ltd. | Russian Federation | YES |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | YES |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | YES |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | NO |
Tin | Operaciones Metalurgicas S.A. | Bolivia | YES |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | YES |
Tin | Ma'anshan Weitai Tin Co., Ltd. | China | YES |
Tin | China Tin Group Co., Ltd. | China | YES |
Tin | VQB Mineral and Trading Group JSC | Viet Nam | NO |
Tin | PT Aries Kencana Sejahtera | Indonesia | NO |
Tin | PT Artha Cipta Langgeng | Indonesia | YES |
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | YES |
Tin | PT Babel Inti Perkasa | Indonesia | YES |
Tin | PT Babel Surya Alam Lestari | Indonesia | YES |
Tin | PT Belitung Industri Sejahtera | Indonesia | NO |
Tin | PT Bukit Timah | Indonesia | NO |
Tin | PT Cipta Persada Mulia | Indonesia | YES |
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | YES |
Tin | CRM Synergies | Spain | YES |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | NO |
Tin | PT Mitra Stania Prima | Indonesia | YES |
Tin | PT Panca Mega Persada | Indonesia | NO |
Tin | PT Timah Nusantara | Indonesia | NO |
Tin | PT Prima Timah Utama | Indonesia | YES |
Tin | PT Refined Bangka Tin | Indonesia | YES |
Tin | PT Sariwiguna Binasentosa | Indonesia | YES |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | NO |
Tin | CV Venus Inti Perkasa | Indonesia | NO |
Tin | PT Stanindo Inti Perkasa | Indonesia | YES |
Tin | PT Sukses Inti Makmur | Indonesia | NO |
Tin | Precious Minerals and Smelting Limited | India | NO |
Tin | Luna Smelter, Ltd. | Rwanda | YES |
Tin | PT Timah Tbk Mentok | Indonesia | YES |
Tin | PT Timah Tbk Kundur | Indonesia | YES |
Tin | PT Tinindo Inter Nusa | Indonesia | YES |
Tin | PT Tirus Putra Mandiri | Indonesia | NO |
Tin | PT Tommy Utama | Indonesia | NO |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | YES |
Tin | PT Mitra Sukses Globalindo | Indonesia | NO |
Tin | Resind Industria e Comercio Ltda. | Brazil | YES |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | YES |
Tin | Yunnan Tin Company Limited | China | YES |
Tin | Rui Da Hung | Taiwan, Province of China | YES |
Tin | Modeltech Sdn Bhd | Malaysia | NO |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | NO |
Tin | Dowa | Japan | YES |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | YES |
Tin | PT Menara Cipta Mulia | Indonesia | YES |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | NO |
Tin | Super Ligas | Brazil | NO |
Tin | Metallo Spain S.L.U. | Spain | YES |
Tin | EM Vinto | Bolivia | YES |
Tin | Estanho de Rondonia S.A. | Brazil | YES |
Tin | Fenix Metals | Poland | YES |
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | YES |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | YES |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | YES |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | YES |
Tantalum | Metallurgical Products India Pvt., Ltd. | India | YES |
Tantalum | Jiangxi Tuohong New Raw Material | China | YES |
Tantalum | Mineracao Taboca S.A. | Brazil | YES |
Tantalum | Global Advanced Metals Aizu | Japan | YES |
Tantalum | Global Advanced Metals Boyertown | United States | YES |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | YES |
Tantalum | NPM Silmet AS | Estonia | YES |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | YES |
Tantalum | TANIOBIS Co., Ltd. | Thailand | YES |
Tantalum | TANIOBIS GmbH | Germany | YES |
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | YES |
Tantalum | H.C. Starck Inc. | United States | YES |
Tantalum | TANIOBIS Japan Co., Ltd. | Japan | YES |
Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | YES |
Tantalum | Telex Metals | United States | YES |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | YES |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | YES |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | YES |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | YES |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | YES |
Tantalum | D Block Metals, LLC | United States | YES |
Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China | YES |
Tantalum | QuantumClean | United States | YES |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | YES |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | YES |
Tantalum | Jiujiang Tanbre Co., Ltd. | China | YES |
Tantalum | Resind Industria e Comercio Ltda. | Brazil | YES |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | YES |
Tantalum | KEMET Blue Metals | Mexico | YES |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | YES |
Tantalum | Taki Chemical Co., Ltd. | Japan | YES |
Tantalum | Exotech Inc. | United States | NO |
Tantalum | F&X Electro-Materials Ltd. | China | YES |
Tantalum | AMG Brasil | Brazil | YES |
Tantalum | FIR Metals & Resource Ltd. | China | YES |
Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | YES |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | YES |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | YES |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | YES |
Tungsten | ACL Metais Eireli | Brazil | YES |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | YES |
Tungsten | Moliren Ltd. | Russian Federation | YES |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | YES |
Tungsten | Global Tungsten & Powders Corp. | United States | YES |
Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | YES |
Tungsten | H.C. Starck Tungsten GmbH | Germany | YES |
Tungsten | Niagara Refining LLC | United States | YES |
Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | YES |
Tungsten | KGETS CO., LTD. | Korea, Republic of | YES |
Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | YES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | YES |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | YES |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | YES |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | YES |
Tungsten | Hydrometallurg, JSC | Russian Federation | YES |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | YES |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | NO |
Tungsten | Japan New Metals Co., Ltd. | Japan | YES |
Tungsten | China Molybdenum Co., Ltd. | China | YES |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | YES |
Tungsten | Wolfram Bergbau und Hutten AG | Austria | YES |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | YES |
Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province of China | YES |
Tungsten | Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd. | China | YES |
Tungsten | NPP Tyazhmetprom LLC | Russian Federation | NO |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | YES |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | YES |
Tungsten | Xiamen Tungsten Co., Ltd. | China | YES |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | YES |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | NO |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | YES |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | YES |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | YES |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | NO |
Tungsten | Cronimet Brasil Ltda | Brazil | YES |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | YES |
Tungsten | Kennametal Fallon | United States | YES |
Tungsten | Kennametal Huntsville | United States | YES |
Tungsten | Unecha Refractory Metals Plant | Russian Federation | YES |
Tungsten | Artek LLC | Russian Federation | NO |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | YES |
Gold | Matsuda Sangyo Co., Ltd. | Japan | YES |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | YES |
Gold | Singway Technology Co., Ltd. | Taiwan, Province of China | YES |
Gold | 8853 S.p.A. | Italy | YES |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | YES |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | NO |
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China | YES |
Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | YES |
Gold | Refinery of Seemine Gold Co., Ltd. | China | NO |
Gold | Advanced Chemical Company | United States | YES |
Gold | Metalor Technologies (Hong Kong) Ltd. | China | YES |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | YES |
Gold | Metalor Technologies (Suzhou) Ltd. | China | YES |
Gold | Metalor Technologies S.A. | Switzerland | YES |
Gold | Metalor USA Refining Corporation | United States | YES |
Gold | Asahi Refining Canada Ltd. | Canada | YES |
Gold | Aida Chemical Industries Co., Ltd. | Japan | YES |
Gold | Geib Refining Corporation | United States | YES |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | NO |
Gold | L'Orfebre S.A. | Andorra | YES |
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | YES |
Gold | Pease & Curren | United States | NO |
Gold | SAAMP | France | YES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | YES |
Gold | Tony Goetz NV | Belgium | NO |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | YES |
Gold | Sudan Gold Refinery | Sudan | NO |
Gold | Mitsubishi Materials Corporation | Japan | YES |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | YES |
Gold | MMTC-PAMP India Pvt., Ltd. | India | YES |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | YES |
Gold | Morris and Watson | New Zealand | NO |
Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province of China | NO |
Gold | Moscow Special Alloys Processing Plant | Russian Federation | NO |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | YES |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | YES |
Gold | Guangdong Jinding Gold Limited | China | NO |
Gold | T.C.A S.p.A | Italy | YES |
Gold | African Gold Refinery | Uganda | NO |
Gold | Argor-Heraeus S.A. | Switzerland | YES |
Gold | Asahi Pretec Corp. | Japan | YES |
Gold | Asaka Riken Co., Ltd. | Japan | YES |
Gold | Bangalore Refinery | India | YES |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | YES |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | YES |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | NO |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | NO |
Gold | Aurubis AG | Germany | YES |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | NO |
Gold | Nihon Material Co., Ltd. | Japan | YES |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | YES |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | NO |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | YES |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | YES |
Gold | International Precious Metal Refiners | United Arab Emirates | NO |
Gold | QG Refining, LLC | United States | NO |
Gold | LT Metal Ltd. | Korea, Republic of | YES |
Gold | Heimerle + Meule GmbH | Germany | YES |
Gold | Planta Recuperadora de Metales SpA | Chile | YES |
Gold | Heraeus Metals Hong Kong Ltd. | China | YES |
Gold | Boliden AB | Sweden | YES |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | YES |
Gold | Tokuriki Honten Co., Ltd. | Japan | YES |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | NO |
Gold | TOO Tau-Ken-Altyn | Kazakhstan | YES |
Gold | K.A. Rasmussen | Norway | NO |
Gold | Torecom | Korea, Republic of | YES |
Gold | C. Hafner GmbH + Co. KG | Germany | YES |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | YES |
Gold | OJSC Novosibirsk Refinery | Russian Federation | NO |
Gold | Caridad | Mexico | NO |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | NO |
Gold | CCR Refinery - Glencore Canada Corporation | Canada | YES |
Gold | Cendres + Metaux S.A. | Switzerland | YES |
Gold | Umicore Precious Metals Thailand | Thailand | YES |
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | YES |
Gold | Hunan Chenzhou Mining Co., Ltd. | China | NO |
Gold | PAMP S.A. | Switzerland | YES |
Gold | United Precious Metal Refining, Inc. | United States | YES |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | NO |
Gold | HwaSeong CJ CO., LTD. | Korea, Republic of | NO |
Gold | Chimet S.p.A. | Italy | YES |
Gold | Valcambi S.A. | Switzerland | YES |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | YES |
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | NO |
Gold | Chugai Mining | Japan | YES |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | YES |
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | YES |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | YES |
Gold | Istanbul Gold Refinery | Turkey | YES |
Gold | Italpreziosi | Italy | YES |
Gold | WIELAND Edelmetalle GmbH | Germany | YES |
Gold | JALAN & Company | India | NO |
Gold | Japan Mint | Japan | YES |
Gold | CGR Metalloys Pvt Ltd. | India | NO |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | NO |
Gold | Dijllah Gold Refinery FZC | United Arab Emirates | NO |
Gold | Gold Coast Refinery | Ghana | NO |
Gold | Sovereign Metals | India | NO |
Gold | C.I Metales Procesados Industriales SAS | Colombia | NO |
Gold | Jiangxi Copper Co., Ltd. | China | YES |
Gold | PX Precinox S.A. | Switzerland | YES |
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | YES |
Gold | Yamakin Co., Ltd. | Japan | YES |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | NO |
Gold | Rand Refinery (Pty) Ltd. | South Africa | YES |
Gold | NH Recytech Company | Korea, Republic of | YES |
Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | YES |
Gold | DSC (Do Sung Corporation) | Korea, Republic of | YES |
Gold | Asahi Refining USA Inc. | United States | YES |
Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | YES |
Gold | DODUCO Contacts and Refining GmbH | Germany | YES |
Gold | Yokohama Metal Co., Ltd. | Japan | YES |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | NO |
Gold | Kundan Care Products Ltd. | India | NO |
Gold | JSC Uralelectromed | Russian Federation | NO |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | YES |
Gold | Shirpur Gold Refinery Ltd. | India | NO |
Gold | AU Traders and Refiners | South Africa | NO |
Gold | Kaloti Precious Metals | United Arab Emirates | NO |
Gold | Yunnan Copper Industry Co., Ltd. | China | NO |
Gold | Augmont Enterprises Private Limited | India | NO |
Gold | Kazakhmys Smelting LLC | Kazakhstan | NO |
Gold | Emerald Jewel Industry India Limited (Unit 1) | India | NO |
Gold | Kazzinc | Kazakhstan | YES |
Gold | Royal Canadian Mint | Canada | YES |
Gold | Emerald Jewel Industry India Limited (Unit 2) | India | NO |
Gold | REMONDIS PMR B.V. | Netherlands | YES |
Gold | Sai Refinery | India | NO |
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | NO |
Gold | Emerald Jewel Industry India Limited (Unit 4) | India | NO |
Gold | Sabin Metal Corp. | United States | NO |
Gold | Modeltech Sdn Bhd | Malaysia | NO |
Gold | Safimet S.p.A | Italy | YES |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | NO |
Gold | SAFINA A.S. | Czech Republic | YES |
Gold | Kennecott Utah Copper LLC | United States | YES |
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | YES |
Gold | Dowa | Japan | YES |
Gold | Samduck Precious Metals | Korea, Republic of | YES |
Gold | Alexy Metals | United States | NO |
Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | NO |
Gold | SAMWON METALS Corp. | Korea, Republic of | NO |
Gold | Kojima Chemicals Co., Ltd. | Japan | YES |
Gold | Abington Reldan Metals, LLC | United States | NO |
Gold | Metallix Refining Inc. | United States | NO |
Gold | Korea Zinc Co., Ltd. | Korea, Republic of | YES |
Gold | Shandong Humon Smelting Co., Ltd. | China | NO |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | YES |
Gold | SAXONIA Edelmetalle GmbH | Germany | NO |
Gold | Sellem Industries Ltd. | Mauritania | NO |
Gold | MD Overseas | India | NO |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | YES |
Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | YES |
Gold | SEMPSA Joyeria Plateria S.A. | Spain | YES |
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | NO |
Gold | L'azurde Company For Jewelry | Saudi Arabia | NO |
Gold | Emirates Gold DMCC | United Arab Emirates | YES |
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of | YES |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | NO |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | YES |
Gold | Lingbao Gold Co., Ltd. | China | NO |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | NO |
Gold | LS-NIKKO Copper Inc. | Korea, Republic of | YES |
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | NO |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | NO |
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | NO |
Gold | Marsam Metals | Brazil | YES |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | YES |
Gold | Fujairah Gold FZC | United Arab Emirates | NO |
Gold | Materion | United States | YES |
* A “Yes” in this column indicates that the smelter (i) has an active certification with the Responsible Minerals Assurance Process (“RMAP”) or is in the process of renewing their certification, (ii) is actively moving through the RMAP certification process, (iii) is a tungsten smelter that has committed to obtain a RMAP certification within 2 years of membership with the Tungsten Industry-Conflict Minerals Committee (TI-CMC), (iv) has obtained a Responsible Gold Certification from the London Bullion Market Association (LBMA), or (v) has obtained a Chain-of-Custody Certification from the Responsible Jewelry Council (RJC).
A “No” in this column indicates that we are unaware of one of the above-referenced certifications for this smelter.
Schedule 2
The following list of potential countries of origin is 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 linked to our products.
Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Republic of the Congo, Czech Republic, Democratic Republic of the Congo, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong SAR, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Republic of Korea, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan (Province of China), Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, Zimbabwe.
