Cardinal Health, Inc.
Conflict Minerals Report
For the 2017 Reporting Period
Introduction
Cardinal Health, Inc. is a globally integrated healthcare services and products company that manages its business in two segments: Pharmaceutical and Medical. As used in this report, "Cardinal Health," "we," "our," "us," and similar pronouns refer to Cardinal Health, Inc. and its consolidated subsidiaries, unless the context requires otherwise.
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the "Rule"), this Conflict Minerals Report describes, for the period from January 1, 2017 to December 31, 2017 (the "2017 Reporting Period"), the measures we have taken to conduct due diligence on the source and chain of custody of the conflict minerals contained in, and necessary to the functionality or production of, the products in our supply chain that we had reason to believe may have originated in the Democratic Republic of Congo or an adjoining country (collectively, the “Covered Countries”) and may not have come from recycled or scrap sources. Under the Rule, "conflict minerals" are defined as columbite-tantalite (coltan), cassiterite, gold and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten.
Products Subject to this Report and Our Supply Chain
We assessed all product lines manufactured or contracted to be manufactured by us throughout our two segments in the 2017 Reporting Period to determine whether they potentially contained conflict minerals. Through the screening process, our product teams determined, to the best of their knowledge, that the following product lines manufactured or contracted to be manufactured by our Medical segment (collectively, the "Products") contained conflict minerals and are subject to this report for the 2017 Reporting Period: radio frequency identification enabled inventory management cabinets and wands; ureteral stone retrieval devices; certain balloon catheters; certain negative pressure wound therapy devices; and certain product lines, including the enteral feeding, electrode and thermometry product lines, manufactured or contracted to be manufactured from July 29, 2017 through December 31, 2017 that we acquired from Medtronic plc ("Medtronic") as part of our acquisition of Medtronic's Patient Care, Deep Vein Thrombosis and Nutritional Insufficiency businesses on July 29, 2017.
Our supply chains are complex and fragmented. As a “downstream” company, we are many tiers removed in the minerals supply chain from smelters and refiners (collectively, "SORs") that process the metals found in the Products, with many intervening third parties between the original sources of conflict minerals and us. We, therefore, must rely on our direct suppliers with which we have business relationships to provide information regarding the sourcing of conflict minerals in the Products. Our direct suppliers, in turn, are also downstream in the minerals supply chain and have similar challenges.
Reasonable Country of Origin Inquiry
We conducted a good faith, reasonable country of origin inquiry ("RCOI") regarding the conflict minerals in materials, components and finished goods supplied to us that relate to the Products. The RCOI was 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 sources.
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| • | With the assistance of a third-party vendor with expertise in supply chain due diligence (the “Vendor”), we engaged 33 suppliers to collect information regarding the presence and sourcing of conflict minerals in the Products. These suppliers were asked to complete the Conflict Minerals Reporting Template (v.5.0 or higher) (the “CMRT”) and return it to the Vendor for assessment and management. The CMRT is an internationally-recognized standardized reporting form developed by the Responsible Minerals Initiative ("RMI," and formerly know as the "Conflict-Free Sourcing Initiative") that requests, among other things, information regarding the country of origin of conflict minerals and the SORs in the conflict minerals supply chain. |
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| • | The Vendor followed up with all unresponsive suppliers using both automated and personalized emails and offered assistance and further information about the requirements of the Rule and our expectations. |
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| • | The Vendor identified and followed up on incomplete or contradictory answers in each CMRT submitted and encouraged suppliers to re-submit a valid form. |
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| • | Where suppliers identified a list of metals processors in their completed CMRTs, the Vendor verified whether the metals processors were actually SORs or recyclers of conflict minerals by comparing the alleged SOR names to RMI’s Standard Smelter List. If a supplier indicated that a metals processor was certified as conflict-free, the Vendor also confirmed that the processor was listed on the RMI's list of validated conflict-free SORs. Our suppliers identified a total 314 SORs verified to exist, of which 255 SORs are |
indicated as conflict-free by RMI. Many of the CMRTs we received were prepared on a company or division-level basis, which did not allow us to identify which SORs actually processed the conflict minerals contained in the Products.
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| • | The Vendor researched and reviewed mine information for the verified SORs to determine, to the best of its knowledge, the country of origin of the conflict minerals processed by those SORs. This information was also compared to the country of origin data available to members of RMI. |
Based on our RCOI, we have reason to believe that at least some of the conflict minerals contained in the Products originated in the Covered Countries, and are not from recycled or scrap sources. Accordingly, we conducted due diligence on the source and chain of custody of these conflict minerals.
Due Diligence
The due diligence measures described below were designed to conform, in all material respects, with the internationally recognized due diligence framework set forth in the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplements on 3T (tin, tantalum and tungsten) and gold (the "OECD Guidance"). The OECD Guidance identifies five steps for due diligence that should be implemented and provides specific guidance with respect to each step. We developed our due diligence measures to address each of these five steps. These measures took into account the OECD Guidance’s recommendations for companies in the downstream segments of the supply chain, which typically are several tiers removed from, and have no direct relationships with, SORs.
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| 1. | Company Management Systems |
The Company has implemented a conflict minerals compliance program (the “Program”) with the following attributes:
Policy Statement
In 2015, we adopted a Conflict Minerals Policy (the "Policy") that sets forth the expectation that our suppliers source materials from suppliers that also source responsibly, including from conflict-free mines in the Covered Countries. The Policy is available on our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.
Steering Committee
In 2015, we established a conflict minerals steering committee to provide cross-functional oversight for the Program, including representatives from sourcing, legal, quality and regulatory, finance and internal audit. Our Executive Vice President, Global Sourcing is the executive leader of the steering committee. Steering committee members report on the Program to our Chief Legal and Compliance Officer, the Environmental, Social and Governance ("ESG") Coordinating Committee and the ESG Working Group of our Disclosure Committee.
Control Systems and Supply Chain Transparency
As discussed above, beginning in 2016, we engaged the Vendor to facilitate supplier engagement and assist us in collecting, analyzing, verifying and storing supplier-provided data and performing due diligence for the Program. With the assistance of the Vendor, we contacted and solicited information from our potential direct suppliers of conflict minerals using the CMRT.
To further strengthen the Program, in 2016, we became a member of RMI, a cross-industry organization that provides resources, tools and information to help companies source conflict-free minerals, including a list of confirmed SORs and RMI’s Responsible Minerals Assurance Process (the "RMAP," and formerly known as the "Conflict-Free Smelter Program"), which validates SORs as conflict-free based on independent third-party audits.
Our Policy encourages suppliers to adopt similar policies and management systems with respect to conflict minerals. It also asks that suppliers take reasonable, good faith steps toward assisting us in reporting on our conflict minerals supply chain and, over time, work to identify and supply materials to us that do not contain conflict minerals that directly or indirectly financed or benefited armed groups in the Covered Countries.
Our Vendor Code of Conduct, which we adopted in 2016 (the "Vendor Code of Conduct"), requires suppliers to comply with the Policy, including working with their suppliers to identify the source and chain of custody of any conflict minerals contained in their products. Suppliers must agree to cooperate with us in connection with any inquiries or due diligence that we choose to perform with respect to such conflict minerals.
The Vendor maintains records of product and supply chain information collected through the due diligence activities carried out under the Program. Documentation related to the annual CMRTs is retained for at least five years.
Supplier Engagement
In support of our Policy, we have incorporated conflict mineral provisions into the standard terms of our Medical segment's supplier agreement template. Since most agreements have multi-year terms, it will take a number of years to integrate these provisions into our various supplier agreements as new supplier relationships are formed and existing suppliers renew their contracts. As discussed above, we also addressed conflict minerals in the Vendor Code of Conduct.
To ensure suppliers understand our expectations, we have, through the Vendor, provided video and written training on conflict minerals and the CMRT to suppliers of the Products. This training includes instructions on completing the CMRT and one-on-one email and phone discussions with supplier personnel, as needed. We utilized the Vendor's on-line learning management system and provided suppliers of the Products with access to on-line conflict minerals training courses. We encouraged all suppliers to complete these courses, and we tracked all training based on completion.
Grievance Mechanism
We have a dedicated email address for reporting questions or concerns relating to our Policy or Program to a Cardinal Health representative. In addition, we have a business conduct line that provides a mechanism for anyone to anonymously report conduct they know or believe is in violation of Cardinal Health guidelines or policies, including any concerns related to the conflict minerals supply chain.
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| 2. | Risk Identification and Assessment |
Risks are identified automatically in the Vendor's system based on criteria established for supplier responses, including the submission of a CMRT with incomplete or contradictory answers. These risks are addressed by the Vendor's staff, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status. All risks are communicated to our conflict minerals steering committee and Chief Legal and Compliance Officer.
The Vendor attempted to match each verified SOR from the CMRT responses to lists of conflict-free SORs (i.e., SORs validated or certified as conflict-free under internationally-recognized programs such as the RMAP, the London Bullion Market Association Good Delivery program and the Responsible Jewellery Council Chain-of-Custody Certification program). SORs classified as actively pursuing conflict-free status under the RMAP also were identified.
Each facility that meets the RMI definition of a SOR of a conflict mineral was assigned a risk rating based on geographic proximity to the Covered Countries, RMAP audit status and any known or plausible evidence of unethical or conflict sourcing. When SORs determined to be of higher risk were reported on a CMRT by one of the suppliers surveyed, we sought to mitigate risk by requesting, through the Vendor, that the supplier to take its own risk mitigation actions, including the submission of a product-specific CMRT to better identify the connection to products that they supply to us.
Additionally, we, through the Vendor, evaluated the strength of our suppliers' conflict minerals due diligence and supply chain control program, further assisting us in identifying supply chain risk. The criteria used to evaluate the program strength of our suppliers included whether the supplier has a conflict minerals policy, whether it has implemented due diligence measures for conflict-free sourcing, whether it verifies due diligence information from its suppliers and whether its verification process includes corrective active management. If a supplier is determined to have a weak program as a result of this evaluation, it receives a communication from the Vendor informing it of this rating.
Together with the Vendor, we have developed a strategy to respond to and assess risks identified in our supply chain. As the Program progresses, the Vendor makes escalating contacts with suppliers that have not responded to our CMRT requests and any suppliers that provided information on the CMRT at the company level are encouraged to re-submit at the product level.
We engage with our suppliers that we may have reason to believe are supplying us with conflict minerals from sources that may support conflict in the Covered Countries and encourage them to establish an alternative source of conflict minerals that does not support such conflict. We ensure that suppliers are provided with access to the proper training materials to understand the risks and to implement appropriate risk mitigation activities down through their own suppliers.
In addition, under our Vendor Code of Conduct, if we determine or believe at any time that a supplier has failed to comply with the standards set forth in the Vendor Code of Conduct, including those with respect to conflict minerals, we have the right to cease the purchase of the supplier's products without liability or obligation.
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| 4. | Audit of Due Diligence Practices of SORs |
We do not have a direct relationship with any SORs of conflict minerals and do not perform or direct audits of these entities within our supply chain. Instead, we support internationally-recognized assessment programs, such as the RMAP, that facilitate and confirm independent third-party audits of SORs’ supply chain due diligence practices, including through our membership in RMI. Any SOR that has not been validated through such an audit or has been determined to be of higher risk receives a communication from the Vendor and from the RMI to encourage the SOR to participate in a conflict-free assessment program such as the RMAP.
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| 5. | Annual Reporting on Supply Chain Due Diligence |
We report annually on our supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the U.S. Securities and Exchange Commission. We have published our Conflict Minerals Report for the 2017 Reporting Period our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.
Due Diligence Results
Survey Results
For the 2017 Reporting Period, we received responses from approximately 94% of all surveyed suppliers.
Smelters and Refiners
Based on the above-described due diligence efforts, we do not have conclusive information regarding the country of origin of, or facilities used to process, the necessary conflict minerals in the Products for the 2017 Reporting Period.
Although we requested information about SORs and country of origin from our suppliers at a product level, many of our supplier CMRT responses consisted of information at a company level. As a result, these suppliers provided information about SORs in their supply chains generally, and not just for the products or components supplied specifically to us. Thus, information we received from our suppliers may not be relevant to any of the Products and may identify SORs that are not actually in our supply chain.
In addition, some suppliers indicated that they have not received information regarding their supply chains from all of their suppliers and, therefore, could not provide a comprehensive list of all SORs in their supply chains.
Set forth in Annex A is a list of SORs reported in supplier CMRTs that are legitimate conflict mineral processing facilities, based on RMI data as of May 9, 2018. As noted above, we are unable to determine whether any of the facilities listed in Annex A in fact processed conflict minerals contained in the Products.
Based on RMI’s country of origin data as of May 9, 2018, which is organized by risk-based categories, Annex B provides an aggregated list of the countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, in addition to recycled and scrap sources.
Cardinal Health's efforts to determine the mine or location of origin of the necessary conflict minerals in its products with the greatest possible specificity consisted of the implementation of the Program and due diligence measures described above in this Conflict Minerals Report.
Risk Mitigation Steps
We took the following actions to improve our Program following the filing of our Conflict Minerals Report for the period from January 1, 2016 to December 31, 2016:
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| • | Improved Supplier Engagement. We have continued to engage a Vendor, through which we have reached out to suppliers, communicated our expectations under the Program and offered education and training for suppliers. The Vendor has encouraged suppliers to access extensive resources on due diligence and risk mitigation on the Vendor's platform and website to improve the suppliers' knowledge and practices. |
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| • | Enhanced Due Diligence Processes. We have continued to utilize the Vendor's expertise in supplier surveys and supply chain due diligence, taking into account improvements in broader industry practice. |
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| • | Supported Efforts to Encourage SOR Participation in Conflict-Free Validation Programs. We have continued to participate as a member of RMI to support programs like the RMAP that facilitate and validate independent third-party audits of SORs’ supply chain due diligence practices. The Vendor has conducted independent outreach on our behalf to SORs not currently participating in these programs to encourage participation and to gather additional information on these SORs' sourcing practices. |
We will continue to monitor legislative and regulatory developments in this area and may modify our Program in response to these developments.
Forward-Looking Statements
This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties, such as whether industry organizations and initiatives remain effective as a source of external support to us in the conflict minerals compliance process. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms and include statements reflecting future results or guidance and statements of outlook. These matters are subject to risks and uncertainties that could cause actual results to differ materially from those projected, anticipated or implied. The most significant of these risks and uncertainties are described under the heading "Risk Factors" in our Annual Reports on Form 10-K and Quarterly Reports on Form 10-Q and in Exhibit 99.1 to those reports. Forward-looking statements are not guarantees of future performance. We assume no obligation to revise or update any forward-looking statements for any reason, except as required by law. Subsequent events may affect our future determinations under the Rule.
ANNEX A
The following is is a list of SORs reported in supplier CMRTs that are legitimate conflict mineral processing facilities, based on RMI data as of May 9, 2018. SORs that have been validated by RMI to have conflict-free sourcing, or are in the process of being validated, are indicated by an asterisk.
As explained in our Conflict Minerals Report, we are unable to determine whether any of the facilities listed in Annex A in fact processed conflict minerals in the Products. As a result, the presence of a SOR on the list does not mean that the Products necessarily contained conflict minerals processed by that SOR.
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| Mineral | SOR Name | SOR Location |
| Gold | Abington Reidan Metals, LLC | UNITED STATES |
| Gold | Advanced Chemical Company* | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd.* | JAPAN |
| Gold | Al Etihad Gold LLC* | UNITED ARAB EMIRATES |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | UZBEKISTAN |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração* | BRAZIL |
| Gold | Argor-Heraeus S.A.* | SWITZERLAND |
| Gold | Asahi Pretec Corp.* | JAPAN |
| Gold | Asahi Refining Canada Ltd.* | CANADA |
| Gold | Asahi Refining USA Inc.* | UNITED STATES |
| Gold | Asaka Riken Co., Ltd.* | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | AU Traders and Refiners* | SOUTH AFRICA |
| Gold | Aurubis AG* | GERMANY |
| Gold | Bangalore Refinery* | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | PHILIPPINES |
| Gold | Boliden AB* | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG* | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | CCR Refinery - Glencore Canada Corporation* | CANADA |
| Gold | Cendres + Métaux S.A.* | SWITZERLAND |
| Gold | Chimet S.p.A.* | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daejin Indus Co., Ltd.* | REPUBLIC OF KOREA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Degussa Sonne / Mond Goldhandle GmbH | GERMANY |
| Gold | DODUCO Contacts and Refining GmbH* | GERMANY |
| Gold | Dowa* | JAPAN |
| Gold | DSC (Do Sung Corporation)* | REPUBLIC OF KOREA |
| Gold | Eco-System Recycling Co., Ltd.* | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES |
| Gold | Emirates Gold DMCC* | UNITED ARAB EMIRATES |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | GCC Gujrat Gold Centre Pvt. | INDIA |
| Gold | Geib Refining Corporation* | UNITED STATES |
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| Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | CHINA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | HeeSung* | REPUBLIC OF KOREA |
| Gold | Heimerle + Meule GmbH* | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd.* | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hwasung CJ Co., Ltd. | REPUBLIC OF KOREA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd.* | JAPAN |
| Gold | Istanbul Gold Refinery* | TURKEY |
| Gold | Italpreziosi* | ITALY |
| Gold | Japan Mint* | JAPAN |
| Gold | Jiangxi Copper Co., Ltd.* | CHINA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant* | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed* | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd.* | JAPAN |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc* | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC* | UNITED STATES |
| Gold | KGHM Polska Miedź Spółka Akcyjna* | POLAND |
| Gold | Kojima Chemicals Co., Ltd.* | JAPAN |
| Gold | Korea Zinc Co., Ltd.* | REPUBLIC OF KOREA |
| Gold | Kyrgyzaltyn JSC* | KYRGYZSTAN |
| Gold | Kyshtym Copper-Electrolytic Plan ZAO | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | L'Orfebre S.A.* | ANDORRA |
| Gold | LS-NIKKO Copper Inc.* | REPUBLIC OF KOREA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Marsam Metals* | BRAZIL |
| Gold | Materion* | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd.* | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd.* | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd.* | CHINA |
| Gold | Metalor Technologies S.A.* | SWITZERLAND |
| Gold | Metalor USA Refining Corporation* | UNITED STATES |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V.* | MEXICO |
| Gold | Mitsubishi Materials Corporation* | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
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| Gold | MMTC-PAMP India Pvt., Ltd.* | INDIA |
| Gold | Modeltech Sdn Bhd* | MALAYSIA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Morris and Watson Gold Coast | AUSTRALIA |
| Gold | Moscow Special Alloys Processing Plant* | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş.* | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nihon Material Co., Ltd.* | JAPAN |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH* | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd.* | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)* | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery* | RUSSIAN FEDERATION |
| Gold | PAMP S.A.* | SWITZERLAND |
| Gold | Pease & Curren | UNITED STATES |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Planta Recuperadora de Metales SpA* | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals* | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk* | INDONESIA |
| Gold | PX Précinox S.A.* | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd.* | SOUTH AFRICA |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | Remondis Argentia B.V.* | NETHERLANDS |
| Gold | Republic Metals Corporation* | UNITED STATES |
| Gold | Royal Canadian Mint* | CANADA |
| Gold | SAAMP* | FRANCE |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | Safimet S.p.A* | ITALY |
| Gold | SAFINA A.S.* | CZECH REPUBLIC |
| Gold | Sai Refinery | INDIA |
| Gold | Samduck Precious Metals* | REPUBLIC OF KOREA |
| Gold | SAMWON Metals Corp. | REPUBLIC OF KOREA |
| Gold | SAXONIA Edelmetalle GmbH* | GERMANY |
| Gold | Schone Edelmetaal B.V.* | NETHERLANDS |
| Gold | SEMPSA Joyería Platería S.A.* | SPAIN |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd.* | CHINA |
| Gold | Singway Technology Co., Ltd.* | TAIWAN |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp.* | TAIWAN |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
| Gold | SungEel HiTech* | REPUBLIC OF KOREA |
| Gold | T.C.A S.p.A* | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K.* | JAPAN |
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| Gold | The Refinery of Shandong Gold Mining Co., Ltd.* | CHINA |
| Gold | Tokuriki Honten Co., Ltd.* | JAPAN |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Tony Goetz NV | BELGIUM |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom* | REPUBLIC OF KOREA |
| Gold | Umicore Brasil Ltda.* | BRAZIL |
| Gold | Umicore Precious Metals Thailand* | THAILAND |
| Gold | Umicore S.A. Business Unit Precious Metals Refining* | BELGIUM |
| Gold | United Precious Metal Refining, Inc.* | UNITED STATES |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
| Gold | Valcambi S.A.* | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint* | AUSTRALIA |
| Gold | WIELAND Edelmetalle GmbH* | GERMANY |
| Gold | Yamamoto Precious Metal Co., Ltd.* | JAPAN |
| Gold | Yokohama Metal Co., Ltd.* | JAPAN |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
| Tantaum | Asaka Riken Co., Ltd.* | JAPAN |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CHINA |
| Tantalum | D Block Metals, LLC* | UNITED STATES |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Exotech Inc.* | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd.* | CHINA |
| Tantalum | FIR Metals & Resource Ltd.* | CHINA |
| Tantalum | Global Advanced Metals Aizu* | JAPAN |
| Tantalum | Global Advanced Metals Boyertown* | UNITED STATES |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd.* | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | CHINA |
| Tantalum | H.C. Starck Co., Ltd.* | THAILAND |
| Tantalum | H.C. Starck Hermsdorf GmbH* | GERMANY |
| Tantalum | H.C. Starck Inc.* | UNITED STATES |
| Tantalum | H.C. Starck Ltd.* | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG* | GERMANY |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH* | GERMANY |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material* | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd.* | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | CHINA |
| Tantalum | KEMET Blue Metals* | MEXICO |
| Tantalum | KEMET Blue Powder* | UNITED STATES |
| Tantalum | King-Tan Tantalum Industry Ltd.* | CHINA |
| Tantalum | LSM Brasil S.A.* | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd.* | INDIA |
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| Tantalum | Mineração Taboca S.A.* | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA |
| Tantalum | NPM Silmet AS* | ESTONIA |
| Tantalum | Power Resources Ltd.* | MACEDONIA |
| Tantalum | QuantumClean* | UNITED STATES |
| Tantalum | Resind Indústria e Comércio Ltda.* | BRAZIL |
| Tantalum | RFH Tantalum Smeltry Co., Ltd.* | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO* | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals* | JAPAN |
| Tantalum | Telex Metals* | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd.* | CHINA |
| Tin | Alpha* | UNITED STATES |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | CHINA |
| Tin | China Tin Group Co., Ltd.* | CHINA |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | CV Ayi Jaya* | INDONESIA |
| Tin | CV Dua Sekawan* | INDONESIA |
| Tin | CV Gita Pesona* | INDONESIA |
| Tin | CV Tiga Sekawan* | INDONESIA |
| Tin | CV United Smelting* | INDONESIA |
| Tin | CV Venus Inti Perkasa* | INDONESIA |
| Tin | Dowa* | JAPAN |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
| Tin | EM Vinto* | BOLIVIA |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Fenix Metals* | POLAND |
| Tin | Gejiu Fengming Metallurgy Chemical Plant* | CHINA |
| Tin | Gejiu Jinye Mineral Company* | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC* | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | CHINA |
| Tin | Gejiu Zili Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company* | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant* | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd.* | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd.* | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd.* | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd.* | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda.* | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA |
| Tin | Melt Metais e Ligas S.A.* | BRAZIL |
| Tin | Metallic Resources, Inc.* | UNITED STATES |
|
| | |
| Tin | Metallo Belgium N.V.* | BELGIUM |
| Tin | Metallo Spain S.L.U.* | SPAIN |
| Tin | Mineração Taboca S.A.* | BRAZIL |
| Tin | Minsur* | PERU |
| Tin | Mitsubishi Materials Corporation* | JAPAN |
| Tin | Modeltech Sdn Bhd* | MALAYSIA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc.* | PHILIPPINES |
| Tin | Operaciones Metalurgical S.A.* | BOLIVIA |
| Tin | PT Aries Kencana Sejahtera* | INDONESIA |
| Tin | PT Artha Cipta Langgeng* | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya* | INDONESIA |
| Tin | PT Babel Inti Perkasa* | INDONESIA |
| Tin | PT Bangka Prima Tin* | INDONESIA |
| Tin | PT Bangka Tin Industry* | INDONESIA |
| Tin | PT Belitung Industri Sejahtera* | INDONESIA |
| Tin | PT Bukit Timah* | INDONESIA |
| Tin | PT DS Jaya Abadi* | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri* | INDONESIA |
| Tin | PT Inti Stania Prima* | INDONESIA |
| Tin | PT Karimun Mining* | INDONESIA |
| Tin | PT Kijang Jaya Mandiri* | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera* | INDONESIA |
| Tin | PT Menara Cipta Mulia* | INDONESIA |
| Tin | PT Mitra Stania Prima* | INDONESIA |
| Tin | PT O.M. Indonesia* | INDONESIA |
| Tin | PT Panca Mega Persada* | INDONESIA |
| Tin | PT Premium Tin Indonesia* | INDONESIA |
| Tin | PT Prima Timah Utama* | INDONESIA |
| Tin | PT Refined Bangka Tin* | INDONESIA |
| Tin | PT Sariwiguna Binasentosa* | INDONESIA |
| Tin | PT Stanindo Inti Perkasa* | INDONESIA |
| Tin | PT Sukses Inti Makmur* | INDONESIA |
| Tin | PT Sumber Jaya Indah* | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur* | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok* | INDONESIA |
| Tin | PT Tinindo Inter Nusa* | INDONESIA |
| Tin | PT Tommy Utama* | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda.* | BRAZIL |
| Tin | Rui Da Hung* | TAIWAN |
| Tin | Soft Metais Ltda.* | BRAZIL |
| Tin | Super Ligas | BRAZIL |
| Tin | Thaisarco* | THAILAND |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | White Solder Metalurgia e Mineração Ltda.* | BRAZIL |
|
| | |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CHINA |
| Tin | Yunnan Tin Company Limited* | CHINA |
| Tungsten | A.L.M.T. TUNGSTEN Corp.* | JAPAN |
| Tungsten | ACL Metais Eireli* | BRAZIL |
| Tungsten | Asia Tungsten Products Vietnam Ltd.* | VIETNAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp.* | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | CHINA |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG* | GERMANY |
| Tungsten | H.C. Starck Tungsten GmbH* | GERMANY |
| Tungsten | Hunan Chenzhou Mining Co., Ltd.* | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.* | CHINA |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd.* | CHINA |
| Tungsten | Hydrometallurg, JSC* | RUSSIAN FEDERATION |
| Tungsten | Japan New Metals Co., Ltd.* | JAPAN |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA |
| Tungsten | Kennametal Fallon* | UNITED STATES |
| Tungsten | Kennametal Huntsville* | UNITED STATES |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
| Tungsten | Moliren Ltd* | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC* | UNITED STATES |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | VIETNAM |
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | VIETNAM |
| Tungsten | Unecha Refractory metals plant* | RUSSIAN FEDERATION |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd.* | VIETNAM |
| Tungsten | Wolfram Bergbau und Hütten AG* | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd.* | REPUBLIC OF KOREA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA |
|
| | |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | CHINA |
ANNEX B
Countries of Origin
Below is an aggregated list of countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, based on data available from RMI as of May 9, 2018.
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| | |
| Argentina | Kazakhstan | |
| Australia | Laos | |
| Austria | Madagascar | |
| Benin | Malaysia | |
| Belgium | Mali | |
| Bolivia | Mexico | |
| Brazil | Mongolia | |
| Burkina Faso | Mozambique | |
| Burundi | Myanmar | |
| Cambodia | Namibia | |
| Canada | Nicaragua | |
| Chile | Nigeria | |
| China | Panama | |
| Colombia | Peru | |
| Democratic Republic of Congo | Portugal | |
| Ecuador | Russian Federation | |
| Eritrea | Rwanda | |
| Ethiopia | Senegal | |
| France | Sierra Leone | |
| Germany | South Africa | |
| Ghana | Spain | |
| Guatemala | Thailand | |
| Guinea | Togo | |
| Guyana | Uganda | |
| Honduras | United Kingdom | |
| Hungary | United States | |
| India | Uzbekistan | |
| Indonesia | Vietnam | |
| Japan | Zimbabwe | |
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