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SD Filing
Best Buy (BBY) SDConflict minerals disclosure
Filed: 31 May 23, 2:21pm
Exhibit 1.01
Best Buy Co., Inc.
Conflict Minerals Report
For The Year Ended December 31, 2022
This Conflict Minerals Report for Best Buy Co., Inc. (“Best Buy”, “we”, “us” or “our”) covers the reporting period from January 1, 2022 to December 31, 2022, and is presented in accordance with the Securities Exchange Act of 1934, Rule 13p‐1 (the “conflict minerals law”).
This Report describes the design of our 2022 conflict minerals program and provides an account of how due diligence was applied to determine, to the best of our ability, the source, chain of custody, and facilities used to process certain minerals used in Best Buy’s private label products in order to verify that no non‐state armed groups in the Democratic Republic of the Congo (“DRC”) or an adjoining country (“covered country”) directly or indirectly benefitted. It is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD and both documents are posted on our website at www.investors.bestbuy.com.
Overview of our Responsible Sourcing Program
Best Buy is committed to respecting human rights and the responsible sourcing of our private label products. We seek to ensure this commitment is fulfilled by engaging our direct suppliers and the smelters and refiners reported to be in our supply chain and, wherever possible, we further embed our commitment through contractual and policy requirements, including a supplier code of conduct that sets specific standards related to labor, health and safety, environmental practices, management systems and ethics, and includes provisions directly relating to the responsible sourcing of raw materials.
We recognize the immense complexity of globalized supply chains requires a collaborative approach to address shared challenges. To that end, Best Buy has a long history of engaging industry peers to develop, share and implement best practices that seek to mitigate supply chain risks. In 2018, Best Buy served as the chair of the Responsible Minerals Initiative (“RMI”), an organization whose mission is to provide its more than 400 members with tools and resources to make responsible sourcing decisions. In addition, we served as the chair of the RMI Smelter Engagement Team (“SET”) (2014‐2021) and the co‐chair of the China SET (2016‐2021) to help guide outreach to smelters and refiners to better understand their sourcing practices and encourage their participation in a third‐party audit program.
In 2022, we engaged 85 of our private label suppliers to conduct due diligence on the responsible sourcing of raw materials. The 85 suppliers collectively reported 260 eligible tin, tungsten, tantalum, and gold facilities that may have processed the metals that were necessary to the functionality and/or production of our private label products. Of the 260 reported facilities, more than 84% have successfully completed a third‐party audit that assessed their responsible sourcing policies and practices, or they are in the process of completing a third‐party audit. For those facilities that had not committed to an audit, we conducted outreach to encourage their participation in an audit program or we requested their removal from our supply chain. While there are limitations to our program, such as
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having no contractual relationship with any smelters or refiners and having to rely on the information provided by several tiers of the supply chain which is challenging to verify, we are unable to confirm that any of the smelters and refiners reported to be in our supply chain sourced from mines that directly or indirectly financed or benefitted non‐state armed groups in the DRC or an adjoining country.
Products
Best Buy is driven by its purpose to enrich lives through technology and our vision to personalize and humanize technology solutions for every stage of life. We accomplish this by leveraging our combination of technology and a human touch to meet our customers’ everyday needs, whether they come to us online, visit our stores or invite us into their homes. In fiscal 2023, we had operations in the U.S. and Canada.
We sell private label product categories, under brand names Insignia, Dynex, Rocketfish, Platinum, Best Buy Essentials, and Modal, collectively known as Exclusive Brands (“ExB”), in which we believe contain tin, tungsten, tantalum, and/or gold and are therefore within scope of our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts include the following:
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Product Category | Product Examples |
Consumer Electronics | TVs, speakers, DVD players, sound bars, radios, etc. |
Computing and Mobile Phones | Tablets, monitors, keyboards, mice, cables, chargers, etc. |
Appliances | Shredders, coffee makers, toasters, blenders, etc. |
Entertainment | Charging stations, power packs, steering wheel combos, etc. |
Reasonable Country of Origin Inquiry
The DRC and its adjoining countries have massive reserves of tin, tantalum, tungsten, and gold (collectively known as “3TG”), all of which are commonly used in the manufacturing of many consumer products. Occasionally, these minerals are illegally mined, transported, taxed, and/or traded in the eastern DRC and surrounding areas by armed groups who use funds derived from these activities to fuel violence and commit human rights violations. As such, these minerals, regardless of where they are mined, are known as “conflict minerals.”
Pursuant to the conflict minerals law, we conducted a RCOI on the source of 3TG necessary to the functionality and/or production of our products (“necessary 3TG”) to determine whether any of the necessary 3TG originated in the DRC and its adjoining countries or were from recycled or scrap sources. As part of our RCOI process, we conducted the following activities:
" | Reviewed past Conflict Minerals Reporting Templates ("CMRTs"), utilized a 3TG risk assessment tool and consulted with our engineering team to identify 85 active, in-scope, first‐tier suppliers we knew or had reason to believe used necessary 3TG in the production of ExB products (“relevant suppliers”); |
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" | Used the CMRT created by the RMI to survey relevant suppliers, requesting the names of the facilities that processed the necessary 3TG they utilized and the country of origin from which the ores (i.e., unrefined minerals) were sourced; |
" | Reviewed information provided by the 85 relevant suppliers to determine the completeness and reasonableness of their responses and verified the processing facilities they identified by comparing against the list of known smelters and refiners as provided by RMI; |
" | Reviewed country of origin information available to Best Buy through our membership in RMI (member ID V1720151223); and |
" | Conducted additional research on the 3TG processing facilities identified by relevant suppliers, including direct contact and reviewing reports from media, government and civil society organizations, to augment the country of origin information gathered through CMRTs and our membership in RMI. |
Based on the results of our RCOI, we had reason to believe that some of the necessary 3TG used in ExB products may have been processed by facilities that sourced from the DRC or an adjoining country and may not have been from recycled or scrap sources. In compliance with the conflict minerals law, we then exercised due diligence on the source and chain of custody of the necessary 3TG processed by these facilities that conformed to an internationally recognized due diligence framework.
Due Diligence
To determine, to the best of our ability, the source and chain of custody of the necessary 3TG used in ExB products, we conducted due diligence on our supply chain. Our due diligence measures were developed to ascertain if the minerals originated from the DRC or an adjoining country and, if so, whether armed groups directly or indirectly benefited as a result. Additional measures were designed to mitigate risks identified through the implementation of our due diligence process.
Design of our Due Diligence Measures
Our due diligence process is designed to conform, in all material aspects given our downstream position in the supply chain, to the Organisation for Economic Co‐operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‐Affected and High‐Risk Areas, Third Edition, and the related supplements on tin, tantalum, tungsten and gold (collectively, the “OECD Guidance”), an internationally recognized due diligence framework. In accordance with the OECD Guidance, the design of our due diligence includes, but is not limited to, the following:
1. | Maintaining a strong company management system through the adoption of a Conflict Minerals Policy, the implementation of a conflict minerals governance structure, applying supply chain controls, and strengthened engagement with our suppliers. |
2. | Identifying and assessing risks by identifying relevant suppliers to engage in our RCOI and due diligence efforts, determining a reasonable engagement approach to identify smelters and refiners in our supply |
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chain and assess their sourcing practices and reviewing and validating smelter information provided by suppliers to determine risks.
3. | Responding to identified risks by reporting to senior management the findings derived from our RCOI and due diligence efforts, designing training for relevant suppliers to improve their systems of transparency and control, and devising and implementing a risk mitigation strategy that seeks to ensure necessary 3TG in the supply chain are conflict‐free. |
4. | Supporting independent, third‐party audits of smelters and refiners’ due diligence via our membership in and financial support of an industry association that developed a third‐party audit program. |
5. | Reporting on due diligence through our Specialized Disclosure and Conflict Minerals Report filed with the SEC and the inclusion of conflict minerals content in our annual Environmental, Social and Governance (ESG) report. |
Due Diligence Measures Performed
We worked with RMI and industry peers to ensure the implementation of our company’s due diligence process was aligned with the OECD Guidance and complemented and amplified the industry’s approach. The primary objective of this alignment was to maximize the efficiency and effectiveness of our efforts to identify smelters and refiners and encourage their participation in RMI’s Responsible Minerals Assurance Process (“RMAP”) or an equivalent program, including the London Bullion Market Association’s (“LBMA”) Good Delivery program and the Responsible Jewellery Council’s (“RJC”) Chain of Custody program. For this reporting period, we performed the due diligence measures described below, many of which go beyond compliance, on the source and chain of custody of necessary 3TG in the ExB supply chain that we knew or had reason to believe originated from the DRC or Covered Countries and may not have been from recycled or scrap sources:
OECD Guidance Step 1: Maintaining a strong company management system
" | We maintained a Conflict Minerals Policy (“Policy”) that specifically requires our suppliers to utilize smelters and refiners (“SORs”) who have successfully completed a third‐party audit of their due diligence practices; |
" | The Policy, communicated to all ExB suppliers, also requires in-scope suppliers to have a conflict minerals policy, provide an annual CMRT that identifies the SORs in their supply chain, and apply relevant aspects of the OECD Guidance to their sourcing practices. These requirements were assessed and reinforced when we conducted social compliance audits at supplier factories; |
" | Our Policy expectations were further reinforced through our supplier code of conduct and contract language that obliges our suppliers to meet Policy requirements; |
" | We maintained a conflict minerals governance structure comprised of an operations team and an executive committee that included the department heads from Legal, External Reporting, Corporate Responsibility, Exclusive Brands, Government Affairs, Supply Chain, Category Management, Best Buy Health, and Communications and Public Affairs as well as a senior executive from Human Resources. The program is ultimately managed by our Chief Communications and Public Affairs Officer; |
" | We further strengthened our engagement with relevant ExB suppliers by providing training regarding the 4 |
conflict minerals law, our policy requirements, and their role in supporting our RCOI and due diligence efforts; and |
" | We partnered with a third-party software platform to streamline data collection and reporting. The software is linked to the RMI facility database and maintains up-to-date information on Smelter and Refiner operational and conformance status, as well as RCOI information. The tool performs initial data validation checks on our suppliers’ CMRT data and has improved the quality of our suppliers’ CMRT data giving us more visibility to potential risk areas. We have streamlined communication through the platform by providing clear and consistent, automated email guides to drive corrective actions for suppliers, including submission reminders, data errors, and additional actions required. |
" | We tracked our program performance across a set of Key Performance Indicators (KPIs) as detailed in the table below: |
Conflict Mineral Program KPIs |
|
Percent of relevant ExB suppliers who received training material | 100% |
Percent of products containing necessary 3TG that have had their supply chains surveyed | 100% |
Percent of relevant ExB suppliers who returned a CMRT | 100% |
Percent of relevant ExB suppliers who have a conflict minerals policy | 96% |
OECD Guidance Step 2: Identifying and assessing risks
" | We surveyed relevant suppliers, via RMI’s Conflict Minerals Reporting Template, twice in 2022 to identify the SORs in the ExB supply chain. We required CMRTs be completed at a product level from more than 51% of relevant suppliers in 2022, resulting in more accurate data; |
" | All our suppliers’ CMRTs underwent a two-step validation process. They were initially assessed through the software platform for completeness and accuracy and returned to vendors as needed to get additional information. We identified 34 suppliers with incomplete or inaccurate CMRTs and all 34 suppliers returned an updated CMRT. This was followed by a more in-depth review by our team. 16 high risk CMRTs were identified as needing additional corrective action and we will continuously monitor these suppliers for their improvement in the coming year. |
" | We reviewed data collected via our RCOI and due diligence efforts to determine if smelters in our supply chain may have been sourcing from a covered country and potentially directly or indirectly financed or benefited armed groups in the DRC or an adjoining country; |
" | We conducted outreach to smelters and refiners who had not been audited to determine their level of conformance to the RMI standard or another independent third‐party standard and to encourage their participation in such a program; |
" | We directly engaged five smelters and refiners to assess their sourcing practices, request country of origin information and/or to better understand the challenges they face to demonstrate their alignment with the OECD Guidance via a third‐party audit; |
" | We further assessed the level of risk posed by SORs reported to be in our supply chain via shared industry insights, media, and other stakeholder reports, publicly available information, and the results of third‐ party audits, including audit programs from RMI, LBMA and RJC; and |
" | We also identified relevant suppliers that posed a risk of not complying with our contractual and policy requirements related to conflict minerals. |
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OECD Guidance Step 3: Responding to identified risks
" | We reported the findings of our RCOI and due diligence measures, the subsequent risks identified, and the risk mitigation strategies to the Executive Human Rights Committee; |
" | We designed, implemented, and monitored risk mitigation strategies for suppliers who did not comply with our Policy and SORs that had not successfully completed a third‐party audit, including communications that reinforced our policy, providing additional training and support, and conducting audits which included corrective action plans; |
" | We served as the chair of the RMI SET and served as the co‐chair of the China SET. Both entities conducted coordinated outreach to known smelters to encourage them to participate in the RMAP or an equivalent program; |
" | We helped smelters and refiners prepare for a RMAP audit and complete corrective action plans post‐ audit, as needed; |
" | We monitored progress on SORs who implemented post‐audit corrective action plans through our membership in RMI to ensure improvements were made and the audit successfully passed; |
" | We took steps to disengage from 15 smelters in our supply chain who were assessed as high‐risk due, in part, to their refusal to be transparent about their sourcing practices and locations; and |
" | We conducted 18 CMRT validation audits. These audits assess the due diligence capabilities of key ExB suppliers, determine their level of compliance with our contract and policy requirements, support better understanding of their alignment with the OECD Guidance, and build their due diligence capacity to improve sourcing practices and the quality of data received from suppliers. |
OECD Guidance Step 4: Supporting independent, third‐party audits of smelter and refiners’ due diligence
" | We contributed to the development and implementation of an effective smelter audit program through our membership in the RMI, which administers the Responsible Minerals Assurance Process audits; |
" | We attended the virtual RMI conference to gather best practices and collaborate with industry peers. |
OECD Guidance Step 5: Reporting on due diligence
" | We disclosed information regarding our due diligence efforts on the sourcing of 3TG via our Specialized Disclosure and the Conflict Minerals Report filed with the SEC and we will include information on our conflict minerals due diligence efforts in our fiscal 2023 Environmental, Social and Governance Report, which we intend to release in the summer of 2023. |
Results of Due Diligence Performed
We conducted the due diligence process described above to identify SORs and ascertain source and chain of custody information for the necessary 3TG in our ExB supply chain. In 2022, we further assessed the products in scope and have excluded any products where the supplier merely has affixed brands, trademarks, logos, or labels to generic products manufactured by a third party, as permitted by Securities and Exchange Commission guidance.
In 2022, more than 84% of the processing facilities reported by relevant suppliers have been found conformant to the RMI, LBMA, or RJC standard via an independent, third‐party audit or they have committed to go through an audit. Nevertheless, based on our due diligence process and the subsequent information we gathered, we are unable to determine the origin of all the 3TG used in our products and whether armed groups directly or indirectly
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benefited. This is primarily due to incomplete information from suppliers who were unable to identify all the SORs used in their supply chain, often because of unwilling or inept upstream actors in their supply chain, company level CMRTs in which we are unable to discern which of the reported SORs processed the necessary 3TG in our products, and the lack of transparency among smelters who have not yet been audited, in particular, gold refiners. Further complicating our ability to determine the origin of all the necessary 3TG is our downstream position in which we have no contractual relationship with upstream actors.
Of the 260 smelters and refiners provided by relevant ExB suppliers, we identified 38 for which we had reason to believe that at least a portion of the 3TG they processed may have originated in the DRC or an adjoining country and may not have been from recycled or scrap sources. All 38 of these processing facilities have been found conformant through RMAP or another independent, third‐party audit program. Furthermore, we have not identified a supplier, smelter, or refiner who we have reason to believe may be sourcing from the DRC or an adjoining country and directly or indirectly benefiting armed groups.
We are also aware that allegations, including violence perpetrated by security forces at source mines and ties to corrupt business entities in the sourcing of gold, have been leveled against a few of the smelters reported to be in our supply chain. We take these allegations seriously and we are monitoring third‐party investigations and corrective actions taken by these smelters. Based on the results of these efforts, we may take additional action, up to and including the removal of these smelters from our supply chain.
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Please see the table below for the status of facilities reported to us by relevant ExB suppliers and see Attachment A for the list of smelters and refiners, their location, and the countries from where they source, which is provided in aggregate by metal.
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Metal | # of SORs | Conformant (1) | Active or TI‐CMC Member (1) | Unknown (1) |
Gold | 116 | 80% | 1% | 19% |
Tantalum | 34 | 97% | 0% | 3% |
Tin | 70 | 81% | 3% | 16% |
Tungsten | 40 | 83% | 0% | 18% |
Totals | 260 | 83% | 1% | 16% |
(1) | Facility status is defined as the following: |
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Facility Status | Status Definition |
Conformant | Facilities as of Apr 12,2023 that conform with a third‐party due diligence standard |
Active or TI‐CMC Member | Facilities that have committed to a RMAP audit or are participating in another independent third‐party audit program |
Unknown | Facilities for which we do not know to what degree they conform to the RMAP or another audit program’s standard |
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Future Steps to Optimize Our Due Diligence Efforts
Best Buy is committed to be a socially and environmentally responsible corporation and this commitment extends throughout the length of our value chain, from the sourcing of raw material to the responsible recycling of products. We recognize that this commitment is a journey and one that we cannot take on our own. This challenge is exacerbated given the complexity of our supply chain, which is, in essence, in a constant state of flux. As a result, we will continue to focus our efforts on collaborating across industries to improve the systems of transparency and control in our supply chain. We will also continue our engagement with relevant suppliers to build their knowledge, so they are able to provide more complete and accurate information on the source of conflict minerals in our ExB supply chain and, furthermore, to impress upon them our expectation that they also apply the OECD Guidance in good faith.
Steps we intend to take in 2023 include:
· | Continue to enhance the system used to store our CMRT results to improve data analysis and reporting; |
· | Continue to conduct CMRT Validation audits at key supplier and leverage the learnings from these audits to update our training material that is delivered to all relevant suppliers; |
· | Continue to participate in RMI meetings to gather best practices and collaborate with industry peers. |
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Attachment A
Many of the CMRT responses we received from relevant suppliers provided data at a company level, meaning they provided the names of smelters and refiners they believe supplied 3TG for all the products they produced, not just the products they produced for Best Buy. Therefore, the processing facilities listed in the table below represent the smelters and refiners provided by our suppliers, but we do not have sufficient information to confirm whether these are the actual smelters that processed necessary 3TG used in our products. Additionally, we are unable to conclusively determine the country of origin information for our necessary 3TG but based on the data gathered from suppliers, processing facilities, public information and RMI, we believe that the sources may include the countries listed in the table below.
Metal | Processing Facility Name (2) | Location of Facility(2) | Facility Status (3) |
Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | Active |
Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
Gold | Shandong Gold Smelting Co., Ltd. | CHINA | Conformant |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant |
Gold | Agosi AG | GERMANY | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
Gold | Asahi Pretec Corp. | JAPAN | Conformant |
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
Gold | Aurubis AG | GERMANY | Conformant |
Gold | Bangalore Refinery | INDIA | Conformant |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
Gold | Boliden AB | SWEDEN | Conformant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
Gold | Chimet S.p.A. | ITALY | Conformant |
Gold | Chugai Mining | JAPAN | Conformant |
Gold | Dowa | JAPAN | Conformant |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
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Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant |
Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
Gold | Heraeus Germany GmbH Co. KG | GERMANY | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | Conformant |
Gold | Italpreziosi | ITALY | Conformant |
Gold | Japan Mint | JAPAN | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
Gold | Kazzinc | KAZAKHSTAN | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | L'Orfebre S.A. | ANDORRA | Conformant |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Materion | UNITED STATES OF AMERICA | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | MKS PAMP SA | SWITZERLAND | Conformant |
Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
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Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
Gold | Royal Canadian Mint | CANADA | Conformant |
Gold | SAAMP | FRANCE | Conformant |
Gold | SAFINA A.S. | CZECHIA | Conformant |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | T.C.A S.p.A | ITALY | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
Gold | Valcambi S.A. | SWITZERLAND | Conformant |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
Gold | Yamakin Co., Ltd. | JAPAN | Conformant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Conformant |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Unknown |
Gold | Umicore Precious Metals Thailand | THAILAND | Unknown |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Unknown |
Gold | Marsam Metals | BRAZIL | Unknown |
Gold | 8853 S.p.A. | ITALY | Unknown |
Gold | Cendres + Metaux S.A. | SWITZERLAND | Unknown |
Gold | Safimet S.p.A | ITALY | Unknown |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unknown |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unknown |
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Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unknown |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unknown |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Unknown |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | Unknown |
Gold | Sudan Gold Refinery | SUDAN | Unknown |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | Unknown |
Gold | Industrial Refining Company | BELGIUM | Unknown |
Gold | Sai Refinery | INDIA | Unknown |
Gold | Modeltech Sdn Bhd | MALAYSIA | Unknown |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Unknown |
Gold | Sovereign Metals | INDIA | Unknown |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Unknown |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Unknown |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | KEMET de Mexico | MEXICO | Conformant |
Tantalum | TANIOBIS Co., Ltd. | THAILAND | Conformant |
Tantalum | TANIOBIS GmbH | GERMANY | Conformant |
Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | Conformant |
Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | Conformant |
Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
Tantalum | AMG Brasil | BRAZIL | Conformant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | Conformant |
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Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Unknown |
Tin | PT Timah Nusantara | INDONESIA | Active |
Tin | Super Ligas | BRAZIL | Active |
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
Tin | Dowa | JAPAN | Conformant |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
Tin | Fenix Metals | POLAND | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
Tin | Luna Smelter, Ltd. | RWANDA | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
Tin | Aurubis Beerse | BELGIUM | Conformant |
Tin | Aurubis Berango | SPAIN | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tin | Minsur | PERU | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
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Tin | PT Babel Surya Alam Lestari | INDONESIA | Conformant |
Tin | PT Bangka Serumpun | INDONESIA | Conformant |
Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
Tin | PT Prima Timah Utama | INDONESIA | Conformant |
Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant |
Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
Tin | Thaisarco | THAILAND | Conformant |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
Tin | Estanho de Rondonia S.A. | BRAZIL | Conformant |
Tin | CRM Synergies | SPAIN | Conformant |
Tin | PT Mitra Sukses Globalindo | INDONESIA | Conformant |
Tin | PT Bukit Timah | INDONESIA | Conformant |
Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | Conformant |
Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | Conformant |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Conformant |
Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
Tin | CV Ayi Jaya | INDONESIA | Conformant |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
Tin | PT Tommy Utama | INDONESIA | Conformant |
Tin | PT Rajehan Ariq | INDONESIA | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unknown |
Tin | PT Tinindo Inter Nusa | INDONESIA | Unknown |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Unknown |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | Unknown |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Unknown |
Tin | Pongpipat Company Limited | MYANMAR | Unknown |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | Unknown |
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Tin | Precious Minerals and Smelting Limited | INDIA | Unknown |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | Unknown |
Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | Conformant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Masan High-Tech Materials | VIET NAM | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant |
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Unknown |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Unknown |
Tungsten | ACL Metais Eireli | BRAZIL | Unknown |
15
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Unknown |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | Unknown |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unknown |
Country of origin for the mined and recycled Gold processed by the facilities listed above may include: Algeria, Andorra, Antigua and Barbuda, Argentina, Australia, Austria, Azerbaijan, Bahamas, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia(Pluractional State of), Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Côte d'Ivoire, Croatia, Curacao, Cyprus, Czech Republic, Democratic Republic of the Congo, Demark, Dominican Republic, Ecuador, Egypt, Eritrea, Estonia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Greece, Grenada, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Liechtenstein, Lithuania, Luxembourg, Macao, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Monaco, Mongolia, Morocco, Mozambique, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Oman, Pakistan, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russian Federation, Sint Kitts and Nevis, Saudi Arabia, Senegal, Serbia, Singapore, Sint Maarten, Slovakia, Slovenia, South Africa, South Korea, Spain, St Vincent and Grenadines, Sudan, Suriname, Swaziland, Sweden, Switzerland, Tajikistan, Tanzania, Thailand, Trinidad and Tobago, Tunisia, Turkey, Turks and Caicos, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United Status of America, Uruguay, Uzbekistan, Vietnam, Zambia, Zimbabwe.
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Country of origin for the mined and recycled Tantalum processed by the facilities listed above may include: Australia, Belarus, Brazil, Burundi, Canada, China, Czech Republic, Democratic Republic of Congo, El Salvador, Estonia, Ethiopia, France, Germany, Hong Kong, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Mexico, Mozambique, Nigeria, Russia, Rwanda, Sierra Leone, Singapore, South Korea, Spain, Thailand, United Kingdom of Great Britain and Northern Ireland, United states of America, Zimbabwe
| |||
Country of origin for the mined and recycled Tin processed by the facilities listed above may include: Angola, Argentina, Australia, Austria, Bahrain, Bangladesh, Belarus, Belgium, Bolivia, Bolivia (Pluractional State of), Brazil, Bulgaria ,Burundi, Canada, Chile ,China, Colombia, , Croatia, Czech Republic, Democratic Republic of the Congo, Denmark, Egypt, Finland ,France, Germany, Ghana, Greece, Guinea, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Kuwait, Laos, Latvia, Lebanon, Liberia, Lithuania, Malaysia, Malta, Mexico, Morocco, Myanmar, Namibia, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russia, Russian Federation, Rwanda, Saudi Arabia, Senegal ,Serbia, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sudan, Sweden, Switzerland, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Venezuela, Vietnam, Yemen
| |||
Country of origin for the mined and recycled Tungsten processed by the facilities listed above may include: Australia, Austria, Bolivia, Brazil, Burundi, Canada, China, Democratic Republic of the Congo, Germany, Ireland, Israel, Japan, Kazakhstan, Kyrgyzstan, Malaysia, Mexico, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, South Korea, Thailand, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Vietnam, Zimbabwe
|
(1) | Facility name and location as reported by the Responsible Minerals Initiative. |
(2) | Facility status is defined as the following: |
Facility Status | Status Definition |
Conformant | Facilities as of April 12, 2023, that conform with a 3rd party due diligence audit standard |
Active | Facilities that have committed to a RMAP audit or are participating in another independent third‐party audit program |
Unknown | Facilities for which we do not know to what degree they conform to the RMAP or another audit program’s standard |
16