Exhibit 1.01
Carlisle Companies Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2021
This Conflict Minerals Report (the “Report”) of Carlisle Companies Incorporated (“Carlisle,” “the Company,” “we,” “us,” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the year ended December 31, 2021. The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“the Act”).
The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. For purposes of this assessment, conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“Conflict Minerals” or “3TG”) and originated from the Democratic Republic of the Congo or an adjoining country (“Covered Countries”). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict. Please refer to the Rule for definitions of the terms used in this Report, unless otherwise defined herein. Please also note that the report presented herein is not audited.
Company Overview
Carlisle is a diversified, global manufacturer of highly-engineered products, including building envelope products and energy-efficient solutions for customers creating sustainable buildings of the future, high-performance wire and cable and other electronics products for the commercial aerospace, defense electronics, medical device and other industrial markets and liquid, powder, sealants and adhesives finishing equipment and systems for several global end markets, via the following segments:
•Carlisle Construction Materials (“CCM”);
•Carlisle Interconnect Technologies (“CIT”); and
•Carlisle Fluid Technologies (“CFT”).
In 2021, we divested our former Carlisle Brake & Friction ("CBF") segment. CBF is not included in this Report since our due diligence for the 2021 Report Year, described in greater detail below, did not begin until after our CBF divestiture was completed.
Products Overview
CCM manufactures a complete range of building envelope products for commercial, industrial and residential buildings, including single-ply roofing, rigid foam insulation, spray polyurethane foam technologies, architectural metal, heating, ventilation and air conditioning ("HVAC") hardware and sealants, below-grade waterproofing, and air and vapor barrier systems focused on the weatherproofing and thermal performance of the building envelope. Key raw materials for this segment include methylene diphenyl diisocyanate ("MDI"), polyol, ethylene propylene diene monomer (“EPDM”) polymer, thermoplastic polyolefin (“TPO”) polymer, silicone polymer, carbon black and coated steel.
CIT designs and manufactures high-performance wire and cable, including optical fiber, for the commercial aerospace, military and defense electronics, medical device, industrial, and test and measurement markets. Key raw materials for this segment include gold, copper conductors that are plated with tin, nickel, or silver, polyimide tapes, polytetrafluoroethylene (“PTFE”) tapes, PTFE fine powder resin, thermoplastic resins, stainless steel, beryllium copper rod, machined metals, plastic parts, and various marking and identification materials. Key raw materials are typically sourced worldwide.
CFT designs, manufactures and sells highly-engineered liquid, powder, sealants and adhesives finishing equipment and integrated system solutions for spraying, pumping, mixing, metering and curing a variety of coatings used primarily in the automotive manufacture, general industrial, protective coating, wood, specialty and automotive refinish markets. Key raw materials for this segment include carbon steel and various grades of stainless steel, brass, aluminum, copper, machined metals, carbide, machined plastic parts and PTFE. Key raw materials are typically sourced worldwide.
Based on a review of the key raw materials used by the segments and discussions with key operations personnel across all segments, the Company determined that all four Conflict Minerals are present and that the CIT segment has the highest utilization of 3TG. It has been determined that CFT has significantly less utilization of 3TG than CIT, and that CCM does not use materials in the manufacturing process that contain Conflict Minerals. For the year ended December 31, 2021, the Company’s reasonable country of origin inquiry (“RCOI”) and due diligence inquiries focused primarily on CIT and CFT.
Conflict Minerals Policy
The Company has adopted a Conflict Minerals Policy, which is publicly available on our website at www.carlisle.com under “Corporate Governance”.
Reasonable Country of Origin Inquiries
The Company completed a detailed scoping exercise, led by key operating and purchasing personnel, including reviewing all purchases over a 12-month period to identify any 3TG and corresponding suppliers. The suppliers were sorted according to their likelihood of supplying components or materials containing Conflict Minerals. Those that were known to or could potentially supply components or materials containing Conflict Minerals with whom annual spend exceeded a specified threshold were considered to be in scope for supplier inquiries.
As a result of this scoping process, 701 different suppliers were identified for RCOI outreach.
We conducted a RCOI reasonably designed to determine whether the 3TG in our products in the 2021 Report Year originated from the Covered Countries or are from recycled or scrap sources in accordance with the requirements of the Rule. The Covered Countries are the Democratic Republic of Congo and its adjoining countries (Angola, Burundi, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia). As part of its RCOI, and with the assistance of a third-party consultant, Assent Compliance, Inc. (“Assent”), the Company engaged its potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. Suppliers were asked to complete and submit, within a certain time frame, the RBA-GeSI Conflict Minerals Reporting Template ("CMRT") version 6.1. The CMRT is a standardized reporting template developed by the Responsible Minerals Initiative (“RMI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the smelters or refiners ("SOR") in the supply chain. Assent followed up with all unresponsive suppliers through a defined process through both automated emails and one-on-one emails, including offering assistance and further information to suppliers about the requirements of the Rule and the Company’s expectations.
Because of the size, complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging to identify providers upstream from our direct suppliers. There are potentially many tiers of suppliers and sub-suppliers between the Company and the SORs that process the 3TG that is contained in each product manufactured or contracted to be manufactured by Carlisle. Therefore, it is inherently difficult to determine the ultimate source of 3TGs in our products.
Based on the responses received thus far from direct suppliers, there is reason to believe that some of the necessary Conflict Minerals used in our products may have originated from the Covered Countries, but no instances were identified in which this sourcing, directly or indirectly, financed or benefited armed groups from the Covered Countries. However, since not all supplier responses have been received and not all additional inquiries have been completed, we are unable to determine the country of origin of some Conflict Minerals or whether they originated from recycled or scrap sources. We continue to reach out to unresponsive suppliers and perform additional inquiries until such time we have 100% response rate.
As a result of the above conclusion and pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary Conflict Minerals in our products which we had reason to believe may have originated from Covered Countries and which may not have come from recycled scrap or scrap sources. There is significant overlap between our RCOI efforts and our due diligence measures performed.
Due Diligence Performed
Carlisle undertook systematic due diligence to determine the status of the Conflict Minerals used in its businesses. Due diligence efforts have been designed to conform, in all material respects, with the framework presented by The Organization for Economic Co-operation and Development (“OECD”) in the publication OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris (http://dx.doi.org/10.1787/9789264252479-en) and the related Supplements for gold and for tin, tantalum and tungsten, an internationally recognized due diligence framework. The OECD Due Diligence Guidance includes the following five-step program:
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices
Step 5: Report annually on supply chain due diligence
Establish and Maintain Strong Company Management Systems
•Conflict Minerals Policy: As noted above, the Company has adopted and maintains a Conflict Minerals Policy related to our sourcing of 3TG. The policy has been provided to our suppliers and is publicly available on our company website.
•Internal Team and Training: The Conflict Minerals team responsible for overseeing Carlisle’s compliance is comprised of our General Counsel and our CIT Director of Supplier Development along with designated representatives within the supply chain organizations at each segment. Additionally, a professional services firm was engaged to augment the internal management group responsible for the design and implementation of our planned due diligence.
•Control Systems: A management system has been established to support supply chain due diligence related to 3TG. We employ a supply chain system of controls and transparency through the use of due diligence tools, such as the CMRT used to identify the smelters and refiners that process the necessary Conflict Minerals contained in a company's products and the country of origin of those Conflict Minerals.
•Supplier Engagement: We have feature requirements related to Conflict Minerals in our standard template for significant supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on Conflict Minerals, including participation in a supply chain survey and related due diligence activities.
•Grievance Mechanism: In the event of an actual or possible violation of our policies, including the Company’s Conflict Minerals Policy, employees (internal) and suppliers (external) can report violations as part of the Company’s protocol for reporting suspected violations of the Carlisle Code of Business Conduct and Ethics. The Company’s Code of Business Conduct and Ethics is available on our website at www.carlisle.com under “Corporate Governance”.
•Records Maintenance: We employ a database to assess due diligence information and maintain records related to our conflict mineral program, in accordance with our record retention policies.
Identify and Assess Risks in the Supply Chain
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
Our primary means of determining origin of our 3TG for the 2021 Report Year was by conducting a supply chain survey with direct suppliers using the CMRT. This supply chain survey, and Carlisle’s Conflict Minerals program as a whole, has been developed and implemented in cooperation with Assent.
Assent provided each supplier a copy of the CMRT to complete for purposes of Conflict Minerals tracking. Assent followed up with all unresponsive suppliers through a defined process through both automated emails and one-on-one emails. The software platform automatically reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses.
Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the RMI Responsible Minerals Assurance Process ("RMAP"). If a SOR was not validated by the RMI’s RMAP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted research to determine whether there are any additional publicly available sources of information regarding the SORs' sourcing practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with Conflict Minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the Supply Chain. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:
•Geographic proximity to the DRC and covered countries;
•RMAP audit status;
•Known or plausible evidence of unethical or conflict sourcing;
•Known mineral source country of origin;
•Peer assessments conducted by credible third-party sources.
If a risk is identified, risk mitigation activities are initiated. As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these risks from the supply chain.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
Design and Implement a Strategy to Respond to Identified Risks
The Company maintains a risk management plan to respond to risks identified in the above-described risk assessment. The Company’s Conflict Minerals program is implemented, managed and monitored in accordance with this risk management plan.
The Company’s Conflict Minerals team provides updates to senior management of the Company in connection with the Conflict Minerals program, including with regard to risk assessment and results of the annual due diligence process.
As described in our Conflict Minerals Policy, we expect our suppliers to fully support our compliance efforts, including in connection with our due diligence efforts to trace the source and chain of custody of our 3TG. As part of our risk management plan, to ensure suppliers understand our expectations, we worked with Assent to provide documented instructions to suppliers and answered all inquiries that needed further clarification. We will continue improving our Conflict Minerals process to obtain complete and accurate information about SORs.
Support Independent Third Party Audits of Supply Chain
The Company does not typically have a direct relationship with 3TG smelters and refiners. Therefore, we rely on the RMI’s RMAP to manage and report results of the independent third-party audits of smelters and the related certification.
Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices
While we currently do not engage an independent third-party audit of smelters/refiners identified in our supply chain, we support the auditing efforts of the RMI.
Results of Due Diligence
As a result of the due diligence efforts described above, we received responses from 79.7%, or 559, of our direct suppliers for the year ended December 31, 2021. Of these, 536 were completed and validated CMRTs. From these responses, a list was compiled of the smelters and refiners that may have been used to process 3TGs necessary to the functionality or production of our products. For all smelters identified, Assent confirmed that the name was listed on the RMI’s Standard Smelter List. We have validated 332 smelters to date and continue to work on validating the additional entries from submitted CMRTs. Based on the smelter lists provided by suppliers via the CMRTs and publicly available information regarding the results of sourcing audits by the RMI, we have identified 229 Conflict-Free SORs, with an additional 18 that are active in the audit process (See Appendix A).
The information that we received from a majority of our direct suppliers was at a company-wide level. Therefore, the smelters identified by our direct suppliers may include facilities that processed 3TGs that our direct suppliers supplied to their other customers rather than to us. Thus, we are unable to conclusively determine whether these smelters were used to process the 3TGs necessary to the functionality or production of our products during 2021. Because of this uncertainty, we are also unable to conclusively determine the country of origin of 3TGs in our products during 2021, and therefore, are unable to conclusively determine the source and chain of custody of those 3TGs. In addition, the third-party audits conducted by the RMI, and the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete Conflict Minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI RMAP and, as a result, are not responsible for the quality of these audits or the audit findings.
Due Diligence Procedures to be Performed
Carlisle will continue to implement steps to improve the information gathered from its due diligence to further mitigate the risk that its necessary Conflict Minerals benefit armed groups. We will continue to work to increase the response rate of suppliers and will continue to evaluate responses to the surveys with the expectation that the third-party developed software will continue to help increase efficiency and identify any necessary follow-up procedures. This includes executives and supply chain management teams completing a supplier scoping exercise, sending CMRTs to any supplier selling goods to Carlisle that may contain 3TG minerals, detailed analysis of all survey responses, and additional inquiries as necessary.
Appendix A
Summary of Smelter and Refiner Status
The table below details, as of December 31, 2021, the status of operational smelter and refiner facilities, identified by the surveyed suppliers, and the results of our smelter and refiner due diligence activities. The table indicates the number of such smelters and refiner facilities that:
•have received a "conflict-free" designation from an independent third party audit program (referred to as "Conformant"),
•have begun participating in an independent third party audit program (referred to as "Active"),
•have received a "non-conformant" designation from an independent third-party audit program (referred to as "Non-Conformant") or
•have not begun participating in an independent third party audit program (referred to as "Not Enrolled").
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Gold | 8853 S.p.A. | Italy | Conformant |
| Gold | Abington Reldan Metals, LLC | United States Of America | Active |
| Gold | Advanced Chemical Company | United States Of America | Conformant |
| Gold | African Gold Refinery | Uganda | Not Enrolled |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | Conformant |
| Gold | Alexy Metals | United States Of America | Active |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | 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 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Not Enrolled |
| Gold | AU Traders and Refiners | South Africa | Non-Conformant |
| Gold | Augmont Enterprises Private Limited | India | Active |
| 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 | C.I Metales Procesados Industriales SAS | Colombia | Active |
| Gold | Caridad | Mexico | Not Enrolled |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | Conformant |
| Gold | Cendres + Metaux S.A. | Switzerland | Conformant |
| Gold | CGR Metalloys Pvt Ltd. | India | Not Enrolled |
| Gold | Chimet S.p.A. | Italy | Conformant |
| Gold | Chugai Mining | Japan | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Not Enrolled |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | Not Enrolled |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | Not Enrolled |
| 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 |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | Not Enrolled |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | Not Enrolled |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | Not Enrolled |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | Not Enrolled |
| Gold | Emirates Gold DMCC | United Arab Emirates | Conformant |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | Not Enrolled |
| Gold | Fujairah Gold FZC | United Arab Emirates | Not Enrolled |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | Active |
| Gold | Geib Refining Corporation | United States Of America | Conformant |
| Gold | Gold Coast Refinery | Ghana | Not Enrolled |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | Not Enrolled |
| Gold | Guangdong Jinding Gold Limited | China | Not Enrolled |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Not Enrolled |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Not Enrolled |
| Gold | Heimerle + Meule GmbH | Germany | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | China | Conformant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | Not Enrolled |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | Not Enrolled |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | Not Enrolled |
| Gold | Industrial Refining Company | Belgium | Non-Conformant |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant |
| Gold | International Precious Metal Refiners | United Arab Emirates | Not Enrolled |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant |
| Gold | Istanbul Gold Refinery | Turkey | Conformant |
| Gold | Italpreziosi | Italy | Conformant |
| Gold | JALAN & Company | India | Not Enrolled |
| Gold | Japan Mint | Japan | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | China | Conformant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Not Enrolled |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Gold | JSC Uralelectromed | Russian Federation | Non-Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant |
| Gold | K.A. Rasmussen | Norway | Not Enrolled |
| Gold | Kaloti Precious Metals | United Arab Emirates | Not Enrolled |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | Not Enrolled |
| 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 | Kundan Care Products Ltd. | India | Not Enrolled |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Non-Conformant |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | Not Enrolled |
| Gold | L'azurde Company For Jewelry | Saudi Arabia | Not Enrolled |
| Gold | Lingbao Gold Co., Ltd. | China | Not Enrolled |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Not Enrolled |
| 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 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Not Enrolled |
| Gold | Marsam Metals | Brazil | Conformant |
| Gold | Materion | United States Of America | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Conformant |
| Gold | MD Overseas | India | Not Enrolled |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | Conformant |
| Gold | Metallix Refining Inc. | United States Of America | Not Enrolled |
| 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 | Modeltech Sdn Bhd | Malaysia | Non-Conformant |
| Gold | Morris and Watson | New Zealand | Not Enrolled |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | Non-Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Conformant |
| Gold | NH Recytech Company | Korea, Republic Of | 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 |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | Non-Conformant |
| Gold | OJSC Novosibirsk Refinery | Russian Federation | Non-Conformant |
| Gold | PAMP S.A. | Switzerland | Conformant |
| Gold | Pease & Curren | United States Of America | Not Enrolled |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Not Enrolled |
| Gold | Planta Recuperadora de Metales SpA | Chile | Conformant |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Non-Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant |
| Gold | PX Precinox S.A. | Switzerland | Conformant |
| Gold | QG Refining, LLC | United States Of America | Not Enrolled |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | Conformant |
| Gold | Refinery of Seemine Gold Co., Ltd. | China | Not Enrolled |
| Gold | REMONDIS PMR B.V. | Netherlands | Conformant |
| Gold | Royal Canadian Mint | Canada | Conformant |
| Gold | SAAMP | France | Conformant |
| Gold | Sabin Metal Corp. | United States Of America | Not Enrolled |
| Gold | Safimet S.p.A | Italy | Conformant |
| Gold | SAFINA A.S. | Czechia | Conformant |
| Gold | Sai Refinery | India | Not Enrolled |
| Gold | Samduck Precious Metals | Korea, Republic Of | Conformant |
| Gold | Samwon Metals Corp. | Korea, Republic Of | Not Enrolled |
| Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | Active |
| Gold | Sellem Industries Ltd. | Mauritania | Not Enrolled |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | Conformant |
| Gold | Shandong Humon Smelting Co., Ltd. | China | Not Enrolled |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Not Enrolled |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | Not Enrolled |
| Gold | Shirpur Gold Refinery Ltd. | India | Not Enrolled |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | Conformant |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Non-Conformant |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | Conformant |
| Gold | Sovereign Metals | India | Not Enrolled |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | Not Enrolled |
| Gold | Sudan Gold Refinery | Sudan | Not Enrolled |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | Conformant |
| Gold | Super Dragon Technology Co., Ltd. | China | Not Enrolled |
| Gold | T.C.A S.p.A | Italy | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | Conformant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Not Enrolled |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | Conformant |
| Gold | Torecom | Korea, Republic Of | Conformant |
| Gold | Umicore Precious Metals Thailand | Thailand | 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 | Value Trading | Belgium | Not Enrolled |
| Gold | WEEEREFINING | France | Active |
| 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 | Yunnan Copper Industry Co., Ltd. | China | Not Enrolled |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Conformant |
| Tantalum | D Block Metals, LLC | United States Of America | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | China | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | Conformant |
| Tantalum | Global Advanced Metals Boyertown | United States Of America | Conformant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Conformant |
| Tantalum | H.C. Starck Co., Ltd. | Thailand | Conformant |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Conformant |
| Tantalum | H.C. Starck Inc. | United States Of America | Conformant |
| Tantalum | H.C. Starck Ltd. | Japan | Conformant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | KEMET Blue Metals | Mexico | Conformant |
| Tantalum | LSM Brasil S.A. | Brazil | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | Conformant |
| Tantalum | Mineracao Taboca S.A. | Brazil | Conformant |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
| Tantalum | NPM Silmet AS | Estonia | Conformant |
| Tantalum | QuantumClean | United States Of America | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | Japan | Conformant |
| Tantalum | Telex Metals | United States Of America | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | Conformant |
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | China | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tin | Alpha | United States Of America | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Not Enrolled |
| 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 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Active |
| Tin | CRM Synergies | Spain | Conformant |
| Tin | CV Venus Inti Perkasa | Indonesia | Active |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | Non-Conformant |
| Tin | Dowa | Japan | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Non-Conformant |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | Conformant |
| Tin | Estanho de Rondonia S.A. | Brazil | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | Fenix Metals | Poland | Conformant |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Not Enrolled |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | Non-Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Conformant |
| Tin | Gejiu Zili Mining And Metallurgy 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 | Ma'anshan Weitai Tin Co., Ltd. | China | Conformant |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant |
| Tin | Melt Metais e Ligas S.A. | Brazil | Not Enrolled |
| Tin | Metallic Resources, Inc. | United States Of America | Conformant |
| Tin | Metallo Belgium N.V. | Belgium | Conformant |
| Tin | Metallo Spain S.L.U. | Spain | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | Conformant |
| Tin | Minsur | Peru | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | Conformant |
| Tin | Modeltech Sdn Bhd | Malaysia | Non-Conformant |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | Not Enrolled |
| Tin | Novosibirsk Processing Plant Ltd. | Russian Federation | 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 | Pongpipat Company Limited | Myanmar | Not Enrolled |
| Tin | Precious Minerals and Smelting Limited | India | Non-Conformant |
| Tin | PT Aries Kencana Sejahtera | Indonesia | Active |
| Tin | PT Artha Cipta Langgeng | Indonesia | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
| Tin | PT Babel Inti Perkasa | Indonesia | Conformant |
| Tin | PT Babel Surya Alam Lestari | Indonesia | Conformant |
| Tin | PT Bangka Serumpun | Indonesia | Conformant |
| Tin | PT Belitung Industri Sejahtera | Indonesia | Not Enrolled |
| Tin | PT Bukit Timah | Indonesia | Conformant |
| Tin | PT Cipta Persada Mulia | Indonesia | Conformant |
| Tin | PT Menara Cipta Mulia | Indonesia | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | Conformant |
| Tin | PT Mitra Sukses Globalindo | Indonesia | Active |
| Tin | PT Panca Mega Persada | Indonesia | Not Enrolled |
| Tin | PT Prima Timah Utama | Indonesia | Conformant |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | Conformant |
| Tin | PT Refined Bangka Tin | Indonesia | Conformant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | Conformant |
| Tin | PT Stanindo Inti Perkasa | Indonesia | Conformant |
| Tin | PT Sukses Inti Makmur | Indonesia | Active |
| Tin | PT Timah Nusantara | Indonesia | Active |
| Tin | PT Timah Tbk Kundur | Indonesia | Conformant |
| Tin | PT Timah Tbk Mentok | Indonesia | Conformant |
| Tin | PT Tinindo Inter Nusa | Indonesia | Conformant |
| Tin | PT Tirus Putra Mandiri | Indonesia | Not Enrolled |
| Tin | PT Tommy Utama | Indonesia | Not Enrolled |
| Tin | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | Rui Da Hung | Taiwan, Province Of China | Conformant |
| Tin | Soft Metais Ltda. | Brazil | Conformant |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Tin | Super Ligas | Brazil | Active |
| Tin | Thaisarco | Thailand | Conformant |
| Tin | Tin Technology & Refining | United States Of America | Conformant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | Not Enrolled |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | Not Enrolled |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Conformant |
| Tin | Yunnan Tin Company Limited | China | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Non-Conformant |
| Tungsten | A.L.M.T. Corp. | Japan | Conformant |
| Tungsten | ACL Metais Eireli | Brazil | Conformant |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Active |
| Tungsten | Artek LLC | Russian Federation | Not Enrolled |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | China Molybdenum Co., Ltd. | China | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | Not Enrolled |
| Tungsten | Cronimet Brasil Ltda | Brazil | Conformant |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | Conformant |
| Tungsten | Fujian Xinlu Tungsten | 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 | GEM Co., Ltd. | China | Conformant |
| Tungsten | Global Tungsten & Powders Corp. | United States Of America | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Conformant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Conformant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | 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 Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Not Enrolled |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Conformant |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | RMAP Audit Status |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | 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 Tungsten Chemical LLC (MTC) | Viet Nam | Conformant |
| Tungsten | Moliren Ltd. | Russian Federation | Conformant |
| Tungsten | Niagara Refining LLC | United States Of America | Conformant |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | Active |
| Tungsten | OOO “Technolom” 1 | Russian Federation | Active |
| Tungsten | OOO “Technolom” 2 | Russian Federation | Active |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant |
| Tungsten | Unecha Refractory metals plant | Russian Federation | 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 | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | Conformant |
