PLANTRONICS, INC. CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2018
Introduction
This Conflict Minerals Report for the calendar year ended December 31, 2018 (“CY 2018”) is presented by Plantronics, Inc. (“we” or the “Plantronics”) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).
Plantronics is a global company that manufactures and contracts to manufacture communications headsets and related equipment, as listed on our Form SD of which this report is a part, from a global supply chain with many levels. We work with our supplier base to identify the facilities processing Tin, Tantalum, Tungsten and Gold (3TG) in our supply chain.
As part of the RCOI described in Form SD, Plantronics performed a supplier survey using the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) during the second half of CY 2018. Fifty-six (56) direct first tier suppliers providing components used in Plantronics products within scope of the rule as described further in the Form SD were included in the survey utilized for both RCOI and Due Diligence. The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Plantronics products may have originated in the Democratic Republic of Congo or the adjoining countries (the “covered countries”) and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.
Design and Execution of Due Diligence
We first designed and implemented the majority of our due diligence measures in preparation for the reporting year CY 2013 with incremental modifications we have made over time to improve and refine the process, such as implementing supplier survey software and onsite supplier audits. These measures were continued in CY 2018 and are described herein. They are designed to conform, in all material respects, to the framework 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 (OECD 2016) including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies (collectively the “OECD Guidance”). In accordance with the five step OECD Guidance, our measures are designed to determine, to the best of our ability, the source of the 3TG materials necessary for the functionality and/or production of our products, to ascertain if the materials originated in one of the covered countries, and if so, whether armed groups directly or indirectly benefited as a result.
1. | Establish Strong Company Management Systems |
a. | Plantronics has a company Conflict Minerals team consisting of senior representatives from Quality (Senior Director, Quality Excellence), Operations/Materials (Procurement Director, NPD and Sr. Global Supply Manager), Legal (VP, Deputy General Counsel), Compliance (Senior Director, Compliance), and members of their staffs. |
b. | Plantronics has a conflict minerals policy statement publicly available at: www.plantronics.com/conflictminerals. |
c. | We maintain a grievance reporting system open to both employees and suppliers through our ethics reporting system at www.plantronics.com/conflictminerals. Alternatively, grievances specifically relating to Conflict Minerals may be submitted directly to RMI at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. |
d. | In addition to any annual survey using the CMRT, supplier obligations and requirements in this regard have been incorporated into the Supplier Code of Conduct, which is available on the corporate governance section of our website. |
In addition, Conflict Minerals Requirements, including due diligence and participation in annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document.
e. | Plantronics purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause. |
f. | Plantronics establishes and maintains long term relationships with the majority of our first tier Original Design, Contract, and Custom Part Manufacturers to facilitate engagement with suppliers to improve due diligence performance. |
g. | Since we have limited direct relationships with any facilities processing 3TG, we are an active participant in the Responsible Minerals Initiative (RMI) (http://www.responsiblemineralsinitiative.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the SOR level and further upstream. |
h. | Conflict Minerals materials records are maintained pursuant to our records retention policy. |
i. | The formal Quarterly Compliance report includes a section providing conflict minerals program progress and findings to upper management. |
j. | We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures. |
k. | Since CY 2014 we have used a software tool to improve management and auditability of supplier communications, as well as to request, receive, evaluate, store, and determine statistics on incoming CMRTs. The software is linked to the RMI database and is regularly updated regarding SOR operational status, conformance to third party audit standards, as well as RCOI information. |
l. | Starting in CY 2015 our supplier quality team has conducted Conflict Minerals Ongoing Compliance surveys of selected first tier suppliers’ conflict minerals due diligence programs. Suppliers are selected based on the criticality of components to Plantronics products and the amount of 3TG likely present and the number of 3TG processing facilities in their supply chain, based on previous years’ surveys. These suppliers are primarily Original Design Manufacturers (ODMs) and cable or transducer suppliers. These surveys assess policy, training, record retention and data validation. |
In 2018 five (5) surveys of existing suppliers were performed and three (3) of the surveys found supplier deficiencies which were addressed by corrective action plans, two (2) of which were successfully completed and the third is in progress. In addition, nine (9) potential new suppliers being considered for components or products potentially containing 3TG also underwent the required Conflict Minerals Compliance Survey to be approved.
2. | Identified and Assessed Risk in the Supply Chain |
• | Prior to and during CY 2018 we conducted face to face one-on-one training as well as teleconference training with newly qualified critical component or product suppliers. Training was primarily focused on ensuring a complete SOR list by proper scoping of products and components to identify all likely locations of 3TG, including parts and components purchased by the 1st tier supplier. |
• | We conducted a supplier survey of the fifty-six (56) direct first tier suppliers providing products or components within scope of the rule; necessary for the functionality of our products and likely to contain 3TG. The survey required that the supplier return the current version of the CMRT (5.1x or higher). Our request included information to inform the suppliers of Plantronics’ reporting obligations under the Conflict Minerals Rule as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. A link to the Plantronics’ Conflict Minerals policy was included in the request. |
• | Reminders, late notices and delinquent notices were sent to non-responsive suppliers. Commodity Managers were involved in escalation at the time of the delinquent notices. We have not found it necessary to restrict business or disengage from any currently active suppliers due to failure to respond to the survey at this point. There may be potential corrective actions pending. |
• | All incoming CMRTs underwent a two-step review process. The first step is a PASS/FAIL check by our Conflict Minerals software for completeness and internal consistency of the declaration and submitted SOR list. A message |
was automatically sent by the software system to suppliers submitting CMRTs containing errors, with an explanation of the error and a request for corrective action and re-submission.
• | In addition to direct suppliers, we used a data mining service to obtain conflict minerals information, also using the RMI CMRT, from thirty-five (35) manufacturers of critical and high usage off-the-shelf components with whom we had no direct relationship. |
• | Once CMRTs passed this first evaluation, they were then evaluated by internal compliance engineers on an ACCEPT/MODIFY basis for consistency with the known content and complexity of the products or components provided. A message was sent to suppliers submitting CMRTs found insufficient or incomplete with an explanation and request for corrective action. We continued to communicate with those suppliers to improve the content and quality of their responses. Greater than ninety percent (90%) of the suppliers responded by returning a CMRT, and eventually ninety-eight percent (98%) of those responses were accepted after review and, in some cases, correction. |
• | Eighty-six (86) of the ninety-one (91) CMRTs (some suppliers provided more than one product level CMRT) reported that all SORs in their supply chain were included. Seventy (70) of the CMRTs indicated covered country sourcing of at least one metal. |
• | Facilities processing 3TG reported by our supply chain are categorized, based on information available through RMI, as |
• | SORs eligible to participate in a recognized audit program. |
• | Entities determined to not be eligible, active SORs during the reporting period |
• | Entities alleged to be SORs, whose business could not be determined during the reporting period. |
• | In addition to SORs known to, or believed to possibly, source from the covered countries and who were not validated as conflict free, Plantronics believes non-eligible, alleged and non-responsive SORs declining to participate in any audit program as a source of risk, since the actual source of the 3TG is not known. |
3. | Designed and Implemented a Strategy to Respond to Identified Risks |
• | We have previously conducted research into “alleged” SORs - companies reported that were not on any list of known SORs- reported in our supplier survey to determine the nature of these entities’ business. This effort was done both through collaborative efforts in RMI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the final number of “alleged” SORs has been significantly reduced progressively from the number in previous reporting years, from eighty-three (83) in CY 2013 to forty-six (46) in CY 2014 to none in CY 2015, CY 2016, and CY 2017 final survey results. No alleged SORs were reported in this year’s survey. This is attributable to determining that many of the alleged SORs were indeed legitimate SORs or legitimate SOR aliases, or determination of the company’s actual business, as well as improved supplier reporting. |
• | The only SORs reported this year that were not active, eligible SORs were fourteen (14) that had previously been on the CMRT SOR list and had either ceased operations or changed their business type. We gave feedback concerning the actual reason for removal, such as timing of ceased operations as this information was available through RMI. |
• | We are members and active participants in RMI and a number of working groups, including Due Diligence Practices, SOR Engagement (SET), China SET, and SOR Disposition teams and work within these teams to determine the legitimacy of “alleged SORs” reported by our supply chain or other RMI members as well as conducting outreach in coordination with RMI to encourage legitimate SORs reported by our supply chain that have not been validated as DRC conflict free by a recognized conflict free program such as Responsible Minerals Assurance Process, London Bullion Market Association, Responsible Jewellry Council or TI-CMC, to enter such a program. Plantronics associates attended China Gold Congress as part of RMI team to speak directly with attending China Gold refiners. |
• | We require that suppliers provide information regarding all sources of 3TG in their supply chain. We review this information for accuracy and consistency. We request further information when a response is considered insufficient. We inform suppliers of potential high risk SORs in their supply chain, and request confirmation of the SORs’ presence and possible disengagement. |
4. | Carry out independent 3rd Party Audit of SORs’ Due Diligence Practices |
• | Because Plantronics has few direct business relationships with SORs, we worked within industry initiatives to implement validation of DRC conflict free SORs as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by RMAP and cross-recognized programs London Bullion Market Association (LBMA) and Responsible Jewelry Council -(RJC) to determine SORs’ Due Diligence Practices. |
5. | Report Annually on Supply Chain Due Diligence |
• | Our Form SD and this Report together constitute our annual report on our Conflict Minerals Due Diligence. These have been filed with the SEC and are available on our website at www.plantronics.com/conflictminerals. |
Results of due diligence performed
• | Most of our direct supplier responses represented their supply chain at a company-level rather than being product specific. Therefore, the list of processing facilities contained in this report may contain more facilities than those that actually process the conflict minerals contained in our products. The total number of unique entities reported as SORs by the Plantronics supplier base as result of CY 2018 Supplier Survey was three hundred twenty-four (324). Of these, three hundred seven (307) have been confirmed as being legitimate operating SORs by RMI., fourteen are known to not be operational SORs during CY 2018, and there were no reported entities whose status could not be confirmed as of our cutoff date of May 01, 2019. |
• | Of the three hundred seven legitimate SORs reported by the supplier base, two hundred fifty-five had been validated as being in conformance with an RMI cross-recognized conflict free audit protocol (RMAP, London Bullion Market Association, or Responsible Jewelry Council). Another five were actively engaged in the process, in communication with RMAP, or participating in another cross-recognized program, but had not achieved conformant status as of May 22, 2019. |
• | Forty-seven eligible reported SORs are not participating in a compliance scheme and have status of: |
• | Outreach required: Twenty- nine (29) have not yet been convinced to participate in any audit program., but efforts to encourage them should continue. |
• | Communication Suspended (not interested): seven (7) have stated clearly that they do not want to participate. |
• | Non-conformant: five (5) do not conform, failed audit, previously conformant, but did not complete re-audit or corrective action in a timely manner. |
• | Due Diligence required: six (6) there may be issues other than DRC conflict involved. |
• | Fourteen (14) entities were reported by our supply chain that are not currently considered eligible. These SORs had all been classified as operating SORs and listed on the CMRT at some time. They were reclassified by RMI due to either a change in their business operations or having either temporarily or permanently suspended operations. These are not included on the Smelter list. |
• | The remaining SORs that are not conformant as yet require outreach to encourage participation in a conflict free program. Plantronics actively participates in RMI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls. |
• | Of the three hundred seven legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that one hundred fifty-four of the SORs sourced or may have sourced any minerals from the covered countries. |
• | Of the remaining SORs with definitive RCOI information available through RMI or other publicly available information, twenty-three (23) were known or reasonably believed to directly or indirectly source minerals from the DRC, the surrounding countries or countries known as possible routes for smuggling or export of minerals out of the DRC. All twenty-three (23) are RMAP Conformant. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. All countries believed to be the source of 3TG in our products during 2018 are listed in Table II. |
• | The percentage of SORs reported by our supply chain that have been validated as conformant to a recognized program has increased year over year |
Smelters and Refiners Reported by Our Supply Chain by Year | |||
Calendar Year | Total Eligible | Total Conformant | % Conformant |
2014 | 159 | 76 | 47.80% |
2015 | 299 | 214 | 71.57% |
2016 | 336 | 246 | 73.21% |
2017 | 320 | 250 | 78.13% |
2018 | 324 | 255 | 78.70% |
• | The SOR information collected from our suppler base continued to include a number of eligible SORs that had not been audited and validated as conformant by the RMAP, or any other cross recognized program. The existence of such facilities in our supply chain is sufficient to prevent us from declaring with certainty that no armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free. |
• | From CY 2017 to the present, Plantronics has become of aware of OECD Annex II or other risks in the 3TG supply chain unrelated to financing conflict in the DRC and adjoining countries. These risks include, but are not limited to, material sourced in conflict risk areas other than the DRC, SORs in countries under sanction or wholly or partially owned by individuals under sanction, or securing raw materials from sanctioned entities. Other concerns are child or forced labor and money laundering. There are some SORs on CY 2018 SOR list that will require further due diligence. |
• | Two (2) United States sanctioned gold refiners were listed on the CMRTs from three (3) suppliers in our supply chain. We requested that they confirm the presence of those SORs in their supply chain and if they were, to inform us of their actions to disengage from them. These refiners were previously conformant to LBMA, but were removed after sanctions were imposed in April of 2018. |
• | There are two (2) gold refiners involved in media and NGO reports of possible involvement with smuggled DRC gold. One of these was reported in one instance in our supply chain. We have asked that supplier to disengage from that refiner. |
• | There are four (4) other reported SORs on the SOR list that are in RMI Due Diligence status. We have also informed suppliers reporting these SORs of that status with a request for more information. |
• | Of the eight higher risk SORs, none were reported by more than four different suppliers. |
Steps to be taken to further mitigate risk
We intend to take the following steps where possible to build on momentum established in previous years to improve the due diligence conducted, and to further mitigate the risk that the necessary conflict minerals in our products benefit armed groups in the Covered Countries or facilitate any other types of human rights violations.
• | In coordination with RMI, engage directly with selected SORs to help guide them through the RMAP audit process by participating a pre-audit visit. To the extent possible, attend metals industry conferences in conjunction with RMI to use direct contact to encourage participation in validation schemes. As gold appears to exhibit the highest risk in multiple risk categories, focus outreach and due diligence efforts on gold refiners. |
• | Take advantage of added RMI resources by adding a link on our website to RMI conflict minerals specific grievance system in addition to the existing PLT company grievance system and utilize RMI incident reporting tool to evaluate risk and red flags in upstream supply chain. |
• | Strongly encourage our supply chain to source only from conformant SORs, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible. |
• | Work with our supply chain to reduce or discontinue sourcing materials from SORs that have consistently refused to participate in any conflict free programs, or SORs that have failed audits or declined to undergo re-audits. |
• | Implement procedures to facilitate removal of SORs considered high risk for reasons other than DRC conflict; US or other sanctions or OECD Annex II issues. |
Table I. Plantronics SOR List
The list of reported SORs and status is as of May 22, 2019. RCOI data from RMI is as of March 29, 2019. The list includes one hundred and fifty-three (153) SORs that are either known to obtain at least some minerals from the covered countries or are SORs where the source of the minerals was not disclosed and could not be determined. Gold refiners validated as conformant through LBMA or RJC are included in this list, since they are not required to disclose the country of origin of their minerals. The list does not include those SORs that source only from outside the covered countries as determined through RCOI, or process only recycled or scrap materials. As the majority of our suppliers responded to surveys at a company level rather than with respect to specific products, and due to the complexity of the electronics supply chain, as well as the diversity of both our products and our suppliers’ products, we cannot conclude with certainty that material from all of the SORs reported by our supply chain and included in this report are actually contained in Plantronics’ products.
“Country” refers to the location of the facility, not the source of minerals. The SOR location was not used for RCOI, since it does not necessarily determine the source of the ore, although SOR location near abundant mineral resources can be an indicator of mineral sourcing.
Status is defined as:
Conformant: SORs that have been audited and have been validated as compliant with the RMAP SOR Program or cross recognized (LBMA, RJC) assessment protocols. This includes SORs that were compliant as of 12/31/2018 as well as SORs that have completed audits and become conformant in 2019 prior to this report.
Active or In Communication: On RMI Active list or in communication with RMI. SORs on the Active list have committed to undergo a CFSP audit.
Outreach Required or Not Interested: Thirty-six (36) eligible SORs who have not yet completed a CFSP or cross recognized audit validating a conflict free process. This status includes some SORs indicating that they do not want to participate in a recognized validation system. Many claim the reason to be that they process only scrap or ore from their own mines and do not source ore from the covered countries. While this may be true, with no audit for verification, they are considered as “may source from covered countries”.
Non-Conformant: Five (5) SORs that failed RMAP audit, did not complete audit or re-audit corrective actions in the allotted time, or have previously been audited and have been conformant with the RMAP SOR Program or cross recognized (LBMA, RJC) assessment programs, but have not undergone a re-audit within the required time frame.
Due Diligence Required: Six (6) audit eligible SORs cannot be currently audited until concerns regarding sanctions or suspension from metals exchanges are resolved.
TABLE I
Metal | Smelter Name | Country | SOR ID | Status |
Gold | Kazzinc | KAZAKHSTAN | CID000957 | CONFORMANT |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | CONFORMANT |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | CONFORMANT |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | CONFORMANT |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | CONFORMANT |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | CONFORMANT |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | CONFORMANT |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | CONFORMANT |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | CONFORMANT |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 | CONFORMANT |
Metal | Smelter Name | Country | SOR ID | Status |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 | CONFORMANT |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | CONFORMANT |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | CONFORMANT |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | CONFORMANT |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | CONFORMANT |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | CONFORMANT |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | CONFORMANT |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | CONFORMANT |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | CONFORMANT |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | CONFORMANT |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | CONFORMANT |
Gold | PAMP S.A. | SWITZERLAND | CID001352 | CONFORMANT |
Gold | Aurubis AG | GERMANY | CID000113 | CONFORMANT |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | CONFORMANT |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | CONFORMANT |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | CONFORMANT |
Gold | Boliden AB | SWEDEN | CID000157 | CONFORMANT |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | CONFORMANT |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | CONFORMANT |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 | CONFORMANT |
Gold | Japan Mint | JAPAN | CID000823 | CONFORMANT |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | CONFORMANT |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | CONFORMANT |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | CONFORMANT |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 | CONFORMANT |
Gold | Chimet S.p.A. | ITALY | CID000233 | CONFORMANT |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | CONFORMANT |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | CONFORMANT |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | CONFORMANT |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | CONFORMANT |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | CONFORMANT |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | CONFORMANT |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | CONFORMANT |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 | CONFORMANT |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | CONFORMANT |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 | CONFORMANT |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | CONFORMANT |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | CONFORMANT |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | CONFORMANT |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | CONFORMANT |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | CONFORMANT |
Metal | Smelter Name | Country | SOR ID | Status |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | CONFORMANT |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | CONFORMANT |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | CONFORMANT |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | CONFORMANT |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | CONFORMANT |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | CONFORMANT |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | CONFORMANT |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | CONFORMANT |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | CONFORMANT |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | CONFORMANT |
Gold | Royal Canadian Mint | CANADA | CID001534 | CONFORMANT |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | CONFORMANT |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | CONFORMANT |
Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | CONFORMANT |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | CONFORMANT |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 | CONFORMANT |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | CONFORMANT |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | CONFORMANT |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | CONFORMANT |
Gold | T.C.A S.p.A | ITALY | CID002580 | CONFORMANT |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | CONFORMANT |
Gold | SAAMP | FRANCE | CID002761 | CONFORMANT |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 | CONFORMANT |
Gold | Italpreziosi | ITALY | CID002765 | CONFORMANT |
Gold | Safimet S.p.A | ITALY | CID002973 | CONFORMANT |
Gold | Bangalore Refinery | INDIA | CID002863 | CONFORMANT |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | CONFORMANT |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | ACTIVE |
Gold | Chugai Mining | JAPAN | CID000264 | ACTIVE |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | ACTIVE |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | IN COMMUNICATION |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | IN COMMUNICATION |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 | OUTREACH REQUIRED |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 | OUTREACH REQUIRED |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | OUTREACH REQUIRED |
Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 | OUTREACH REQUIRED |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | OUTREACH REQUIRED |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | OUTREACH REQUIRED |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | OUTREACH REQUIRED |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | OUTREACH REQUIRED |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | OUTREACH REQUIRED |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 | OUTREACH REQUIRED |
Metal | Smelter Name | Country | SOR ID | Status |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | OUTREACH REQUIRED |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | OUTREACH REQUIRED |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | OUTREACH REQUIRED |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | OUTREACH REQUIRED |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | OUTREACH REQUIRED |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 | OUTREACH REQUIRED |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 | OUTREACH REQUIRED |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | OUTREACH REQUIRED |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 | OUTREACH REQUIRED |
Gold | Sudan Gold Refinery | SUDAN | CID002567 | OUTREACH REQUIRED |
Gold | African Gold Refinery | UGANDA | CID003185 | OUTREACH REQUIRED |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 | OUTREACH REQUIRED |
Gold | Sai Refinery | INDIA | CID002853 | OUTREACH REQUIRED |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 | NOT INTERESTED |
Gold | Morris and Watson | NEW ZEALAND | CID002282 | NOT INTERESTED |
Gold | Caridad | MEXICO | CID000180 | NOT INTERESTED |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 | NOT INTERESTED |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 | NOT INTERESTED |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 | DUE DILIGENCE REQUIRED |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | DUE DILIGENCE REQUIRED |
Gold | SAFINA A.S. | CZECHIA | CID002290 | DUE DILIGENCE REQUIRED |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | DUE DILIGENCE REQUIRED |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | DUE DILIGENCE REQUIRED |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | DUE DILIGENCE REQUIRED |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Non-CONFORMANT |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Non-CONFORMANT |
Gold | Tony Goetz NV | BELGIUM | CID002587 | Non-CONFORMANT |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 | Non-CONFORMANT |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | CONFORMANT |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | CONFORMANT |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | CONFORMANT |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | CONFORMANT |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | CONFORMANT |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 | CONFORMANT |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | CONFORMANT |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | CONFORMANT |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | CONFORMANT |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | CONFORMANT |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | CONFORMANT |
Metal | Smelter Name | Country | SOR ID | Status |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | CONFORMANT |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 | CONFORMANT |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | CONFORMANT |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | CONFORMANT |
Tin | PT Tirus Putra Mandiri | INDONESIA | CID002478 | CONFORMANT |
Tin | Thaisarco | THAILAND | CID001898 | CONFORMANT |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | CONFORMANT |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 | OUTREACH REQUIRED |
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 | OUTREACH REQUIRED |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | OUTREACH REQUIRED |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | OUTREACH REQUIRED |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | OUTREACH REQUIRED |
Tin | Super Ligas | BRAZIL | CID002756 | OUTREACH REQUIRED |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | CID002572 | Non-CONFORMANT |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | CONFORMANT |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | CONFORMANT |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | CONFORMANT |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | CONFORMANT |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 | CONFORMANT |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | CONFORMANT |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | NOT INTERESTED |
TABLE II
The Countries of Origin for the minerals present in Plantronics products are believed to potentially include, but may not be limited to, the following. Information is from RMI SORs, news reports, industry associations, metals brokers’ reports, and USGS reports (Countries listed for 3T are reported to account for ~98% of global mined ore). Data also checked for plausibility against RMI known countries from which conformant 3TG SORs source information was included in RMI RCOI reports.
Tungsten: Democratic Republic of Congo, Burundi, Rwanda, China, Vietnam, Russia, Canada, Bolivia, Australia, Austria, Spain, Portugal, United States, DRC, Mexico, Mongolia, Uzbekistan, Uganda
Tantalum Democratic Republic of Congo, Rwanda, Burundi, Brazil, Mozambique, China, Nigeria, Australia, Uganda, Bolivia, Colombia, Mongolia, Nigeria, Portugal, Russia, Spain, Mozambique
Tin: Bolivia, Brazil, Myanmar, China, Indonesia, Peru, Australia, Democratic Republic of Congo, Malaysia, Nigeria, Rwanda, Vietnam, Burundi, Mongolia, Niger, Portugal, Russia, Tanzania, Thailand, Uganda
Gold: China, Australia, Russia, United States, Peru, Canada, South Africa, Mexico, Uzbekistan, Ghana, Brazil, Papua New Guinea; Democratic Republic of Congo, Kazakhstan, Argentina, Tanzania, Mali, Dominican Republic, Columbia, Philippines Chile, Burkina Faso, Ivory Coast, Mongolia, Turkey, Guinea, Senegal, Togo