EXHIBIT 1.01
STANLEY BLACK & DECKER, INC.
Conflict Minerals Report
For The Year Ended December 31, 2022
This report for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“the Rule”).
1. Overview
Stanley Black & Decker, Inc. ("the Company") is a global provider of hand tools, power tools, outdoor products and related accessories, as well as a leading provider of engineered fastening solutions and attachment tools for infrastructure applications. The Company manufactures products for which tin, tantalum, tungsten and gold ("3TG minerals" or "conflict minerals") are necessary to the functionality or production of those products and which otherwise constitute products under the Rule.
In accordance with the Rule, the Company conducted a good faith reasonable country of origin inquiry ("RCOI") that was reasonably designed to determine whether any of the 3TG minerals in the Company's products originated in the Democratic Republic of the Congo (the "DRC") or Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia ("adjoining countries"), or were from recycled or scrap sources. Based on the Company's RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products originated in the DRC or adjoining countries and may not have been from recycled or scrap sources. Accordingly, the Company exercised due diligence to determine the source and chain of custody of these 3TG minerals. The Company's due diligence was designed to materially conform 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 (2016) and the related Supplements for gold and for tin, tantalum and tungsten (collectively "the OECD Guidance"). A description of the Company's RCOI and due diligence measures is set forth in this report.
Product Description
The Company’s operations are classified into two reportable business segments: Tools & Outdoor and Industrial.
Tools & Outdoor
The Tools & Outdoor segment is comprised of the Power Tools Group ("PTG"), Hand Tools, Accessories & Storage ("HTAS"), and Outdoor Power Equipment ("Outdoor") businesses.
The PTG business includes both professional and consumer products. Professional products include professional grade corded and cordless electric power tools and equipment including drills, impact wrenches and drivers, grinders, saws, routers and sanders, as well as pneumatic tools and fasteners including nail guns, nails, staplers and staples, and concrete and masonry anchors. Consumer products include corded and cordless electric power tools sold primarily under the BLACK+DECKER® brand, and home products such as hand-held vacuums, paint tools and cleaning appliances.
The HTAS business sells hand tools, power tool accessories and storage products. Hand tools include measuring, leveling and layout tools, planes, hammers, demolition tools, clamps, vises, knives, saws, chisels and industrial and automotive tools. Power tool accessories include drill bits, screwdriver bits, router bits, abrasives, saw blades and threading products. Storage products include tool boxes, sawhorses, medical cabinets and engineered storage solution products.
The Outdoor business primarily sells corded and cordless electric lawn and garden products, including hedge trimmers, string trimmers, lawn mowers, pressure washers and related accessories, and gas powered lawn and garden products, including lawn tractors, zero turn ride on mowers, walk behind mowers, snow blowers, residential robotic mowers, utility terrain vehicles (UTVs), hand-held outdoor power equipment, garden tools, and parts and accessories to professionals and consumers under the DEWALT®, CUB CADET®, BLACK+DECKER®, CRAFTSMAN®, TROY-BILT®, and HUSTLER® brand names.
On December 1, 2021, the Company acquired the remaining 80 percent ownership stake in MTD Holdings Inc. ("MTD"), a privately held global designer, manufacturer and distributor of lawn tractors, zero turn ride on mowers, walk behind mowers, snow blowers, residential robotic mowers, handheld outdoor power equipment and garden tools for both residential and professional consumers under well-known brands like CUB CADET® and TROY-BILT®. The Company previously acquired a 20 percent interest in MTD in January 2019. The results of this acquisition have been consolidated into the Company's Tools & Outdoor segment and were included in the Company's due diligence procedures in 2022.
On November 12, 2021, the Company acquired Excel Industries ("Excel"), a leading designer and manufacturer of premium commercial and residential turf-care equipment under the HUSTLER® brand. The results of this acquisition have been consolidated into the Company's Tools & Outdoor segment and were included in the Company's due diligence procedures in 2022.
Industrial
The Industrial segment is comprised of the Engineered Fastening and Infrastructure businesses.
The Engineered Fastening business primarily sells highly engineered components such as fasteners, fittings and various engineered products, which are designed for specific application across multiple verticals. The product lines include externally threaded fasteners, blind rivets and tools, blind inserts and tools, drawn arc weld studs and systems, engineered plastic and mechanical fasteners, self-piercing riveting systems, precision nut running systems, micro fasteners, high-strength structural fasteners, axel swage, latches, heat shields, pins, and couplings.
The Infrastructure business sells hydraulic tools and high quality, performance-driven heavy equipment attachment tools for off-highway applications.
Divestitures
On August 19, 2022, the Company sold its Oil & Gas business comprised of the pipeline services and equipment businesses to Pipeline Technique Limited.
On July 22, 2022, the Company sold its Convergent Security Solutions ("CSS") business comprised of the commercial electronic security and healthcare businesses to Securitas AB.
On July 5, 2022, the Company sold its Mechanical Access Solutions ("MAS") business comprised of the automatic doors business to Allegion plc.
This report primarily covers the businesses and their products described above except for those which were determined to be out-of-scope of the Rule, primarily CSS and Oil & Gas.
Supply Chain
The Company both manufactures and contracts to manufacture its products described above, as well as components and raw materials for those products. Some of those products may be manufactured using 3TG minerals which are procured globally and from multiple suppliers who are several tiers away from the origin of and smelters of their raw materials. As such, the Company does not typically have a direct relationship with smelters and refiners of 3TG minerals. Additionally, the Company’s size, complexity of its products, and the depth, breadth and constant evolution of its supply chain, make it difficult to identify sub-tier suppliers from its direct suppliers, and therefore, the Company is reliant upon its direct suppliers to provide information on the origin of 3TG minerals contained in components and materials purchased. The Company’s suppliers are similarly reliant upon information provided by their suppliers and therefore face similar challenges to obtaining origin information. Additionally, many of the Company’s suppliers and its suppliers’ suppliers are foreign and not directly subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“the Dodd-Frank Act”).
Conflict Minerals Policy
The Company has adopted the following Conflict Minerals Policy:
Stanley Black & Decker is committed to conducting business in an ethical, law abiding manner. This includes our commitment to not only comply with all applicable laws and regulations but also to operate our business on a foundation of integrity, trust and respect throughout our supply chain. Along with governmental and non-governmental organizations, civil society and affected third parties, we are concerned about the potential human rights issues, such as forced labor, inhumane or cruel treatment, and child labor, associated with the mining of Conflict Minerals (defined as tin, tungsten, tantalum and gold) which are occurring in the Democratic Republic of Congo ("DRC") and adjoining countries (“DRC region”).
Stanley Black & Decker is cognizant of our obligations under Section 1502 of the Dodd-Frank Act and is working with our suppliers to meet the due diligence and reporting requirements of Section 1502. As part of this process, we are helping our suppliers understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products they sell us. If, based on our due diligence, we determine there is a reasonable risk that Conflict Minerals in our products may be directly or indirectly linked to the financing of conflict in the DRC region, we will determine an appropriate course of action based on the facts and circumstances relating to the affected products. Such action may include, but is not limited to, the suspension or termination of our relationship with particular suppliers.
Determining whether all products sold by Stanley Black & Decker are Conflict Free is a time consuming and difficult process. We manufacture and distribute thousands of products, many of which contain, or may contain, the minerals that have been defined as Conflict Minerals. We source the raw materials and component parts for the products we manufacture, as well as finished products, from thousands of other companies around the world. Stanley Black & Decker is and has been working with our suppliers to educate them regarding Stanley Black & Decker’s disclosure obligations under the Dodd-Frank Act and concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they supply to us.
Stanley Black & Decker has the following expectations of its suppliers:
•suppliers should identify any products sold to Stanley Black & Decker that contain any Conflict Minerals which are not DRC Conflict Free;
•suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to Stanley Black & Decker; and
•Stanley Black & Decker suppliers should source Conflict Minerals only from sources that are DRC Conflict Free.
In doing so, suppliers are expected to:
•implement and communicate to their personnel and suppliers policies that are consistent with this policy, and require their direct and indirect suppliers to do the same;
•put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable;
•use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require their direct and indirect suppliers to do the same;
•advise Stanley Black & Decker of any determination that the supplier either has concluded or has a reasonable basis to believe the products it currently sells or has sold to Stanley Black & Decker are not DRC Conflict Free;
•maintain reviewable business records supporting the source of Conflict Minerals; and
•from time to time, at Stanley Black & Decker's request, provide Stanley Black & Decker with information concerning the origin of Conflict Minerals included in products sold to Stanley Black & Decker, which Stanley Black & Decker shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of a confidentiality agreement that do not specifically reference this paragraph.
Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.
Consequences of Supplier Noncompliance
Stanley Black & Decker evaluates its relationships with its suppliers on an ongoing basis. Stanley Black & Decker reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this policy. Stanley Black & Decker also reserves the right to request additional documentation from suppliers regarding the origin of any Conflict Minerals included in any products sold to Stanley Black & Decker.
Suppliers who do not reasonably comply with this policy shall be reviewed by Stanley Black & Decker’s Global Supply Management ("GSM") organization for future business.
In the event Stanley Black & Decker determines that the supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Stanley Black & Decker reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier. Nothing in this policy is intended to in any way grant any additional rights or expectations to any Stanley Black & Decker supplier or in any way modify or otherwise limit in any way any of Stanley Black & Decker's contractual or legal rights.
Grievance Mechanism and Reporting
Our employees, suppliers and other parties can report concerns and alleged violations of this policy via the SBD Integrity Helpline ("Integrity Helpline"). The Integrity Helpline can be reached 24 hours/365 days a year, and translators are available.
Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law.
We will not take any retaliatory action against our employees, suppliers or other parties who make a report in good faith. Our suppliers are encouraged to contact the Integrity Helpline if they wish to seek guidance on the application of this policy.
Conclusion
Stanley Black & Decker fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.
This policy is publicly available at www.stanleyblackanddecker.com/investors under the Governance section.
RCOI
Prior to conducting the Company's RCOI, the Company performed a risk-based assessment of its products for components and/or raw materials which were most likely to contain 3TG minerals. The Company required direct suppliers of those components and/or raw materials to complete a supply chain survey through a third-party compliance tool that uses the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.
The Company's escalation process for suppliers who were delinquent in responding to the Company's survey by the specified date included:
•Two non-system generated emails
•Direct phone call(s) from GSM supplier owner
•Direct phone call(s) from Conflict Mineral Working Group member
•Weekly pulsing calls between GSM supplier owners and Conflict Mineral Working group member to update on response status
Smelters and refiners identified in the survey responses were aggregated and then validated against the RMI's Standard Smelter List, and once validated, against the RMI's Responsible Minerals Assurance Process (“RMAP”) to determine conformance status. RMAP conformant smelters and refiners were then validated against the RMI’s RCOI Data Document to determine country of origin information for the minerals being processed by the smelters and refiners.
Based on the suppliers' responses to the RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products may have originated in the DRC or adjoining countries and may not have been from recycled or scrap sources.
2. Due Diligence
2.1 Design of Due Diligence
The Company's due diligence measures are designed to materially conform with the OECD Guidance.
OECD Step 1: Establish Strong Company Management Systems
Company Policy
The Company has a Conflict Mineral Policy which is posted on its website at www.stanleyblackanddecker.com/investors under the Governance section.
Internal Team
The Company has a Steering Committee sponsored by the Company’s Executive Vice President and Chief Financial Officer, as well as a Working Group. Members of the Steering Committee and Working Group are subject matter experts from relevant functions such as Global Supply Management, Sustainability, Finance and Legal. The Steering Committee is responsible for oversight of the Company’s conflict minerals compliance strategy and due diligence process, monitoring the due diligence progress, ensuring communication of critical information reaches employees and suppliers, and ensuring the timely and accurate filing of this report. The Working Group is charged with implementation of the Company's policy, conducting due diligence, communications to suppliers and others, and reporting its progress to the Steering Committee on a regular basis.
System of Controls and Transparency Over the Supply Chain
The Company surveys its supply chain utilizing a third-party compliance tool that models the RMI's Conflict Minerals Reporting Template (“the CMRT”). The CMRT is a supply chain survey designed to gather information from a company's suppliers to determine whether any of the components and/or raw materials provided to the Company originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.
Supplier Engagement
The Company's Conflict Mineral Policy is posted on its supplier portal for all suppliers to access. Additionally, the Company's supplier Master Purchase Agreements include a Conflict Minerals provision which requires its suppliers to provide information necessary to allow the Company and its customers to comply with the provisions of the Dodd-Frank Act and explicitly gives the Company the rights to audit the supply chain and terminate arrangements with suppliers who are unwilling or unable to comply. As the specific Conflict Minerals provision was introduced into supplier Master Purchase Agreements several years ago, the majority of the Company's agreements contain this provision. As older agreements come up for renewal, the Conflict Minerals provision is introduced into new agreements. While the Company cannot unilaterally impose new contract terms, including those that would compel its suppliers to support the Company's conflict minerals due diligence efforts, all Master Purchase Agreements contain a compliance with laws clause which provides for the Company’s suppliers to abide by directives from the Company to be in compliance with applicable laws. The Company does not knowingly engage new suppliers who are not in compliance with the Company's Conflict Mineral policy.
Grievance Mechanism
The Company has an established grievance mechanism for reporting violations of the Company’s policies.
Maintain Records
The Company maintains Conflict Mineral related information in accordance with its record retention policy.
OECD Step 2: Identify and Assess Risk in the Supply Chain
The Company performs a risk-based assessment of its products for components and/or raw materials which are most likely to contain 3TG minerals and surveys suppliers of those components and/or raw materials using the CMRT to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, identify smelters and refiners in the Company's supply chain. Identified smelters and refiners are aggregated and validated against the RMI's Standard Smelter List, and once validated, against the RMI's Responsible Minerals Assurance Process (“RMAP”) to determine compliance status.
The Company reviews responses to the survey for red flags in order to identify areas of potential risk such as incomplete responses, insufficient due diligence or potentially higher risk sourcing based upon criteria internally defined.
OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks
Results of the supply chain assessment are reported to the Steering Committee which is responsible for monitoring any actual or potential risks identified in the supply chain and reporting findings to the Company's Executive Vice President and Chief Financial Officer.
The Company has a risk mitigation plan to manage its non-conformant suppliers towards conformity with the Company's Conflict Mineral policy. GSM is responsible for taking appropriate actions up to and including suspension or termination of the Company's relationship with non-conformant suppliers. The Company does not knowingly engage new suppliers who are not in compliance with the Company's Conflict Mineral policy.
The Company supports the RMI's RMAP which audits smelters' and refiners' due diligence activities. The data on which the Company relies for certain statements in this report is obtained through the Company's membership (member "SBDI") in the RMI, using the reasonable country of origin inquiry report for the Company, or based upon the information publicly available on the RMI's website.
The Company's new product introduction process includes a step to ensure information on the presence of 3TG minerals in new products is provided to the Working Group for integration into the Company's due diligence procedures. The Company has also revised its new product specifications to ensure that the use of 3TG is limited solely to the product's functionality.
The Company also integrates new acquisitions into its due diligence processes described herein.
OECD Step 4: Carry Out Independent Third Party Audit of Smelter/Refiner's Due Diligence Practices
The Company supports the RMAP's efforts to audit the due diligence practices of the smelters and refiners, through its active membership in the RMI. The Company utilizes information on the RMI's website (www.responsiblemineralsinitiative.org) to determine which smelters and refiners are RMAP conformant.
OECD Step 5: Report Annually on Supply Chain Due Diligence
This report is the Company’s annual report on its due diligence, is filed along with Form SD with the Securities and Exchange Commission, and is publicly available on the Company’s website (www.stanleyblackanddecker.com/investors) under the Financial Information section.
2.2 Due Diligence Performed
The Company performed the following due diligence for the reporting period:
•Identified suppliers of components and/or raw materials which were most likely to contain 3TG minerals and surveyed those suppliers using a third-party compliance tool that utilizes the latest published CMRT. Those suppliers were engaged through direct electronic communication from the Vice President of GSM.
•Identified suppliers providing 3TG minerals from the DRC or adjoining countries and compiled an aggregate list of smelters and refiners identified by those suppliers.
•Utilized a third-party compliance tool to validate those smelters and refiners against the RMI list.
•Compared those validated smelters and refiners against those identified by the RMI’s RMAP as RMAP conformant or RMAP active and for those that are RMAP conformant, against the RMI's RCOI Data Document to determine country of origin for the 3TG minerals processed by those smelters and refiners.
•Utilized a third-party compliance tool to identify non-responding suppliers and provide reports to GSM for follow-up, including direct phone call(s) from GSM supplier owner and/or Conflict Minerals Working Group member, as well as periodic pulsing calls between GSM and Conflict Minerals Working Group members to update on response status.
•Reported status of due diligence progress, including identification of red flag suppliers, to the Company's Steering Committee and to the Company's Executive Vice President and Chief Financial Officer.
•Supported the RMAP through maintenance of an active membership in the RMI.
3. Due Diligence Results
The Company received responses from 90% of its suppliers surveyed, representing 94% of the supplier spend surveyed. The Company’s suppliers are generally several tiers away from the origin of and smelters of their raw materials, and are therefore faced with similar challenges in performing their due diligence. In some instances, the information provided by the Company's suppliers is incomplete or not verified, and the Company is therefore unable to verify with certainty the source and chain of custody of all the 3TG minerals in the Company's supply chain.
The Company identified 342 smelters and refiners, as reported by the Company's suppliers, as potentially having processed the 3TG minerals contained in the Company's products for the reporting period. Some of the Company's suppliers responded at a company-level rather than product-level; therefore, there may be more smelters and refiners included in the Company's results than those that actually processed the 3TG minerals contained in the Company's products. The Company has only included in its results those smelters and refiners that have been validated as smelters and refiners appearing on the RMI Standard Smelter List as of May 5, 2023. Other processing facilities were reported in the Company's supply chain; however, are not included in its results, as they have not yet been validated by the RMI. The identified smelters and refiners are further broken out as follows:
| | | | | | | | | | | | | | | | | |
| Smelters and Refiners | Gold | Tantalum | Tin | Tungsten | Total |
| Number of RMI validated | 175 | 34 | 83 | 50 | 342 |
| Number of RMAP conformant* | 100 | 32 | 63 | 34 | 229 |
| % RMAP conformant | 57% | 94% | 76% | 68% | 67% |
*Includes 8 smelters and refiners that are active in the RMAP but have not yet completed the program as of May 5, 2023.
The following tables list smelters and refiners identified by the Company's suppliers' survey responses.
Table 1. RMAP Conformant Smelters and Refiners
The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have been validated as conformant according to the RMAP as of May 5, 2023.
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Gold | L'Orfebre S.A. | CID002762 | Andorra |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 | Australia |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | Austria |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | Belgium |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 | Brazil |
| Gold | Asahi Refining Canada Ltd. | CID000924 | Canada |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | Canada |
| Gold | Royal Canadian Mint | CID001534 | Canada |
| Gold | Planta Recuperadora de Metales SpA | CID002919 | Chile |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 | China |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 | China |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | China |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | China |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | China |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | China |
| Gold | Shandong Gold Smelting Co., Ltd. | CID001916 | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | China |
| Gold | Gold by Gold Colombia | CID003641 | Colombia |
| Gold | Sancus ZFS (L’Orfebre, SA) | CID003529 | Colombia |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Gold | SAFINA A.S. | CID002290 | Czechia |
| Gold | SAAMP | CID002761 | France |
| Gold | Agosi AG | CID000035 | Germany |
| Gold | Aurubis AG | CID000113 | Germany |
| Gold | C. Hafner GmbH + Co. KG | CID000176 | Germany |
| Gold | Heimerle + Meule GmbH | CID000694 | Germany |
| Gold | Heraeus Germany GmbH Co. KG | CID000711 | Germany |
| Gold | WIELAND Edelmetalle GmbH | CID002778 | Germany |
| Gold | Bangalore Refinery | CID002863 | India |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | India |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | Indonesia |
| Gold | Chimet S.p.A. | CID000233 | Italy |
| Gold | Italpreziosi | CID002765 | Italy |
| Gold | T.C.A S.p.A | CID002580 | Italy |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | Japan |
| Gold | Asahi Pretec Corp. | CID000082 | Japan |
| Gold | Asaka Riken Co., Ltd. | CID000090 | Japan |
| Gold | Chugai Mining | CID000264 | Japan |
| Gold | Dowa | CID000401 | Japan |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 | Japan |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 | Japan |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | Japan |
| Gold | Japan Mint | CID000823 | Japan |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | Japan |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | Japan |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | Japan |
| Gold | Mitsubishi Materials Corporation | CID001188 | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | Japan |
| Gold | Nihon Material Co., Ltd. | CID001259 | Japan |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | Japan |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | Japan |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | Japan |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | Japan |
| Gold | Yamakin Co., Ltd. | CID002100 | Japan |
| Gold | Yokohama Metal Co., Ltd. | CID002129 | Japan |
| Gold | Kazzinc | CID000957 | Kazakhstan |
| Gold | TOO Tau-Ken-Altyn | CID002615 | Kazakhstan |
| Gold | DSC (Do Sung Corporation) | CID000359 | Korea, Republic of |
| Gold | Korea Zinc Co., Ltd. | CID002605 | Korea, Republic of |
| Gold | LS-NIKKO Copper Inc. | CID001078 | Korea, Republic of |
| Gold | LT Metal Ltd. | CID000689 | Korea, Republic of |
| Gold | NH Recytech Company | CID003189 | Korea, Republic of |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 | Korea, Republic of |
| Gold | Torecom | CID001955 | Korea, Republic of |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 | Mexico |
| Gold | REMONDIS PMR B.V. | CID002582 | Netherlands |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | Philippines |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 | Poland |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | Singapore |
| Gold | Metal Concentrators SA (Pty) Ltd. | CID003575 | South Africa |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | South Africa |
| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 | Spain |
| Gold | Boliden AB | CID000157 | Sweden |
| Gold | Argor-Heraeus S.A. | CID000077 | Switzerland |
| Gold | Metalor Technologies S.A. | CID001153 | Switzerland |
| Gold | MKS PAMP SA | CID001352 | Switzerland |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Gold | PX Precinox S.A. | CID001498 | Switzerland |
| Gold | Valcambi S.A. | CID002003 | Switzerland |
| Gold | Solar Applied Materials Technology Corp. | CID001761 | Taiwan |
| Gold | Istanbul Gold Refinery | CID000814 | Turkey |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 | Turkey |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 | United Arab Emirates |
| Gold | Emirates Gold DMCC | CID002561 | United Arab Emirates |
| Gold | Abington Reldan Metals, LLC | CID002708 | United States of America |
| Gold | Advanced Chemical Company | CID000015 | United States of America |
| Gold | Asahi Refining USA Inc. | CID000920 | United States of America |
| Gold | Geib Refining Corporation | CID002459 | United States of America |
| Gold | Kennecott Utah Copper LLC | CID000969 | United States of America |
| Gold | Materion | CID001113 | United States of America |
| Gold | Metalor USA Refining Corporation | CID001157 | United States of America |
| Gold | United Precious Metal Refining, Inc. | CID001993 | United States of America |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | Uzbekistan |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | Uzbekistan |
| Tantalum | AMG Brasil | CID001076 | Brazil |
| Tantalum | Mineracao Taboca S.A. | CID001175 | Brazil |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 | Brazil |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | China |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | China |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | China |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | China |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | China |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CID003583 | China |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CID000616 | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | China |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | China |
| Tantalum | NPM Silmet AS | CID001200 | Estonia |
| Tantalum | TANIOBIS GmbH | CID002545 | Germany |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | CID002550 | Germany |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | India |
| Tantalum | Global Advanced Metals Aizu | CID002558 | Japan |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 | Japan |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 | Japan |
| Tantalum | TANIOBIS Japan Co., Ltd. | CID002549 | Japan |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | Kazakhstan |
| Tantalum | KEMET de Mexico | CID002539 | Mexico |
| Tantalum | TANIOBIS Co., Ltd. | CID002544 | Thailand |
| Tantalum | D Block Metals, LLC | CID002504 | United States of America |
| Tantalum | Global Advanced Metals Boyertown | CID002557 | United States of America |
| Tantalum | Materion Newton Inc. | CID002548 | United States of America |
| Tantalum | QuantumClean | CID001508 | United States of America |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Tantalum | Telex Metals | CID001891 | United States of America |
| Tin | Aurubis Beerse | CID002773 | Belgium |
| Tin | EM Vinto | CID000438 | Bolivia |
| Tin | Operaciones Metalurgicas S.A. | CID001337 | Bolivia |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | CID003486 | Brazil |
| Tin | Estanho de Rondonia S.A. | CID000448 | Brazil |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | CID003582 | Brazil |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | Brazil |
| Tin | Mineracao Taboca S.A. | CID001173 | Brazil |
| Tin | Resind Industria e Comercio Ltda. | CID002706 | Brazil |
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 | Brazil |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 | China |
| Tin | China Tin Group Co., Ltd. | CID001070 | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | China |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 | China |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 | China |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CID002180 | China |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | China |
| Tin | CV Ayi Jaya | CID002570 | Indonesia |
| Tin | CV Venus Inti Perkasa | CID002455 | Indonesia |
| Tin | PT Aries Kencana Sejahtera | CID000309 | Indonesia |
| Tin | PT Artha Cipta Langgeng | CID001399 | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | Indonesia |
| Tin | PT Babel Inti Perkasa | CID001402 | Indonesia |
| Tin | PT Babel Surya Alam Lestari | CID001406 | Indonesia |
| Tin | PT Bangka Prima Tin | CID002776 | Indonesia |
| Tin | PT Bangka Serumpun | CID003205 | Indonesia |
| Tin | PT Bukit Timah | CID001428 | Indonesia |
| Tin | PT Cipta Persada Mulia | CID002696 | Indonesia |
| Tin | PT Menara Cipta Mulia | CID002835 | Indonesia |
| Tin | PT Mitra Stania Prima | CID001453 | Indonesia |
| Tin | PT Mitra Sukses Globalindo | CID003449 | Indonesia |
| Tin | PT Premium Tin Indonesia | CID000313 | Indonesia |
| Tin | PT Prima Timah Utama | CID001458 | Indonesia |
| Tin | PT Putera Sarana Shakti (PT PSS) | CID003868 | Indonesia |
| Tin | PT Rajawali Rimba Perkasa | CID003381 | Indonesia |
| Tin | PT Rajehan Ariq | CID002593 | Indonesia |
| Tin | PT Refined Bangka Tin | CID001460 | Indonesia |
| Tin | PT Sariwiguna Binasentosa | CID001463 | Indonesia |
| Tin | PT Stanindo Inti Perkasa | CID001468 | Indonesia |
| Tin | PT Sukses Inti Makmur | CID002816 | Indonesia |
| Tin | PT Timah Tbk Kundur | CID001477 | Indonesia |
| Tin | PT Timah Tbk Mentok | CID001482 | Indonesia |
| Tin | PT Tommy Utama | CID001493 | Indonesia |
| Tin | Dowa | CID000402 | Japan |
| Tin | Mitsubishi Materials Corporation | CID001191 | Japan |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | Malaysia |
| Tin | DS Myanmar | CID003831 | Myanmar |
| Tin | Minsur | CID001182 | Peru |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | Philippines |
| Tin | Fenix Metals | CID000468 | Poland |
| Tin | Luna Smelter, Ltd. | CID003387 | Rwanda |
| Tin | Aurubis Berango | CID002774 | Spain |
| Tin | CRM Synergies | CID003524 | Spain |
| Tin | Rui Da Hung | CID001539 | Taiwan |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | Thailand |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Tin | Thaisarco | CID001898 | Thailand |
| Tin | Alpha | CID000292 | United States of America |
| Tin | Metallic Resources, Inc. | CID001142 | United States of America |
| Tin | Tin Technology & Refining | CID003325 | United States of America |
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 | Austria |
| Tungsten | Cronimet Brasil Ltda | CID003468 | Brazil |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CID002641 | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | China |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CID003609 | China |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | China |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | China |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CID003417 | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | China |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CID002513 | China |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | China |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | China |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 | Germany |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | CID002542 | Germany |
| Tungsten | A.L.M.T. Corp. | CID000004 | Japan |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | Japan |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | Philippines |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 | Taiwan |
| Tungsten | Global Tungsten & Powders LLC | CID000568 | United States of America |
| Tungsten | Kennametal Fallon | CID000966 | United States of America |
| Tungsten | Kennametal Huntsville | CID000105 | United States of America |
| Tungsten | Niagara Refining LLC | CID002589 | United States of America |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | Vietnam |
| Tungsten | Masan High-Tech Materials | CID002543 | Vietnam |
| Tungsten | Tungsten Vietnam Joint Stock Company | CID003993 | Vietnam |
The Company requested both country of origin information and mine or location of origin information from its suppliers for purposes of determining the source and chain of custody of the 3TG minerals in the Company's supply chain. The Company relied on country of origin information provided by its suppliers (if known), as well as by the RMI's RMAP and RCOI Data Document. Some of the Company's suppliers provided mine or location of origin information, but many were unable to obtain such information for their 3TG minerals.
RMAP conformant gold smelters and refiners included in Table 1 have disclosed mineral sources as originating from recycled and scrap sources and/or from the following countries: Algeria, Andorra, Antigua and Barbuda, Argentina, Australia, Austria, Azerbaijan, Bahamas, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Cote d'Ivoire, Croatia, Curacao, Cyprus, Czechia, Denmark, Dominican Republic, DRC and adjoining countries, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Fiji, Finland, France, Georgia, Germany, Ghana, Greece, Grenada, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Kuwait,
Kyrgyzstan, Lao People's Democratic Republic, Latvia, Lebanon, Liberia, Liechtenstein, Lithuania, Luxembourg, Macau, 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, Republic of Korea, Romania, Russian Federation, Saint Kitts and Nevis, Saudi Arabia, Senegal, Serbia, Singapore, Sint Maarten, Slovakia, Slovenia, South Africa, Spain, St Vincent and Grenadines, Sudan, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Trinidad and Tobago, Tunisia, Turkey, Turks and Caicos, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Vietnam and Zimbabwe.
RMAP conformant tantalum, tin and tungsten smelters and refiners included in Table 1 have disclosed mineral sources as originating from recycled and scrap sources and/or from the following countries: Argentina, Australia, Austria, Bahrain, Bangladesh, Belarus, Belgium, Bolivia, Brazil, Bulgaria, Canada, Chile, China, Colombia, Croatia, Czechia, Denmark, DRC and adjoining countries, Egypt, El Salvador, Estonia, Ethiopia, Finland, France, Germany, Ghana, Greece, Guinea, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Kyrgyzstan, Kuwait, Lao People's Democratic Republic, Latvia, Lebanon, Liberia, Lithuania, Malaysia, Malta, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Puerto Rico, Republic of Korea, Romania, Russian Federation, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Venezuela, Vietnam, Yemen and Zimbabwe.
Mineral sources are disclosed for all of the RMAP conformant smelters and refiners as of March 31, 2023. Twenty one of the smelters and refiners discussed above have disclosed mineral sources as originating from the DRC and adjoining countries.
Table 2. RMAP Participating Smelters and Refiners
The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have agreed to participate in the RMAP but have not yet completed the program as of May 5, 2023.
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Gold | C.I Metales Procesados Industriales SAS | CID003421 | Colombia |
| Gold | WEEEREFINING | CID003615 | France |
| Gold | Augmont Enterprises Private Limited | CID003461 | India |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | CID002852 | India |
| Gold | Alexy Metals | CID003500 | United States of America |
| Tin | Super Ligas | CID002756 | Brazil |
| Tin | PT Belitung Industri Sejahtera | CID001421 | Indonesia |
| Tin | PT Timah Nusantara | CID001486 | Indonesia |
Mineral sources for RMAP participating smelters and refiners are not available.
Table 3. Smelters and Refiners with No Known RMAP Participation
The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have not been validated as conformant according to the RMAP as of May 5, 2023.
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| | | |
| Gold | ABC Refinery Pty Ltd. | CID002920 | Australia |
| Gold | Industrial Refining Company | CID002587 | Belgium |
| Gold | Marsam Metals | CID002606 | Brazil |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | China |
| Gold | Dongwu Gold Group | CID003663 | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | China |
| Gold | Guangdong Jinding Gold Limited | CID002312 | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | China |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 | China |
| Gold | Lingbao Gold Co., Ltd. | CID001056 | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | China |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | China |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | China |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 | China |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 | China |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | China |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CID002750 | China |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 | China |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | China |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 | Germany |
| Gold | Gold Coast Refinery | CID003186 | Ghana |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 | India |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | CID003487 | India |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | CID003488 | India |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | CID003489 | India |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | CID003490 | India |
| Gold | JALAN & Company | CID002893 | India |
| Gold | Kundan Care Products Ltd. | CID003463 | India |
| Gold | MD Overseas | CID003548 | India |
| Gold | Sai Refinery | CID002853 | India |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 | India |
| Gold | Sovereign Metals | CID003383 | India |
| Gold | 8853 S.p.A. | CID002763 | Italy |
| Gold | Safimet S.p.A | CID002973 | Italy |
| Gold | Kazakhmys Smelting LLC | CID000956 | Kazakhstan |
| Gold | HwaSeong CJ CO., LTD. | CID000778 | Korea, Republic of |
| Gold | Samduck Precious Metals | CID001555 | Korea, Republic of |
| Gold | Samwon Metals Corp. | CID001562 | Korea, Republic of |
| Gold | Kyrgyzaltyn JSC | CID001029 | Kyrgyzstan |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 | Lithuania |
| Gold | Modeltech Sdn Bhd | CID002857 | Malaysia |
| Gold | Sellem Industries Ltd. | CID003540 | Mauritania |
| Gold | Caridad | CID000180 | Mexico |
| Gold | Morris and Watson | CID002282 | New Zealand |
| Gold | K.A. Rasmussen | CID003497 | Norway |
| Gold | Albino Mountinho Lda. | CID002760 | Portugal |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | Russian Federation |
| Gold | JSC Novosibirsk Refinery | CID000493 | Russian Federation |
| Gold | JSC Uralelectromed | CID000929 | Russian Federation |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 | Russian Federation |
| Gold | Moscow Special Alloys Processing Plant | CID001204 | Russian Federation |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | Russian Federation |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | Russian Federation |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | Russian Federation |
| Gold | L'azurde Company For Jewelry | CID001032 | Saudi Arabia |
| Gold | AU Traders and Refiners | CID002850 | South Africa |
| Gold | Sudan Gold Refinery | CID002567 | Sudan |
| Gold | Cendres + Metaux S.A. | CID000189 | Switzerland |
| Gold | Singway Technology Co., Ltd. | CID002516 | Taiwan |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 | Taiwan |
| Gold | Umicore Precious Metals Thailand | CID002314 | Thailand |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | Turkey |
| Gold | African Gold Refinery | CID003185 | Uganda |
| Gold | Dijllah Gold Refinery FZC | CID003348 | United Arab Emirates |
| Gold | Fujairah Gold FZC | CID002584 | United Arab Emirates |
| Gold | International Precious Metal Refiners | CID002562 | United Arab Emirates |
| Gold | Kaloti Precious Metals | CID002563 | United Arab Emirates |
| Gold | Metallix Refining Inc. | CID003557 | United States of America |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Facility Name | RMI Smelter Identification | Facility Location |
| Gold | Pease & Curren | CID002872 | United States of America |
| Gold | QG Refining, LLC | CID003324 | United States of America |
| Gold | Sabin Metal Corp. | CID001546 | United States of America |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 | Zimbabwe |
| Tantalum | 5D Production OU | CID003926 | Estonia |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | Russian Federation |
| Tin | Melt Metais e Ligas S.A. | CID002500 | Brazil |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 | China |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | China |
| Tin | Precious Minerals and Smelting Limited | CID003409 | India |
| Tin | PT Bangka Tin Industry | CID001419 | Indonesia |
| Tin | PT Panca Mega Persada | CID001457 | Indonesia |
| Tin | PT Tinindo Inter Nusa | CID001490 | Indonesia |
| Tin | PT Tirus Putra Mandiri | CID002478 | Indonesia |
| Tin | Modeltech Sdn Bhd | CID002858 | Malaysia |
| Tin | Pongpipat Company Limited | CID003208 | Myanmar |
| Tin | Novosibirsk Tin Combine | CID001305 | Russian Federation |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | Vietnam |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | Vietnam |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | Vietnam |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | Vietnam |
| Tin | VQB Mineral and Trading Group JSC | CID002015 | Vietnam |
| Tungsten | ACL Metais Eireli | CID002833 | Brazil |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 | Brazil |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | China |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CID003662 | China |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | CID004060 | Korea, Republic of |
| Tungsten | HANNAE FOR T Co., Ltd. | CID003978 | Korea, Republic of |
| Tungsten | Artek LLC | CID003553 | Russian Federation |
| Tungsten | Hydrometallurg, JSC | CID002649 | Russian Federation |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 | Russian Federation |
| Tungsten | LLC Vostok | CID003643 | Russian Federation |
| Tungsten | Moliren Ltd. | CID002845 | Russian Federation |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 | Russian Federation |
| Tungsten | OOO “Technolom” 1 | CID003614 | Russian Federation |
| Tungsten | OOO “Technolom” 2 | CID003612 | Russian Federation |
| Tungsten | Unecha Refractory metals plant | CID002724 | Russian Federation |
4. Steps to be Taken to Mitigate Risk
The Company intends to take the following steps to mitigate the risk that 3TG minerals contained in the Company’s products could benefit armed groups in the DRC or adjoining countries:
•Continue to encourage the Company's suppliers to improve response rates and the content of responses, including names, country of origin and mine or location of origin. Continue to use and encourage the Company's suppliers to use the Conflict Minerals Resources Center and other publicly available tools from the RMI. Engage suppliers to request their smelters and refiners participate in the RMAP or other independent third party audit programs.
•Continue to provide non-validated processing facilities to the RMI for validation and potential participation in the RMAP.
•Continue to support the RMI’s efforts to support the responsible sourcing of minerals.
•Encourage the Company's suppliers to consider alternative sources for the 3TG minerals.
•Continue to integrate Conflict Minerals contractual language in the Company’s new or renewed supplier contracts.
•Determine an appropriate course of action which may include, but is not limited to, the suspension or termination of the Company's relationship with a non-conformant supplier.
•Avoid engaging with new suppliers who are not in compliance with the Company's Conflict Mineral policy.
The Company recognizes that due diligence is a dynamic process and requires on-going risk monitoring. After implementing these risk mitigation strategies, the Company will reassess the effectiveness of its risk management plan, and may adapt further strategies or refine existing strategies to ensure effective risk mitigation. Furthermore, future acquisitions will be integrated into the Company's due diligence processes.
FORWARD-LOOKING STATEMENTS
Certain statements contained herein constitute “forward-looking statements” as defined in the Private Securities Litigation Reform Act of 1995. Forward-looking statements are based on currently available information and involve factors that are subject to change, assumptions, risk and uncertainties that could cause actual results to differ materially. Examples of forward-looking statements include statements relating to the Company’s ability to effectively continue its due diligence efforts on the conflict minerals in its supply chain, engagement with the Company’s suppliers to comply with the Company’s supplier policies and due diligence processes and the Company’s ability to implement future due diligence processes effectively. Except as required by law, the Company undertakes no obligation to update or revise its forward-looking statements. Further information on factors that could cause actual results to differ materially from those expressed or implied in the forward-looking statements is disclosed from time to time in our other filings with the SEC.
