United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Western Digital Corporation
(Exact name of registrant as specified in its charter)
| Delaware | 1-8703 | 33-0956711 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 5601 Great Oaks Parkway San Jose, California |
95119 | |
| (Address of principal executive offices) | (Zip Code) |
Michael C. Ray
Executive Vice President, Chief Legal Officer and Secretary
(408) 717-6000
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 through December 31, 2017. |
Section 1—Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
As contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”), we are providing a Conflict Minerals Report as an Exhibit to this Form SD, which is also available on the Internet at: http://investor.wdc.com/sec.cfm.
Information concerning tin, tantalum, tungsten and gold from recycled or scrap sources that may be contained in our in-scope products is included in the Conflict Minerals Report and is incorporated in this Form SD by reference.
Item 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2—Exhibits
Item 2.01 Exhibits
Exhibit 1.01 Conflict Minerals Report for the calendar year ended December 31, 2017.
2
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| WESTERN DIGITAL CORPORATION (Registrant) |
||||||||
| By: | /s/ Michael C. Ray |
May 31, 2018 | ||||||
| Name: | Michael C. Ray | |||||||
| Title: | Executive Vice President, Chief Legal Officer and Secretary | |||||||
3
Exhibit 1.01
Conflict Minerals Report
Western Digital Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for calendar year 2017 as contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 31, 2018.
Unless the context indicates otherwise, the terms “we,” “its,” “us,” “our” and “Company” refer to Western Digital Corporation, or WDC, and its consolidated subsidiaries. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (the “DRC”), its adjoining countries, the United States or elsewhere. You should not place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.
Applicability of the Conflict Minerals Rule to Our Company
We are a leading developer, manufacturer and provider of data storage devices and solutions that address the evolving needs of the information technology industry and the infrastructure that enables the proliferation of data in virtually every industry. Our broad portfolio of technology and products address the following key markets: Client Devices (mobile, desktop, gaming and digital video hard drives, client SSDs, embedded products and wafers); Data Center Devices and Solutions (capacity and performance enterprise HDD, enterprise SSD, data center software and system solutions); and Client Solutions (removable products, hard drive content solutions and flash content solutions). We also generate license and royalty revenue related to our intellectual property, which is included in each of these three categories.
We are subject to the Conflict Minerals Rule because certain products that we manufacture or contract to be manufactured contain 3TG that are necessary to the functionality or production of the products. We do not directly source 3TG from mines, smelters or refiners and believe that in most cases we are several steps removed in the supply chain from these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with the expectations provided in our Conflict Minerals Policy, which we describe below.
We describe our product, smelter and refiner information for 2017 under “Product Information” below and on Annex A. For 2017, we did not find that any of the necessary 3TG contained in these in-scope products directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.” Our use of the terms “adjoining country,” “armed group” and “DRC conflict free” have the same meanings as those provided in the Conflict Minerals Rule.
1
Our Conflict Minerals Policy
We strongly disapprove of the violence in the DRC and adjoining countries. Since well before the adoption of the Conflict Minerals Rule, we have been committed to supporting responsible sourcing of 3TG. We started communicating with suppliers in 2010 regarding this issue. We also take seriously our compliance obligations under the Conflict Minerals Rule. To these ends, we have adopted and communicated to our suppliers and the public our policy regarding 3TG (our “Conflict Minerals Policy”). Our Conflict Minerals Policy provides our expectations that our suppliers:
| 1. | supply materials to us that are “DRC conflict free,” which, as stated in our Conflict Minerals Policy, means (a) any 3TG necessary to the functionality and production of supplied materials do not directly or indirectly finance armed groups through mining or mineral trading in the DRC or an adjoining country, or (b) any 3TG in supplied materials are from recycled or scrap sources; and |
| 2. | adopt policies with respect to 3TG in support of our Conflict Minerals Policy and, throughout the supply chain, to require their suppliers to adopt similar policies. |
We do not support the embargoing of 3TG from the DRC region, but rather encourage our suppliers to continue to source responsibly from the region.
In addition, we have been a member of the Responsible Business Alliance (“RBA,” and formerly the Electronic Industry Citizenship Coalition) since 2007. The RBA is the world’s largest industry coalition dedicated to electronics supply chain responsibility. Through the RBA’s Responsible Minerals Initiative (the “RMI,” and formerly the Conflict Free Sourcing Initiative), we have worked and continue to work with other companies focusing on responsible 3TG sourcing.
Reasonable Country of Origin Inquiry Information
As required by the Conflict Minerals Rule, we conducted a “reasonable country of origin inquiry” covering 2017. Our outreach included communicating requests for Conflict Minerals Reporting Templates from those suppliers that we identified as having provided us with components, parts or products containing 3TG, or that we believe may have provided us with components, parts or products containing 3TG. Our outreach for 2017 included 193 suppliers, 100% of which responded to our request for information.
For 2017, the responding suppliers identified 248 different smelters and refiners that processed the necessary 3TG contained in our in-scope products. Based on our reasonable country of origin inquiry with our suppliers, the information reported by suppliers that submitted Conflict Minerals Reporting Templates to us, and the country of origin information that the RMI makes available to its members, we concluded that 39 of these smelters and refiners sourced from within the DRC and its adjoining countries. All of the identified smelters and refiners that sourced from the DRC and its adjoining countries were listed as conformant, as described under “Identified Smelters and Refiners.”
Nineteen of the smelters and refiners that were identified by suppliers as having processed necessary 3TG in our supply chain were reasonably believed by us to have sourced only recycled or scrap content for at least part of 2017. An additional 80 of the smelters and refiners identified to us by our suppliers processed 3TG from both recycled or scrap and newly mined sources. The foregoing determinations were based on origin information that the RMI makes available to its members. To the extent that a smelter or refiner processed both recycled or scrap and newly mined 3TG, we were unable to determine from which source the necessary 3TG in our products originated.
For our reasonable country of origin inquiry, to the extent applicable, we utilized the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the OECD Guidance (as defined below) design framework, which are described below in this Conflict Minerals Report.
2
Pursuant to the Conflict Minerals Rule, based on the results of our reasonable country of origin inquiry, we were required to conduct due diligence for 2017. We discuss these due diligence efforts below.
Due Diligence Program Design
Design Framework
We have designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”).
Selected Elements of Design Framework
The OECD Guidance established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. We discuss selected elements of our due diligence program design below. However, these are not all of the elements of our due diligence program designed to help ensure the responsible sourcing of 3TG contained in our products. The headings below conform to the headings used in the OECD Guidance for each of the five steps. We discuss selected due diligence measures that we took in respect of 2017 under “Due Diligence Program Execution.”
| 1. | Establish strong company management systems |
| a. | We have a team of senior staff who are members of the working group responsible for the management and continued implementation of our 3TG compliance strategy. This staff reports to senior leadership of our Company. The following functional areas are represented on the working group or are otherwise involved with our compliance process: financial reporting; internal audit; investor relations; legal; procurement; and quality. Leadership of the compliance program resides with our Senior Vice President, Global Procurement, and Chief Procurement Officer. |
| b. | Selected personnel receive training, as needed, on the Conflict Minerals Rule, the OECD Guidance, our compliance program and our procedures for reviewing and validating supplier responses to our inquiries. We have internal procedures documents addressing various aspects of our compliance program, including our review and validation of supplier responses. These documents are communicated to the members of the working group. |
| c. | We utilize specialist outside counsel and other consultants to assist us with our compliance efforts. |
| d. | We have a Conflict Minerals Policy. The Conflict Minerals Policy is posted on our website and distributed electronically to selected employees and suppliers. |
| e. | We utilize the RMI’s Conflict Minerals Reporting Template to identify smelters and refiners in our supply chain. The Conflict Minerals Reporting Template requires suppliers to provide information concerning the usage and source of 3TG in their components, parts and products, as well as information concerning their related compliance efforts. We encourage our suppliers to consult the information contained on the RMI website and to participate in appropriate third-party training, to enhance the accuracy and quality of the information that they provide to us. |
| f. | We are a member of the RBA and the RMI. |
| g. | We have procedures to maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, on a computerized database for at least five years. |
| h. | Certain of our forms of purchase order terms and conditions contain a requirement to comply with environmental specifications for materials, components and products, which specifically reference 3TG compliance, and the RBA Code of Conduct, which provides for the responsible sourcing of minerals generally. |
| i. | With the dissemination of the Conflict Minerals Reporting Template, we remind suppliers of our Conflict Minerals Policy and indicate third-party resources that they can refer to for additional information. In addition, we remind certain suppliers of our compliance expectations during supplier business reviews. |
3
| j. | As a grievance mechanism, we have a third-party managed Ethics Hotline available for employees, suppliers and other interested parties to report potential violations of our Conflict Minerals Policy. We communicate to these stakeholders the availability of our Ethics Hotline for reporting potential violations of our company policies, which include our Conflict Minerals Policy. The number for the Ethics Hotline is (877) 548-6716. |
| 2. | Identify and assess risk in the supply chain |
| a. | We request that suppliers provide us with information concerning the usage and source (including the identity of smelters/refiners in our supply chain) of 3TG in the components, parts and products that they sell to us and their related compliance efforts through the completion of a Conflict Minerals Reporting Template. We follow up by email or phone with suppliers that do not respond to the request for a completed Conflict Minerals Reporting Template within a specified time frame. As part of the supplier on-boarding process, we require the completion of a Conflict Minerals Reporting Template or otherwise make inquiries concerning 3TG content. |
| b. | We use internally-approved written review criteria to identify incomplete responses, potential errors and inaccuracies in suppliers’ Conflict Minerals Reporting Templates. As part of our review, we check whether smelters and refiners disclosed by suppliers processed the types of metals contained in the components, parts and products sourced from those suppliers. We follow up by email or phone with a supplier that submits an incomplete response or a response that we believe contains errors or inaccuracies or that otherwise provides a written response determined not to be suitable by us. We follow up with other suppliers as we deem appropriate. |
| c. | We review smelter and refiner information that suppliers provide against the Smelter Look-up tab list of the Conflict Minerals Reporting Template. To the extent that a smelter or refiner identified by a supplier is not on this list, we request that the supplier confirm that the listed entity is a smelter or refiner and/or, through the RMI or publicly available information, we attempt to determine whether the listed entity is a smelter or refiner. |
| d. | We also review smelter and refiner information against the lists of “conformant,” “active” and the equivalent smelters and refiners and country of origin information published by the RMI, the London Bullion Market Association (“LBMA”), the Responsible Jewellery Council (“RJC”) and the Tungsten Industry – Conflict Minerals Council (“TI-CMC”). To the extent that a smelter or refiner identified by a supplier is not listed as “conformant,” “active” or the equivalent by any of these independent third-parties, we consult information that the RMI makes available to its members to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. |
| e. | Suppliers are categorized by internally-developed supplier risk levels, which assign risk across multiple criteria, including smelter or refiner certification status, “red flags” identified and the supplier relationship. Suppliers that are identified as being in higher risk categories are escalated in accordance with our risk mitigation procedures, which are described below. |
| 3. | Design and implement a strategy to respond to identified risks |
| a. | We have procedures for monitoring and reporting on risk to designated senior management and the Audit Committee of the Board of Directors. Pursuant to these procedures, the findings of our compliance efforts are reported to senior personnel at our Company, including leadership for our 3TG compliance program, and the Audit Committee of the Board of Directors. |
| b. | We have written risk management procedures. Risk mitigation actions under our procedures can include escalation by delivering a written request to higher management levels in the supplier’s organization and issuing a formal complaint and a temporary reduction or suspension in trade. Our |
4
| risk management procedures provide for increasing levels of escalation to specified internal personnel and allow for a flexible response that is commensurate with the risks identified. In addition, to the extent that identified smelters and refiners are not conformant, we work through the RMI to encourage such smelters and refiners to become conformant. We also utilize information provided by the RMI to its members to monitor smelter and refiner improvement. |
| 4. | Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain |
| a. | In connection with our due diligence, we utilize and rely on information made available by the RMI, the LBMA, the RJC and the TI-CMC concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence and to determine whether the smelter or refiner is conformant or the equivalent. |
| b. | We also support independent third-party audits by being a member of the RMI. |
| 5. | Report on supply chain due diligence |
We file a Form SD, and to the extent applicable a Conflict Minerals Report, with the Securities and Exchange Commission and make them available on our website.
Due Diligence Program Execution
We performed the following due diligence measures in respect of the 2017 compliance period, but these are not all of the measures that we took in respect of 2017 in furtherance of our Conflict Minerals Policy and 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, please see “Due Diligence Program Design.”
| 1. | We sent requests to all of our suppliers that we identified for 2017 as having provided us with components, parts or products containing 3TG, or that we believe may have provided us with components, parts or products containing 3TG, to provide us with a completed Conflict Minerals Reporting Template. We requested that our suppliers furnish us with a completed template at the product level (i.e., specific to the products that they sold to us, rather than pertaining to the products sold to all of their customers). We followed up by email or phone with suppliers that did not provide a completed template within the specified time frame communicated to the suppliers. |
| 2. | As part of the supplier on-boarding process, we required that suppliers complete a Conflict Minerals Reporting Template or otherwise made inquiries concerning the 3TG content of the components, parts and/or products prior to making purchases from them. |
| 3. | We reviewed the completed Conflict Minerals Reporting Templates based on our internally-approved written review criteria to identify incomplete responses, potential errors, inaccuracies and potential DRC region sourcing. |
| 4. | We reviewed the smelters and refiners identified by our suppliers against those contained on the Smelter Look-up tab list of the Conflict Minerals Reporting Template. To the extent that they were not on that list, we (a) requested that the supplier confirm that the listed entity is a smelter or refiner and/or (b) through the RMI or publicly available information, attempted to determine whether the listed entity is a smelter or refiner. |
| 5. | When a completed Conflict Minerals Reporting Template from a supplier identified a smelter or refiner, we also reviewed that information against the lists of conformant and active (or the equivalent) smelters and refiners and country of origin information published by the RMI, the LBMA, the RJC and the TI-CMC. |
| 6. | When a completed Conflict Minerals Reporting Template from a supplier identified a smelter or refiner that was not listed as conformant or active (or the equivalent) by the RMI, the LBMA, the RJC or the |
5
| TI-CMC, we consulted the information that the RMI makes available to its members to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. |
| 7. | The findings of our compliance efforts in respect of 2017 were reported to senior personnel at our Company, including leadership for our 3TG compliance program, and the Audit Committee of the Board of Directors. |
| 8. | Pursuant to our risk management procedures, we sent requests to higher management levels in certain suppliers’ organizations where it was deemed advisable, to help incentivize suppliers to cooperate with our requests. |
| 9. | We supported independent third-party audits of smelters and refiners through our membership in the RMI. In addition, certain of our personnel were members of or participated in various RMI committees, including the Smelter Engagement Team. Through our support of and participation in the RMI, we utilized information provided by the RMI to its members to monitor smelter and refiner improvement, to exercise leverage over smelters and refiners to become conformant and to assess smelter and refiner due diligence. |
| 10. | In addition, to mitigate the risk that the necessary 3TG contained in the in-scope products that we manufacture or contract to manufacture directly or indirectly finance or benefit armed groups in the DRC or an adjoining country, we: |
| a. | Updated our reasonable country of origin inquiry and due diligence procedures to align with the then latest revision of the Conflict Minerals Reporting Template. |
| b. | Continued to refine our internal compliance procedures and reporting metrics, to better ensure that we are effectively using program resources and collecting data that is useful to assessing and mitigating risk. |
| c. | Reviewed selected supplier policies to confirm that they do not provide for an embargo of 3TG from the DRC region. Policies were selected for review based on the information provided by suppliers in their Conflict Minerals Reporting Templates. Based on that review, none of the reviewed suppliers were suspected of embargoing the DRC region. |
| d. | We communicated to suppliers the target dates we have set for them to transition to exclusively sourcing from conformant smelters and refiners. |
Product Information
For 2017, our in-scope product categories were: (1) hard disk drives; (2) solid-state drives; (3) NAND-flash storage devices; (4) direct attached storage solutions; (5) personal cloud network attached storage solutions; and (6) public and private cloud data center storage solutions. For a further discussion of our products, see our Annual Report on Form 10-K for the fiscal year ended June 30, 2017. The information contained in our Form 10-K is not incorporated by reference into, or a part of, this Conflict Minerals Report.
For 2017, we did not find that any necessary 3TG contained in these in-scope products directly or indirectly financed or benefitted an armed group in the DRC or an adjoining country. An “armed group” under the Conflict Minerals Rule is an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.”
We do not directly source 3TG from mines, smelters or refiners. We believe that in most cases we are several steps removed in the supply chain from these market participants.
6
Identified Smelters and Refiners
In connection with our reasonable country of origin inquiry or due diligence, as applicable, our suppliers identified to us the smelters and refiners listed on Annex A as having processed the necessary 3TG contained in our in-scope products for 2017. Of those 248 smelters and refiners identified, all were listed as conformant. These smelters and refiners may not be all of the smelters and refiners in our 2017 supply chain for the reasons indicated in note (1)(a) to Annex A. Due to our position in the supply chain, which is discussed above, we rely on our suppliers for complete and accurate smelter and refiner information. Our due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our 2017 in-scope products.
The table below presents a summary of the smelter and refiner information contained in Annex A. Please see the notes accompanying Annex A for additional information relevant to the table below.
Smelter and Refiner and Country of Origin Information (1)
| Conformant | Active | On Smelter Look-up List Only |
||||||||||||||||||||||
| DRC Region Sourced |
Non-DRC Region Sourced |
Not Disclosed |
Recycled or Scrap |
|||||||||||||||||||||
| Tantalum |
29 | 37 | 31 | 0 | 0 | |||||||||||||||||||
| Tin |
5 | 66 | 1 | 24 | 0 | 0 | ||||||||||||||||||
| Tungsten |
5 | 40 | 18 | 0 | 0 | |||||||||||||||||||
| Gold |
0 | 13 | 71 | 26 | 0 | 0 | ||||||||||||||||||
| (1) | If a smelter or refiner sourced from multiple sources, it is included in the table under each applicable category. |
We endeavored to determine the mine or location of origin of the 3TG contained in our 2017 in-scope products by requesting that our suppliers provide us with a completed Conflict Minerals Reporting Template. Where a Conflict Minerals Reporting Template provided by a supplier identified a smelter or refiner, we also reviewed information made available by the RMI, the LBMA, the RJC and the TI-CMC, to the extent available, to try to determine the mine or location of origin.
Future Risk Mitigation Efforts
We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our 2018 in-scope products benefit armed groups:
| 1. | Continue to encourage suppliers that provided company level information for 2017 to provide product level information for 2018 through ongoing outreach with these suppliers. |
| 2. | Engage with suppliers that provided incomplete responses for 2017 to help ensure that they provide requested information for 2018. |
| 3. | Communicate to new potentially in-scope suppliers our sourcing expectations, including through the dissemination of our Conflict Minerals Policy to them. |
| 4. | Continue to review selected supplier policies to confirm that they do not provide for an embargo of 3TG from the DRC region. |
| 5. | Continue to communicate to suppliers that we are committed to responsible sourcing from the DRC region. |
| 6. | Monitor supplier progress toward transitioning to exclusively sourcing from conformant smelters and refiners in accordance with the target dates that we have set for them. |
All of the foregoing steps are in addition to the steps that we took in respect of 2017, which we intend to continue to take in respect of our 2018 compliance efforts, to the extent applicable.
7
Annex A
Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.
Smelters and Refiners
In connection with our reasonable country of origin inquiry or due diligence, as applicable, our suppliers identified to us the smelters and refiners listed below as having processed the necessary Conflict Minerals contained in our in-scope products in 2017. Please see the notes that accompany the table for important information concerning the data in the table.
A-1
Smelter and Refiner Information (1)
| Metal |
Name of Smelter or Refiner |
Country of Location |
Smelter or | |||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant | |||
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conformant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Conformant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Conformant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant | |||
| Gold | Aurubis AG | GERMANY | Conformant | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant | |||
| Gold | Boliden AB | SWEDEN | Conformant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant | |||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant | |||
| Gold | Chimet S.p.A. | ITALY | Conformant | |||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant | |||
| Gold | Dowa | JAPAN | Conformant | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant | |||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant | |||
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Conformant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Conformant | |||
| Gold | Italpreziosi | ITALY | Conformant | |||
| Gold | Japan Mint | JAPAN | Conformant |
A-2
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conformant | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant | |||
| Gold | Kazzinc | KAZAKHSTAN | Conformant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant | |||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Marsam Metals | BRAZIL | Conformant | |||
| Gold | Materion | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant | |||
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Conformant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Conformant | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant | |||
| Gold | PAMP S.A. | SWITZERLAND | Conformant | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant | |||
| Gold | PX Précinox S.A. | SWITZERLAND | Conformant | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant | |||
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Conformant |
A-3
| Gold | Royal Canadian Mint | CANADA | Conformant | |||
| Gold | SAAMP | FRANCE | Conformant | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Conformant | |||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Conformant | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant | |||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | T.C.A S.p.A | ITALY | Conformant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Conformant | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Valcambi S.A. | SWITZERLAND | Conformant | |||
| Gold | Western Australian Mint (trading as The Perth Mint) | AUSTRALIA | Conformant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Conformant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | F & X | CHINA | Conformant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
A-4
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Conformant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | |||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Conformant | |||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Conformant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Conformant | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Conformant | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Conformant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Conformant | |||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Conformant | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Solikamsk Metal Works | RUSSIAN FEDERATION | Conformant | |||
| Tantalum | Taki Chemicals | JAPAN | Conformant | |||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | ULBA | KAZAKHSTAN | Conformant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant | |||
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
A-5
| Tin | CV Ayi Jaya | INDONESIA | Conformant | |||
| Tin | CV Dua Sekawan | INDONESIA | Conformant | |||
| Tin | CV Gita Pesona | INDONESIA | Conformant | |||
| Tin | CV Tiga Sekawan | INDONESIA | Conformant | |||
| Tin | CV United Smelting | INDONESIA | Conformant | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Conformant | |||
| Tin | Dowa | JAPAN | Conformant | |||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
| Tin | Fenix Metals | POLAND | Conformant | |||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant | |||
| Tin | Gejiu Jinye Mineral Company | CHINA | Conformant | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant | |||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Conformant | |||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Conformant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant | |||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant | |||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant | |||
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant | |||
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Conformant | |||
| Tin | Minsur | PERU | Conformant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Conformant | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Conformant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Conformant |
A-6
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Bukit Timah | INDONESIA | Conformant | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Conformant | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conformant | |||
| Tin | PT Inti Stania Prima | INDONESIA | Conformant | |||
| Tin | PT Karimun Mining | INDONESIA | Conformant | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant | |||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant | |||
| Tin | PT Panca Mega Persada | INDONESIA | Conformant | |||
| Tin | PT Premium Tin | INDONESIA | Conformant | |||
| Tin | PT Prima Timah Utama | INDONESIA | Conformant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Conformant | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Conformant | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant | |||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conformant | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant | |||
| Tin | PT Tommy Utama | INDONESIA | Conformant | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Conformant | |||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Tin | Soft Metais Ltda. | BRAZIL | Conformant | |||
| Tin | Thaisarco | THAILAND | Conformant | |||
| Tin | White Solder Metalurgica | BRAZIL | Conformant | |||
| Tin | Yunnan Chengfeng | CHINA | Conformant | |||
| Tin | Yunnan Tin Company, Ltd. | CHINA | Conformant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant | |||
| Tungsten | ALMT Corp. | JAPAN | Conformant | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
A-7
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant | |||
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant | |||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conformant | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant |
| (1) | We note the following in connection with the information contained in the foregoing table: |
| (a) | The smelters and refiners listed in the table were identified by our suppliers as being part of our 2017 supply chain. Some of our suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. In addition, the smelters and refiners reflected above may not be all of the smelters and refiners in our 2017 supply chain, since: (i) we have not included smelter and refiner information that our suppliers reported to us at a “company level,” meaning that they reported to us the 3TG contained in all of their products, not just the products that they sold to us; and (ii) many of our suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products. |
A-8
| (b) | The table only includes entities that were listed as smelters or refiners by the RMI, the LBMA, the RJC or the TI-CMC, as of April 10, 2018. |
| (c) | Smelter or refiner status information in the table is as of April 10, 2018. |
| (d) | “Conformant” means that a smelter or refiner was listed as conformant with the Responsible Minerals Assurance Process’s (“RMAP”) assessment protocols, including through mutual recognition and those indicated as “re-audit in process.” Included smelters and refiners were not necessarily conformant for all or part of 2017 and may not continue to be conformant for any future period. We do not have information on the origin of the 3TG processed by any of the conformant smelters and refiners prior to their respective certification dates. |
| (e) | “Active” means that the smelter or refiner is a participant in the RMAP and has committed to undergo an audit or is participating in a cross-recognized certification program. |
| (f) | Smelter or refiner status reflected in the table is based solely on information made publicly available by the RMI, LBMA, RJC and/or TI-CMC, without independent verification by us. |
| (g) | “On Smelter Look-up List” means that a smelter or refiner is listed on the Smelter Look-up tab of the Conflict Minerals Reporting Template, but is not listed as “Conformant” or “Active.” |
Country of Origin Information
The countries of origin of the 3TG processed by the Conformant smelters and refiners listed above may have included the countries listed below. The listed countries of origin are derived from information made available by the RMI to its members. Except for the DRC, the RMI does not indicate individual countries of origin of the 3TG processed by Conformant smelters and refiners. Instead, the RMI indicates country of origin by category. In addition, for some of the listed Conformant smelters and refiners, origin information is not disclosed. Conformant smelters and refiners listed above were in one or more of the categories below:
L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of from the DRC and its nine adjoining countries: Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Senegal, Sierra Leone, Spain, Thailand, Togo, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe.
L2 – Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Mozambique and South Africa.
L3 – The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC – The Democratic Republic of the Congo.
In addition, according to information made available by the RMI to its members, some of the listed smelters and refiners processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly mined content from one or more of the regions indicated above.
We did not determine the countries of origin of the 3TG processed by other smelters and refiners listed on this Annex A.
A-9