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 | 001-08703 | 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, 2018. |
Section 1—Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report |
As required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”), Western Digital Corporation (the “Company”) has filed this Form SD for the reporting period from January 1, 2018 to December 31, 2018.
The description of the Company’s reasonable country of origin inquiry (“RCOI”) process, the results of our inquiry, and the determination we reached as a result of the RCOI are included in the Company’s Conflict Minerals Report, attached as an exhibit to this Form SD.
This Form SD and our Conflict Minerals Report, filed as an Exhibit to this Form SD, are publicly available on the Internet at: http://investor.wdc.com/sec.cfm. The content of any website referred to in this Form SD or the related Conflict Minerals Report is included for general information only and is not incorporated by reference in this Form SD or the related Conflict Minerals Report.
| 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 |
The following exhibit is filed as part of this report.
| Exhibit 1.01 | Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD. |
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, 2019 | ||||
| Name: |
Michael C. Ray | |||||
| Title: |
Executive Vice President, Chief Legal Officer and Secretary |
|||||
Exhibit 1.01
WESTERN DIGITAL CORPORATION
Conflict Minerals Report
For the Reporting Period from January 1, 2018 to December 31, 2018
Western Digital Corporation has filed this Conflict Minerals Report as an exhibit to its Form SD for calendar year 2018 as contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”).
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 risks related to the sourcing of the necessary 3TG.
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, (3) political and regulatory developments, whether in the Democratic Republic of the Congo, 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; Data Center Devices and Solutions; and Client 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. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with the expectations stated in our Conflict Minerals Policy, which we describe below.
Our Conflict Minerals Policy
We strongly disapprove of the violence in the Democratic Republic of Congo (the “DRC”) and adjoining countries (collectively, the “Covered Countries”). Since well before the adoption of the Conflict Minerals Rule, we have been committed to supporting responsible sourcing of 3TG, including from the Covered Countries through conformant smelters and refiners. 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 Conflict-Free Minerals (our “Conflict Minerals Policy”). Our Conflict Minerals Policy expresses our expectation that our suppliers:
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| 1. | supply materials to us that are “DRC conflict free,” by which we mean (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. |
Under the Conflict Minerals Rule, an “armed group” 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 a Covered Country.
We do not support the embargoing of 3TG from Covered Countries, 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,” 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,” formerly the Conflict Free Sourcing Initiative), we have worked with 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 in good faith a “reasonable country of origin inquiry” (“RCOI”) covering 2018. Our RCOI was reasonably designed to determine whether any of the necessary 3TG contained in our products originated in the Covered Countries or came from recycled or scrap sources. We identified 160 suppliers that we believe provided us with components, parts or products containing necessary 3TG, or that we believe may have provided us with components, parts or products containing necessary 3TG. We provided those suppliers with, and asked those suppliers to complete, the Conflict Minerals Reporting Template developed by the RMI. 100% of those suppliers responded to our request for information.
For 2018, the responding suppliers identified a total of 258 different smelters and refiners that processed the necessary 3TG contained in our products. Based on the information reported by our 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 26 of these smelters and refiners sourced or may have sourced from the Covered Countries.
Twenty-four (24) of the smelters and refiners that were identified by suppliers as having processed necessary 3TG in our products were reasonably believed by us to have sourced only recycled or scrap content for 2018, 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 the origin of the necessary 3TG in our products.
Some of our suppliers did not provide product-level information about the materials they supplied to us, and some of our suppliers were unable to provide country of origin information to us because of incomplete or insufficiently detailed responses from their own suppliers. As a result, we were not able to determine that none of our necessary 3TG originated or may have originated in the Covered Countries or are not or may not be from recycled or scrap sources. Therefore, we conducted due diligence on the source and chain of custody of those necessary conflict minerals in our products.
For our reasonable country of origin inquiry, to the extent applicable, we utilized many of the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the OECD Guidance (as defined below), which are described below in this Conflict Minerals Report.
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Due Diligence
Due Diligence Design
We have designed our due diligence measures relating to 3TG to conform with, in all material respects, the due diligence framework set forth in the Organisation for Economic Co-operation and Development’s (“OECD”) 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) (collectively, the “OECD Guidance”).
Due Diligence Measures Performed
The following is a description of the due diligence measures we performed during/for the Reporting Period. The headings below conform to the headings used in the OECD Guidance for each of the five steps.
| 1. | OECD Step #1: Establish and maintain 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: legal; procurement; and quality. Leadership of the compliance program resides with our Senior Vice President and Chief Procurement Officer. |
| b. | Members of the Global Procurement – Responsible Supply Chain team receive training from RMI 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 at https://www.westerndigital.com/company/corporate-sustainability/responsible-supply-chain and is distributed electronically to selected employees and all suppliers of materials that we believe contain 3TG. |
| e. | We utilize the RMI’s Conflict Minerals Reporting Template to identify smelters and refiners in our supply chain. We request in-scope suppliers to complete the Conflict Minerals Reporting Template in order to provide information concerning the usage and source of 3TG in their components, parts and products, as well as information concerning their related due diligence and 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 six years. |
| h. | Certain of our forms of purchase order terms and conditions contain a requirement that our suppliers comply with environmental specifications for materials, components and products, which specifically reference 3TG compliance and the RBA Code of Conduct, which requires the responsible sourcing of minerals generally. |
| i. | With the annual 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. |
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| j. | As a grievance mechanism, we have a third-party managed Ethics Helpline 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 Helpline for reporting potential violations of our company policies, which include our Conflict Minerals Policy. The number for the Ethics Helpline is (877) 548-6716. It is our policy that if concerns about our 3TG sourcing or potential violations were to be reported, we would investigate appropriately. |
| 2. | OECD Step #2: Identify and assess risk in the supply chain |
| a. | We sent requests to all of our 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, in the calendar year ended December 31, 2018, and asked them 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 respond to the request for a completed Conflict Minerals Reporting Template within a specified time frame. |
| b. | As part of the supplier on-boarding process, we required that new 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. We continue to survey suppliers annually thereafter if they are identified as an in-scope supplier. |
| c. | 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 Covered Country sourcing. As part of our review, we checked whether smelters and refiners disclosed by suppliers processed the types of metals contained in the components, parts and products sourced from those suppliers. We followed up by email or phone with a supplier that submitted an incomplete response or a response that we believed contained errors or inaccuracies or that otherwise provided a written response determined not to be suitable by us. We followed up with other suppliers as we deemed appropriate. |
| d. | 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 and whether it has ceased operations. |
| e. | 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 London Bullion Market Association (“LBMA”), the Responsible Jewellery Council (“RJC”) and the Tungsten Industry – Conflict Minerals Council (“TI-CMC”). When a completed Conflict Minerals Reporting Template from a supplier identified a smelter or refiner that was not listed as a conformant or active (or the equivalent) of these independent third-parties, we consulted 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 a Covered Country and whether those smelters and refiners have ceased operations. |
| f. | 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. |
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| 3. | OECD Step #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 in respect of 2018 were 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, pursuant to which we sent requests to higher management levels in certain suppliers’ organization where it was deemed advisable to encourage them to respond to our inquiries and to help incentivize suppliers to cooperate with our requests. Our 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 were, according to the RMI information, neither conformant nor active, we worked through the RMI to encourage such smelters and refiners to become conformant, except where the smelters or refiners have, according to the RMI information, permanently or temporarily ceased operations. We also utilize information provided by the RMI to its members to monitor smelter and refiner improvement. |
| 4. | OECD Step #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 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. |
| 5. | OECD Step #5: Report annually on supply chain due diligence |
Each year, 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 at: http://investor.wdc.com/sec.cfm.
Product Information
For 2018, 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 29, 2018. The information contained in our Form 10-K is not incorporated by reference into, or a part of, this Conflict Minerals Report.
Results of Review
As described above, we conducted due diligence to determine the source and chain of custody of the necessary 3TG in our products. As part of that process, we actively surveyed our direct suppliers that we believed potentially supplied us with products, materials or components containing necessary 3TG during 2018 and requested that they disclose the smelters and refiners that processed the necessary 3TG in the products they supplied to us in 2018. For calendar year 2018, we received completed Conflict Minerals Reporting Templates from 100% of the suppliers surveyed.
Facilities Used to Process the Necessary 3TG in Our Products
For calendar year 2018, our suppliers identified to us the smelters and refiners listed on Annex A as having processed the necessary 3TG contained in our products. Of the 258 smelters and refiners identified, 250 were identified by the RMI as “conformant,” 3 were identified by the RMI as “active,” and 5 were on the Smelter Look-up tab only. All 5 of the smelters and refiners on the Smelter Look-up tab only have, according to the RMI, ceased operations either permanently or temporarily. These 258 smelters and refiners may not be all of the smelters and refiners in our 2018 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. Therefore, our due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our 2018 products.
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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 | |||||||||||||||||||
| Likely Sourced from Covered Countries |
Not Likely Sourced from Covered Countries |
Not Disclosed |
100% Recycled or Scrap |
|||||||||||||||||
| Tantalum |
14 | 26 | 0 | 2 | 0 | |||||||||||||||
| Tin |
2 | 72 | 0 | 5 | 1 | |||||||||||||||
| Tungsten |
7 | 34 | 0 | 2 | 0 | |||||||||||||||
| Gold |
3 | 100 | 0 | 15 | 2 | |||||||||||||||
| (1) | If a smelter or refiner sourced from multiple sources, it is included in the table under each applicable category. |
Country of Origin of the Necessary 3TG in Our Products
We attempted to determine the countries of origin of the necessary 3TG in our products in reliance on country of origin information for smelters and refiners made available by the RMI to its members. However, except for the DRC, the RMI does not name specific countries of origin of the 3TG processed by conformant smelters and refiners. Instead, the RMI indicates countries of origin for each smelter and refiner by category. In addition, for some of the listed conformant smelters and refiners, country of origin information is not disclosed. Therefore, because of the lack of detail and the limitations on the RMI’s information, we are not able to disclose the specific country of origin of the necessary 3TG in our products for calendar year 2018.
Efforts to Determine the Mine or Location of Origin
We endeavored to determine the mine or location of origin of the necessary 3TG contained in our 2018 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. Our suppliers’ responses and the RMI’s information did not provide sufficiently detailed information for us to determine the mine or location of origin of the necessary 3TG in our products for calendar year 2018.
Steps Taken and to be Taken to Mitigate Risk and Improved Due Diligence
Since the start of calendar year 2018, we have taken and currently intend to continue to take the following additional steps to mitigate the risk that the necessary 3TG in our 2019 products benefit armed groups:
| 1. | Updated our reasonable country of origin inquiry and due diligence procedures to align with the then latest revision of the Conflict Minerals Reporting Template. |
| 2. | Continued to encourage suppliers that provided company level information for 2018 to provide product level information for 2019 through ongoing outreach with these suppliers. |
| 3. | Engaged with suppliers that provided incomplete responses for 2018 to help ensure that they provide requested information for 2019. |
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| 4. | 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. |
| 5. | Communicated to new potentially in-scope suppliers our sourcing expectations, including through the dissemination of our Conflict Minerals Policy to them. |
| 6. | Reviewed selected supplier policies to confirm that they do not provide for an embargo of 3TG from Covered Countries. Policies were selected for review based on the information provided by suppliers in their Conflict Minerals Reporting Templates. If any reviewed suppliers were suspected of embargoing Covered Countries, we followed up with such suppliers to urge them to amend their policies. |
| 7. | Continued to communicate to suppliers that we are committed to responsible sourcing from Covered Countries. |
| 8. | Urged our suppliers to transition to exclusively sourcing from conformant smelters and refiners and monitored their progress toward that objective. |
| 9. | Urged certain suppliers, smelters and refiners to participate in the RMI’s Responsible Minerals Assurance Process. |
| 10. | Continued to monitor best practices and regulatory guidance through membership and participation in RMI. |
All of the foregoing steps are in addition to the steps that we took in respect of 2018, which we intend to continue to take in respect of our 2019 compliance efforts, to the extent applicable.
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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 3TG contained in our products in 2018. Please see the notes that accompany the table for important information concerning the data in the table.
Smelter and Refiner Information (1)
| Metal |
Name of Smelter or Refiner |
Country of Location |
Smelter or Refiner | |||
| 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 Corrego do Sitio Mineracao | BRAZIL |
Conformant | |||
| Gold |
Argor-Heraeus S.A. | SWITZERLAND |
Conformant | |||
| Gold |
Asahi Pretec Corp. | JAPAN |
Conformant | |||
| Gold |
Asahi Refining Canada Ltd. | CANADA |
Conformant |
A-1
| Metal |
Name of Smelter or Refiner |
Country of Location |
Smelter or Refiner | |||
| 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 |
Bangalore Refinery | INDIA |
Active | |||
| 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 |
Cendres + Metaux S.A. | SWITZERLAND |
Conformant | |||
| Gold |
Chimet S.p.A. | ITALY |
Conformant | |||
| Gold |
Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Conformant | |||
| Gold |
Doduco | 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 Metals Hong Kong Ltd. | 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 |
A-2
| Gold |
Italpreziosi | ITALY |
Conformant | |||
| Gold |
Japan Mint | JAPAN |
Conformant | |||
| Gold |
Jiangxi Copper Co., Ltd. | CHINA |
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 |
KGHM Polska Miedz Spolka Akcyjna | POLAND |
Active | |||
| Gold |
Kojima Chemicals Co., Ltd. | JAPAN |
Conformant | |||
| Gold |
Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Conformant | |||
| Gold |
Kyrgyzaltyn JSC | KYRGYZSTAN |
Conformant | |||
| Gold |
L’Orfebre S.A. | ANDORRA |
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 |
Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
Conformant | |||
| Gold |
Mitsubishi Materials Corporation | JAPAN |
Conformant | |||
| Gold |
Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Conformant | |||
| Gold |
MMTC-PAMP India Pvt., Ltd. | INDIA |
Conformant | |||
| Gold |
Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Conformant | |||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
Conformant | |||
| Gold |
Nihon Material Co., Ltd. | JAPAN |
Conformant | |||
| Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Conformant | |||
| Gold |
Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Conformant | |||
| Gold |
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 |
Planta Recuperadora de Metales SpA | CHILE |
Conformant | |||
| Gold |
Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Conformant | |||
| Gold |
PT Aneka Tambang (Persero) Tbk | INDONESIA |
Conformant |
A-3
| Gold |
PX Precinox S.A. | SWITZERLAND |
Conformant | |||
| Gold |
Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Conformant | |||
| Gold |
Remondis Argentia B.V. | NETHERLANDS |
Conformant | |||
| Gold |
Republic Metals Corporation | UNITED STATES OF AMERICA |
Not Applicable | |||
| Gold |
Royal Canadian Mint | CANADA |
Conformant | |||
| Gold |
SAAMP | FRANCE |
Conformant | |||
| Gold |
Safimet S.p.A | ITALY |
Conformant | |||
| Gold |
Samduck Precious Metals | KOREA, REPUBLIC OF |
Conformant | |||
| Gold |
SAXONIA Edelmetalle GmbH | GERMANY |
Conformant | |||
| Gold |
SEMPSA Joyeria Plateria S.A. | SPAIN |
Conformant | |||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Conformant | |||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Conformant | |||
| Gold |
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 (T/a The Perth Mint) | AUSTRALIA |
Conformant | |||
| Gold |
WIELAND Edelmetalle GmbH | GERMANY |
Conformant | |||
| Gold |
Yamakin Co., Ltd. | JAPAN |
Conformant | |||
| Gold |
Yokohama Metal Co., Ltd. | JAPAN |
Conformant | |||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Conformant | |||
| Tantalum |
Asaka Riken Co., Ltd. | JAPAN |
Conformant | |||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
Conghua Tantalum and Niobium Smeltry | CHINA |
Conformant |
A-4
| Tantalum |
D Block Metals, LLC | UNITED STATES OF AMERICA |
Conformant | |||
| Tantalum |
Exotech Inc. | UNITED STATES OF AMERICA |
Conformant | |||
| Tantalum |
F&X Electro-Materials Ltd. | CHINA |
Conformant | |||
| Tantalum |
FIR Metals & Resource Ltd. | CHINA |
Conformant | |||
| Tantalum |
Global Advanced Metals Aizu | JAPAN |
Conformant | |||
| Tantalum |
Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
Conformant | |||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
H.C. Starck Co., Ltd. | THAILAND |
Conformant | |||
| Tantalum |
H.C. Starck Hermsdorf GmbH | GERMANY |
Conformant | |||
| Tantalum |
H.C. Starck Inc. | UNITED STATES OF AMERICA |
Conformant | |||
| Tantalum |
H.C. Starck Ltd. | JAPAN |
Conformant | |||
| Tantalum |
H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Conformant | |||
| Tantalum |
H.C. Starck Tantalum and Niobium GmbH | GERMANY |
Conformant | |||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
Jiangxi Tuohong New Raw Material | CHINA |
Conformant | |||
| Tantalum |
Jiujiang Janny New Material Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
Jiujiang Nonferrous Metals Smelting Company Limited | 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 |
Mineracao Taboca S.A. | BRAZIL |
Conformant | |||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Conformant | |||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
NPM Silmet AS | ESTONIA |
Conformant | |||
| Tantalum |
Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
Conformant | |||
| Tantalum |
QuantumClean | UNITED STATES OF AMERICA |
Conformant | |||
| Tantalum |
Resind Industria e Comercio Ltda. | BRAZIL |
Conformant | |||
| Tantalum |
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
Conformant | |||
| Tantalum |
Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Conformant | |||
| Tantalum |
Taki Chemical Co., Ltd. | JAPAN |
Conformant | |||
| Tantalum |
Telex Metals | UNITED STATES OF AMERICA |
Conformant |
A-5
| Tantalum |
Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Conformant | |||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Conformant | |||
| Tin |
Alent plc | UNITED STATES OF AMERICA |
Conformant | |||
| Tin |
Chenzhou Yun Xiang mining limited liability company | CHINA |
Conformant | |||
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Conformant | |||
| Tin |
China Tin Group Co., Ltd. | CHINA |
Conformant | |||
| Tin |
CV Ayi Jaya | INDONESIA |
Conformant | |||
| Tin |
CV Dua Sekawan | INDONESIA |
Conformant | |||
| Tin |
CV Gita Pesona | INDONESIA |
Conformant | |||
| Tin |
CV Serumpun Sebalai | 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 |
Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Active | |||
| 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 |
Not Applicable | |||
| 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 |
Mineracao Taboca S.A. | BRAZIL |
Conformant | |||
| Tin |
Minsur | PERU |
Conformant | |||
| Tin |
Mitsubishi Materials Corporation | JAPAN |
Conformant | |||
| Tin |
Modeltech Sdn Bhd | MALAYSIA |
Conformant | |||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Conformant |
A-6
| 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 Serumpun | INDONESIA |
Conformant | |||
| Tin |
PT Bangka Tin Industry | INDONESIA |
Conformant | |||
| 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 |
Not Applicable | |||
| 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 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 Industria e Comercio 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 Metalurgia e Mineracao Ltda. | BRAZIL |
Conformant | |||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Conformant | |||
| Tin |
Yunnan Tin Company Limited | CHINA |
Conformant | |||
| Tungsten |
ACL Metais Eireli | BRAZIL |
Conformant | |||
| Tungsten |
ALMT Corp | JAPAN |
Conformant |
A-7
| Tungsten |
Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Not Applicable | |||
| 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 Haichuang Tungsten Co., Ltd. | CHINA |
Conformant | |||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Conformant | |||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Conformant | |||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Conformant | |||
| Tungsten |
Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
Conformant | |||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Conformant | |||
| Tungsten |
H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Conformant | |||
| Tungsten |
H.C. Starck Tungsten GmbH | GERMANY |
Conformant | |||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. | CHINA |
Conformant | |||
| Tungsten |
Hunan 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 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 |
Not Applicable | |||
| Tungsten |
Wolfram Bergbau und Hutten AG | AUSTRIA |
Conformant | |||
| Tungsten |
Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Conformant | |||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Conformant |
A-8
| 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 2018 supply chain, including those that sourced only recycled or scrap content. Some of our suppliers may have reported to us smelters and refiners that were not actually 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 2018 supply chain, because: (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 because we believe that such information is likely to be over-inclusive; 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 products. |
| (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 March 7, 2019. |
| (c) | Smelter or refiner status information in the table is as of March 7, 2019. |
| (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 2018 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) | “Not Applicable” 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.” All 5 of the smelters and refiners listed as “Not Applicable” have, according to the RMI information provided as of March 7, 2019, ceased operations, either permanently or temporarily. |
A-9