UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
________________________________________________________________________________________________________________________________
Aptiv PLC
(Exact name of registrant as specified in its charter)
________________________________________________________________________________________________________________________________
| | | | | | |
| Jersey | 001-35346 | |
| (State or other jurisdiction of incorporation) | (Commission file number) | |
| | | | | | |
5 Hanover Quay
Grand Canal Dock
Dublin, Ireland | | D02 VY79 |
| (Address of principal executive offices) | | (Zip code) |
| | | | | | | | |
| Katherine H. Ramundo
(248) 813-3005 | |
| (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: | | | | | |
| ý | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
| ☐ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____________________. |
Section 1 – Conflict Minerals Disclosure | | | | | |
| Item 1.01 | Conflict Minerals Disclosure and Report |
Aptiv PLC (“Aptiv” or the “Company”), after performing the steps required by Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), has concluded in good faith that during the year ended December 31, 2023, it manufactured products as to which Conflict Minerals (as defined in the Rule) were necessary to the functionality or production of such products.
Accordingly, Aptiv has filed this Specialized Disclosure Form (Form SD) and the attached Conflict Minerals Report. The Conflict Minerals Report and the Company’s Conflict Minerals policy are publicly available at aptiv.com. The information contained on Aptiv’s website is not a part of this Form SD and is not deemed incorporated by reference into this Form SD or any other public filing made with the Securities and Exchange Commission.
A copy of the Company's Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at aptiv.com.
Section 2 – Resource Extraction Issuer Disclosure | | | | | |
| Item 2.01 | Resource Extraction Issuer Disclosure and Report |
Not applicable.
Exhibit 1.01 - Conflict Minerals Report of Aptiv PLC for the period January 1 to December 31, 2023, as required by Items 1.01 and 1.02 of this Form.
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.
| | | | | | | | | | | | | | |
| Date: | May 28, 2024 | | APTIV PLC |
| | | | |
| | | | By: | /s/ Katherine H. Ramundo |
| | | | Katherine H. Ramundo |
| | | | Executive Vice President, Chief Legal Officer, Chief Compliance Officer and Secretary |
EXHIBIT INDEX
| | | | | |
| Exhibit | |
| Number | Description |
| |
| 1.01 | |
Aptiv PLC
Conflict Minerals Report
For the Year Ended December 31, 2023
Introduction and Background
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2023 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of the Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the registrant must exercise due diligence on the Conflict Minerals’ source and chain of custody and submit a CMR to the SEC that includes a description of those due diligence measures.
This CMR relates to the process undertaken for Aptiv products that were manufactured, or contracted to be manufactured, during calendar year 2023 and that contain Conflict Minerals. This CMR was not subjected to an independent private sector audit, as none was required pursuant to the guidance provided by the SEC in its “Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule” dated April 29, 2014.
This report has been prepared by management of Aptiv PLC (herein referred to as “Aptiv,” the “Company,” “we,” “us” or “our”). The information includes the activities of all consolidated subsidiaries in which Aptiv holds a controlling financial or management interest and which meet the guidelines for inclusion based on the acquisition date. It does not include the activities of non-controlled affiliates that are not required to be consolidated.
Executive Summary of the 2023 Conflict Minerals Program
In order to determine the sources of 3TG in its supply chain, Aptiv performed a Reasonable Country of Origin Inquiry (“RCOI”) by surveying the relevant portion of our supply base for 3TG use. As a result of these survey procedures, 347 smelters and refineries (herein collectively referred to as “smelters”) were identified. Of these 347 smelters, 51 were identified as sourcing, or we had reason to believe may be sourcing, from the Covered Countries. We then exercised due diligence procedures over these 51 smelters, and as a result identified that 37 of these 51 smelters have been audited and are recognized as conformant with the Responsible Minerals Assurance Process (“RMAP”). The remaining 14 smelters were subject to Aptiv's risk mitigation process according to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas. As part of our due diligence procedures, we communicated concerns to the applicable suppliers in our supply chain that source from these smelters and encouraged our suppliers to take appropriate action to remove these smelters from their supply chain and to encourage the smelters to become RMAP Conformant.
I. Company Overview
Aptiv is a leading global technology and mobility architecture company primarily serving the automotive sector. We deliver end-to-end mobility solutions, enabling our customers’ transition to more electrified, software-defined vehicles. We design and manufacture vehicle components and provide electrical, electronic and active safety technology solutions to the global automotive and commercial vehicle markets. Aptiv is one of the largest vehicle technology suppliers, and its customers include the 25 largest automotive original equipment manufacturers in the world. As of December 31, 2023, we operated 138 major manufacturing facilities and 11 major technical centers, with a presence in 50 countries.
Products
As of December 31, 2023, we operated our core business along two operating segments, grouped on the basis of similar product, market and operating factors:
Signal and Power Solutions. This segment provides complete design, manufacture and assembly of the vehicle’s electrical architecture, including engineered component products, connectors, wiring assemblies and harnesses, cable management, electrical centers and high voltage and safety-critical distribution systems. Core product lines include:
•High quality connectors are engineered primarily for use in automotive and related markets, and also have applications in the industrial, telematics, aerospace, defense and medical sectors.
•Electrical centers provide centralized electrical power and signal distribution and all of the associated circuit protection and switching devices, needed to support the optimization of the overall vehicle electrical system.
•Distribution systems, including 48-volt hybrid and high voltage systems, are integrated into one optimized vehicle electrical system that can utilize smaller cable and gauge sizes and ultra-thin wall insulation.
Advanced Safety and User Experience. This segment provides critical technologies and services to enhance vehicle safety, security, comfort and convenience, including sensing and perception systems, electronic control units, multi-domain controllers, vehicle connectivity systems, cloud-native software platforms, application software, autonomous driving technologies and end-to-end DevOps tools. Core product lines include:
•Advanced Safety primarily consists of solutions that enable advanced safety features and vehicle automation, as well as radar, vision and other sensing technologies.
•User Experience primarily enables in-cabin solutions around infotainment, driver interface and interior sensing solutions.
•Smart Vehicle Compute and Software primarily consists of zone control and centralized computing platforms, as well as edge-to-cloud tools.
Following completion of our due diligence measures, as described below, it was determined that, like many of our peers in the automotive industry, Aptiv’s products contain 3TG materials. Aptiv considers these 3TG materials necessary to the functionality or production of a significant portion of our manufactured products in both of our operating segments. Aptiv has designed and implemented a Conflict Minerals process, including performance of due diligence measures, to be consistent, in all material respects, with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tantalum, tin, tungsten and gold (the “OECD Guidance”).
II. Reasonable Country of Origin Inquiry
We procure our raw materials and components from a variety of suppliers around the world. We rely on our direct suppliers to provide information on the source of the 3TG materials contained in components and materials supplied to us - including sources of 3TG that are supplied to them from upstream suppliers.
In order to understand the sources of 3TG in our supply chain, we performed an RCOI. Aptiv’s RCOI process involved two stages: Supplier RCOI, which was designed and performed in accordance with Step 2A of the OECD Guidance, and Smelter RCOI, which was designed and performed in accordance with Steps 2B, C and D of the OECD Guidance. While we utilize a third party provider to assist us in the survey process and to perform the smelter RCOI, we manage the overall process and engage with suppliers as part of the due diligence process, as further described below.
Supplier RCOI
Aptiv designed its Supplier RCOI process to identify, to the best of its efforts, the smelters of 3TG within Aptiv’s supply chain in accordance with Step 2A of the OECD Guidance. Aptiv conducted a good faith, risk-based applicability assessment of its supply base to identify those suppliers that were reasonably believed to supply products or components to us that may contain 3TG. Aptiv identified the suppliers based on information in its material data system, including the International Material Data System, assessments by Aptiv purchasing and materials personnel and prior year supplier Conflict Minerals Reporting Template (“CMRT”) submissions. Aptiv's supplier RCOI process included surveying the identified relevant suppliers (which represented approximately 1,136 suppliers and/or original manufacturers that supply parts and materials for products manufactured by Aptiv that we believe may contain 3TG). Aptiv’s 2023 RCOI process was designed to include substantially all of the parts and materials necessary to the functionality or production of products manufactured by Aptiv in 2023. Aptiv did not include suppliers of indirect material, such as packaging or office supplies, or providers of services, in its supplier survey.
These relevant suppliers and original manufacturers were contacted, provided with Aptiv’s Conflict Minerals Policy and requested to disclose to us the sources of 3TG materials used in the products sold to us, including smelter information, via the CMRT developed by the Responsible Minerals Initiative (“RMI”). At the same time, we defined and provided instructions regarding the expected due diligence of high risk smelters that may be reported. We reviewed all supplier responses for
completeness and accuracy. For suppliers that did not provide adequate responses, where additional follow-up was needed based on the Company’s internal risk assessment methodology, or if responses were not provided in a timely manner, we actively solicited clarifications and responses.
Our 2023 RCOI and supplier response results represented approximately 97% of the Company’s total Annual Purchase Value (“APV”) from the relevant suppliers. After review of these responses, Aptiv consolidated the supplier responses into a single list of unique smelter names which met the definition of a smelter under one of three industry recognized audit protocols. We then reviewed this listing of smelters and compared it to the RMI list of known smelters in order to determine if we had identified reasonably all of the smelters in our supply chain. As a result of the supplier RCOI process, 347 smelters of 3TG were identified by our suppliers.
The large majority of the CMRT responses received from our suppliers provided data to us at a total company level, and our suppliers were unable to specify the smelters or refiners used for the specific components supplied to us during the reporting period. We are therefore unable to determine whether the 3TGs reported by our suppliers were contained in components or parts supplied to us during the reporting period. We are also unable to verify that all of the 3TG smelters that our suppliers identified were part of our supply chain. Based on the information provided by our suppliers, we made a reasonable good faith effort to collect and evaluate the information concerning 3TG smelters in our supply chain.
Smelter RCOI
Aptiv assessed the country of origin information for the 347 smelters identified by our suppliers, and determined that 51 of these smelters either source, or Aptiv had reason to believe they may source, 3TG from the Covered Countries. Due to the overlap between smelter RCOI and smelter due diligence, our smelter RCOI process is summarized below in the Due Diligence section of this report.
III. Due Diligence Process
Establishment of Strong Company Management Systems (OECD Step 1)
In accordance with Step 1 of the OECD Guidance, Aptiv has established a management system for Conflict Minerals, which includes:
•Company Policies (1A) - Aptiv has adopted a Conflict Minerals Policy which is publicly available at aptiv.com/legal-compliance/policies. Aptiv communicated its policy directly to its suppliers as part of the RCOI process, as further described below.
•Internal Management Team (1B) - We maintain a cross-functional Conflict Minerals Team, supported by external advisors, to support Aptiv's supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program, including compliance activities associated with the Rule. The Conflict Minerals Team periodically reports the status of Aptiv's Conflict Minerals program to a Conflict Minerals Steering Committee comprised of designated senior management members, including the Senior Vice President, Chief Legal Officer, Chief Compliance Officer and Secretary and the Senior Vice President, Supply Chain and Global Real Estate.
•System of Supply Chain Controls and Transparency (1C) - We established a system of controls over the Company's mineral supply chain, including the implementation of a process to collect information to perform the RCOI and due diligence procedures described below, as well as a risk assessment methodology designed to define, identify, mitigate and manage risks. Should a risk arise, it would be reported to the Conflict Minerals Steering Committee.
Aptiv supports an industry-wide approach to addressing social responsibility matters regarding Conflict Minerals. During the 2023 reporting period, Aptiv was an active member in the Responsible Minerals Working Group of the Automotive Industry Action Group (“AIAG”) as well as the Smelter Engagement Team, which regularly contacts non-conformant smelters to encourage participation in the RMAP. We also participate in several subcommittees as an active member of the RMI, which is an initiative of the Responsible Business Alliance. The RMI designed and manages the RMAP to identify the smelters that process 3TG and independently audit those smelters to validate company level management processes for responsible mineral procurement. The data on which we relied for certain statements in this report was obtained through our membership in the RMI, using the RCOI report for members. In addition, we participate in several RMI subgroups to support industry initiatives and keep informed of current and developing issues.
•Supplier Engagement (1D) - Due to our size and the nature of our products, and the corresponding size and depth of our supply chain, it is difficult to identify actors upstream from our direct suppliers. We rely on our suppliers to provide us with information concerning the source and chain of custody of 3TG contained in the products and components they supply. Many of our suppliers are also subject to the Rule, and they rely on information provided by their upstream suppliers. Our standard global contract terms and conditions require suppliers to provide information with respect to the origin of their products supplied to Aptiv. We also communicated with suppliers regarding our Conflict Minerals program, as detailed in this Conflict Minerals Report, which included direct engagement with our suppliers to collect required supplier and smelter RCOI and due diligence data, as further described below. This engagement included providing training to our suppliers on our Conflict Minerals program, if such assistance was requested by a supplier. We continue to maintain and communicate to our suppliers a dedicated email address (conflict.minerals@aptiv.com) to facilitate supplier communication with us regarding Conflict Minerals.
As a downstream entity, we drive responsible sourcing through our supply chain by exercising due diligence over our suppliers’ sourcing of raw materials in their upstream supply chains. We mitigate risks associated with the sourcing of 3TGs by working with our suppliers to identify 3TG smelters and refiners and encouraging those facilities to become RMAP Conformant. We also support broader industry efforts to promote responsible mining and sourcing, as further described above.
•Grievance Mechanism (1E) - We have grievance mechanisms through which our employees and suppliers can report suspected or potential violations of our policies, laws or general ethics or compliance concerns. We maintain an email address (conflict.minerals@aptiv.com) for suppliers to ask questions, voice concerns and report violations with respect to our Conflict Minerals program. Aptiv also maintains a reporting system that allows employees and others to ask questions, voice concerns and report violations with respect to Aptiv policies confidentially and anonymously.
Identification and Assessment of Risks in the Supply Chain (OECD Step 2)
As described in the Reasonable Country of Origin section above, we, with the support of external advisors, surveyed our supply base to identify the smelters in their supply chain, as well as the country of origin, source and chain of custody of 3TGs in order to identify each of the smelters that placed Conflict Minerals into our supply chain, which we believed would facilitate our ability to identify the source and chain of custody of the Conflict Minerals contained in our products. Through our membership in the RMI, we reviewed RMAP information to assist us in determining whether a smelter was sourcing Conflict Minerals in a socially responsible manner, as further described below.
Design and Implement a Strategy to Respond to Risks (OECD Step 3)
In response to the risk assessment described in the foregoing section, Aptiv has an approved risk management process through which the Conflict Minerals program is implemented, managed and monitored. Aptiv performs risk mitigation on any high risk smelter (smelters that are identified as sourcing, or believed to be sourcing, from the Covered Countries) that is not recognized as RMAP Conformant. Aptiv’s risk mitigation process was designed in accordance with Step 3B of the OECD Guidance and is reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee in accordance with Step 3A of the OECD Guidance. If there is reason to believe the smelters subject to Aptiv’s risk mitigation process were directly or indirectly financing or benefiting armed groups in the Covered Countries, Aptiv would initiate action with our suppliers for the removal of this smelter from our supply base, which is consistent with Step 3B of the OECD Guidance and helps prevent unnecessary boycotts of the Covered Countries.
Third Party Audit of Supply Chain Due Diligence (OECD Step 4)
Aptiv is an active RMI member serving on several subcommittees and supports smelter audits through the RMAP.
Annual Reporting on Supply Chain Due Diligence (OECD Step 5)
Aptiv's Form SD and CMR are filed annually with the SEC, and a copy of the CMR is publicly available on the Company’s website in the Financial Information section of the Investors page at ir.aptiv.com.
IV. Due Diligence Performance and Results
In accordance with the Rule’s requirements for 3TGs that are, or Aptiv had reason to believe may be, sourced from the Covered Countries, Aptiv was required to exercise due diligence on the source and chain of custody of these identified 3TG's in accordance with a nationally or internationally recognized due diligence framework.
Aptiv designed its smelter RCOI and due diligence processes in accordance with the applicable sections of Steps 2, 3 and 4 of the OECD Guidance. Based on its assessment of the survey responses received from suppliers as part of its RCOI process, Aptiv performed smelter RCOI and due diligence measures as described below in a manner consistent with the OECD Guidance on the smelters that were identified by our suppliers as potential sources of 3TG in our products.
For each 3TG smelter that was identified by our suppliers as being in Aptiv's supply chain, Aptiv attempted to directly engage the smelter to determine whether or not the smelter sourced from the Covered Countries. For smelters that did not respond to direct engagement, Aptiv reviewed publicly available information to determine if there was any reason to believe that the smelter may have sourced 3TG from the Covered Countries during the reporting period. This information included the most recent report by the United Nations (“U.N.”) Group of Experts on the Democratic Republic of the Congo, publications by non-governmental organizations such as the SWISSAID, Global Witness, the Business and Human Rights Resource Centre and Radio Okapi (the U.N. funded news organization in the conflict region of the DRC) and a search of other publicly available information. For smelters that declared directly (e.g. through correspondence, publicly available Conflict Minerals policy, or information available on their website), or through their relevant industry association, that they did not source from the Covered Countries, and were not recognized as RMAP Conformant, Aptiv reviewed the publicly available information sources listed above to determine if there was any contrary evidence to the smelter’s declaration.
Due Diligence Results
As a result of these procedures, 51 of the 347 smelters identified by our suppliers either source, or Aptiv had reason to believe they may source, 3TG from the Covered Countries. The countries of origin of 3TG from these 51 smelters may include the DRC, Rwanda, Burundi, Tanzania, Uganda and Central African Republic. As described above, this assessment was based on information received directly from the smelters, information received through the RMAP and/or the other public information sources listed above.
In accordance with the Rule’s requirements for 3TGs that are, or Aptiv had reason to believe may be, sourced from the Covered Countries, Aptiv was required to exercise due diligence on these minerals’ source and chain of custody. Of these 51 smelters, 37 smelters were conformant with the RMAP and were accordingly listed on the RMI’s website as RMAP Conformant, meaning that the smelters have been determined to be conformant with the RMAP’s, or an equivalent, independent third party audit program.
The following table categorizes the smelters identified by our suppliers as being in our supply chain by 3TG mineral, those identified as sourcing from the Covered Countries and RMAP status: | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| | Covered Country Sourced | | Non-Covered Country Sourced | | Total Smelters |
| | RMAP Conformant | | RMAP Active | | Not RMAP Conformant | | Total | | RMAP Conformant | | RMAP Active | | Not RMAP Conformant | | Total | |
| Tin | 8 | | | — | | | — | | | 8 | | | 58 | | | 2 | | | 18 | | | 78 | | | 86 | |
| Tantalum | 18 | | | 1 | | | — | | | 19 | | | 14 | | | — | | | 2 | | | 16 | | | 35 | |
| Tungsten | 6 | | | — | | | — | | | 6 | | | 27 | | | — | | | 18 | | | 45 | | | 51 | |
| Gold | 5 | | | — | | | 13 | | | 18 | | | 85 | | | 2 | | | 70 | | | 157 | | | 175 | |
| Total | 37 | | | 1 | | | 13 | | | 51 | | | 184 | | | 4 | | | 108 | | | 296 | | | 347 | |
| | | | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | | | |
All compliance status information in the above table is as of February 6, 2024, and is based solely on information made available by the RMI and listed on the RMI website, without independent verification by us. “Conformant” means that the smelter was listed as conformant with the RMAP assessment protocols. “Active” means that the smelter has committed to undergo an RMAP audit or is participating in one of the cross-recognized certification programs. Smelters not listed as Conformant or Active are classified as “Not Conformant.” Sourcing status information is based on information received directly from the smelters, information received through the RMAP and/or the other public information sources listed above. Included in “Covered Country Sourced” are smelters which Aptiv had reason to believe may source from the Covered Countries, and included in “Non-Covered Country Sourced” are smelters which Aptiv had no reason to believe source from the Covered Countries.
The mines used by these smelters are not publicly available and were not disclosed by these smelters. Through experience gained from participating in the RMI, we have concluded that requiring our suppliers to complete the CMRT and conducting the due diligence process described above represents the most reasonable best effort we can make at this time to identify the mines and countries of origin of 3TGs contained in our products with the greatest possible specificity.
Risk Mitigation
Aptiv conducted risk mitigation on the smelters that were identified as sourcing, or believed to be sourcing, from the Covered Countries and that were not recognized as RMAP Conformant. Aptiv’s risk mitigation was designed in accordance with Step 3B of the OECD Guidance and was reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee in accordance with Step 3A of the OECD Guidance.
Aptiv conducted risk mitigation on 14 total smelters (13 gold and 1 tantalum) that Aptiv had reason to believe may source from the Covered Countries. Based on the information provided by our suppliers, the gold and tantalum provided by these smelters may have been included in products manufactured in 2023 by at least one of our business segments.
Aptiv’s risk mitigation process included performing additional due diligence to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries. This additional due diligence included further review of the publicly available information sources noted above in order to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries, verifying with internal stakeholders and relevant suppliers whether 3TGs from the smelter were actually in Aptiv’s supply chain in the 2023 reporting period and direct engagement with each high risk smelter to verify risk and to encourage the smelter to become RMAP Conformant. As part of our due diligence procedures, we communicated concerns to the applicable suppliers in our supply chain that source from these smelters and encouraged our suppliers to take appropriate action to remove these smelters from their supply chain and to encourage the smelters to become RMAP Conformant.
Continuous Improvement of Supply Chain Due Diligence
The activities undertaken by Aptiv as described in this report have helped to mitigate the risk that the 3TG materials necessary to our products benefited armed groups in the Covered Countries. Going forward, we intend to take the following steps to improve our due diligence process and further mitigate the risk that the 3TG materials necessary to our products benefit armed groups:
▪Continue to refine the supplier lists from all Aptiv entities to ensure relevant suppliers are included;
•Continue to strengthen our engagement with our suppliers regarding Conflict Minerals, and require relevant new suppliers to provide a CMRT;
•Continue to communicate Aptiv’s Conflict Minerals policy and provide training materials to suppliers;
•Continue to expect our suppliers to obtain current, accurate and complete information from their supply chain about their smelters and refiners of Conflict Minerals;
•Encourage all smelters identified as a possible part of our supply chain to be audited and certified to a protocol recognized by the RMAP, particularly those which are sourcing, or believed to be sourcing, from the Covered Countries either directly or indirectly through suppliers and/or relevant industry partnerships, including follow-up in 2024 on smelters that required risk mitigation in 2023;
•Continue to participate in the AIAG, RMI or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance; and
•Expand the expected responsible sourcing behavior to all Conflict Affected and High Risk Areas (CAHRAs).
Additional Risk Factors
The statements within this CMR are based on the RCOI process and due diligence performed in good faith by Aptiv, and are based on the information available at the time. A number of factors could introduce errors or otherwise affect the statements made within. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions in information provided by suppliers, errors or omissions in information provided by smelters, confusion by suppliers over requirements of the SEC final rule, gaps in supplier education and knowledge, errors or omissions in public information, translation of public data, oversights or errors in conflict-free smelter audits, Covered Country-sourced materials being declared secondary materials, illegally tagged Conflict Minerals from Covered Countries being introduced into the supply chain and smuggling of Conflict Minerals from Covered Countries to countries beyond the Covered Countries.
Appendix to the 2023 Conflict Minerals Report of Aptiv PLC
Processing Facilities Identified in Supplier CMRT Responses
The following table lists the name and 3TG of the processing facilities identified in supplier CMRT responses to Aptiv as part of its 2023 reasonable country of origin inquiry as described in the CMR. All information in the following table is based on information made available by the RMI and listed on the RMI website as of February 6, 2024.
| | | | | | | | | |
| 3TG Metal | Standard Smelter Name | Smelter ID | |
| Gold | 8853 S.p.A. | CID002763 | |
| Gold | ABC Refinery Pty Ltd. | CID002920 | |
| Gold | Abington Reldan Metals, LLC | CID002708 | |
| Gold | Advanced Chemical Company | CID000015 | |
| Gold | African Gold Refinery* | CID003185 | |
| Gold | Agosi AG | CID000035 | |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 | |
| Gold | Albino Mountinho Lda. | CID002760 | |
| Gold | Alexy Metals | CID003500 | |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 | |
| Gold | Argor-Heraeus S.A. | CID000077 | |
| Gold | Asahi Pretec Corp. | CID000082 | |
| Gold | Asahi Refining Canada Ltd. | CID000924 | |
| Gold | Asahi Refining USA Inc. | CID000920 | |
| Gold | Asaka Riken Co., Ltd. | CID000090 | |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | |
| Gold | AU Traders and Refiners | CID002850 | |
| Gold | Augmont Enterprises Private Limited | CID003461 | |
| Gold | Aurubis AG | CID000113 | |
| Gold | Bangalore Refinery | CID002863 | |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | |
| Gold | Boliden Ronnskar | CID000157 | |
| Gold | C. Hafner GmbH + Co. KG | CID000176 | |
| Gold | Caridad | CID000180 | |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | |
| Gold | Cendres + Métaux S.A. | CID000189 | |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 | |
| Gold | Chimet S.p.A. | CID000233 | |
| Gold | Chugai Mining | CID000264 | |
| Gold | Coimpa Industrial LTDA | CID004010 | |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 | |
| Gold | Dijllah Gold Refinery FZC | CID003348 | |
| Gold | Dongwu Gold Group | CID003663 | |
| Gold | Dowa | CID000401 | |
| Gold | DSC (Do Sung Corporation) | CID000359 | |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 | |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 | |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 | |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | CID003487 | |
| | | | | | | | | |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | CID003488 | |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | CID003489 | |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | CID003490 | |
| Gold | Emirates Gold DMCC | CID002561 | |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 | |
| Gold | Fujairah Gold FZC | CID002584 | |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | CID002852 | |
| Gold | Gold by Gold Colombia | CID003641 | |
| Gold | Gold Coast Refinery | CID003186 | |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 | |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | |
| Gold | Guangdong Jinding Gold Limited | CID002312 | |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | |
| Gold | Heimerle + Meule GmbH | CID000694 | |
| Gold | Henan Yuguang Gold & Lead Co., Ltd. | CID002519 | |
| Gold | Heraeus Germany GmbH Co. KG | CID000711 | |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 | |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 | |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 | |
| Gold | HwaSeong CJ Co., Ltd. | CID000778 | |
| Gold | Industrial Refining Company | CID002587 | |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | |
| Gold | International Precious Metal Refiners | CID002562 | |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | |
| Gold | Istanbul Gold Refinery | CID000814 | |
| Gold | Italpreziosi | CID002765 | |
| Gold | JALAN & Company | CID002893 | |
| Gold | Japan Mint | CID000823 | |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | |
| Gold | JSC Novosibirsk Refinery | CID000493 | |
| Gold | JSC Uralelektromed* | CID000929 | |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | |
| Gold | K.A. Rasmussen | CID003497 | |
| Gold | Kaloti Precious Metals | CID002563 | |
| Gold | Kazakhmys Smelting LLC | CID000956 | |
| Gold | Kazzinc | CID000957 | |
| Gold | Kennecott Utah Copper LLC | CID000969 | |
| Gold | KGHM Polska Miedź Spółka Akcyjna | CID002511 | |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | |
| Gold | Korea Zinc Co., Ltd. | CID002605 | |
| Gold | Kundan Care Products Ltd. | CID003463 | |
| Gold | Kyrgyzaltyn JSC | CID001029 | |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 | |
| Gold | L'azurde Company For Jewelry | CID001032 | |
| Gold | L'Orfebre S.A. | CID002762 | |
| Gold | Lingbao Gold Co., Ltd. | CID001056 | |
| | | | | | | | | |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | |
| Gold | LS MnM Inc. | CID001078 | |
| Gold | LT Metal Ltd. | CID000689 | |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | |
| Gold | Marsam Metals | CID002606 | |
| Gold | Materion | CID001113 | |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | |
| Gold | MD Overseas | CID003548 | |
| Gold | Metal Concentrators SA (Pty) Ltd. | CID003575 | |
| Gold | Metallix Refining Inc. | CID003557 | |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | |
| Gold | Metalor Technologies S.A. | CID001153 | |
| Gold | Metalor USA Refining Corporation | CID001157 | |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 | |
| Gold | Mitsubishi Materials Corporation | CID001188 | |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | |
| Gold | MKS PAMP S.A. | CID001352 | |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | |
| Gold | Modeltech Sdn Bhd | CID002857 | |
| Gold | Morris and Watson | CID002282 | |
| Gold | Moscow Special Alloys Processing Plant | CID001204 | |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 | |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | |
| Gold | NH Recytech Company | CID003189 | |
| Gold | Nihon Material Co., Ltd. | CID001259 | |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | CID001326 | |
| Gold | Pease & Curren | CID002872 | |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | |
| Gold | Planta Recuperadora de Metales SpA | CID002919 | |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | |
| Gold | PX Précinox S.A. | CID001498 | |
| Gold | QG Refining, LLC | CID003324 | |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 | |
| Gold | REMONDIS PMR B.V. | CID002582 | |
| Gold | Royal Canadian Mint | CID001534 | |
| Gold | SAAMP | CID002761 | |
| Gold | Sabin Metal Corp. | CID001546 | |
| Gold | Safimet S.p.A | CID002973 | |
| Gold | SAFINA A.S. | CID002290 | |
| Gold | Sai Refinery | CID002853 | |
| Gold | Sam Precious Metals | CID003666 | |
| Gold | Samduck Precious Metals | CID001555 | |
| | | | | | | | | |
| Gold | SAMWON Metals Corp. | CID001562 | |
| Gold | SEMPSA Joyería Platería S.A. | CID001585 | |
| Gold | Shandong Gold Smelting Co., Ltd. | CID001916 | |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 | |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CID002750 | |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 | |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 | |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | |
| Gold | Singway Technology Co., Ltd. | CID002516 | |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | |
| Gold | Solar Applied Materials Technology Corp. | CID001761 | |
| Gold | Sovereign Metals | CID003383 | |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 | |
| Gold | Sudan Gold Refinery | CID002567 | |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 | |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 | |
| Gold | T.C.A S.p.A | CID002580 | |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | |
| Gold | TOO Tau-Ken-Altyn | CID002615 | |
| Gold | Torecom | CID001955 | |
| Gold | Umicore Precious Metals Thailand | CID002314 | |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | |
| Gold | United Precious Metal Refining, Inc. | CID001993 | |
| Gold | Valcambi S.A. | CID002003 | |
| Gold | WEEEREFINING | CID003615 | |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 | |
| Gold | WIELAND Edelmetalle GmbH | CID002778 | |
| Gold | Yamakin Co., Ltd. | CID002100 | |
| Gold | Yokohama Metal Co., Ltd. | CID002129 | |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | |
| Gold | Zhongkuang Gold Industry Co., Ltd. | CID002214 | |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | |
| Tantalum | 5D Production OU | CID003926 | |
| Tantalum | AMG Brasil | CID001076 | |
| Tantalum | D Block Metals, LLC | CID002504 | |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | |
| Tantalum | Global Advanced Metals Aizu | CID002558 | |
| Tantalum | Global Advanced Metals Boyertown | CID002557 | |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 | |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | |
| | | | | | | | | |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | |
| Tantalum | KEMET de Mexico | CID002539 | |
| Tantalum | Materion Newton Inc. | CID002548 | |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | |
| Tantalum | Mineração Taboca S.A. | CID001175 | |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 | |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | |
| Tantalum | NPM Silmet AS | CID001200 | |
| Tantalum | PowerX Ltd. | CID004054 | |
| Tantalum | QuantumClean | CID001508 | |
| Tantalum | Resind Indústria e Comércio Ltda. | CID002707 | |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CID003583 | |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 | |
| Tantalum | TANIOBIS Co., Ltd. | CID002544 | |
| Tantalum | TANIOBIS GmbH | CID002545 | |
| Tantalum | TANIOBIS Japan Co., Ltd. | CID002549 | |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | CID002550 | |
| Tantalum | Telex Metals | CID001891 | |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CID000616 | |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | |
| Tin | Alpha | CID000292 | |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | |
| Tin | Aurubis Beerse | CID002773 | |
| Tin | Aurubis Berango | CID002774 | |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 | |
| Tin | China Tin Group Co., Ltd. | CID001070 | |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | CID003486 | |
| Tin | CRM Synergies | CID003524 | |
| Tin | CV Ayi Jaya | CID002570 | |
| Tin | CV Venus Inti Perkasa | CID002455 | |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 | |
| Tin | Dowa | CID000402 | |
| Tin | DS Myanmar | CID003831 | |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | |
| Tin | EM Vinto | CID000438 | |
| Tin | Estanho de Rondônia S.A. | CID000448 | |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | CID003582 | |
| Tin | Fenix Metals | CID000468 | |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 | |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | |
| | | | | | | | | |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 | |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 | |
| Tin | Luna Smelter, Ltd. | CID003387 | |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | |
| Tin | Melt Metais e Ligas S.A. | CID002500 | |
| Tin | Metallic Resources, Inc. | CID001142 | |
| Tin | Mineração Taboca S.A. | CID001173 | |
| Tin | Mining Minerals Resources SARL | CID004065 | |
| Tin | Minsur | CID001182 | |
| Tin | Mitsubishi Materials Corporation | CID001191 | |
| Tin | Modeltech Sdn Bhd | CID002858 | |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | |
| Tin | Novosibirsk Tin Combine | CID001305 | |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | |
| Tin | Operaciones Metalúrgicas S.A. | CID001337 | |
| Tin | Pongpipat Company Limited | CID003208 | |
| Tin | Precious Minerals and Smelting Limited | CID003409 | |
| Tin | PT Aries Kencana Sejahtera | CID000309 | |
| Tin | PT Artha Cipta Langgeng | CID001399 | |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | |
| Tin | PT Babel Inti Perkasa | CID001402 | |
| Tin | PT Babel Surya Alam Lestari | CID001406 | |
| Tin | PT Bangka Prima Tin | CID002776 | |
| Tin | PT Bangka Serumpun | CID003205 | |
| Tin | PT Bangka Tin Industry | CID001419 | |
| Tin | PT Belitung Industri Sejahtera | CID001421 | |
| Tin | PT Bukit Timah | CID001428 | |
| Tin | PT Cipta Persada Mulia | CID002696 | |
| Tin | PT Menara Cipta Mulia | CID002835 | |
| Tin | PT Mitra Stania Prima | CID001453 | |
| Tin | PT Mitra Sukses Globalindo | CID003449 | |
| Tin | PT Panca Mega Persada | CID001457 | |
| Tin | PT Premium Tin Indonesia | CID000313 | |
| Tin | PT Prima Timah Utama | CID001458 | |
| Tin | PT Putera Sarana Shakti (PT PSS) | CID003868 | |
| Tin | PT Rajawali Rimba Perkasa | CID003381 | |
| Tin | PT Rajehan Ariq | CID002593 | |
| Tin | PT Refined Bangka Tin | CID001460 | |
| Tin | PT Sariwiguna Binasentosa | CID001463 | |
| Tin | PT Stanindo Inti Perkasa | CID001468 | |
| Tin | PT Sukses Inti Makmur | CID002816 | |
| Tin | PT Timah Nusantara | CID001486 | |
| Tin | PT Timah Tbk Kundur | CID001477 | |
| Tin | PT Timah Tbk Mentok | CID001482 | |
| | | | | | | | | |
| Tin | PT Tinindo Inter Nusa | CID001490 | |
| Tin | PT Tirus Putra Mandiri | CID002478 | |
| Tin | PT Tommy Utama | CID001493 | |
| Tin | Resind Indústria e Comércio Ltda. | CID002706 | |
| Tin | Rui Da Hung | CID001539 | |
| Tin | Super Ligas | CID002756 | |
| Tin | Thaisarco | CID001898 | |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CID002180 | |
| Tin | Tin Technology & Refining | CID003325 | |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | |
| Tin | VQB Mineral and Trading Group JSC | CID002015 | |
| Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 | |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | |
| Tungsten | A.L.M.T. Corp. | CID000004 | |
| Tungsten | ACL Metais Eireli | CID002833 | |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 | |
| Tungsten | Artek LLC | CID003553 | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CID002641 | |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 | |
| Tungsten | Cronimet Brasil Ltda | CID003468 | |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | CID004060 | |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CID003609 | |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | |
| Tungsten | Global Tungsten & Powders Ltd. | CID000568 | |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 | |
| Tungsten | HANNAE FOR T Co., Ltd. | CID003978 | |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CID003417 | |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CID000769 | |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CID002513 | |
| Tungsten | Hydrometallurg, JSC | CID002649 | |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | |
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | CID003408 | |
| Tungsten | Kennametal Fallon | CID000966 | |
| Tungsten | Kennametal Huntsville | CID000105 | |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 | |
| Tungsten | LLC Vostok | CID003643 | |
| | | | | | | | | |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | |
| Tungsten | Masan High-Tech Materials | CID002543 | |
| Tungsten | Moliren Ltd. | CID002845 | |
| Tungsten | Nam Viet Cromit Joint Stock Company | CID004034 | |
| Tungsten | Niagara Refining LLC | CID002589 | |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 | |
| Tungsten | OOO “Technolom” 1 | CID003614 | |
| Tungsten | OOO “Technolom” 2 | CID003612 | |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CID004430 | |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | CID002542 | |
| Tungsten | Tungsten Vietnam Joint Stock Company | CID003993 | |
| Tungsten | Unecha Refractory Metals Plant | CID002724 | |
| Tungsten | Wolfram Bergbau und Hütten AG | CID002044 | |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CID003662 | |
* The United States Department of the Treasury’s Office of Foreign Assets Control designated African Gold Refinery and JSC Uralelektromed as Specially Designated Nationals on March 17, 2022 and July 20, 2023, respectively. Pursuant to its standard policy, Aptiv complies with all applicable sanctions laws. Aptiv has not identified any direct transactions or contractual relationships with African Gold Refinery or JSC Uralelektromed and, to date, has not received confirmation from any of its suppliers that they utilized African Gold Refinery or JSC Uralelektromed in providing 3TG to Aptiv. Aptiv continues to work with its supply base to ensure compliance with all applicable sanctions laws.
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