UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Medtronic plc
(Exact name of Registrant as Specified in its Charter)
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| Ireland | | 1-36820 | | 98-1183488 |
(State or other jurisdiction
of incorporation) | | (Commission
File Number) | | (IRS Employer
Identification No.) |
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20 On Hatch, Lower Hatch Street
Dublin 2, Ireland | | n/a |
| (Address of principal executive offices) | | (Zip Code) |
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| Karen Parkhill | | 763-514-4000 |
(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:
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| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
INFORMATION TO BE INCLUDED IN THE REPORT
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Medtronic plc (the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2023 to December 31, 2023
A copy of Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and details the due diligence measures undertaken during the reporting period by the Company on a consolidated basis. A copy of the Conflict Minerals Report is also publicly available through the Company’s website: www.medtronic.com (under the “Our Company” caption and “Financials” subcaption).
Item 1.02 Exhibit
The Company has filed, as an exhibit to this Form SD, the Conflict Minerals Report of the Company required by Item 1.01.
Section 2 - Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 - Conflict Minerals Report of the Company
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.
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| | | Medtronic plc |
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| Date: May 23, 2024 | | By | /s/ Karen L. Parkhill |
| | | Karen L. Parkhill |
| | | Executive Vice President and Chief Financial Officer |
EXHIBIT INDEX
Medtronic plc
Form SD
Exhibit 1.01
Medtronic plc
Conflict Minerals Report
For the Year Ended December 31, 2023
Overview
This Conflict Minerals Report (this “Report”) of Medtronic plc (“Medtronic,” the “Company,” “we,” “us,” and “our”) has been prepared by us on a consolidated basis for the reporting period from January 1, 2023 to December 31, 2023 (the “Reporting Period”) pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. Conflict minerals are defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten and gold (often referred to as 3TG) for the purposes of this assessment. The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.
If a registrant knows or has reason to believe that any of the conflict minerals necessary to the functionality or production of their products may have originated in the Covered Countries, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk about the sourcing of our conflict minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities) or these plans may not be effective. In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in the Company’s most recently submitted Quarterly or Annual Reports. Except as required by law, we disclaim any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.
Company Summary
Medtronic plc, headquartered in Dublin, Ireland, is the leading global healthcare technology company. Medtronic was founded in 1949 and today serves healthcare systems, physicians, clinicians, and patients in more than 150 countries worldwide. We remain committed to a mission written by our founder in 1960 that directs us “to contribute to human welfare by the application of biomedical engineering in the research, design, manufacture, and sale of products to alleviate pain, restore health, and extend life.”
Medtronic’s business segments and products for the Reporting Period included:
•The Cardiovascular Portfolio is made up of the Cardiac Rhythm & Heart Failure, Structural Heart & Aortic, and Coronary & Peripheral Vascular divisions. Cardiovascular products include pacemakers, insertable cardiac monitors, cardiac resynchronization therapy devices, implantable cardioverter defibrillators (ICD), leads and delivery systems, ablation products, electrophysiology catheters, products for the treatment of atrial fibrillation, information systems for the management of patients with Cardiac Rhythm & Heart Failure devices, products designed to reduce surgical site infections, coronary and peripheral stents and related delivery systems, balloons and related delivery systems, endovascular stent graft systems, heart valve replacement technologies, cardiac tissue ablation systems, and open heart and coronary bypass grafting surgical products. Cardiovascular also includes Care Management Services and Cath Lab Managed Services (CLMS) within the Cardiac Rhythm & Heart Failure division.
•The Medical Surgical Portfolio is made up of the Surgical Innovations and Respiratory, Gastrointestinal, & Renal divisions. Medical Surgical’s products span the entire continuum of patient care from diagnosis to recovery, with a
focus on diseases of the gastrointestinal tract, lungs, pelvic region, kidneys, obesity, and preventable complications. The products include those for advanced and general surgical products, surgical stapling devices, vessel sealing instruments, wound closure, electrosurgery products, hernia mechanical devices, mesh implants, advanced ablation, interventional lung, ventilators, airway products, renal care products, and sensors and monitors for pulse oximetry, capnography, level of consciousness and cerebral oximetry.
•The Neuroscience Portfolio is made up of the Cranial & Spinal Technologies, Specialty Therapies, and Neuromodulation divisions. Neuroscience's products include various spinal implants, bone graft substitutes, biologic products, image-guided surgery and intra-operative imaging systems, robotic guidance systems used in the robot-assisted spine procedures, and systems that incorporate advanced energy surgical instruments. Neuroscience's products also focus on the treatment of overactive bladder, urinary retention, fecal incontinence, gastroparesis, as well as products to treat ear, nose, and throat (ENT), and therapies to treat the diseases of the vasculature in and around the brain, including coils, neurovascular stents and flow diversion products. Neuroscience also manufactures products related to implantable neurostimulation therapies and drug delivery systems for the treatment of chronic pain, movement disorders, and epilepsy.
•Diabetes' products include insulin pumps, continuous glucose monitoring (CGM) systems, insulin pump consumables, and smart insulin pen systems.
This Report has been prepared by Company management.
Design of Conflict Minerals Program
The Company has designed its conflict minerals program, and the reasonable country of origin inquiry and due diligence measures contained therein, to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2013) and related supplements for gold, tin, tantalum and tungsten. Due to the depth of the Company’s supply chain, the Company is far removed from the sources of ore from which conflict minerals are produced and the smelters and refiners that process those ores, and the Company has limited influence over the behavior of these smelters and refiners. Moreover, because of the geographic diversity and ongoing changes in the Company’s supply chain, the Company often has significant difficulty identifying those suppliers who are further upstream from the Company’s direct suppliers. As a result, the Company’s program was specifically designed to relate to our position in the minerals supply chain as a "downstream" purchaser. Summarized below are the design components of the Company’s conflict minerals program as they relate to the five-step framework from the OECD Guidance:
Step 1. Establish and Maintain Strong Company Management Systems
•Establish and maintain a policy for the sourcing of minerals from the Covered Countries, which is available at https://www.medtronic.com/content/dam/medtronic-com/us-en/corporate/corporate-governance/documents/medtronic-responsible-minerals-policy.pdf
•Maintain continued membership in the Responsible Minerals Initiative (“RMI”).
•Establish a system of controls and transparency through the use of the Conflict Minerals Reporting Template (“CMRT”) as a standard survey tool to identify smelters and refiners.
•Establish and maintain a conflict minerals management structure composed of three teams:
oSteering Committee comprised of the Chief Procurement Officer, Global Supply Management Leadership Team which is responsible for the overall program management of the conflict minerals compliance program, including strategy, governance structure, and oversight through the Supply Management Leadership Team.
oCentral Team comprised of the Director, Responsible Supply Management Program, a Supply Chain Program Manager, a Program Data Analyst, and a legal representative, which is responsible for the overall conflict minerals program design and implementation, including data collection, applicability and supplier review, reasonable country of origin inquiry (“RCOI”), due diligence, audit readiness, and reporting, as well as day-to-day program management; and
oRepresentatives from the Global Supply Management organization who support the work of the Central Team and act as liaisons to the business.
•Update Steering Committee on the status of the conflict minerals program on a quarterly basis.
•Develop and maintain a training document for employees that discusses the highlights of the Rule and the Company’s expectations of its suppliers to assist in complying with the Rule. Employees are trained through materials that are made available on the Company’s intranet site.
•Enable the Company to receive external inquiries and grievances from customers, employees, or other interested parties via the Company’s confidential Voice Your Concern Line at www.VoiceYourConcernLine.com or the conflict minerals e-mail box (rs.conflictminerals@medtronic.com).
•Develop and add a clause to templates for new and renewed supply agreements and to standard purchase order terms and conditions that requires suppliers to provide information about the sourcing of conflict minerals and smelters or refiners and to conduct due diligence on the source and chain of custody for any conflict minerals used in their manufacturing processes.
•Maintain records of the Company’s conflict minerals process for a minimum of five years, in accordance with the OECD Guidance
Step 2. Identify and Assess Risks in the Supply Chain
•Engage with affected suppliers by sending an email notifying them that the Company is subject to the Rule and that their cooperation in responding to a conflict minerals survey is requested.
•Conduct a supply chain survey, based on the CMRT developed by the RMI, of direct suppliers that supply the Company with products or components that may contain necessary conflict minerals.
•Receive and review responses from suppliers that were surveyed.
•Assess the reasonableness of all responses claiming to not use conflict minerals in their manufacturing processes based on internal knowledge of supplies purchased.
•Perform an automated red flag review of all supplier responses.
•Communicate with suppliers on the required corrective actions and request additional information as necessary.
Step 3. Design and Implement a Strategy to Respond to Identified Risks
•Implement a risk management plan that outlines the Company’s responses to identified risks.
•Send reminder letters to each supplier who does not respond to the Company’s initial survey request in an attempt to receive a completed CMRT and work through Category and/or Commodity managers to personally follow up with non-responsive, high-spend suppliers.
•Review supplier responses that claim to source conflict minerals from one or more of the Covered Countries.
•Follow up with suppliers that do not provide a smelter or refiner list or indicate that they do not provide a complete smelter or refiner list to request additional smelter or refiner information.
•Compare a list of unique smelters or refiners received from suppliers who respond that they source conflict minerals from the Covered Countries against conformant, active, and standard smelter or refiner lists per the RMAP for verification of existence and location of the smelters or refiners, as well as the location from which conflict minerals were sourced. Identify smelters or refiners on the RMAP conformant list. For all suppliers who provide unknown or non-RMAP conformant smelters or refiners, continue to work with the supplier to investigate the smelter or refiner and determine the location from which the conflict minerals originated.
•Evaluate facilities listed on CMRTs submitted by suppliers against red flag indicators defined in the OECD Guidance: geographic proximity to the Covered Countries, RMAP audit status, and credible evidence of unethical or conflict sourcing. If facilities meeting these criteria appear on CMRTs submitted by suppliers, the suppliers receive instructions to take risk mitigation actions.
•Send communication to non-conformant smelters and refiners identified in the Company’s supply chain asking them to get audited and become conformant.
•Send communication to direct suppliers who trigger due diligence by indicating sourcing from the Covered Countries reminding them of the Company’s responsible minerals policy and asking them to make every effort to source conflict minerals from the validated sources.
Step 4. Carry Out Independent Third-Party Audit of Smelter or Refiner’s Due Diligence Practices
•The Company is a downstream consumer of necessary conflict minerals and many steps removed from smelters or refiners who provide minerals and ores. The Company does not perform or direct audits of smelters or refiners within its supply chain and relies on the RMAP and its partners to conduct smelter and refiner due diligence.
Step 5. Report Annually on Supply Chain Due Diligence
•This Conflict Minerals Report is annually filed with the U.S. Securities and Exchange Commission. This Conflict Minerals Report is also available at www.medtronic.com (under the “Investors” caption and “SEC Filings” sub caption).
2023 Process
The Company determined that tin, tantalum, tungsten, and gold, often referred to as 3TG, were necessary to the functionality of many of its products. In order to conform to the Rule, the Company then performed a risk-based assessment to determine if the necessary conflict minerals in the products the Company manufactured or contracted to manufacture directly or indirectly financed or benefited armed groups in one or more of the Covered Countries. This risk-based assessment is discussed in further detail in the following sections.
Reasonable Country of Origin Inquiry
In accordance with the Rule, after the Company’s initial determination that conflict minerals were necessary to the functionality of many of its products, the Company conducted a reasonable country of origin inquiry (“RCOI”) to determine whether the Company had reason to believe that any of the conflict minerals necessary to the functionality or production of its products may have originated in the Covered Countries. The Company identified suppliers to survey by reviewing 2023 direct material purchases and applying applicability filters to segment suppliers that supply the Company with products or components that may contain necessary conflict minerals. After identifying the relevant suppliers, the Company then conducted a supply chain survey, based on the current version of the Conflict Minerals Reporting Template (“CMRT”) originally developed by the Conflict Free Sourcing Initiative (“CFSI”), of 190 direct suppliers that supply the Company with products or components that may contain necessary conflict minerals. The Company utilized a third-party web-based software platform and analysis system to conduct this supply chain survey. The suppliers surveyed represented all suppliers determined to be in-scope for 2023 based on the Company’s applicability filters, as mentioned above.
The Company received 178 responses from suppliers that were surveyed, representing a 94% response rate and 94% of all spend surveyed. The Company sent up to three reminder letters to each supplier who did not respond to the Company’s initial survey request in an attempt to receive a completed CMRT and worked through relationship managers to personally follow up with non-responsive, high-spend suppliers.
Of the 178 responses, 59 suppliers either claimed to source conflict minerals from one or more of the Covered Countries or provided information that caused the Company to reasonably believe that the supplier sourced conflict minerals from one or more of the Covered Countries. In addition, 11 suppliers identified using high-risk smelters that source from CAHRA’s, but not from Covered Countries. As a result, the Company has reason to believe that necessary conflict minerals in its products may have originated in the Covered Countries.
Red Flag Review
The Company performed an automated red flag review of all supplier responses. Each facility that met the RMI definition of a smelter or refiner of a 3TG mineral was assessed according to red flag indicators defined in the OECD Guidance. The three factors evaluated to determine the level of risk that each smelter poses to the supply chain are:
•Geographic proximity to the Covered Countries.
•RMAP audit status; and
•Credible evidence of unethical or conflict sourcing.
Based on these criteria the following facilities have been identified with red-flag risks in their supply chain:
•African Gold Refinery - CID003185 - Uganda
•Artek LLC - CID003553 - Russian Federation
•AU Traders and Refiners - CID002850 - South Africa
•Emirates Gold DMCC - CID002561 - United Arab Emirates
•Fidelity Printers and Refiners Ltd. - CID002515 - Zimbabwe
•Gejiu Kai Meng Industry and Trade LLC - CID000942 - China
•Gejiu Zili Mining and Metallurgy Co., Ltd. - CID000555 - China
•GGC Gujrat Gold Centre Pvt. Ltd. - CID002852 - India
•Hunan Jintai New Material Co., Ltd. - CID000769 - China
•Hydrometallurg, JSC - CID002649 - Russian Federation
•Industrial Refining Company - CID002587 - Belgium
•JSC "Kirovgrad Hard Alloys Plant" - CID003408 - Russian Federation
•JSC Ekaterinburg Non-Ferrous Metal Processing Plant - CID000927 - Russian Federation
•JSC Novosibirsk Refinery - CID000493 - Russian Federation
•JSC Uralelectromed - CID000929 - Russian Federation
•KalotPrecious Metals - CID002563 - United Arab Emirates
•Kyshtym Copper-Electrolytic Plant ZAO - CID002865 - Russian Federation
•Lingbao Gold Co., Ltd. - CID001056 - China
•LLC Vostok - CID003643 - Russian Federation
•Moliren Ltd. - CID002845 - Russian Federation
•Moscow Special Alloys Processing Plant - CID001204 - Russian Federation
•Novosibirsk Tin Combine - CID001305 - Russian Federation
•NPP Tyazhmetprom LLC - CID003416 - Russian Federation
•OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) - CID001326 - Russian Federation
•OOO “Technolom” 1 - CID003614 - Russian Federation
•OOO “Technolom” 2 - CID003612 - Russian Federation
•Pongpipat Company Limited - CID003208 - Myanmar
•Prioksky Plant of Non-Ferrous Metals - CID001386 - Russian Federation
•PT Panca Mega Persada - CID001457 - Indonesia
•Samduck Precious Metals - CID001555 - Korea, Republic Of
•Singway Technology Co., Ltd. - CID002516 - Taiwan, Province Of China
•SOE Shyolkovsky Factory of Secondary Precious Metals - CID001756 - Russian Federation
•Solikamsk Magnesium Works OAO - CID001769 - Russian Federation
•Sudan Gold Refinery - CID002567 - Sudan
•Umicore Precious Metals Thailand - CID002314 - Thailand
•Unecha Refractory metals plant - CID002724 - Russian Federation
•VQB Mineral and Trading Group JSC - CID002015 - Viet Nam
•Yunnan Copper Industry Co., Ltd. - CID000197 - China
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Submissions that included any of the above facilities immediately produced a return email instructing the supplier to take their own risk mitigation actions and to escalate this matter up within the supplier in order to work to remove these red flag smelters or refiners from their supply chain.
Due Diligence Measures Performed
Following the Company’s RCOI, the Company performed the following measures to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in the Company’s products which the Company has reason to believe may have originated from the Covered Countries:
•Reviewed supplier responses that claimed to source conflict minerals from one or more of the Covered Countries (59 out of 178 completed supplier responses) and compiled initial list of smelters and refiners provided by such suppliers.
•Followed up with suppliers that claimed to source, or provided information that caused the Company to reasonably believe that the supplier sourced, conflict minerals from one or more of the Covered Countries but did not provide a smelter or refiner list or indicated that they did not provide a complete smelter or refiner list to request additional smelter or refiner information.
•Compared a list of 522 potential unique smelters or refiners received from the above suppliers against conformant, active, and legitimate smelter or refiner lists per the RMAP for verification of existence and location of the smelters or refiners, as well as the location from which conflict minerals were sourced.
•Identified 225 smelters or refiners on the RMAP conformant list and 9 smelters on the RMAP active list.
•For all suppliers who provided non-RMAP conformant or non-RMAP active smelters or refiners (102 suppliers), the Company reached out to them and asked them to work with their smelters and encourage them to become RMAP conformant.
Results of Due Diligence Measures
As a downstream purchaser of products which contain conflict minerals, the Company’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. The Company’s due diligence processes are based on the necessity of seeking data from direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. The Company also relies, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information due to, among other reasons, gaps in supplier or smelter data, errors or omissions in information provided by suppliers or smelters, or misunderstandings by suppliers or smelters regarding the SEC requirements.
Per the Company’s supply chain survey, 59 of the Company’s suppliers claimed to source, or provided information that caused the Company to reasonably believe that the supplier sourced, conflict minerals from one or more of the Covered Countries.
Suppliers identified 522 potential smelter and refiner facilities that may process the necessary conflict minerals contained in the materials provided to the Company. Of those facilities:
•225 are listed as “conformant” on the RMAP list, meaning that they are conformant with the RMAP assessment protocols.
•9 are listed as “active” on the RMAP list, meaning that they have committed to undergo a RMAP audit or are participating in a cross-recognized certification program.
•120 are included on the RMAP list, but are not listed as “conformant” or “active”; and
•after comparing the remaining 168 names to the RMAP database, the Company was unable to determine that these were valid smelter names.
A listing of the known smelters and refiners identified by the Company’s suppliers is included in Annex I below. Not all of the included smelters and refiners may have processed the necessary conflict minerals contained in the Company’s products. In some cases, suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their respective suppliers, the decision of such suppliers to provide information on a company-wide level rather than a product-based level, or for other reasons. The smelters and refiners listed in Annex I may not be all of the smelters and refiners in the Company’s supply chain, since certain suppliers were unable to identify the smelters and refiners of some of the necessary conflict minerals content contained in our products and because not all suppliers responded to our inquiries.
The RMAP-conformant smelters disclosed that, in addition to sourcing from recycled or scrap sources, they have sourced materials from L1, L2 and L3 countries, as well as from the Democratic Republic of the Congo. L1 and L2 countries are, respectively, countries with known active ore production that are not identified as conflict regions or plausible countries of smuggling or export of conflict minerals and countries that are known or plausible countries for smuggling, export out of L3 countries, or transit of materials containing conflict minerals. The L3 countries consist of the Covered Countries. The smelters that are not listed as “conformant” on the RMAP list disclosed that, in addition to sourcing from recycled or scrap sources, they have sourced materials from China, Australia, Canada, Indonesia, Peru, Bolivia, the United States of America and the L1 countries; however, many smelters did not provide specific country of origin data, and, as a result, this list is likely incomplete. The smelters that are not listed as “conformant” on the RMAP list did not disclose any mines located in the Covered Countries. An aggregate listing of all known countries of origin for sourced materials is included in Annex II below.
Compared to the 2022 reporting year, the Company observed the following changes through the analysis of RCOI and source and chain of custody due diligence data for the 2023 reporting year:
•There was an increase in the number of suppliers reporting high risk smelters or refiners from 63 to 70 due to the addition of 8 non-conformant smelters sourcing from CAHRAs.
•We saw an increase in the total number of smelters reported (from 468 to 522) and an increase in the number of non-legitimate smelter entities (126 to 168).
•11 suppliers identified using high-risk smelters or refiners that source 3TGs from CAHRAs but not from the Covered Countries.
Independent Private Sector Audit
The Company does not have sufficient information to determine whether its products are “DRC conflict free.” As such, an independent private sector audit is not required at this time.
Continuous Improvement
The Company took the following steps, among others, to mature its conflict minerals program, including its RCOI and due diligence measures, in accordance with OECD Guidance and to further mitigate the risk that the conflict minerals contained in its products finance or benefit armed groups in the Covered Countries:
•Continued to partner with a third-party software and service provider with extensive expertise in turn-key conflict minerals services.
•Shared all due diligence results with the Steering Committee who demonstrated awareness and concern, as well as responsiveness to the risks identified in the due diligence.
•Engaged with suppliers by directing them to training resources to increase the response rate and improve the quality of the supplier survey responses.
•Reached out to smelters and refiners within the Company’s supply chain who are not currently on the RMAP list and encouraged them to become conformant.
•Reached out to suppliers who indicated that they source conflict minerals from the Covered Countries to reiterate the Company’s policy and ask them to apply every effort to use only conformant sources of conflict minerals.
•Worked with non-responsive suppliers through follow-up letters and direct outreach by commodity managers to educate suppliers and facilitate responses.
•Created a process to receive external inquiries and grievances from customers, employees, or other interested parties.
•Participated in multiple webinars and conferences.
•Maintained membership in RMI since 2015, which provides the Company with the ability to participate in shaping industry policies regarding conflict minerals, a forum for engagement with stakeholder groups related to conflict minerals, and access to data regarding those facilities that are validated through the RMI.
The Company expects to take the following steps as part of continuous improvement:
•Review Conflict Minerals governance and participation of the Steering Committee.
•Work to further mature the Company’s conflict minerals program and build transparency over its supply chain in accordance with the OECD Guidance.
•Continue to evaluate the Company’s suppliers in order to determine those suppliers that are in-scope and should be surveyed as part of the Company’s conflict minerals program.
•Continue to drive our suppliers to obtain current, accurate, and complete information from their supply chain about their smelters and refiners of conflict minerals.
•Further focus on the analysis of supplier responses and maturing the Company’s due diligence efforts and procedures for suppliers that report to source from one or more of the Covered Countries, specifically at the smelter or refiner and component level.
•Increase the Company’s focus on conflict minerals compliance on high-risk and high-spend suppliers.
Annex I
Smelters and Refiners RY2023
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| Metal | Smelter Name | Smelter Facility Location | Smelter ID | RMAP Audit Status |
| Tungsten | A.L.M.T. Corp. | Japan | CID000004 | Conformant |
| Gold | Advanced Chemical Company | United States of America | CID000015 | Active |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 | Conformant |
| Gold | Agosi AG | Germany | CID000035 | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 | Conformant |
| Gold | Argor-Heraeus S.A. | Switzerland | CID000077 | Conformant |
| Gold | Asahi Pretec Corp. | Japan | CID000082 | Conformant |
| Gold | Asaka Riken Co., Ltd. | Japan | CID000090 | Conformant |
| | | | | | | | | | | | | | |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | CID000103 | Outreach Required |
| Tungsten | Kennametal Huntsville | United States of America | CID000105 | Conformant |
| Gold | Aurubis AG | Germany | CID000113 | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 | Conformant |
| Gold | Boliden AB | Sweden | CID000157 | Conformant |
| Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 | Conformant |
| Gold | Caridad | Mexico | CID000180 | Outreach Required |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 | Conformant |
| Gold | Cendres + Metaux S.A. | Switzerland | CID000189 | Non Conformant |
| Gold | Yunnan Copper Industry Co., Ltd. | China | CID000197 | Outreach Required |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 | Conformant |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 | Conformant |
| Gold | Chimet S.p.A. | Italy | CID000233 | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 | Conformant |
| Gold | Chugai Mining | Japan | CID000264 | Conformant |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | CID000281 | Outreach Required |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | CID000291 | Conformant |
| Tin | Alpha | United States of America | CID000292 | Conformant |
| Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309 | Conformant |
| Tin | PT Premium Tin Indonesia | Indonesia | CID000313 | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | CID000343 | Outreach Required |
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359 | Conformant |
| Gold | Dowa | Japan | CID000401 | Conformant |
| Tin | Dowa | Japan | CID000402 | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 | Conformant |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 | Conformant |
| Tin | Estanho de Rondonia S.A. | Brazil | CID000448 | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | China | CID000460 | Conformant |
| Tin | Fenix Metals | Poland | CID000468 | Conformant |
| Gold | JSC Novosibirsk Refinery | Russian Federation | CID000493 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Refinery of Seemine Gold Co., Ltd. | China | CID000522 | Outreach Required |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 | Conformant |
| Tin | Gejiu Zili Mining and Metallurgy Co., Ltd. | China | CID000555 | Non Conformant |
| Tungsten | Global Tungsten & Powders LLC | United States of America | CID000568 | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | CID000616 | Conformant |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | CID000651 | Outreach Required |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | CID000671 | Outreach Required |
| Gold | LT Metal Ltd. | Korea, Republic Of | CID000689 | Conformant |
| | | | | | | | | | | | | | |
| Gold | Heimerle + Meule GmbH | Germany | CID000694 | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | Germany | CID000711 | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | CID000767 | Outreach Required |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | CID000769 | Non Conformant |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773 | Outreach Required |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | CID000778 | Communication Suspended - Not Interested |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 | Conformant |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 | Conformant |
| Gold | Istanbul Gold Refinery | Turkey | CID000814 | Conformant |
| Gold | Japan Mint | Japan | CID000823 | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | China | CID000855 | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 | Conformant |
| Gold | Asahi Refining USA Inc. | United States of America | CID000920 | Conformant |
| Gold | Asahi Refining Canada Ltd. | Canada | CID000924 | Conformant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927 | RMI Due Diligence Review - Unable to Proceed |
| Gold | JSC Uralelectromed | Russian Federation | CID000929 | RMI Due Diligence Review - Unable to Proceed |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 | Conformant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | CID000942 | Non Conformant |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | CID000956 | Outreach Required |
| Gold | Kazzinc | Kazakhstan | CID000957 | Conformant |
| Tungsten | Kennametal Fallon | United States of America | CID000966 | Conformant |
| Gold | Kennecott Utah Copper LLC | United States of America | CID000969 | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 | Conformant |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | CID001029 | Non Conformant |
| Gold | L'azurde Company for Jewelry | Saudi Arabia | CID001032 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Lingbao Gold Co., Ltd. | China | CID001056 | Outreach Required |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | CID001058 | Outreach Required |
| Tin | China Tin Group Co., Ltd. | China | CID001070 | Conformant |
| Tantalum | AMG Brasil | Brazil | CID001076 | Conformant |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078 | Conformant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093 | Outreach Required |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 | Conformant |
| Gold | Materion | United States of America | CID001113 | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 | Conformant |
| | | | | | | | | | | | | | |
| Tin | Metallic Resources, Inc. | United States of America | CID001142 | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 | Conformant |
| Gold | Metalor Technologies S.A. | Switzerland | CID001153 | Conformant |
| Gold | Metalor USA Refining Corporation | United States of America | CID001157 | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | CID001173 | Conformant |
| Tantalum | Mineracao Taboca S.A. | Brazil | CID001175 | Conformant |
| Tin | Minsur | Peru | CID001182 | Conformant |
| Gold | Mitsubishi Materials Corporation | Japan | CID001188 | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | CID001191 | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 | Conformant |
| Tantalum | NPM Silmet AS | Estonia | CID001200 | Conformant |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236 | Conformant |
| Gold | Nihon Material Co., Ltd. | Japan | CID001259 | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 | Conformant |
| Tin | Novosibirsk Tin Combine | Russian Federation | CID001305 | RMI Due Diligence Review - Unable to Proceed |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 | Conformant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 | RMI Due Diligence Review - Unable to Proceed |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State | CID001337 | Conformant |
| Gold | MKS PAMP SA | Switzerland | CID001352 | Conformant |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | CID001362 | Outreach Required |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 | RMI Due Diligence Review - Unable to Proceed |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 | Conformant |
| Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 | Conformant |
| Tin | PT Babel Inti Perkasa | Indonesia | CID001402 | Conformant |
| Tin | PT Babel Surya Alam Lestari | Indonesia | CID001406 | Conformant |
| Tin | PT Bangka Tin Industry | Indonesia | CID001419 | Active |
| | | | | | | | | | | | | | |
| Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421 | Conformant |
| Tin | PT Bukit Timah | Indonesia | CID001428 | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | CID001453 | Conformant |
| Tin | PT Panca Mega Persada | Indonesia | CID001457 | Outreach Required |
| Tin | PT Prima Timah Utama | Indonesia | CID001458 | Conformant |
| Tin | PT Refined Bangka Tin | Indonesia | CID001460 | Conformant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463 | Conformant |
| Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 | Conformant |
| Tin | PT Timah Tbk Kundur | Indonesia | CID001477 | Conformant |
| Tin | PT Timah Tbk Mentok | Indonesia | CID001482 | Conformant |
| Tin | PT Timah Nusantara | Indonesia | CID001486 | Conformant |
| Tin | PT Tinindo Inter Nusa | Indonesia | CID001490 | Conformant |
| Tin | PT Tommy Utama | Indonesia | CID001493 | Conformant |
| Gold | PX Precinox S.A. | Switzerland | CID001498 | Conformant |
| Tantalum | QuantumClean | United States of America | CID001508 | Conformant |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 | Conformant |
| Gold | Royal Canadian Mint | Canada | CID001534 | Conformant |
| Tin | Rui Da Hung | Taiwan, Province of China | CID001539 | Conformant |
| Gold | Sabin Metal Corp. | United States of America | CID001546 | Communication Suspended - Not Interested |
| Gold | Samduck Precious Metals | Korea, Republic Of | CID001555 | Non Conformant |
| Gold | Samwon Metals Corp. | Korea, Republic Of | CID001562 | Communication Suspended - Not Interested |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 | Conformant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619 | Outreach Required |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 | Conformant |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China | CID001761 | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 | Conformant |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province of China | CID001810 | Outreach Required |
| Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 | Conformant |
| Tantalum | Telex Metals | United States of America | CID001891 | Conformant |
| Tin | Thaisarco | Thailand | CID001898 | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 | Non Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | CID001909 | Outreach Required |
| Gold | Shandong Gold Smelting Co., Ltd. | China | CID001916 | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 | Conformant |
| | | | | | | | | | | | | | |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | CID001947 | Outreach Required |
| Gold | Torecom | Korea, Republic Of | CID001955 | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 | Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 | Conformant |
| Gold | United Precious Metal Refining, Inc. | United States of America | CID001993 | Conformant |
| Gold | Valcambi S.A. | Switzerland | CID002003 | Conformant |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | CID002015 | Outreach Required |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 | Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 | Conformant |
| Gold | Yamakin Co., Ltd. | Japan | CID002100 | Conformant |
| Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180 | Conformant |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 | Conformant |
| Gold | Morris and Watson | New Zealand | CID002282 | Outreach Required |
| Gold | SAFINA A.S. | Czechia | CID002290 | Conformant |
| Gold | Guangdong Jinding Gold Limited | China | CID002312 | Outreach Required |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313 | Communication Suspended - Not Interested |
| Gold | Umicore Precious Metals Thailand | Thailand | CID002314 | Non Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 | Conformant |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 | Conformant |
| Tin | CV Venus Inti Perkasa | Indonesia | CID002455 | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 | Conformant |
| Tin | PT Tirus Putra Mandiri | Indonesia | CID002478 | Communication Suspended - Not Interested |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 | Conformant |
| Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 | Non Conformant |
| | | | | | | | | | | | | | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502 | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 | Conformant |
| Tantalum | D Block Metals, LLC | United States of America | CID002504 | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | CID002505 | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 | Conformant |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513 | Conformant |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province of China | CID002516 | Non Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 | Conformant |
| Gold | Shandong Humon Smelting Co., Ltd. | China | CID002525 | Outreach Required |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | CID002527 | Outreach Required |
| Tantalum | KEMET de Mexico | Mexico | CID002539 | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002542 | Conformant |
| Tungsten | Masan High-Tech Materials | Viet Nam | CID002543 | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | CID002544 | Conformant |
| Tantalum | TANIOBIS GmbH | Germany | CID002545 | Conformant |
| Tantalum | Materion Newton Inc. | United States of America | CID002548 | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | CID002549 | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002550 | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 | Conformant |
| Tantalum | Global Advanced Metals Boyertown | United States of America | CID002557 | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | CID002558 | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 | Non Conformant |
| Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 | Non Conformant |
| Gold | International Precious Metal Refiners | United Arab Emirates | CID002562 | Outreach Required |
| Gold | Kaloti Precious Metals | United Arab Emirates | CID002563 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Sudan Gold Refinery | Sudan | CID002567 | Outreach Required |
| Tin | CV Ayi Jaya | Indonesia | CID002570 | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | CID002572 | Non Conformant |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002573 | Outreach Required |
| | | | | | | | | | | | | | |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574 | Outreach Required |
| Gold | T.C.A S.p.A | Italy | CID002580 | Conformant |
| Gold | REMONDIS PMR B.V. | Netherlands | CID002582 | Conformant |
| Gold | Fujairah Gold FZC | United Arab Emirates | CID002584 | Outreach Required |
| Gold | Industrial Refining Company | Belgium | CID002587 | Non Conformant |
| Gold | Shirpur Gold Refinery Ltd. | India | CID002588 | Outreach Required |
| Tungsten | Niagara Refining LLC | United States of America | CID002589 | Conformant |
| Tin | PT Rajehan Ariq | Indonesia | CID002593 | Conformant |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 | Conformant |
| Gold | Marsam Metals | Brazil | CID002606 | Non Conformant |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615 | Conformant |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | CID002641 | Conformant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 | RMI Due Diligence Review - Unable to Proceed |
| Tin | PT Cipta Persada Mulia | Indonesia | CID002696 | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | CID002703 | Outreach Required |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707 | Conformant |
| Gold | Abington Reldan Metals, LLC | United States of America | CID002708 | Conformant |
| Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 | Non Conformant |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China | CID002750 | Outreach Required |
| Tin | Super Ligas | Brazil | CID002756 | Conformant |
| Gold | Albino Mountinho Lda. | Portugal | CID002760 | Outreach Required |
| Gold | SAAMP | France | CID002761 | Non Conformant |
| Gold | L'Orfebre S.A. | Andorra | CID002762 | Conformant |
| Gold | 8853 S.p.A. | Italy | CID002763 | Non Conformant |
| Gold | Italpreziosi | Italy | CID002765 | Conformant |
| Tin | Aurubis Beerse | Belgium | CID002773 | Conformant |
| Tin | Aurubis Berango | Spain | CID002774 | Conformant |
| Tin | PT Bangka Prima Tin | Indonesia | CID002776 | Conformant |
| Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 | Conformant |
| Tin | PT Sukses Inti Makmur | Indonesia | CID002816 | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 | Conformant |
| Tungsten | ACL Metais Eireli | Brazil | CID002833 | Non Conformant |
| Tin | PT Menara Cipta Mulia | Indonesia | CID002835 | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | CID002844 | Conformant |
| Tungsten | Moliren Ltd. | Russian Federation | CID002845 | RMI Due Diligence Review - Unable to Proceed |
| Gold | AU Traders and Refiners | South Africa | CID002850 | Non Conformant |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | CID002852 | Non Conformant |
| Gold | Sai Refinery | India | CID002853 | Outreach Required |
| Gold | Modeltech Sdn Bhd | Malaysia | CID002857 | Non Conformant |
| | | | | | | | | | | | | | |
| Tin | Modeltech Sdn Bhd | Malaysia | CID002858 | Non Conformant |
| Gold | Bangalore Refinery | India | CID002863 | Active |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | CID002867 | Outreach Required |
| Gold | Pease & Curren | United States of America | CID002872 | Communication Suspended - Not Interested |
| Gold | JALAN & Company | India | CID002893 | Outreach Required |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918 | Conformant |
| Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 | Conformant |
| Gold | ABC Refinery Pty Ltd. | Australia | CID002920 | Outreach Required |
| Gold | Safimet S.p.A | Italy | CID002973 | Non Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 | Conformant |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153 | Outreach Required |
| Gold | African Gold Refinery | Uganda | CID003185 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Gold Coast Refinery | Ghana | CID003186 | Outreach Required |
| Gold | NH Recytech Company | Korea, Republic Of | CID003189 | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 | Conformant |
| Tin | PT Bangka Serumpun | Indonesia | CID003205 | Conformant |
| Tin | Pongpipat Company Limited | Myanmar | CID003208 | Outreach Required |
| Gold | QG Refining, LLC | United States of America | CID003324 | Outreach Required |
| Tin | Tin Technology & Refining | United States of America | CID003325 | Conformant |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | CID003348 | Outreach Required |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | CID003356 | Non Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | CID003379 | Non Conformant |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381 | Conformant |
| Gold | CGR Metalloys Pvt Ltd. | India | CID003382 | Outreach Required |
| Gold | Sovereign Metals | India | CID003383 | Outreach Required |
| Tin | Luna Smelter, Ltd. | Rwanda | CID003387 | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province of China | CID003407 | Conformant |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408 | RMI Due Diligence Review - Unable to Proceed |
| Tin | Precious Minerals and Smelting Limited | India | CID003409 | Active |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 | Outreach Required |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | CID003416 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | CID003417 | Conformant |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | CID003424 | Conformant |
| | | | | | | | | | | | | | |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | CID003425 | Conformant |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427 | Non Conformant |
| Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449 | Conformant |
| Gold | Augmont Enterprises Private Limited | India | CID003461 | Non Conformant |
| Gold | Kundan Care Products Ltd. | India | CID003463 | Outreach Required |
| Tungsten | Cronimet Brasil Ltda | Brazil | CID003468 | Conformant |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486 | Conformant |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | CID003487 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | CID003488 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | CID003489 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | CID003490 | Outreach Required |
| Gold | K.A. Rasmussen | Norway | CID003497 | Outreach Required |
| Gold | Alexy Metals | United States of America | CID003500 | Non Conformant |
| Tin | CRM Synergies | Spain | CID003524 | Conformant |
| Gold | MD Overseas | India | CID003548 | Outreach Required |
| Tungsten | Artek LLC | Russian Federation | CID003553 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Metallix Refining Inc. | United States of America | CID003557 | Outreach Required |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | CID003575 | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 | Conformant |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583 | Conformant |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | CID003609 | Conformant |
| Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | OOO “Technolom” 1 | Russian Federation | CID003614 | RMI Due Diligence Review - Unable to Proceed |
| Gold | WEEEREFINING | France | CID003615 | Conformant |
| Gold | Gold by Gold Colombia | Colombia | CID003641 | Conformant |
| Tungsten | LLC Vostok | Russian Federation | CID003643 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | CID003662 | Outreach Required |
| Gold | Dongwu Gold Group | China | CID003663 | Outreach Required |
| Gold | Sam Precious Metals | United Arab Emirates | CID003666 | Outreach Required |
| Tin | DS Myanmar | Myanmar | CID003831 | Conformant |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | CID003868 | Conformant |
| Tantalum | 5D Production OU | Estonia | CID003926 | Outreach Required |
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | CID003978 | Outreach Required |
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | CID003993 | Conformant |
| Gold | Coimpa Industrial LTDA | Brazil | CID004010 | Conformant |
| | | | | | | | | | | | | | |
| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | CID004034 | Outreach Required |
| Tantalum | PowerX Ltd. | Rwanda | CID004054 | Conformant |
| Tungsten | MALAMET SMELTING SDN. BHD. | Malaysia | CID004056 | Outreach Required |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | CID004060 | Outreach Required |
| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic of The | CID004065 | Conformant |
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan, Province of China | CID004397 | Conformant |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | CID004403 | Active |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | CID004430 | Conformant |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | CID004434 | In Communication |
| Gold | GG Refinery Ltd. | Tanzania, United Republic Of | CID004506 | Active |
| Gold | Impala Refineries – Base Metals Refinery (BMR) | South Africa | CID004604 | Active |
| Gold | Impala Rustenburg | South Africa | CID004610 | Active |
| Tungsten | Kenee Mining Corporation Vietnam | Viet Nam | CID004619 | Active |
Annex II
Countries of Origin RY2023
| | |
| Andorra |
| Australia |
| Austria |
| Belgium |
| Bolivia (Plurinational State Of) |
| Brazil |
| Canada |
| Chile |
| China |
| Colombia |
| Congo, Democratic Republic of The |
| Czechia |
| Estonia |
| France |
| Germany |
| Ghana |
| India |
| Indonesia |
| Italy |
| Japan |
| Kazakhstan |
| Korea, Republic Of |
| | |
| Kyrgyzstan |
| Lithuania |
| Malaysia |
| Mauritania |
| Mexico |
| Myanmar |
| Netherlands |
| New Zealand |
| North Macedonia |
| Norway |
| Peru |
| Philippines |
| Poland |
| Portugal |
| Russian Federation |
| Rwanda |
| Saudi Arabia |
| Singapore |
| South Africa |
| Spain |
| Sudan |
| Sweden |
| Switzerland |
| Taiwan, Province of China |
| Tanzania, United Republic Of |
| Thailand |
| Turkey |
| Uganda |
| United Arab Emirates |
| United Kingdom of Great Britain and Northern Ireland |
| United States of America |
| Uzbekistan |
| Viet Nam |
| Zimbabwe |
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