Exhibit 1.01
Conflict Minerals Report
Becton, Dickinson and Company has included this Conflict Minerals Report as an exhibit to its Form SD for 2017, as contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 15, 2018.
The term “BD,” “we,” “us” and “our” refer to Becton, Dickinson and Company and its consolidated subsidiaries for or at the end of 2017. Except where indicated or the context indicates otherwise, these references include C.R. Bard, Inc. (“Bard”), which is discussed further below. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin, and tungsten, without regard to the location of origin of the minerals or derivative metals. The “Conflict Affected Region” is defined as the Democratic Republic of the Congo and its adjacent countries, which include Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
Overview
BD is a global medical technology company engaged in the development, manufacture and sale of a broad range of medical supplies, devices, laboratory equipment and diagnostic products used by healthcare institutions, life science researchers, clinical laboratories, the pharmaceutical industry and the general public. BD’s products are manufactured and sold worldwide. On December 29, 2017, BD completed its acquisition of C.R. Bard, Inc. (“Bard”), which previously was a public company required to file periodic reports under the Exchange Act. Bard is a leading multinational developer, manufacturer and marketer of innovative, life-enhancing medical technologies in the fields of vascular, urology, oncology and surgical specialty products. This Conflict Minerals Report includes Bard for 2017. BD and Bard’s 3TG compliance programs are being integrated in 2018. The separate 3TG compliance programs for BD and Bard had many similar elements, although not all of the program elements discussed herein were part of both programs for 2017.
BD is subject to the Conflict Minerals Rule because, for 2017, certain of the raw materials and components contained in some of the products that we manufactured or contracted to manufacture contained 3TG that were necessary to the functionality or production of the products. Many of our products do not contain any 3TG or are otherwise not in-scope for purposes of our Conflict Minerals Rule compliance.
We do not directly source 3TG from mines, smelters, or refiners, and we believe that we are many levels removed from these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below.
Our Conflict Minerals Policies
As separate companies, BD and Bard had separate conflict minerals policies, as described below. In 2018, we intend to introduce an updated Conflict Minerals Policy that applies to all of our applicable business units.
BD. BD expects its suppliers and subcontractors to source responsibly, respect human rights, and not contribute to conflict.
Without limiting the foregoing, BD expects that its suppliers and subcontractors will not knowingly source 3TG from sources that directly or indirectly finance or benefit armed groups in the Conflict Affected Region. In furtherance of this expectation and BD’s obligations under the Conflict Minerals Rule, applicable BD suppliers and
subcontractors (as defined by BD) will be expected to complete a declaration concerning the usage and source of any 3TG in the products supplied to us. As part of gathering the information for the declaration, applicable BD suppliers and subcontractors will be expected to conduct a reasonable country of origin inquiry and/or due diligence, as applicable, in accordance with the Conflict Minerals Rule and the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”).
In cases where suppliers or subcontractors are found to not be in compliance with our policy, we intend to work with and encourage them to source responsibly. Where these efforts fail or we believe that further engagement with a supplier or subcontractor is inappropriate, we will re-evaluate our business relationship.
We discourage the embargoing of 3TG from the Conflict Affected Regions and advocate the responsible sourcing of 3TG from the region.
Bard. Bard also is committed to ethical business practices and compliance with the law and has published expectations of suppliers. Bard’s supplier expectations indicate that it expects them to: (1) comply with all applicable laws, rules, and regulations relating to 3TG; (2) give timely, complete, and reliable responses to Bard’s supply chain inquiries regarding 3TG; (3) implement their own policies and procedures to prevent the use of 3TG from conflict sources in the raw materials, components and finished products that they supply to Bard; (4) make reasonable efforts to ensure the responsible sourcing of 3TG minerals from “conflict-free” suppliers and smelters; and (5) work with their own suppliers to determine the source of 3TG minerals when unknown.
Reasonable Country of Origin Inquiry; Smelter and Refiner and Country of Origin Information
As required by the Conflict Minerals Rule, for 2017, we conducted a “reasonable country of origin inquiry.” Our outreach included 2027 suppliers for BD and 258 suppliers for Bard (the “Suppliers”) that were identified through our internal scoping processes as having provided, or that we believe may have provided, us with raw materials or components that contain 3TG. Suppliers representing 90% of BD’s in-scope spend responded to BD’s reasonable country of origin inquiry and suppliers representing 91% of Bard’s in-scope spend responded to Bard’s inquiry.
For 2017, our Suppliers identified to us the smelters and refiners described in the table below, sorted by mineral and risk level, as potentially having processed the necessary 3TG contained in our in-scope products. The names of the identified smelters and refiners are listed on Annex 1. We were able to determine the origin of only a portion (if any) of the necessary Conflict Minerals contained in each of our in-scope products.
| Covered Country Sourced RMAP Conformant 1 |
Non
Covered Country Sourced RMAP Conformant |
Source Country Unknown |
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| 100% Recycled or Scrap |
RMAP Conformant |
RMAP Active |
On Smelter Look-up List Only |
Total Smelters |
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| Gold |
0 | 15 | 13 | 73 | 6 | 39 | 146 | |||||||||||||||||||||
| Tantalum |
29 | 9 | 2 | 0 | 0 | 0 | 40 | |||||||||||||||||||||
| Tin |
5 | 61 | 3 | 1 | 2 | 7 | 79 | |||||||||||||||||||||
| Tungsten |
5 | 35 | 1 | 0 | 1 | 4 | 46 | |||||||||||||||||||||
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| Total |
39 | 120 | 19 | 74 | 9 | 50 | 311 | |||||||||||||||||||||
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Based on the results of our reasonable country of origin inquiry, we conducted due diligence for 2017. These due diligence efforts are discussed later in this Conflict Minerals Report.
| 1 | See Annex for definitions. |
Conclusion Statement
Based on our due diligence, none of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the Conflict Affected Region. However, we did not conclude that any of our products were “DRC conflict free.” The terms “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
Due Diligence Program Design
Design Framework
Our due diligence measures relating to 3TG were designed to conform with the criteria set forth in the OECD Guidance, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition).
Selected Elements of Design Framework
The OECD Guidance has established a framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the elements of the program that we have designed to ensure that the 3TG contained in our products are responsibly sourced. Selected due diligence measures that we took in respect of 2017 are discussed under “Due Diligence Program Execution.”
Conflict Minerals Policy
BD’s Conflict Minerals Policy, as described in this Conflict Minerals Report, is available on our website at http://www.bd.com/en-us/company/sustainability-at-bd/corporate-policies-and-resources-for-suppliers.
Bard’s Conflict Minerals Policy, as described in this Conflict Minerals Report is available at
https://www.crbard.com/CRBard/media/CRBardCorporate/General%20Site%20Images/Healthcare%20Professionals/PDFs/Conflicts-Minerals.pdf?ext=.pdf
Conflict Minerals Teams
In 2018, the legacy BD and Bard Conflict Minerals Steering Teams were combined.
We have a centralized Conflict Minerals Team (the “Core Team”) to provide cross-functional support for the 3TG compliance program. The Core Team is comprised of representatives from Global Procurement, the Office of Global Sustainability, and business units with products likely to contain 3TG. The Core Team is led by the Conflict Minerals Program Leader with support and oversight from the Director, Product Stewardship Compliance. Executive leadership of the Conflict Minerals Program resides with Global Sustainability.
We also have a Conflict Minerals Steering Team (the “Steering Team”) responsible for overseeing the compliance activity while engaging with functional leadership around progress, reviewing and approving internal and external policy language, and collaborating with necessary third-party resources. The Steering Team consists of the Program Leader, Executive Leader and representatives from the Law Group and Global Procurement.
Our compliance efforts are supplemented by specialist outside counsel.
Internal and External Communication of Conflict Minerals Program and Training
We communicate to selected associates our commitment to comply with the Conflict Minerals Rule, in writing and through in-person training sessions and other live communications. In addition, applicable associates are educated on the Conflict Minerals Rule and our compliance program.
Applicable suppliers and subcontractors are provided with information on the Conflict Minerals Rule, our commitment to compliance with the Rule and/or our sourcing expectations. This is done in writing, through in-person meetings and other live communications and/or through contractual requirements.
Participation in and Support of Multi-Stakeholder Initiatives
We are a member of the Responsible Minerals Initiative (“RMI,” and formerly known as the Conflict-Free Sourcing Initiative or CFSI). BD participates on the RMI’s Smelter Engagement and Due Diligence teams.
Data Storage and Retention
We utilize an internal database and an external Conflict Minerals Platform for the maintenance of business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions. These records are maintained for 5 years.
Contractual Compliance Requirements
We include provisions in certain purchase orders and contracts requiring suppliers to provide information to support our compliance efforts under the Conflict Minerals Rule. In addition, BD’s Expectations for Suppliers, which contains our supplier compliance requirements relating to many different subject areas, includes compliance requirements relating to 3TG.
Grievance Mechanisms
We have grievance mechanisms for employees, suppliers and other interested parties to report alleged violations of our Conflict Minerals Policies and we publicly communicate our grievance mechanisms. Any grievances received are communicated to the Program Leader and Steering Team. Associates, suppliers, and other interested parties can report actions inconsistent with the Expectations for Suppliers through our Global Ethics Help Line, the number of which is 1-800-821-5452. Under our internal procedures, all such calls will be investigated.
Collection, Assessment, and Internal Reporting of Supply Chain Information
Suppliers that BD determined to be in-scope are requested to complete a Conflict Minerals Reporting Template, which contains questions on the inclusion and source of 3TG in the materials they supplied to us and their compliance activities. If a supplier does not respond to our request within a reasonable time frame, we may follow-up with electronic reminders, by email and/or phone inquiries. If the supplier does not respond within a reasonable time frame or refuses to respond, this information is forwarded to Global Procurement or local buyers at manufacturing plants to assist as part of an escalation process. Suppliers that Bard determined to be in-scope or potentially in-scope were requested to respond to a Request For Information. If the supplier to Bard replied that they used 3TG, they were requested to complete a Conflict Minerals Reporting Template. As part of the Bard process we make several system inquiries, then email and phone inquiries. If a Bard supplier does not respond within a reasonable time frame, this information is forwarded to Global Procurement or local buyers at manufacturing plants to assist. Bard communicates all supplier’s status (including if they have responded and number of times we reached out) to the Steering Team.
Upon receipt of a Conflict Minerals Reporting Template from a supplier, the response is processed through our Supplier Response Analysis process. This process includes reviewing the supplier’s responses against a series of identified “red flags.” Additionally, we review submitted Conflict Minerals Reporting Templates for certain errors and inaccuracies and follow up with these suppliers as well.
Smelter and refiner information provided by suppliers is reviewed against the Smelter Look-up tab of the Conflict Minerals Reporting Template and the global smelter library in our software system, which includes information published by RMI, the Responsible Jewellery Council (the “RJC”) and the London Bullion Market Association (the “LBMA”).
Smelter and refiner information is also reviewed against the lists of “conformant” and “active” (or the equivalent) smelters and refiners and country of origin information published by the RMI, the RJC and the LBMA. To the extent that a smelter or refiner identified by a supplier is not listed as conformant or the equivalent by the RMI, RJC, or LBMA, we consult publicly available information to attempt to determine whether the smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the Conflict Affected Region.
Based on the information furnished by suppliers and other information known to us, we assess the risk of adverse impacts. The Steering Team reports the findings of its supply chain risk assessment to senior management on a regular basis.
We determine on a case-by-case basis the appropriate mitigation strategy for any identified non-compliance with our Conflict Minerals Policy and other supplier requirements and expectations relating to our 3TG compliance program. Potential outcomes under our mitigation strategy include continuing to work with the supplier while non-compliances are addressed, or suspending or terminating the relationship with the supplier. Under our mitigation strategy, to the extent that areas of non-compliance that require mitigation are identified, we monitor and track the performance of the mitigation efforts and report back to appropriate senior oversight personnel. Under our procedures, we also will undertake additional fact and risk assessments, as determined by the Steering Team, for non-compliances that require mitigation or after a change of circumstances.
In addition, to the extent that identified smelters or refiners are not listed as conformant, we seek to exercise leverage over the smelters and refiners to become conformant through our participation in and support of the RMI. We also utilize information provided by the RMI to its members to monitor smelter and refiner improvement.
Carry out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
In connection with our due diligence, we utilize and rely on information made available by the RMI concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence and to determine whether the smelter or refiner is conformant. We are a member of the RMI. We also made a contribution to the RMI Initial Audit Fund to support smelter and refiner audits.
Report on Supply Chain Due Diligence
We file a Form SD and a Conflict Minerals Report, with the Securities and Exchange Commission and make these documents available on our website.
Due Diligence Program Execution
We performed the following due diligence measures in respect of the 2017 compliance period. These are not all of the measures that we took in respect of 2017 in furtherance of BD’s and Bard’s Conflict Minerals Policies or pursuant to our 3TG compliance program, the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, please see “Due Diligence Program Design.”
| 1. | BD sent requests to 2027 Suppliers to provide us with a completed Conflict Minerals Reporting Template. Bard sent requests to 258 suppliers. We followed up by email or phone with the Suppliers that did not provide a response within the specified time frame. |
| 2. | We reviewed the completed responses received from the Suppliers based on our “red flags” review criteria and for errors and inaccuracies. |
| 3. | We reviewed the smelters and refiners identified to us by the Suppliers against those contained on the Smelter Look-up tab of the Conflict Minerals Reporting Template and, and the smelter and refiner database available to members of the RMI. |
| 4. | To the extent that a completed response identified a smelter or refiner, we also reviewed that information against the list of conformant and active (or the equivalent) smelters and refiners published by the RMI, LBMA, and RJC as of March 26, 2018. See “Reasonable Country of Origin Inquiry: Smelter and Refiner and Country of Origin Information” and Annex 1 for further information on the smelters and refiners identified by the Suppliers. |
| 5. | To the extent that a smelter or refiner identified by a Supplier was not listed as conformant (or the equivalent) by the RMI, LBMA, or RJC, we consulted publicly available information to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the Conflict Affected Region. |
| 6. | The Steering Team reported the findings of our supply chain assessment to senior management. |
| 7. | In addition, to mitigate the risk that the necessary 3TG contained in our in-scope products directly or indirectly finance or benefit armed groups in the Conflict Affected Region, we: |
| a. | Participated on the RMI’s Smelter Engagement and Due Diligence teams and we made a contribution to the RMI Initial Audit Fund. |
| b. | Further refined our in-scope commodity categories to better focus our efforts on the highest risk areas. |
| c. | Further refined the country of origin information by mineral. |
Product Information
In-scope products for 2017 included (1) for BD, a broad range of electrical or electronic medical devices, laboratory equipment and diagnostic products we manufacture or contract to be manufactured and (2) for Bard, vascular products, urology products, oncology products and surgical specialty products. Not all of the products in each of these categories were in-scope for purposes of our compliance, i.e. not all of our products contain necessary 3TG or were manufactured or contracted to be manufactured by us
For 2017, we were unable to determine at least a portion of the smelters and refiners, and countries of origin, of the necessary 3TG contained in each of our in-scope products. Identified smelters and refiners and country of origin information are described under “Reasonable Country of Origin Inquiry”, “Smelter and Refiner and Country of Origin Information” and on Annex 1.
Additional Mitigation Efforts
In respect of 2018, we have taken or intend to take the following additional steps to mitigate the risk that the necessary 3TG contained in our in-scope products finance or benefit armed groups:
| ◾ | Monitor and encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2017 that the source of 3TG was unknown or undeterminable. |
| • | Contribute the amount of the average cost of an audit to the RMI Initial Audit Fund. |
| • | Continue to refine our in-scope commodity categories to focus our efforts on the highest risk areas. |
| • | Continue to harmonize and integrate BD’s and Bard’s previously separate 3TG compliance programs. |
The foregoing steps are in addition to the steps that we took for 2017, which we intend to continue to take for 2018 to the extent applicable.
Annex 1
Capitalized terms used and not otherwise defined in this Annex have the meanings indicated in our Conflict Minerals Report.
Smelters and Refiners
In connection with our reasonable country of origin inquiry and due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below, sorted by mineral and risk level, as potentially having processed the necessary 3TG contained in our in-scope products in 2017.
| Metal |
Processor |
Country Location |
Status | |||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant | |||
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conformant | |||
| Gold | Argor-Heraeus SA | SWITZERLAND | Conformant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Conformant | |||
| Gold | Asahi Refining Canada Limited | CANADA | Conformant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES | Conformant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant | |||
| Gold | Aurubis AG | GERMANY | Conformant | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant | |||
| Gold | Boliden AB | SWEDEN | Conformant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant | |||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant | |||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant | |||
| Gold | Chimet S.p.A. | ITALY | Conformant | |||
| Gold | China National Gold Group Corporation | CHINA | Conformant | |||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | DODUCO GmbH | GERMANY | Conformant | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Dowa Metalmine Co. Ltd | JAPAN | Conformant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant | |||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant | |||
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Conformant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Conformant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Conformant | |||
| Gold | Italpreziosi | ITALY | Conformant | |||
| Gold | Japan Mint | JAPAN | Conformant |
| Gold | Jiangxi Copper Company Limited | CHINA | Conformant | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conformant | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant | |||
| Gold | Kazzinc | KAZAKHSTAN | Conformant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Conformant | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant | |||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Marsam Metals | BRAZIL | Conformant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant | |||
| Gold | Materion | UNITED STATES OF AMERICA | Conformant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant | |||
| Gold | Metalor Technologies SA | SWITZERLAND | Conformant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Conformant | |||
| Gold | Metalurgica Met-Mex Penoles S.A. DE C.V | MEXICO | Conformant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Conformant | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant | |||
| Gold | PAMP SA | SWITZERLAND | Conformant | |||
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant | |||
| Gold | PX Précinox SA | SWITZERLAND | Conformant | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant | |||
| Gold | Republic Metals Corporation | UNITED STATES | Conformant | |||
| Gold | Royal Canadian Mint | CANADA | Conformant | |||
| Gold | SAAMP | FRANCE | Conformant | |||
| Gold | Safimet S.p.A | ITALY | Conformant | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Conformant | |||
| Gold | SEMPSA Joyería Platería SA | SPAIN | Conformant | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Conformant | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant | |||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | T.C.A S.p.A | ITALY | Conformant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Conformant | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Conformant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Conformant | |||
| Gold | Valcambi SA | SWITZERLAND | Conformant | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Conformant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant | |||
| Gold | YAMAKIN CO., LTD. | JAPAN | Conformant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant | |||
| Gold | Bangalore Refinery | INDIA | Active | |||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active | |||
| Gold | L’Orfebre S.A. | ANDORRA | Active | |||
| Gold | Modeltech Sdn Bhd | MALAYSIA | Active | |||
| Gold | Remondis Argentia B.V. | NETHERLANDS | Active | |||
| Gold | SAFINA A.S. | CZECH REPUBLIC | Active | |||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List Only | |||
| Gold | Anhui Tongling non-ferrous Pioneer Metals Corporation | CHINA | On Smelter Look-up List Only | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Smelter Look-up List Only | |||
| Gold | Caridad | MEXICO | On Smelter Look-up List Only | |||
| Gold | Chugai Mining | JAPAN | On Smelter Look-up List Only | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | On Smelter Look-up List Only | |||
| Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List Only | |||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | On Smelter Look-up List Only | |||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | On Smelter Look-up List Only | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | On Smelter Look-up List Only | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | On Smelter Look-up List Only | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | HwaSeong CJ Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Look-up List Only | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | On Smelter Look-up List Only | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Smelter Look-up List Only |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | On Smelter Look-up List Only | |||
| Gold | L’ azurde Company For Jewelry | SAUDI ARABIA | On Smelter Look-up List Only | |||
| Gold | Lingbao Gold Company Limited | CHINA | On Smelter Look-up List Only | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Morris and Watson | NEW ZEALAND | On Smelter Look-up List Only | |||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | On Smelter Look-up List Only | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | On Smelter Look-up List Only | |||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | On Smelter Look-up List Only | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | On Smelter Look-up List Only | |||
| Gold | Sai Refinery | INDIA | On Smelter Look-up List Only | |||
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF | On Smelter Look-up List Only | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | On Smelter Look-up List Only | |||
| Gold | Sudan Gold Refinery | SUDAN | On Smelter Look-up List Only | |||
| Gold | Tony Goetz NV | BELGIUM | On Smelter Look-up List Only | |||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | On Smelter Look-up List Only | |||
| Gold | Universal Precious Metals Refining | ZAMBIA | On Smelter Look-up List Only | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES | Conformant | |||
| Tantalum | Exotech Inc. | UNITED STATES | Conformant | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Conformant | |||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES | Conformant | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Conformant | |||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | Conformant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Conformant | |||
| Tantalum | KEMET Blue Powder | UNITED STATES | Conformant | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Conformant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Conformant | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Conformant | |||
| Tantalum | Ningxia Non-Ferrous Metal Smeltery | CHINA | Conformant | |||
| Tantalum | NPM Silmet AS | ESTONIA | Conformant | |||
| Tantalum | Power Resources Ltd. | MACEDONIA | Conformant | |||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Conformant | |||
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant | |||
| Tantalum | Taki Chemicals | JAPAN | Conformant | |||
| Tantalum | Telex Metals | UNITED STATES | Conformant | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant | |||
| Tin | Alpha | UNITED STATES | Conformant | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA | Conformant | |||
| Tin | China Rare Metal Materials Company | CHINA | Conformant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant | |||
| Tin | Complejo Metalurgico Vinto S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | |||
| Tin | CV Ayi Jaya | INDONESIA | Conformant | |||
| Tin | CV Dua Sekawan | INDONESIA | Conformant | |||
| Tin | CV Gita Pesona | INDONESIA | Conformant | |||
| Tin | CV United Smelting | INDONESIA | Conformant | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Conformant | |||
| Tin | Dowa | JAPAN | Conformant | |||
| Tin | Fenix Metals | POLAND | Conformant | |||
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | Conformant | |||
| Tin | Gejiu Jinye Mineral Company | CHINA | Conformant | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant | |||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant | |||
| Tin | Indonesian State Tin Corp | INDONESIA | Conformant | |||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Conformant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| Tin | Melt Metais e Ligas S/A | BRAZIL | Conformant | |||
| Tin | Metallic Resources, Inc. | UNITED STATES | Conformant | |||
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant | |||
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Conformant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Conformant | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Conformant | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Conformant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Conformant | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Bukit Timah | INDONESIA | Conformant | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Conformant | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conformant | |||
| Tin | PT Inti Stania Prima | INDONESIA | Conformant | |||
| Tin | PT Karimun Mining | INDONESIA | Conformant | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant | |||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant | |||
| Tin | PT Panca Mega Persada | INDONESIA | Conformant | |||
| Tin | PT Premium Tin Indonesia | INDONESIA | Conformant | |||
| Tin | PT Prima Timah Utama | INDONESIA | Conformant | |||
| Tin | PT RAJEHA ARIQ | INDONESIA | Conformant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Conformant | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Conformant | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant | |||
| Tin | PT Tommy Utama | INDONESIA | Conformant | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Conformant | |||
| Tin | Rui Da Hung | TAIWAN | Conformant | |||
| Tin | SA Minsur | PERU | Conformant | |||
| Tin | Soft Metais Ltda. | BRAZIL | Conformant | |||
| Tin | Thaisarco | THAILAND | Conformant | |||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Conformant | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conformant | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co. ,Ltd. | CHINA | Conformant | |||
| Tin | Yunnan Tin Company Limited | CHINA | Conformant | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Active | |||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Active | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | On Smelter Look-up List Only | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | On Smelter Look-up List Only | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | On Smelter Look-up List Only | |||
| Tin | Gejiu Zili Mining and Metallurgy Co., Ltd. | CHINA | On Smelter Look-up List Only |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List Only | |||
| Tin | Super Ligas | BRAZIL | On Smelter Look-up List Only | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List Only | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Conformant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Conformant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Kennametal Fallon | UNITED STATES | Conformant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES | Conformant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Niagara Refining LLC | UNITED STATES | Conformant | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant | |||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conformant | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant | |||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Active | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | On Smelter Look-up List Only |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | On Smelter Look-up List Only | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | On Smelter Look-up List Only |
We note the following in connection with the information in the table:
| (a) | The smelters and refiners listed in the table were identified by the Suppliers as being part of our 2017 supply chain. Some of the Suppliers may have reported to us smelters and refiners that were not in our supply chain (i) since they reported at a “company level,” meaning that they reported to us the 3TG contained in all of their products, not just the products that they sold to us, or (ii) due to over-inclusiveness in the information received from their suppliers. In addition, the smelters and refiners reflected above may not be all of the smelters and refiners in our 2017 supply chain, since many of the Suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products and because not all of the Suppliers responded to our inquiries. |
| (b) | All information in the table is as of April 5, 2018. |
| (c) | “Conformant” means that the smelter or refiner was listed as conformant with the RMI’s Responsible Minerals Assurance Process (“RMAP”) assessment protocols, including through mutual recognition and those indicated as “re-audit in process.” Included smelters or refiners were not necessarily Conformant for all or part of 2017 and may not continue to be Conformant for any future period. |
| (d) | “Active” means that the smelter or refiner is a participant in the RMAP and has committed to undergo an audit or is participating in a cross-recognized certification program. |
| (e) | “On Smelter Look-up List Only” means the smelter or refiner is not listed as “Conformant” or “Active.” The table only includes entities that were listed as smelters or refiners by the RMI. |
| (f) | The compliance status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us. |
| (g) | Country location is the location of the smelter or refiner. |
Country of Origin Information
The countries of origin of the 3TG processed by the Conformant smelters and refiners listed above may have included countries in each of the categories listed below. The countries below are sorted by risk level. See “Reasonable Country of Origin Inquiry; Smelter and Refiner and Country of Origin Information” for additional origin information.
Known Countries from which Conformant Gold Smelters Source:
L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Benin, Bolivia, Burkina Faso, Canada, Chile, Colombia, Ecuador, Eritrea, Ghana, Guatemala, Guinea, Guyana, Honduras, Mali, Nicaragua, Panama, Peru, Russian Federation, Senegal, Togo, and United States of America.
L2 – Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: South Africa.
Known Countries from which Conformant Tantalum Smelters Source:
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Australia, Bolivia, Brazil, China, Colombia, Ethiopia, France, Guinea, Guyana, India, Kazakhstan, Madagascar, Malaysia, Namibia, Nigeria, Russian Federation, Sierra Leone, Thailand, United States of America, and Zimbabwe
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Mozambique
L3 – The DRC and its nine adjoining countries: Burundi and Rwanda.
DRC – The Democratic Republic of the Congo.
Known Countries from which Conformant Tin Smelters Source:
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG:
Argentina, Australia, Bolivia, Brazil, China, Colombia, Germany, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Thailand, United Kingdom of Great Britain and Northern Ireland, Vietnam, and Zimbabwe
L3 – The DRC and its nine adjoining countries: Burundi, Rwanda, and Uganda.
DRC – The Democratic Republic of the Congo.
Known Countries from which Conformant Tungsten Smelters Source:
L1- Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Australia, Austria, Bolivia, Brazil, Cambodia, Canada, China, Colombia, Japan, Mexico, Mongolia, Nigeria, Portugal, Russian Federation, Spain, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, and Vietnam
L3 - The DRC and its nine adjoining countries: Burundi, and Rwanda.
DRC – The Democratic Republic of the Congo.
In addition, some of the listed Conformant smelters and refiners may have processed 3TG originating from recycled or scrap sources.
For 2017, we were not able to determine the country of origin of the 3TG processed by 133 smelters or refiners.