Form SD MICRON TECHNOLOGY INC

May 26, 2022 5:11 PM EDT

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

Specialized Disclosure Report


micronnamea05.jpg
MICRON TECHNOLOGY, INC.
(Exact name of registrant as specified in its charter)
Delaware1-1065875-1618004
(State or other jurisdiction of incorporation)(Commission File Number)(IRS Employer Identification No.)
8000 South Federal Way
Boise, Idaho 83716-9632
(Address of principal executive offices and Zip Code)
Mark Murphy
Executive Vice President and Chief Financial Officer
(208) 368-4000
(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:

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended _____.








Section 1 - Conflict Minerals Disclosure
Item 1.01.Conflict Minerals Disclosure and Report.

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), we conducted a reasonable country of origin inquiry (“RCOI”) to assess whether conflict minerals necessary to the functionality or production of products we manufactured or contracted to manufacture in calendar year 2021 originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) or were from recycled or scrap sources. The Rule defines conflict minerals as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives (tin, tantalum, and tungsten).

Based on the results of our RCOI, we have reason to believe that certain conflict minerals contained in our 2021 products may have originated in the Covered Countries and may not have been from recycled or scrap sources. We therefore conducted due diligence on the source and chain of custody of these minerals and prepared a Conflict Minerals Report, filed as Exhibit 1.01 hereto.
Conflict Minerals Disclosure
A copy of the Conflict Minerals Report for the calendar year ended December 31, 2021 is available on our website at micron.com/about/our-commitment/sourcing-responsibly/responsible-minerals-policy.
Item 1.02.Exhibit.

The Conflict Minerals Report for the calendar year ended December 31, 2021 is filed as Exhibit 1.01 hereto.
Section 2 - Resource Extraction Issuer Disclosure

Not applicable.

Section 3 - Exhibits
Item 3.01.Exhibits.

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.




SIGNATURE

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.
MICRON TECHNOLOGY, INC.
Date:May 26, 2022By:/s/ Mark Murphy
Name:Mark Murphy
Title:Executive Vice President and Chief Financial Officer



Exhibit 1.01

Micron Technology, Inc.
Conflict Minerals Report
Calendar Year 2021

We1 prepared this Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). This CMR covers the calendar year reporting period ended December 31, 20212 and is filed as an exhibit to our Form SD. This CMR includes a description of the measures we have taken to exercise due diligence on the source and chain of custody of conflict minerals3 (specifically gold, and the derivatives tin, tantalum, and tungsten (collectively “3TG”)) necessary to the functionality or production of our memory and storage products manufactured during the year ended December 31, 2021.

Overview of Our Commitment to Responsible Sourcing:

In support of global responsible sourcing, we are committed to monitoring our supply chain with a goal to ensure that conflict minerals directly or indirectly supporting civil violence or human rights abuses in the Democratic Republic of the Congo (“DRC”) or adjoining countries are not used in the manufacture of Micron products. We also believe that responsible sourcing means continuing to support stable economic development in the DRC region (rather than a DRC embargo), and accordingly we do not prohibit our suppliers from using 3TG metals sourced from the region. Our conflict mineral supply chain monitoring program is consistent with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) (the “OECD Guidance”) and integrates tools developed by the Responsible Minerals Initiative (“RMI”).

Micron is a founding member of RMI (member ID MICR). We continue to support RMI and its Responsible Minerals4 third-party auditing program, the Responsible Minerals Assurance Process (“RMAP”), as part of our commitment to drive ethical sourcing of 3TG metals throughout our supply chain. In 2021, we continued working with RMI and provided leadership through multiple RMI leadership working groups, including the Smelter Engagement, Multi-Stakeholder, Gold, Cobalt, Due Diligence Practices, Minerals Reporting Template and RMI Plenary Working Groups. The RMI Plenary Working Group is tasked with defining future directions, protocol, procedures, issue resolutions, recognition of other reporting organizations, training, oversight, and smelter and refiner engagements. To learn more about RMI’s initiatives to help companies achieve a responsible minerals supply chain and the RMAP visit responsiblemineralsinitiative.org.

Micron’s Responsible Minerals Policy is published at micron.com/about/our-commitment/sourcing-responsibly/responsible-minerals-policy. To learn more about our responsible minerals supplier requirements, see our Micron Supplier Requirements Standard (“SRS”) at micron.com/about/our-commitment/sourcing-responsibly/suppliers. The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.
1    In this CMR, unless otherwise indicated or the context otherwise requires, “we,” “us,” “our,” “Micron,” and the “Company” refers to Micron Technology, Inc. and its subsidiaries.
2    Unless otherwise noted, any designation of years refers to calendar years.
3    Conflict minerals are those minerals regulated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Currently, they consist of columbite-tantalite, also known as coltan (and its derivative tantalum); cassiterite (and its derivative tin); wolframite (and its derivative tungsten); and gold.
4    The term “responsible minerals” as used herein refers to a process to verify that relevant smelters or refiners are Conformant with the RMI’s RMAP or an equivalent third-party auditing program.











Overview of Micron’s Responsible Minerals Program:

We require our suppliers5 to source 3TG metals from smelters and refiners validated as Conformant6 with responsible minerals sourcing standards (such as the RMAP or standards enacted by the London Bullion Market Association (“LBMA”) or the Responsible Jewellery Council (“RJC”)). To ensure our suppliers meet our SRS requirements for responsible minerals sourcing, we make all suppliers aware of our commitment to responsible sourcing and our expectation that all smelters and refiners in our supply chain are Conformant with responsible minerals sourcing standards; conduct ongoing due diligence on the source and chain of custody of conflict minerals in our supply chain in conformance with the OECD Guidance; encourage suppliers to adopt responsible sourcing practices; and collaborate with industry stakeholders through our leadership in the RMI. To further transparency in the conflict mineral supply chain, in addition to publicly reporting the results of our due diligence efforts annually, we share our due diligence results directly with our customers.

In 2021, we requested that all new suppliers take a Supplier Compliance Training, which helped increase awareness of and focus on our requirement that Micron suppliers may only use Conformant smelters and refiners. As a result, during 2021 and for the fifth consecutive year, no supplier within our memory and storage products supply chain proposed adding any smelters or refiners that had a Non-Conformant status with RMI. We also continued to implement our resolution process to quickly identify and work toward removal of smelters and refiners from our supply chain when they drop out of the RMI, LBMA, or RJC programs and thus become Non-Conformant.

Based on the information provided by our suppliers and our due diligence efforts through December 31, 2021, we identified a total of 219 smelters and refiners we believe were in our memory and storage products supply chain at any point during the year ended December 31, 2021, none of which had a Non-Conformant status with RMI at the time they entered our supply chain. Eleven smelters and refiners that were reported to be in our memory and storage products supply chain during 2021 were subsequently determined to be inoperative or removed on or prior to December 31, 2021. We determined that 208 smelters and refiners were in our memory and storage products supply chain as of December 31, 2021, of which 204 were validated as Conformant and four were listed as Active7 with RMI.

1. Our Outreach to Suppliers and Reasonable Country of Origin Inquiry

Our goal is to ensure that all 3TG metals in our supply chain are sourced through responsible minerals smelters and refiners. In furtherance of that goal, we collect information at least annually utilizing the RMI Conflict Minerals Reporting Template (“CMRT”) from applicable suppliers regarding their supply chains, including the names and locations of smelters and refiners of 3TG as well as the country of origin of 3TG processed by such smelters and refiners. We then ask that suppliers review and acknowledge our Responsible Minerals Policy and our SRS, which sets out our expectations that all smelters and refiners in our supply chain are, and remain, validated as Conformant.

In addition, we required that new suppliers in our memory and storage products supply chain participate in our Supplier Lifecycle Performance Management process as they were added to our memory and storage products supply chain throughout the year, and we requested that they complete our formal Supplier Compliance Training program.

5    The term “supplier(s)” refers to both incumbent and new suppliers and manufacturers that are likely to provide us with products containing 3TG metals that are necessary to the function or manufacture of our memory and storage products. The term “supplier(s)” does not include suppliers and manufacturers to the extent that they supply us with equipment or tools used in manufacturing our products,
6    The term “Conformant” means that smelters or refiners are verified as Conformant with the RMI’s RMAP or an equivalent third-party auditing program.
7     The term “Active,” with respect to the RMI, means that a smelter or refiner has committed to undergo an RMAP assessment, completed the relevant documents, and scheduled an on-site assessment.
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We make our suppliers aware that smelters and refiners that fail to become Conformant in one or more responsible sourcing auditing programs will be targeted for removal from our memory and storage products supply chain. In addition, the terms and conditions we include with every Micron purchase order further reinforce our responsible sourcing expectations and requirements with direct reference to our SRS. Throughout 2021, we worked with our suppliers to help raise awareness of our expectations, provide ongoing education concerning our requirements, and provide training through our risk mitigation and escalation process.

Our outreach to suppliers, which included our reasonable country of origin inquiry, did not provide us with complete information on the origin of 3TG from smelters and refiners reported to be in our memory and storage products supply chain in 2021. We had reason to believe, however, that at least some sourcing was from the DRC and adjoining countries. Accordingly, we conducted due diligence on the chain and custody of 3TG and prepared this Conflict Minerals Report.

2. Our Conflict Minerals Due Diligence Program

2.1 Our Conflict Minerals Due Diligence Program Design

We have designed our conflict minerals due diligence program in conformance with the principles of the OECD Guidance and the supplements thereto as applied to downstream companies. As a downstream purchaser of 3TG metals, our due diligence program can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the 3TG metals necessary to the functionality or production of our products. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the 3TG metals we use. We also rely, to a large extent, on information collected and provided by RMI and other third-party auditing programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.

2.2 Our Conflict Minerals Due Diligence for 2021 Products

2.2.1 Our Management System

For the year ended December 31, 2021, management of our responsible minerals program was provided by a cross-functional Responsible Minerals Steering Team, with representatives from Micron’s Procurement, Supply Chain, Finance, Sales, Sustainability and Legal departments, headed by a Senior Procurement Compliance Manager. The Steering Team met at least monthly during the year ended December 31, 2021 to review progress towards maintaining our goal of a responsibly-sourced supply chain. Oversight of the Responsible Minerals Steering Team was provided by a cross-functional Responsible Minerals Executive Team comprised of Vice President-level executives, which is charged with sponsoring and reviewing our responsible minerals program. The Steering Team reported to the Executive Team on a monthly basis during the year ended December 31, 2021. In addition, our Global Supply Chain Compliance Council, which includes a subset of our Responsible Minerals Executive Team, is charged with direct oversight of our responsible sourcing program. During the year ended December 31, 2021, the Steering Team reported regularly to the Global Supply Chain Compliance Council to review our progress towards our goal of achieving a responsibly-sourced supply chain. In addition, in January 2022, we added dedicated resources to further strengthen our responsible minerals program.

We also continued to incorporate our responsible minerals supplier requirements (i.e., that suppliers must report 100% of their supply chain and only source from Conformant smelters and refiners) into the terms and conditions of our purchase orders and supplier agreements, and maintained internal and third-party access to our ethics and compliance hotline, which can be used to report issues relating to conflict minerals. Our program included a ten-year record retention policy for our responsible minerals documents.

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2.2.2 Our Risk Assessment

We conducted due diligence, as described in this CMR, to try to determine the source and chain of custody of the necessary 3TG metals contained in these memory and storage products. Our management assessment process led us to believe that at least some sourcing is from the DRC and adjoining countries. We were unable to determine the country of origin of some of the 3TG metals contained in memory and storage products we manufactured and sold during the year ended December 31, 2021 and/or whether some of the memory and storage products we manufactured and sold during the year ended December 31, 2021 contained 3TG metals that may have directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.

As part of our due diligence process, we collected, screened and analyzed CMRTs from all applicable suppliers for the year ended December 31, 2021. We provided our suppliers with formal notification of Micron’s requirements to convey our expectations that they report to us, within fourteen days of any such occurrence, any changes to their supply chains that would affect their CMRT status.

2.2.3 Our Risk Management

We reviewed all CMRT responses and updates received for the year ended December 31, 2021 and determined whether the disclosed smelters or refiners were recognized by RMI or equivalents as processors of 3TG metals, and if so, whether they had been validated as Conformant with these organizations. We reviewed supplier CMRTs for accuracy and overall adherence to our responsible minerals requirements, as delivered through our inquiry letter to suppliers, and we began our risk mitigation (and escalation processes, if necessary) set out in our responsible minerals procedures with suppliers having disclosed any smelters or refiners that were not Conformant. If a supplier reports a CMRT that includes smelters or refiners not listed as Conformant, we implement our risk mitigation procedures, beginning with direct outreach to the supplier and escalating discussions up the management structure of our respective companies. We work with these suppliers throughout the risk mitigation process to provide awareness of Micron’s goal to only source from Conformant smelters or refiners. Eleven smelters and refiners that were reported to be in our memory and storage products supply chain during 2021 were subsequently determined to be inoperative or removed on or prior to December 31, 2021. As of December 31, 2021, four smelters and refiners in our memory and storage products supply chain were listed as Active with RMI, of which one became Conformant after December 31, 2021, and three continue to be in the process of removal from our supply chain as of the date of filing of this Report.

We are members of multiple RMI working groups, including the RMI Smelter Engagement Working Group, which was tasked with identifying and influencing smelters in the supply chains of RMI members to join the RMAP and become validated as responsibly sourced. Micron also has additional RMI formal representation and leadership positions on multiple RMI working groups, including the Multi-Stakeholder, Due Diligence Practices, Minerals Reporting Template, Gold, Cobalt, and RMI Plenary Working Groups. Through our membership dues, we provide funding to DRC in-region agencies.

2.2.4 Smelter and Refiner Auditing

As we do not source 3TG metals directly from smelters or refiners, we rely on independent third-party auditing programs, such as the RMAP, LBMA, and RJC to coordinate audits of smelters and refiners in our memory and storage products supply chain.

2.2.5 Reporting

We report our annual conflict minerals due diligence results in our responsible minerals program to the U.S. Securities and Exchange Commission through the Form SD and the CMR. We make the CMR available on our company website.

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3. Our Product Descriptions

Our product portfolio of memory and storage solutions, is based on our high-performance semiconductor memory and storage technologies, including dynamic random access memory (“DRAM”), NAND, and NOR. We sell our products into various markets through our business units in numerous forms, including wafers, components, modules, solid state drives (“SSDs”), managed NAND, and Multi-Chip Package (“MCP”) products. Our system-level solutions, including SSDs and managed NAND, combine NAND, a controller, firmware, and in some cases DRAM. During the year ended December 31, 2021, we manufactured or contracted to manufacture the following memory and storage products containing 3TG metals.

DRAM

DRAM products are dynamic random access memory semiconductor devices with low latency that provide high-speed data retrieval with a variety of performance characteristics. DRAM products lose content when power is turned off (“volatile”) and are most commonly used in client, cloud server, enterprise, networking, graphics, industrial, and automotive markets. Low-power DRAM products, which are engineered to meet standards for performance and power consumption, are sold into smartphone and other mobile-device markets (including client markets for Chromebooks and notebook PCs), as well as into the automotive, industrial, and consumer markets.

NAND

NAND products are non-volatile, re-writeable semiconductor storage devices that provide high-capacity, low-cost storage with a variety of performance characteristics. NAND is used in SSDs for the enterprise and cloud, client, and consumer markets and in removable storage markets. Managed NAND is used in smartphones and other mobile devices, and in consumer, automotive, and embedded markets. Low-density NAND is ideal for applications like automotive, surveillance, machine-to-machine, automation, printer, and home networking.

NOR

NOR products are non-volatile re-writable semiconductor memory devices that provide fast read speeds. NOR is most commonly used for reliable code storage (e.g., boot, application, operating system, and execute-in-place code in an embedded system) and for frequently changing small data storage and is ideal for automotive, industrial, and consumer applications.

3D XPoint

3D XPoint is a class of non-volatile technology between DRAM and NAND in the memory and storage hierarchy. Effective as of March 4, 2021, we ceased development of 3D XPoint technology and products. We ceased producing 3D XPoint products in October 2021.

Reported Smelters and Refiners Used to Process 3TG Metals

Throughout 2021, we worked with our suppliers in an effort to source only from smelters and refiners that were validated as Conformant with a responsibly-sourced auditing program. We identified 219 smelters and refiners that are recognized by RMI, LBMA, or RJC to be processors of 3TG metals and that we believe were potentially in our memory and storage products supply chain for the year ended December 31, 2021, none of which had a Non-Conformant status with RMI at the time they entered our supply chain. Eleven smelters and refiners that were reported to be in our memory and storage products supply chain during 2021 were subsequently determined to be inoperative or removed on or prior to December 31, 2021. We determined that 208 smelters and refiners were in our memory and storage products supply chain as of December 31, 2021, of which 204 were validated as Conformant and four were listed as Active with RMI.

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Many of our suppliers reported smelter and refiner information at the company level rather than limiting their responses to smelters and refiners associated with products sold to Micron. As a result, some reported smelters and refiners may not be associated with our memory and storage products. Appendix A sets forth a list of the names and locations of all of the smelters and refiners in our memory and storage products supply chain as reported by our suppliers for the year ended December 31, 2021.

Aggregated Countries of Origin of 3TG Metals

Our due diligence efforts did not result in sufficient information to conclusively determine the countries of origin of all 3TG metals in our products. Appendix B sets forth a list of countries of origin of 3TG metals that may be in our products based on information provided to us by our suppliers and RMI, which is available to us (and is therefore being disclosed) on an aggregated basis only for RMAP Conformant smelters.

Efforts to Determine the Mine or Location of Origin

RMI has an established audit protocol to assess whether smelters and refiners of 3TG metals employed policies, practices, and procedures to source responsibly-sourced minerals. RMI, through the RMAP, collects and provides access for its members to certain information regarding the origin of minerals processed at RMAP responsibly-sourced smelters and refiners.

We required the suppliers in our memory and storage products supply chain to complete the RMI CMRT, which requested information regarding the mine or location of origin of necessary conflict minerals processed by the smelters and refiners our suppliers identified as potentially associated with our 3TG metals supply chain. We reviewed the supplier responses as well as information available through the RMI on the mine or location of origin of 3TG metals processed by these smelters and refiners collectively. Because we were unable to confirm the supplier data, our list of the countries of origin in Appendix B reflects the aggregated list of countries provided by RMI for RMAP responsibly-sourced smelters and refiners.

4. 2022 Due Diligence Improvement Measures

During the 2022 reporting year, Micron intends to:

Continue to engage with and provide active participation and leadership in the various RMI working groups;

Continue to proactively work with all suppliers in an effort to accomplish our goal that all smelters and refiners in our supply chain are Conformant;

Continue to refine and improve our escalation processes to ensure quick remediation, including removal, of any smelter or refiner that loses Conformant status; and

Expand our responsible minerals program to ensure responsible sourcing of additional minerals and include more geographies as practicable in line with industry standards and RMI capabilities and programs.

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This Conflict Minerals Report contains forward looking statements related to our conflict minerals due diligence programs for 2022. We wish to caution you that such statements are predictions and that actual events or results may differ materially. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, levels of activity, performance or achievements. We are under no duty to update any of the forward-looking statements after the date of this Report to conform these statements to actual results.
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Appendix A
Reported 3TG Smelters and Refiners List

This table provides the names and locations of all of the smelters and refiners in our memory and storage products supply chain as reported by our suppliers for the year ended December 31, 2021. The smelter and refiner names and locations appear as they are listed in the RMI Smelter Database as of January 28, 2022. We cannot confirm that any or all smelters and refiners in this table processed the necessary 3TG metals contained in our products, as many of our in-scope suppliers identified all smelters and refiners in their total supply chain rather than just those smelters and refiners associated with products sold to us.

MetalSmelter or Refinery NameLocation
Gold8853 S.p.A.Italy
GoldAdvanced Chemical CompanyUnited States
GoldAgosi AGGermany
GoldAl Etihad Gold Refinery DMCCUnited Arab Emirates
GoldAlmalyk Mining and Metallurgical Complex (AMMC)Uzbekistan
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazil
GoldArgor-Heraeus S.A.Switzerland
GoldAsahi Pretec Corp.Japan
GoldAsahi Refining Canada Ltd.Canada
GoldAsahi Refining USA Inc.United States
GoldAU Traders and Refiners*South Africa
GoldAurubis AGGermany
GoldBangalore RefineryIndia
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)Philippines
GoldBoliden ABSweden
GoldC. Hafner GmbH + Co. KGGermany
GoldCCR Refinery - Glencore Canada CorporationCanada
GoldCendres + Metaux S.A.Switzerland
GoldChimet S.p.A.Italy
GoldChugai Mining*Japan
GoldDowaJapan
GoldEmirates Gold DMCCUnited Arab Emirates
GoldGold Refinery of Zijin Mining Group Co., Ltd.China
GoldHeimerle + Meule GmbHGermany
GoldHeraeus Germany GmbH Co. KGGermany
GoldHeraeus Metals Hong Kong Ltd.China
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.China
GoldIshifuku Metal Industry Co., Ltd.Japan
GoldIstanbul Gold RefineryTurkey
GoldItalpreziosiItaly
GoldJapan MintJapan



MetalSmelter or Refinery NameLocation
GoldJiangxi Copper Co., Ltd.China
GoldJSC Novosibirsk RefineryRussia
GoldJSC UralelectromedRussia
GoldJX Nippon Mining & Metals Co., Ltd.Japan
GoldKazzincKazakhstan
GoldKennecott Utah Copper LLCUnited States
GoldKGHM Polska Miedz Spolka AkcyjnaPoland
GoldKojima Chemicals Co., Ltd.Japan
GoldKorea Zinc Co., Ltd.South Korea
GoldKyrgyzaltyn JSC*Kyrgyzstan
GoldL'Orfebre S.A.Andorra
GoldLS-NIKKO Copper Inc.South Korea
GoldLT Metal Ltd.South Korea
GoldMarsam MetalsBrazil
GoldMaterion*United States
GoldMatsuda Sangyo Co., Ltd.Japan
GoldMetalor Technologies (Hong Kong) Ltd.China
GoldMetalor Technologies (Singapore) Pte., Ltd.Singapore
GoldMetalor Technologies (Suzhou) Ltd.China
GoldMetalor Technologies S.A.Switzerland
GoldMetalor USA Refining CorporationUnited States
GoldMetalurgica Met-Mex Penoles S.A. De C.V.Mexico
GoldMitsubishi Materials CorporationJapan
GoldMitsui Mining and Smelting Co., Ltd.Japan
GoldMMTC-PAMP India Pvt., Ltd.India
GoldMoscow Special Alloys Processing PlantRussia
GoldNadir Metal Rafineri San. Ve Tic. A.S.Turkey
GoldNavoi Mining and Metallurgical CombinatUzbekistan
GoldNihon Material Co., Ltd.Japan
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustria
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russia
GoldPAMP S.A.Switzerland
GoldPlanta Recuperadora de Metales SpAChile
GoldPrioksky Plant of Non-Ferrous MetalsRussia
GoldPT Aneka Tambang (Persero) TbkIndonesia
GoldPX Precinox S.A.Switzerland
GoldRand Refinery (Pty) Ltd.South Africa
GoldRoyal Canadian MintCanada
GoldSAAMPFrance
GoldSafimet S.p.AItaly
GoldSamduck Precious MetalsSouth Korea



MetalSmelter or Refinery NameLocation
GoldSAXONIA Edelmetalle GmbHGermany
GoldSEMPSA Joyeria Plateria S.A.Spain
GoldShandong Gold Smelting Co., Ltd.China
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.China
GoldSichuan Tianze Precious Metals Co., Ltd.China
GoldSingway Technology Co., Ltd.Taiwan
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussia
GoldSolar Applied Materials Technology Corp.Taiwan
GoldSumitomo Metal Mining Co., Ltd.Japan
GoldT.C.A S.p.AItaly
GoldTanaka Kikinzoku Kogyo K.K.Japan
GoldTokuriki Honten Co., Ltd.Japan
GoldTOO Tau-Ken-AltynKazakhstan
GoldTSK Pretech*South Korea
GoldUmicore Precious Metals ThailandThailand
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgium
GoldUnited Precious Metal Refining, Inc.United States
GoldValcambi S.A.Switzerland
GoldWestern Australian Mint (T/a The Perth Mint)Australia
GoldWIELAND Edelmetalle GmbHGermany
GoldYamakin Co., Ltd.Japan
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChina
TantalumAMG BrasilBrazil
TantalumAsaka Riken Co., Ltd.*Japan
TantalumChangsha South Tantalum Niobium Co., Ltd.China
TantalumD Block Metals, LLCUnited States
TantalumExotech Inc.United States
TantalumF&X Electro-Materials Ltd.China
TantalumFIR Metals & Resource Ltd.China
TantalumGlobal Advanced Metals AizuJapan
TantalumGlobal Advanced Metals BoyertownUnited States
TantalumH.C. Starck Hermsdorf GmbHGermany
TantalumH.C. Starck Inc.United States
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.China
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.China
TantalumJiangxi Tuohong New Raw MaterialChina
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
TantalumJiujiang Tanbre Co., Ltd.China
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.China
TantalumKEMET de MexicoMexico
TantalumMeta Materials*Macedonia



MetalSmelter or Refinery NameLocation
TantalumMetallurgical Products India Pvt., Ltd.India
TantalumMineracao Taboca S.A.Brazil
TantalumMitsui Mining and Smelting Co., Ltd.Japan
TantalumNingxia Orient Tantalum Industry Co., Ltd.China
TantalumNPM Silmet ASEstonia
TantalumResind Industria e Comercio Ltda.Brazil
TantalumSolikamsk Magnesium Works OAORussia
TantalumTANIOBIS Co., Ltd.Thailand
TantalumTANIOBIS GmbHGermany
TantalumTANIOBIS Japan Co., Ltd.Japan
TantalumTANIOBIS Smelting GmbH & Co. KGGermany
TantalumTelex MetalsUnited States
TantalumUlba Metallurgical Plant JSCKazakhstan
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChina
TantalumXinXing HaoRong Electronic Material Co., Ltd.China
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
TinAlphaUnited States
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.China
TinChifeng Dajingzi Tin Industry Co., Ltd.China
TinChina Tin Group Co., Ltd.China
TinCV Venus Inti Perkasa***Indonesia
TinEM VintoBolivia
TinFenix MetalsPoland
TinGejiu Fengming Metallurgy Chemical Plant*China
TinGejiu Kai Meng Industry and Trade LLCChina
TinGejiu Non-Ferrous Metal Processing Co., Ltd.China
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.China
TinGejiu Zili Mining And Metallurgy Co., Ltd.China
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.China
TinHuiChang Hill Tin Industry Co., Ltd.China
TinJiangxi New Nanshan Technology Ltd.China
TinLuna Smelter, Ltd.Rwanda
TinMagnu's Minerais Metais e Ligas Ltda.Brazil
TinMalaysia Smelting Corporation (MSC)Malaysia
TinMelt Metais e Ligas S.A.Brazil
TinMetallic Resources, Inc.United States
TinMetallo Belgium N.V.Belgium
TinMetallo Spain S.L.U.Spain
TinMineracao Taboca S.A.Brazil
TinMinsurPeru
TinOperaciones Metalurgicas S.A.Bolivia



MetalSmelter or Refinery NameLocation
TinPT Artha Cipta LanggengIndonesia
TinPT ATD Makmur Mandiri JayaIndonesia
TinPT Babel Inti PerkasaIndonesia
TinPT Babel Surya Alam LestariIndonesia
TinPT Bangka SerumpunIndonesia
TinPT Menara Cipta MuliaIndonesia
TinPT Mitra Stania PrimaIndonesia
TinPT Mitra Sukses Globalindo***Indonesia
TinPT Prima Timah UtamaIndonesia
TinPT Rajawali Rimba PerkasaIndonesia
TinPT Rajehan Ariq*Indonesia
TinPT Refined Bangka TinIndonesia
TinPT Sariwiguna BinasentosaIndonesia
TinPT Stanindo Inti PerkasaIndonesia
TinPT Timah Nusantara***Indonesia
TinPT Timah Tbk KundurIndonesia
TinPT Timah Tbk MentokIndonesia
TinPT Tinindo Inter NusaIndonesia
TinResind Industria e Comercio Ltda.Brazil
TinRui Da HungTaiwan
TinSoft Metais Ltda.Brazil
TinThai Nguyen Mining and Metallurgy Co., Ltd.Vietnam
TinThaisarcoThailand
TinTin Smelting Branch of Yunnan Tin Co., Ltd.**China
TinTin Technology & RefiningUnited States
TinWhite Solder Metalurgia e Mineracao Ltda.Brazil
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.China
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.China
TungstenA.L.M.T. Corp.Japan
TungstenACL Metais EireliBrazil
TungstenAsia Tungsten Products Vietnam Ltd.Vietnam
TungstenChenzhou Diamond Tungsten Products Co., Ltd.China
TungstenChina Molybdenum Tungsten Co., Ltd.China
TungstenChongyi Zhangyuan Tungsten Co., Ltd.China
TungstenFujian Ganmin RareMetal Co., Ltd.China
TungstenGanzhou Haichuang Tungsten Co., Ltd.China
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.China
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
TungstenGanzhou Seadragon W & Mo Co., Ltd.China
TungstenGlobal Tungsten & Powders Corp.United States
TungstenGuangdong Xianglu Tungsten Co., Ltd.China



MetalSmelter or Refinery NameLocation
TungstenH.C. Starck Tungsten GmbHGermany
TungstenHunan Chenzhou Mining Co., Ltd.China
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.China
TungstenHydrometallurg, JSCRussia
TungstenJapan New Metals Co., Ltd.Japan
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.China
TungstenKennametal FallonUnited States
TungstenKennametal HuntsvilleUnited States
TungstenMalipo Haiyu Tungsten Co., Ltd.China
TungstenMasan High-Tech MaterialsVietnam
TungstenMoliren Ltd.Russia
TungstenNiagara Refining LLCUnited States
TungstenTANIOBIS Smelting GmbH & Co. KGGermany
TungstenTejing (Vietnam) Tungsten Co., Ltd.*Vietnam
TungstenUnecha Refractory metals plantRussia
TungstenWolfram Bergbau und Hutten AGAustria
TungstenWoltech Korea Co., Ltd.*South Korea
TungstenXiamen Tungsten (H.C.) Co., Ltd.China
TungstenXiamen Tungsten Co., Ltd.China
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.China

*    The smelter/refiner was reported to be in our memory and storage products supply chain during 2021 and was subsequently determined to be inoperative or removed on or prior to December 31, 2021. Up-to-date information on the validation status of smelters and refiners participating in the RMAP is available at responsiblemineralsinitiative.org/smelters-refiners-lists.
**    The smelter/refiner became Conformant after December 31, 2021.
***    The smelter/refiner was listed as Active with RMI as of December 31, 2021 and continues to be in the process of removal from our supply chain as of the date of filing of this Report.



Appendix B
Aggregated Countries of Origin List

This table sets forth an aggregated list of countries (or regions) of origin for 3TG metals that may be in our products based on information available from RMI on countries of origin for smelters or refiners that have been validated as Conformant with the RMAP. Due to confidential business information concerns, RMI provides this country of origin information on an aggregated basis. This table reflects information available from RMI as of December 31, 2021.

AndorraEl SalvadorLithuaniaSingapore
AngolaEritreaLuxembourgSint Maarten
Antigua and BarbudaEstoniaMacauSlovakia
ArgentinaEthiopiaMadagascarSlovenia
ArmeniaFijiMalaysiaSolomon Islands
AustraliaFinlandMaliSouth Africa
AustriaFranceMaltaSouth Korea
AzerbaijanFrench GuianaMauritaniaSpain
BahamasGabonMexicoSri Lanka
BahrainGeorgiaMonacoSt Lucia
BangladeshGermanyMongoliaSt Vincent and Grenadines
BarbadosGhanaMontenegroSudan
BelarusGreeceMoroccoSuriname
BelgiumGrenadaMozambiqueSwaziland
BeninGuatemalaMyanmarSweden
BoliviaGuernseyNamibiaSwitzerland
Bosnia & HerzegovinaGuineaNetherlandsTaiwan
BotswanaGuyanaNew ZealandTajikistan
BrazilHaitiNicaraguaTanzania
BulgariaHondurasNigerThailand
Burkina FasoHong KongNigeriaTogo
BurundiHungaryNorwayTrinidad and Tobago
CameroonIcelandOmanTunisia
CanadaIndiaPakistanTurkey
Cayman IslandsIndonesiaPanamaTurks and Caicos
ChileIrelandPapua New GuineaUganda
ChinaIsraelPeruUkraine
ColombiaItalyPhilippinesUnited Arab Emirates
Democratic Republic of the CongoIvory CoastPolandUnited Kingdom
Costa RicaJapanPortugalUnited States
Cote d'IvoireJordanPuerto RicoUruguay
CroatiaKazakhstanQatarUzbekistan
CubaKenyaRomaniaVenezuela
CuracaoKrygyzstanRussiaVietnam
CyprusKuwaitRwandaVirgin Islands
CzechiaLaosSaint Kitts and NevisYemen
DenmarkLatviaSan MarinoZambia
DominicaLebanonSaudi ArabiaZimbabwe
Dominican RepublicLiberiaSenegal
EcuadorLibyaSerbia
EgyptLiechtensteinSierra Leone



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