Form SD ABB LTD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

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FORM SD

SPECIALIZED DISCLOSURE REPORT

Commission file number: 001-16429

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ABB Ltd

(Exact name of registrant as specified in its charter)

Switzerland

(Jurisdiction of incorporation or organization)

Affolternstrasse 44

CH-8050 Zurich

Switzerland

(Address of principal executive offices)

Richard A. Brown

Affolternstrasse 44

CH-8050 Zurich

Switzerland

Telephone: +41-43-317-7111

Facsimile: +41-43-317-7992

(Name, Telephone, E-mail and/or Facsimile number and Address of Company Contact Person)

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, 2020.

Introduction

ABB Ltd is a corporation organized under the laws of Switzerland. In this Form SD and the attached Conflict Minerals Report (included as Exhibit 1.01), “ABB”, the “Company”, “we”, and “our” refer to ABB Ltd and its consolidated subsidiaries. ABB is a foreign private issuer as defined under Rule 405 of Regulation C under the Securities Act of 1933 and Rule 3b-4 under the Securities Exchange Act of 1934. Our shares are currently listed on the SIX Swiss Exchange, the NASDAQ OMX Stockholm Exchange and the New York Stock Exchange (in the form of American Depositary Shares).

Conflict minerals are defined as cassiterite, columbite-tantalite and wolframite, and their derivatives, which are limited to tin, tantalum and tungsten, as well as gold (3TG). The functionality of a substantial portion of our global product portfolio relies on the use of direct materials, especially electronic components, which include amounts of tin, tantalum, tungsten or gold (necessary conflict minerals). For example, tin, tantalum, tungsten and gold are each contained respectively in weld wire, capacitors, electronic contacts and electrical connection coatings, each of which are components in many of our products. Our operating businesses and their products are described in more detail below.

In 2020, we operated our business through five businesses based on products and services. These businesses included: Electrification, Industrial Automation, Motion, Robotics & Discrete Automation, and (through July 1, 2020) Power Grids. We also have certain business operations relating to our remaining engineering, procurement, and construction (EPC) contracts, which are being wound down and managed in a separate business unit outside of those businesses. In December 2018, we announced an agreement to divest 80.1 percent of our Power Grids business to Hitachi Ltd which, was completed on July 1, 2020. The scope of our procedures included in this Form SD and the attached Conflict Minerals Report includes the operations of the Power Grids business for the first six months of 2020 and represents approximately 16% of our total suppliers sampled. The description of our businesses and their main products in 2020 is as follows:

·          Electrification: manufactures and sells electrical products and solutions which are designed to provide safe, smart and sustainable electrical flow from the substation to the socket. The portfolio of increasingly digital and connected solutions includes electric vehicle charging infrastructure, renewable power solutions, modular substation packages, distribution automation products, switchboard and panelboards, switchgear, UPS solutions, circuit breakers, measuring and sensing devices, control products, wiring accessories, enclosures and cabling systems and intelligent home and building solutions, designed to integrate and automate lighting, heating, ventilation, security and data communication networks. In February 2020 we completed the sale of our solar inverters business to FIMER S.p.A, and was not included in the scope of our suppliers sampled as the activity level was not material to the operations of the Business Area.

·          Industrial Automation: develops and sells a broad range of industry-specific, integrated automation and electrification systems and solutions, as well as digital solutions, lifecycle services and artificial intelligence applications for the process and hybrid industries. Products and solutions include process and discrete control technologies, advanced process control software and manufacturing execution systems, sensing, measurement and analytical instrumentation, electric ship propulsion systems and large turbochargers. In addition, the business  offers a comprehensive range of services ranging from repair to advanced services such as remote monitoring, preventive maintenance, asset performance management and cybersecurity services.

·          Motion: manufactures and sells drives, motors, generators, traction converters and mechanical power transmission products that are driving the low-carbon future for industries, cities, infrastructure and transportation. These products, digital technologies and related services enable industrial customers to increase energy efficiency, improve safety and reliability, and achieve precise control of their processes.

·          Robotics & Discrete Automation: develops and sells robotics and machinery automation solutions through two operating divisions. The Robotics division includes: industrial robots, software, robotic solutions and systems, field services, spare parts, and digital services. The Machine Automation division specializes in solutions based on its programmable logic controllers (PLC), industrial PCs (IPC), servo motion, transport systems and machine vision. Both divisions offer engineering and simulation software as well as a comprehensive range of digital solutions.

·          Power Grids:  offered a range of products, systems, service and software solutions across the power value chain of generation, transmission and distribution, to utility, industry, transport & infrastructure customers through July 1, 2020. These offerings addressed existing and evolving grid needs such as the integration of renewables, digital substations, network control solutions, microgrids and asset management. The portfolio included AC and DC transmission systems, substations, as well as a wide range of power, distribution and traction transformers and an array of high-voltage products, such as circuit breakers, switchgear and capacitors.

As ABB files reports with the U.S. Securities and Exchange Commission under Section 13(a) of the Securities Exchange Act of 1934, and is a user of necessary conflict minerals to produce its manufactured products, ABB is subject to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (17 CFR Parts 240 and 249b). ABB’s Policy on Conflict Minerals can be found at https://global.abb/group/en/about/supplying/material-compliance/conflict-minerals-policy. 

The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.

Section 1 - Conflict Minerals Disclosures

a.      We have concluded that during the 2020 calendar year:

                   i.      based on an analysis of our global product offering, we manufactured products containing conflict minerals and have determined that the use of these minerals was necessary to the functionality or production of these products.

                 ii.      based on the Reasonable Country of Origin Inquiry (RCOI) conducted (see below), we have reason to believe that a portion of the Company’s necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country¹ (collectively the “covered countries”) and may not be from recycled or scrap sources.

b.      Description of RCOI

We are a large organization and have manufacturing facilities located around the world. In 2020, we manufactured products in more than 500 product lines and had approximately 50,000 unique direct material suppliers.

To assess whether the necessary conflict minerals in our products originated from the covered countries, we performed a RCOI by identifying direct suppliers of products likely to contain 3TG and surveying a sample of these suppliers using the Conflict Minerals Reporting Template (CMRT) as developed and issued by the Responsible Minerals Initiative (RMI) of the Responsible Business Alliance (RBA) and the Global eSustainability Initiative (GeSI).

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1                       Adjoining countries of the Democratic Republic of the Congo are: Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia.  

During 2020, we focused on increasing the quality of responses from the sample of suppliers selected for surveying. We continue to utilize customized systems to track the link between the components purchased from our suppliers and our products allowing us to make a focused selection of the relevant suppliers of 3TG. We continue to require a high level of quality supplier response to be accepted. The response rate from our suppliers was in excess of 90% in both 2020 and 2019 as we continue to execute a structured due diligence process and provide training to our suppliers where needed.

In 2020, we selected approximately 3,500 suppliers to be surveyed based on the identification of components containing 3TG within ABB products. We continue to refine the selection process by reducing the numbers of suppliers invited whom do not supply ABB with 3TG. We believe our current RCOI and the number of surveyed suppliers provides a sufficient level of coverage that could allow us to appropriately assess the conflict status of our products.

As part of our RCOI, suppliers provided us the names of the original smelters/refiners used to process 3TG contained in their products. Based on the list of processing facilities we have compiled and based on smelter/refiner-specific country sourcing information we have received through our membership in the RMI, we believe that some of the necessary conflict minerals in our products may have originated from the covered countries and were not from recycled or scrap sources. Although most suppliers who responded to our survey were able to provide us with a list of the original smelters/refiners that they identified as being used to process 3TG contained in their products, most of our suppliers were unable to identify and represent which smelters/refiners were specifically used for the 3TG in the products or materials supplied to ABB. Therefore, the lists of smelters/refiners provided by suppliers may contain facilities that were not used to process 3TG contained in the components they provided to us.

c.      Disclosure of this Form and the Conflict Minerals report

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report are available on our website at https://global.abb/group/en/investors  under “Quarterly results and annual reports”, “2020”, “SEC & XBRL filings”.

Section 2 - Exhibits

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

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

Exhibit 1.01

Conflict Minerals Report

 ABB Ltd

For the year ended December 31, 2020

This Conflict Minerals Report (CMR) of ABB Ltd for the calendar year 2020 has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1” or the “Rule”). The Rule was adopted by the United States Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of such products. Conflict minerals are defined as cassiterite, columbite-tantalite and wolframite, and their derivatives, which are limited to tin, tantalum and tungsten, as well as gold (3TG). These requirements apply to SEC registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.

The functionality of a substantial portion of our global product portfolio relies on the use of direct materials, especially electronic components, which include amounts of tin, tantalum, tungsten or gold (necessary conflict minerals).  If a registrant can establish that their necessary conflict minerals originated from sources other than from a covered country¹, or are from recycled or scrap sources, they must submit a Form SD which describes their determination and the Reasonable Country of Origin Inquiry (RCOI) performed.

If a registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the covered countries and are not from recycled or scrap sources, or if they are unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody. The registrant must submit a Form SD together with a CMR annually to the SEC that includes a description of those due diligence measures.

Numerous terms in this report are defined in Rule 13p-1 and the associated Form SD and the reader is invited to refer to those sources. The report presented herein is not audited. 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.

Section 1: Due diligence framework

In accordance with Rule 13p-1, we undertook due diligence efforts, including the RCOI described in the associated Form SD, to determine whether the 3TG in our products originated from sources (e.g. suppliers, smelters, refiners, mines) that did not or do not directly or indirectly finance or benefit armed groups in the covered countries. We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework set forth in the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016) (the OECD Framework) and related supplements and its five-step framework.

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¹ The Democratic Republic of the Congo and its adjoining countries (Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda, or Zambia).

Section 2: Due diligence measures undertaken

Our due diligence measures to identify the sources of 3TG contained in our products continue to progress and improve. In 2020, our due diligence efforts focused on selecting a focused list of relevant suppliers and improving the quality of the supplier responses while maintaining the other existing company-wide measures. Our customized supply chain systems permit us to identify our suppliers of 3TG and therefore increase the efficiency of the RCOI process. Our due diligence efforts included the following five steps, consistent with the OECD Framework:

Step 1: Establish strong company management systems

We undertook the following measures to establish strong company management systems per Step 1 of the OECD Framework:

Our commitment

·          We continued to promote awareness of the conflict minerals program within ABB through a number of channels including targeted communications to specific employee groups as well as the maintenance of articles and videos on the Company’s intranet.

·          We maintained an external website dedicated to material compliance, including a statement on our position on conflict minerals. The “ABB Policy on Conflict Minerals” with respect to the sourcing of 3TG is published online at https://global.abb/group/en/about/supplying/material-compliance/conflict-minerals-policy. 

Supplier Engagement

·          We maintained and communicated our “Supplier Code of Conduct” which requires our suppliers to implement a policy regarding conflict minerals, to exercise due diligence in investigating the source of these minerals, and to respond in a timely manner to ABB’s requests for evidence of their compliance with these requirements.

·          As part of our supplier onboarding and evaluation process, we continued to invite all new suppliers to take an ABB-specific web-based training course on conflict minerals that covers the highlights of the relevant law and the importance of ethical sourcing to the industry and communicates ABB’s policy on conflict minerals. The training also includes guidance for our suppliers on how to complete the Conflict Minerals Reporting Template (CMRT) as developed and issued by the Responsible Minerals Initiative (RMI) of the Responsible Business Alliance (RBA) and the Global eSustainability Initiative (GeSI). In addition, all new suppliers are required to make an initial conflict minerals self-assessment which indicates if the supplier has taken this training course or an equivalent training.

·          We continued to require suppliers to adhere to the “ABB General Terms and Conditions for Purchase of Goods” which requires our suppliers to provide requested information regarding the use of 3TG in their products supplied to ABB. In addition (as described on our website), these terms and conditions require our suppliers to:

○         work towards ensuring that they do not have 3TG sourced from conflict mines in products supplied to ABB,

○         comply with the ABB Supplier Code of Conduct, including the sections relating to conflict minerals compliance,

○         take the necessary steps to demonstrate that any 3TG contained in the products supplied to ABB do not originate from mines that support or fund conflict within the covered countries, and

○         extend their search further down their supply chain, if necessary, to determine the source of specified minerals.

·          For suppliers who continued to provide us with inaccurate or incomplete responses we enhanced our supplier due diligence process by providing these suppliers with additional training in the form of webinars and other follow-up communications to assist in improving the response quality of such suppliers.

Internal Management Systems

·          Within our global organization, our operating businesses are directly responsible for executing our conflict minerals activities with support from a central project management team including representatives from legal and finance. The representatives from each of our operating businesses come from various backgrounds and have access to the full resources within their respective businesses, including the research and development, the engineering and the production departments. During 2020, senior supply chain managers were responsible for the program. The program was overseen by a Steering Committee and sponsored at the Group Executive Committee level.

·          We continued to provide our ABB-specific web-based training courses. These are customized for specific ABB employee groups (management, buyers, engineering, research and development, product sales and other). Each operating business’s conflict minerals leader identified key conflict minerals personnel to undergo mandatory training on conflict minerals.

Company Level Grievance Mechanism

·          We maintained our company-wide integrity reporting channels, such as the ABB Business Ethics Helpline, which is available for the reporting of any violations of our Supplier Code of Conduct including in relation to conflict minerals. The service provides a grievance mechanism and is maintained by an independent third party. It can be used by ABB employees as well as parties outside ABB, such as suppliers. The service allows for online reporting at www.compliancestakeholder.com and also provides a country-specific telephone number if this method of reporting is preferred.

Step 2: Identify and assess risks in the supply chain

To identify risks in the supply chain, we performed the following:

Use best efforts to identify the smelters/refiners in the supply chain

In 2020, we aimed to identify the smelters/refiners in our supply chain through the survey of approximately 3,500 relevant suppliers as described below. These suppliers identified 333 smelters/refiners of 3TG that were potentially in their supply chains. Our list of these smelters/refiners is included in Annex I, including a summary of their validation status under RMI’s Responsible Minerals Assurance Process (RMAP).

Identify the scope of the risk assessment of the 3TG supply chain

In 2020, we utilized our customized systems to track the link between the components purchased from our suppliers and our products allowing us to make a focused selection of the relevant suppliers of 3TG. Purchased components were evaluated, using ABB experts, including product engineers, material experts and research and development personnel, to determine if the component was likely to contain 3TG. These identified components were then categorized into different levels of risk, depending on the likelihood of 3TG content, the volume of transactions with the supplier and the total value of the components purchased. Based on these evaluations, and the enhanced data available from our information systems, we identified the relevant suppliers and prioritized which suppliers to survey, focusing on the highest-risk suppliers in terms of 3TG content and amount of products purchased. These suppliers were surveyed using the CMRT, as part of the RCOI described in Form SD.

Assess whether the suppliers have carried out all the elements of due diligence for responsible supply chains of 3TG from conflict-affected and high-risk areas

We have a structured process to send and receive supplier surveys, follow up on non-responses, summarize survey results, and identify and respond to red flags. Using the CMRT, we surveyed the selected suppliers to gather information about smelters/refiners in their supply chain and provide us with a list of those smelters/refiners. For most of our businesses, we have a dedicated team, in a global shared service center, who reviews the completeness of supplier responses and assesses whether suppliers appeared to have carried out their own appropriate supply chain due diligence. The review team assesses each response for “red flags” (as described in the OECD Framework) and then further assesses the completeness of the supplier response. To perform the survey process, one of our businesses utilizes a third-party service provider.

Our review process assessed the completeness and accuracy of the list of smelters/refiners provided in the survey responses. This included verifying the name and smelter status by checking against the Smelter Look-up tab list of the RMI’s CMRT and the RMI’s Conformant Smelter List.

Although the suppliers who responded to our survey were able to provide us with a list of the original smelters/refiners they identified as being used to process 3TG contained in their products, most of our suppliers were unable to identify and represent which smelters/refiners were specifically used for 3TG in the products or materials supplied to ABB. Our list of smelters/refiners identified to be processing or refining 3TG in our products is based on the responses received from our suppliers.

Where suppliers did not respond to the initial survey request, additional follow-up inquiries were made. Follow-up inquiries were also made on incomplete or inconsistent supplier responses, requesting additional information or clarification. In certain cases, the follow up was made by product buyers, who worked with suppliers to try to resolve insufficient responses.

For completed surveys, responses were evaluated against a pre-defined list of red flags to determine what corrective action, if any, was required for the identified risk. A corrective action plan was implemented for the identified red flags, including insufficient responses. Ultimately, the corrective action could include the discontinuation of sourcing from a supplier. Our red flag review process is based on guidance from the OECD Framework. When evaluating ongoing supplier relationships, the conflict minerals compliance status of the supplier was considered when determining the continued us of a supplier.

Step 3: Design and implement a strategy to respond to identified risks

Report findings to designated senior management

Throughout the supplier survey process, a management reporting dashboard was available to the conflict minerals senior management team on a real-time basis. This provided timely summary statistics on the supplier survey responses as well as the status of our overall risk assessment process. The dashboard also provided a summary of the number of responses requiring an escalation process to resolve response deficiencies or address identified red flags. The content of the dashboard was reviewed regularly by a central project team including a review of the progress on addressing responses subject to escalation. These results were reported to the Steering Committee which evaluated the appropriateness of risk mitigation measures.

Devise and adopt a risk management plan

In 2020, we contacted our suppliers who were identified to be sourcing 3TG from high-risk smelters/refiners. We sent each such supplier a letter requesting them: (1) to confirm whether the identified high-risk smelters/refiners are in

their supply chain and if materials from the identified high-risk smelters/refiners were in products supplied to ABB, (2) to encourage these smelters/refiners to participate in RMI’s RMAP, and (3) to develop a plan to remove any identified high-risk smelters/refiners from their supply chain if those smelters/refiners refuse to participate in the RMI’s RMAP.

Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices

We are a downstream consumer of 3TG. Generally, we do not purchase raw minerals or ores, and are normally several steps removed from smelters/refiners within our supply chain. Therefore, we do not perform direct audits of those smelters/refiners. We do support the RBA and GeSI’s RMI which is a measure contemplated by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which our Company’s systems (described in Step 1 above) are based. The data on which we relied for certain statements in this CMR was obtained through our membership in the RMI, using the Reasonable Country of Origin Inquiry report for member “ASEA”.

Step 5: Report annually on supply chain due diligence

This report and the associated Form SD are available online at https://global.abb/group/en/investors  under “Quarterly results and annual reports”, “2020”, “SEC Filings”.

Section 3: Results of due diligence

In 2020, despite challenges for many of our suppliers due to COVID-19 disruptions we received and accepted completed reporting templates from 85% of our surveyed suppliers (81% in 2019). The higher acceptance rates reflect the improvements in our supplier engagement efforts and escalation of non-responsive suppliers to the appropriate levels when needed.

Our suppliers are generally several tiers removed from the smelters/refiners of raw materials within their supply chain, and therefore have challenges in performing their due diligence. As a result, the information provided by our suppliers is often incomplete or is not verified, and we are therefore unable to verify with certainty the source and chain of custody of all the 3TG minerals in our supply chain.

In 2020, our supplier responses identified 333 smelters/refiners as being the source of 3TG in their products (297 in 2019). The complete lists of identified smelters/refiners are included in Annex I of this CMR. However, the suppliers only provided the country of origin of the 3TG in a limited number of cases. We obtained further sourcing information through our membership in the RMI which allows us access to the names of the countries of origin for 3TG processed by certain smelters/refiners.

The following table provides the number of smelters/refiners identified in our supply chain.

(1)       Audited and have been found to be conformant with the RMI’s Responsible Minerals Assurance Process (RMAP conformant).

(2)       In the process of being audited (RMAP Active). This category also includes smelters and refiners who are in communication but have not commenced the validation audit.

(3)       Have not commenced the RMAP validation audit.

Through our continued interaction with the RMI, we benefited from their activities, including their efforts to validate smelters as ‘RMAP conformant’ in line with current global standards. The percentage of the identified smelters/refiners which were designated as RMAP conformant in 2020 is 71% compared to 79% in 2019. The high percentage of RMAP conformant smelters/refiners reflects the strong participation of smelters/refiners in the RMI/RMAP audit process. In 2020, new smelters/refiners were onboarded by RMI but due to global travel restrictions, audits were not yet able to be completed. This had the effect of reducing the percentage of compliant smelters compared to 2019.

We have not been able to determine the conflict status for all smelters/refiners used in our supply chain. However, based on the information that we have received from our suppliers, we have not identified any smelters/refiners in our supply chain which are known to be sourcing 3TG that directly or indirectly finances or benefits armed groups in the covered countries.

As allowed by the Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule, issued by the SEC on April 29, 2014, ABB has not described its products as “DRC conflict free” or “having not been found to be ‘DRC conflict free’”.

Section 4: Continuous improvement efforts to mitigate risk

During 2021, we plan to take the following steps as part of our conflict minerals due diligence program:

·          continue to increase the CMRT response rate and quality of supplier responses by:

○     engaging directly with our suppliers to identify 3TG usage in the products provided to ABB,

○     providing additional conflict minerals training to suppliers including direct individual call support where suppliers are new or need additional information on ABB’s conflict minerals requirements,

·          continue to support the RMI and the membership initiatives to work with smelters/refiners to have them undergo the OECD aligned audit for responsible sourcing,

·          conduct smelter/refiner visits where practicable to provide face to face support,

·          continue to lead the RMI Asia smelter engagement team and also the gold outreach in India which involves working with gold refiners in India to educate and encourage them to undergo OECD-aligned responsible sourcing audits,

·          continue to follow the OECD due diligence guidance and attend industry events to support responsible sourcing,

·          engage with suppliers that are reporting nonconformant smelters/refiners to work with their upstream supply chain to encourage OECD aligned audit participation for smelters/refiners,

·          analyze the CMRT’s of suppliers and partner with businesses to review suppliers that are continuously reporting non conformant smelters/refiners, and

·          perform due diligence on our cobalt supply chain in 2021 by working with our suppliers to responsibly source smelters and refiners of cobalt.

Section 5: Independent audit

                As ABB has not concluded on the DRC conflict status for any of its products, this CMR does not require an independent private sector audit.

Annex I – Lists of smelters/refiners

The lists of smelters/refiners were produced by consolidating information we have received from our suppliers. We have provided conflict minerals training to our suppliers and independently verified the status of the smelters/refiners using RMI and other data, but we cannot guarantee that the data we have been provided is accurate or complete. In most cases suppliers have not been able to confirm that these smelters/refiners have been used in the products they have supplied to us because they were not able to provide their CMRTs at the product level. Therefore it is possible that the lists contain smelters/refiners which were not used to process 3TG contained in our products.

We generally do not have direct business relationships with any of the smelters/refiners listed below. In general, we are several tiers removed from smelters/refiners and therefore unable to exert direct influence over smelters/refiners. Due to the size of our supplier base and the complexity of global supply chains, we are also unable to clearly trace at what stage individual smelters/refiners enter the supply chain of our direct suppliers.

RMAP conformant smelters/refiners

RMAP participating smelters/refiners

Other smelters/refiners