Form SD RH

June 1, 2021 6:04 AM EDT

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 


 

Form SD

 

SPECIALIZED DISCLOSURE REPORT

 


 

GRAPHIC

(Exact name of the registrant as specified in charter)

 


 

DELAWARE

 

001-35720

 

45-3052669

(State or other jurisdiction of
incorporation or organization)

 

(Commission
File Number)

 

(IRS Employer
Identification No.)

 

15 Koch Road, Suite K
Corte Madera, CA

 


94925

(Address of principal executive offices)

 

(Zip code)

 

Jack Preston

(415) 945-3535

(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:

 

x          Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.

 

 

 


 

Section 1 Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

Conflict Minerals Disclosure

 

This Specialized Disclosure Report on Form SD of RH (the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2020 to December 31, 2020 (the “reporting period”).

 

The Company determined that during the reporting period, RH contracted to manufacture products as to which conflict minerals are necessary to the functionality or production of such products. As a result, the Company has conducted a good faith reasonable country of origin inquiry to determine whether the necessary conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or came from recycled or scrap sources. A description of our reasonable country of origin inquiry process, the result of the inquiry, and the determination we reached as a result of this inquiry process is included in our Conflict Minerals Report attached as Exhibit 1.01 to this Form SD.

 

A copy of the Conflict Minerals Report filed for the calendar year ended December 31, 2019 is publicly available electronically on the Investor Relations section of the Company’s website at ir.rh.com, by clicking on “Financials & Filings,” and then “SEC Filings.”

 

Item 1.02 Exhibit

 

The Conflict Minerals Report for the calendar year ended December 31, 2020 is filed as Exhibit 1.01 hereto.

 

Section 2 — Exhibits

 

Item 2.01 Exhibits

 

Exhibit 1.01 RH Conflict Minerals Report, as required by Items 1.01 and 1.02 of Form SD.

 

2


 

SIGNATURES

 

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

 

 

RH

 

 

 

 

Dated: May 27, 2021

By:

/s/ Jack Preston

 

Name:

Jack Preston

 

Title:

Chief Financial Officer

 

3


 

Exhibit 1.01

 

2020

 

Conflict Minerals Report of RH in Accordance with Rule 13p-1 under the Securities and Exchange Act of 1934

 

I. Introduction

 

1.                       Overview of our Conflict Minerals Report

 

This Conflict Minerals Report of RH (the “Company,” “us,” “we”) is prepared in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2020 to December 31, 2020 (the “reporting period”). RH is inclusive of its wholly-owned subsidiary Restoration Hardware, Inc. and its subsidiaries, including, but not limited to, the subsidiary that owns the business operating under the name “Waterworks.” The information provided in this Conflict Minerals Report on behalf of RH is inclusive of Waterworks, its products and supply chain.

 

The Rule requires issuers that manufacture or contract to manufacture products that contain conflict minerals that are necessary to the functionality or production of those products to, among other things, disclose annually whether any of those conflict minerals originated in the Covered Countries and if so, to submit a report to the Securities and Exchange Commission (the “SEC”) that includes a description of the measures they took to exercise due diligence on the conflict minerals’ source and chain of custody. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are limited to tantalum, tin and tungsten (the “conflict minerals”). The “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

 

2.                      Overview of our Supply Chain, Verification Process and Conflict Minerals Policy

 

During the reporting period, RH did not own or operate any manufacturing facilities that manufacture products that contain conflict minerals that are necessary to the functionality or production of those products. Instead, RH contracted and had relationships with third-party suppliers who manufacture products for RH that contain conflict minerals that are necessary to the functionality or production of those products. These products that the Company “contracts to manufacture,” as such term is referred to by the Rule, are herein referred to as the “Subject Products.” The Subject Products are manufactured for the Company through such suppliers’ own factories or factories with which such suppliers have commercial relationships. The Company must therefore rely on its third-party suppliers to provide information regarding the existence of conflict minerals in the Subject Products and their origin.

 

The Company relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from the smelters or refiners who may provide those minerals to companies in our supply chain. The Company is many steps removed from the mining of conflict minerals. The Company does not purchase raw or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries. The statements herein are based on the activities performed to date, in good faith, by the Company and on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions in the information provided by suppliers or smelters, ongoing identification of smelters in our supply chain, and incomplete information from industry or other third-party sources, among other factors.

 

We maintain a Conflict Minerals Policy that is incorporated into our Vendor’s Operation Manual (the “Vendor Manual”), which our suppliers are able to access via a secure website.

 

II. Description of Products Covered by this Conflict Minerals Report

 

RH offers merchandise assortments across a growing number of categories, including furniture, lighting, textiles, bathware, décor, outdoor and garden, and children’s furnishings. The Subject Products included products sold by the Company in the following categories: furniture, bathware, plumbing fixtures, lighting fixtures, kitchen and bath hardware, décor, outdoor and garden, and children’s furnishings.

 

III. Reasonable Country of Origin Inquiry

 

In accordance with the Rule, we conducted in good faith a reasonable country of origin inquiry (the “RCOI”) that was reasonably designed to determine whether any of the necessary conflict minerals in the Subject Products originated in the

 


 

Covered Countries or were from recycled or scrap sources.

 

To conduct our RCOI, we used a conflict minerals reporting template developed by the Responsible Minerals Initiative (“RMI”) (formerly Conflict Free Sourcing Initiative (“CFSI”)), an initiative founded by members of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI). We requested this information from our direct suppliers who manufacture our Subject Products.

 

Based on our RCOI, we have reason to believe that some of the necessary conflict minerals used in our Subject Products originated in the Covered Countries and may not have been from recycled or scrap sources. Accordingly, we conducted due diligence to determine the source and chain of custody of these conflict minerals.

 

IV. Due Diligence Process

 

We have designed our diligence efforts to generally conform to the Organization for Economic Cooperation and Development’s (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the “OECD Guidance”).

 

The OECD Guidance identifies five due diligence steps: (i) Establish Strong Company Management Systems; (ii) Identify and Assess Risks in the Supply Chain; (iii) Design and Implement a Strategy to Respond to Identified Risks; (iv) Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence; and (v) Report Annually on Supply Chain Due Diligence.

 

The due diligence steps that we executed included the following:

 

Step

 

OECD Guidance 
Steps

 

Due diligence activities performed by RH

1

 

Establish Strong Company Management Systems

 

Maintain Conflict Minerals Policy

·

We maintained a Conflict Minerals Policy that is published online, in our Vendor Manual.

 

 

 

 

 

 

 

 

 

 

 

Maintained Conflict Minerals Compliance Team

·

We maintained an internal conflict minerals team composed of a representative from the legal department and a representative from our vendor compliance team (the “Conflict Minerals Compliance Team”). The team was structured to ensure our annual conflict minerals due diligence was executed.

 

 

 

 

 

 

 

 

 

 

 

 

·

Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams.

 

 

 

 

 

 

 

 

 

 

 

Internal Engagement

·

We educated and continue educating relevant employees on our conflict minerals program and reporting obligations.

 

 

 

 

 

 

 

 

 

 

 

Supplier Engagement

·

We provided our direct suppliers information on conflict minerals and our disclosure requirements.

 

 

 

 

 

 

 

2

 

Identify and Assess Risks in the Supply Chain

 

Identified Products in Scope

·

Our Conflict Minerals Compliance Team conducted a review of the products contracted to be manufactured during the reporting period to identify suppliers that manufacture product categories and Subject Products that may contain conflict minerals.

 

 

 

 

 

 

 

 

 

 

 

Inquired about Due Diligence

·

We used the responses from our direct suppliers to the RMI reporting template to review their due diligence

 

2


 

 

 

 

 

Measures Performed by Direct Suppliers

 

activities, including whether they had adopted a conflict minerals policy, required their own suppliers to source from processing facilities validated by an independent audit firm, and implemented a review process that includes corrective action management.

 

 

 

 

 

 

 

 

 

 

 

 

·

As deemed appropriate by us, we followed up by email or phone with the suppliers who did not respond to our request to complete the RMI reporting template, or who submitted incomplete responses or responses that we determined may have contained errors or inaccuracies.

 

 

 

 

 

 

 

 

 

 

 

 

·

We employed a conflict minerals data management tool that tracks communications sent to direct suppliers and consolidates suppliers responses to the RMI template for analysis and reporting.

 

 

 

 

 

 

 

 

 

 

 

Identified Smelters

·

We collected a list of smelters/processors that are in our supply chain by utilizing the RMI reporting template via a web-based platform. We determined if the processing facilities adhere to responsible sourcing practices by reconciling that list to the list of facilities designated by the RMI Responsible Minerals Assurance Program (“RMAP”) as RMAP Conformant Smelters & Refiners and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit. We have provided lists of smelters/processors that are reported in our supply chain in Appendix A.

 

 

 

 

 

 

 

3

 

Design and Implement a Strategy to Respond to Identified Risks

 

Internal Reporting System

·

Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams.

 

 

 

 

 

 

 

 

 

 

 

Maintained Conflict Minerals Policy

·

We maintained a Conflict Minerals Policy that is published online, in our Vendor Manual.

 

 

 

 

 

 

 

 

 

 

 

Verified Smelters

·

As part of our risk mitigation process, we determined if the processing facilities identified in our supply chain adhere to responsible sourcing practices by reconciling the list of smelters collected from our direct suppliers to the list of smelter facilities that have been verified as complying with the RMAP and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit.

 

 

 

 

 

 

 

4

 

Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence

 

 

·

We relied on the RMI’s published lists to verify the RMAP compliance status of smelters/processors that are reported in our supply chain.

 

 

 

 

 

 

 

5

 

Report Annually on Supply Chain Due Diligence

 

 

·

This Conflict Minerals Report is filed with the SEC and publicly available on our website at ir.rh.com, by clicking on “Financials & Filings,” and then “SEC Filings.”

 

3


 

V. Review of Due Diligence Results

 

1.                       Facilities Used to Process Conflict Minerals in Subject Products

 

Based on our due diligence process and the information received from our direct suppliers, we have identified, in Appendix A, facilities that may have been used to process conflict minerals used in the Subject Products.

 

2.                               Country of Origin of Conflict Minerals in Subject Products

 

Based on the information provided by our direct suppliers, we have reason to believe that some of the products RH sold during the reporting year contain necessary conflict minerals that originated from the Covered Countries.  Sixteen of our direct suppliers indicated that products supplied to RH contained intentionally added conflict minerals necessary to the function and/or production of the product.  Of these sixteen direct suppliers: ten indicated that the products they sold to RH contained necessary conflict minerals that did not originate in the Covered Countries; three indicated that the products they sold to RH contained necessary conflict minerals originating in the Covered Countries (and one such supplier is required to file an annual conflict minerals disclosure with the SEC); and three did not know the country of origin of the necessary conflict minerals in their products, including if conflict minerals in finished products originated in the Covered Countries.  Three suppliers within this group also reported only using conflict minerals from 100% recycled or scrap sources.  In addition, 16% of our direct suppliers did not respond to our survey. Accordingly, notwithstanding our due diligence efforts, we were unable to determine the origin of a portion of conflict minerals contained in certain of the Subject Products.

 

3.                        Efforts to Identify the Mine or Location of Origin of the Conflict Minerals

 

Our reasonable country-of-origin inquiry and due diligence process described above represent our efforts to identify the mine or location of origin for the conflict minerals contained in the Subject Products for this reporting period.

 

VI. Steps To Be Taken To Mitigate Risk

 

RH intends to continue to require our suppliers to comply with our Conflict Minerals Policy and to keep it posted online in our Vendor Manual for all suppliers to access. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of conflict minerals will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. We expect that our direct suppliers will comply with our Conflict Minerals Policy and (i) provide appropriate information and conduct necessary due diligence to facilitate our compliance with the Rule, (ii) implement and communicate to their relevant personnel and suppliers policies that are consistent with the Policy, (iii) put in place procedures and contractual provisions for the traceability of conflict minerals, working with their suppliers as applicable, (iv) use reasonable efforts to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and (v) adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with our Conflict Minerals Policy.

 

In addition to the due diligence steps that we took during the reporting period, which we intend to continue for 2021 as applicable, we intend to communicate to new suppliers our sourcing expectations, including by disseminating our Conflict Minerals Policy to them.

 

VII. Independent Private Sector Audit

 

Not required for the reporting period.

 

Forward-Looking Statements

 

This Conflict Minerals Report contains forward-looking statements within the meaning of the federal securities laws including statements related to our business, products and conflict mineral efforts, including steps we intend to take in the future to mitigate the risk that the conflict minerals used in the Subject Products benefit the armed groups on the Covered Countries, our ability to monitor the progress of our suppliers or that our suppliers would comply with our Conflict Mineral Policy and our requests for timely and accurate information, our suppliers’ ability to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and the effectiveness of any of our risk management strategies to identify risks in the supply chain consistent with our Conflict Minerals Policy. You

 

4


 

can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. These statements may include words such as “anticipate,” “estimate,” “expect,” “project,” “plan,” “intend,” “believe,” “may,” “will,” “should,” “likely” and other words and terms of similar meaning in connection with any discussion of the timing or nature of future events. We cannot assure you that future developments affecting us will be those that we have anticipated. Important risks and uncertainties that may cause these forward-looking statements to differ materially from our expectations include, among others: failure to carry out our plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers; lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities); internal and external resource constraints; political developments in the Covered Countries and regulatory developments in the United States, as well as those risks and uncertainties disclosed under the sections entitled “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in RH Form 10-K filed with the SEC on March 30, 2021, and similar disclosures in subsequent reports filed with the SEC, which are available on our investor relations website at ir.rh.com and on the SEC website at www.sec.gov. Any forward-looking statement made by us in this Conflict Minerals Report speaks only as of the date on which we make it. We undertake no obligation to publicly update any forward-looking statement, whether as a result of new information, future developments or otherwise, except as may be required by any applicable securities laws.

 

5


 

Appendix A

 

Processing Facilities

 

Table 1. RMAP-conformant processing facilities as listed by RMI as of May 26, 2021

 

Processing facilities and their locations reported in our supply chain that are reported by RMI as conformant with the RMAP.

 

Mineral

 

Facility ID

 

Processing Facility Name

 

Country

Gold

 

CID001153

 

Metalor Technologies S.A.

 

SWITZERLAND

Gold

 

CID001622

 

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

 

CHINA

Gold

 

CID001916

 

The Refinery of Shandong Gold Mining Co., Ltd.

 

CHINA

Tantalum

 

CID000211

 

Changsha South Tantalum Niobium Co., Ltd.

 

CHINA

Tantalum

 

CID002504

 

D Block Metals, LLC

 

UNITED STATES OF AMERICA

Tantalum

 

CID000456

 

Exotech Inc.

 

UNITED STATES OF AMERICA

Tantalum

 

CID000460

 

F&X Electro-Materials Ltd.

 

CHINA

Tantalum

 

CID002505

 

FIR Metals & Resource Ltd.

 

CHINA

Tantalum

 

CID002558

 

Global Advanced Metals Aizu

 

JAPAN

Tantalum

 

CID002557

 

Global Advanced Metals Boyertown

 

UNITED STATES OF AMERICA

Tantalum

 

CID000616

 

Guangdong Zhiyuan New Material Co., Ltd.

 

CHINA

Tantalum

 

CID002544

 

H.C. Starck Co., Ltd.

 

THAILAND

Tantalum

 

CID002547

 

H.C. Starck Hermsdorf GmbH

 

GERMANY

Tantalum

 

CID002548

 

H.C. Starck Inc.

 

UNITED STATES OF AMERICA

Tantalum

 

CID002549

 

H.C. Starck Ltd.

 

JAPAN

Tantalum

 

CID002550

 

H.C. Starck Smelting GmbH & Co. KG

 

GERMANY

Tantalum

 

CID002545

 

H.C. Starck Tantalum and Niobium GmbH

 

GERMANY

Tantalum

 

CID002492

 

Hengyang King Xing Lifeng New Materials Co., Ltd.

 

CHINA

Tantalum

 

CID002512

 

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

 

CHINA

Tantalum

 

CID002842

 

Jiangxi Tuohong New Raw Material

 

CHINA

Tantalum

 

CID000914

 

JiuJiang JinXin Nonferrous Metals Co., Ltd.

 

CHINA

Tantalum

 

CID000917

 

Jiujiang Tanbre Co., Ltd.

 

CHINA

Tantalum

 

CID002506

 

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

 

CHINA

Tantalum

 

CID002539

 

KEMET Blue Metals

 

MEXICO

Tantalum

 

CID001076

 

LSM Brasil S.A.

 

BRAZIL

Tantalum

 

CID001163

 

Metallurgical Products India Pvt., Ltd.

 

INDIA

Tantalum

 

CID001175

 

Mineracao Taboca S.A.

 

BRAZIL

Tantalum

 

CID001192

 

Mitsui Mining and Smelting Co., Ltd.

 

JAPAN

Tantalum

 

CID001277

 

Ningxia Orient Tantalum Industry Co., Ltd.

 

CHINA

Tantalum

 

CID001200

 

NPM Silmet AS

 

ESTONIA

Tantalum

 

CID001508

 

QuantumClean

 

UNITED STATES OF AMERICA

Tantalum

 

CID002707

 

Resind Industria e Comercio Ltda.

 

BRAZIL

 

6


 

Tantalum

 

CID001769

 

Solikamsk Magnesium Works OAO

 

RUSSIAN FEDERATION

Tantalum

 

CID001869

 

Taki Chemical Co., Ltd.

 

JAPAN

Tantalum

 

CID001891

 

Telex Metals

 

UNITED STATES OF AMERICA

Tantalum

 

CID001969

 

Ulba Metallurgical Plant JSC

 

KAZAKHSTAN

Tantalum

 

CID002508

 

XinXing HaoRong Electronic Material Co., Ltd.

 

CHINA

Tantalum

 

CID001522

 

Yanling Jincheng Tantalum & Niobium Co., Ltd.

 

CHINA

Tin

 

CID000292

 

Alpha

 

UNITED STATES OF AMERICA

Tin

 

CID000228

 

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

 

CHINA

Tin

 

CID001070

 

China Tin Group Co., Ltd.

 

CHINA

Tin

 

CID000402

 

Dowa

 

JAPAN

Tin

 

CID000438

 

EM Vinto

 

BOLIVIA (PLURINATIONAL STATE OF)

Tin

 

CID000468

 

Fenix Metals

 

POLAND

Tin

 

CID000942

 

Gejiu Kai Meng Industry and Trade LLC

 

CHINA

Tin

 

CID000538

 

Gejiu Non-Ferrous Metal Processing Co., Ltd.

 

CHINA

Tin

 

CID001908

 

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

 

CHINA

Tin

 

CID000555

 

Gejiu Zili Mining And Metallurgy Co., Ltd.

 

CHINA

Tin

 

CID003116

 

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

 

CHINA

Tin

 

CID002844

 

HuiChang Hill Tin Industry Co., Ltd.

 

CHINA

Tin

 

CID000760

 

Huichang Jinshunda Tin Co., Ltd.

 

CHINA

Tin

 

CID001231

 

Jiangxi New Nanshan Technology Ltd.

 

CHINA

Tin

 

CID002468

 

Magnu’s Minerais Metais e Ligas Ltda.

 

BRAZIL

Tin

 

CID001105

 

Malaysia Smelting Corporation (MSC)

 

MALAYSIA

Tin

 

CID002500

 

Melt Metais e Ligas S.A.

 

BRAZIL

Tin

 

CID001142

 

Metallic Resources, Inc.

 

UNITED STATES OF AMERICA

Tin

 

CID002773

 

Metallo Belgium N.V.

 

BELGIUM

Tin

 

CID002774

 

Metallo Spain S.L.U.

 

SPAIN

Tin

 

CID001173

 

Mineracao Taboca S.A.

 

BRAZIL

Tin

 

CID001182

 

Minsur

 

PERU

Tin

 

CID001191

 

Mitsubishi Materials Corporation

 

JAPAN

Tin

 

CID001314

 

O.M. Manufacturing (Thailand) Co., Ltd.

 

THAILAND

Tin

 

CID002517

 

O.M. Manufacturing Philippines, Inc.

 

PHILIPPINES

Tin

 

CID001399

 

PT Artha Cipta Langgeng

 

INDONESIA

Tin

 

CID001453

 

PT Mitra Stania Prima

 

INDONESIA

Tin

 

CID001460

 

PT Refined Bangka Tin

 

INDONESIA

Tin

 

CID001477

 

PT Timah Tbk Kundur

 

INDONESIA

Tin

 

CID001482

 

PT Timah Tbk Mentok

 

INDONESIA

Tin

 

CID002706

 

Resind Industria e Comercio Ltda.

 

BRAZIL

 

7


 

Tin

 

CID001539

 

Rui Da Hung

 

TAIWAN, PROVINCE OF CHINA

Tin

 

CID001758

 

Soft Metais Ltda.

 

BRAZIL

Tin

 

CID001898

 

Thaisarco

 

THAILAND

Tin

 

CID003325

 

Tin Technology & Refining

 

UNITED STATES OF AMERICA

Tin

 

CID002036

 

White Solder Metalurgia e Mineracao Ltda.

 

BRAZIL

Tin

 

CID002158

 

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

 

CHINA

Tin

 

CID002180

 

Yunnan Tin Company Limited

 

CHINA

Tungsten

 

CID000004

 

A.L.M.T. Corp.

 

JAPAN

Tungsten

 

CID002833

 

ACL Metais Eireli

 

BRAZIL

Tungsten

 

CID002502

 

Asia Tungsten Products Vietnam Ltd.

 

VIET NAM

Tungsten

 

CID002513

 

Chenzhou Diamond Tungsten Products Co., Ltd.

 

CHINA

Tungsten

 

CID000258

 

Chongyi Zhangyuan Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID002645

 

Ganzhou Haichuang Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID000875

 

Ganzhou Huaxing Tungsten Products Co., Ltd.

 

CHINA

Tungsten

 

CID002315

 

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

 

CHINA

Tungsten

 

CID002494

 

Ganzhou Seadragon W & Mo Co., Ltd.

 

CHINA

Tungsten

 

CID000568

 

Global Tungsten & Powders Corp.

 

UNITED STATES OF AMERICA

Tungsten

 

CID000218

 

Guangdong Xianglu Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID002542

 

H.C. Starck Smelting GmbH & Co. KG

 

GERMANY

Tungsten

 

CID002541

 

H.C. Starck Tungsten GmbH

 

GERMANY

Tungsten

 

CID000766

 

Hunan Chenzhou Mining Co., Ltd.

 

CHINA

Tungsten

 

CID000769

 

Hunan Chunchang Nonferrous Metals Co., Ltd.

 

CHINA

Tungsten

 

CID002649

 

Hydrometallurg, JSC

 

RUSSIAN FEDERATION

Tungsten

 

CID000825

 

Japan New Metals Co., Ltd.

 

JAPAN

Tungsten

 

CID002551

 

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

 

CHINA

Tungsten

 

CID002321

 

Jiangxi Gan Bei Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID002318

 

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

 

CHINA

Tungsten

 

CID002317

 

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

 

CHINA

Tungsten

 

CID002316

 

Jiangxi Yaosheng Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID000966

 

Kennametal Fallon

 

UNITED STATES OF AMERICA

Tungsten

 

CID000105

 

Kennametal Huntsville

 

UNITED STATES OF AMERICA

Tungsten

 

CID002319

 

Malipo Haiyu Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID002543

 

Masan Tungsten Chemical LLC (MTC)

 

VIET NAM

Tungsten

 

CID002845

 

Moliren Ltd.

 

RUSSIAN FEDERATION

Tungsten

 

CID002589

 

Niagara Refining LLC

 

UNITED STATES OF AMERICA

Tungsten

 

CID002827

 

Philippine Chuangxin Industrial Co., Inc.

 

PHILIPPINES

 

8


 

Tungsten

 

CID002724

 

Unecha Refractory metals plant

 

RUSSIAN FEDERATION

Tungsten

 

CID002044

 

Wolfram Bergbau und Hutten AG

 

AUSTRIA

Tungsten

 

CID002843

 

Woltech Korea Co., Ltd.

 

KOREA, REPUBLIC OF

Tungsten

 

CID002320

 

Xiamen Tungsten (H.C.) Co., Ltd.

 

CHINA

Tungsten

 

CID002082

 

Xiamen Tungsten Co., Ltd.

 

CHINA

Tungsten

 

CID002830

 

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

 

CHINA

 

Table 2. RMAP-participating processing facilities as listed by RMI as of May 26, 2021

 

Processing facilities and their locations reported in our supply chain that are reported by RMI as active with the RMAP.

 

Mineral

 

Facility ID

 

Processing Facility Name

 

Country

Tin

 

CID000448

 

Estanho de Rondonia S.A.

 

BRAZIL

Tin

 

CID002756

 

Super Ligas

 

BRAZIL

 

Table 3. RMAP-non-participating processing facilities as of May 26, 2021

 

Processing facilities and their locations reported in our supply chain that are not reported as either compliant with or participating in the RMAP.

 

Mineral

 

Facility ID

 

Processing Facility Name

 

Country

Gold

 

Not Listed

 

Daffara Dorature

 

ITALY

Gold

 

Not Listed

 

Morvillo & Son

 

UNITED STATES OF AMERICA

Gold

 

Not Listed

 

SHR Precious Metals, Inc.

 

UNITED STATES OF AMERICA

Tin

 

Not Listed

 

Almag

 

ITALY

Tin

 

CID002703

 

An Vinh Joint Stock Mineral Processing Company

 

VIET NAM

Tin

 

Not Listed

 

Dongguan Best Allows Co., Ltd

 

CHINA

Tin

 

Not Listed

 

Heshan Jinyi Copper Co., Ltd

 

CHINA

Tin

 

Not Listed

 

Lee Kee Group

 

CHINA

Tin

 

CID002573

 

Nghe Tinh Non-Ferrous Metals Joint Stock Company

 

VIET NAM

Tin

 

Not Listed

 

Prandelli Lorenzo & Figli SRL

 

ITALY

Tin

 

Not Listed

 

Suzhou Honlux Copperalloy Material Co., LTD

 

CHINA

Tin

 

Not Listed

 

Tomghsia Industrial Co., Ltd

 

TAIWAN, PROVINCE OF CHINA

Tin

 

Not Listed

 

Trafilerie Carlo Gnutti

 

ITALY

Tin

 

CID002574

 

Tuyen Quang Non-Ferrous Metals Joint Stock Company

 

VIET NAM

 

9




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