Form SD ABB LTD
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Commission file number: 001-16429
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:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
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 2019, we operated our business through five businesses based on products and services. These businesses included: Electrification, Industrial Automation, Motion, Robotics & Discrete Automation, and 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 the five operating businesses. In December 2018, we announced an agreement to divest 80.1 percent of our Power Grids business to Hitachi Ltd which is expected to be completed at the end of the second quarter of 2020. The scope of our procedures included in this Form SD and the attached Conflict Minerals Report continue to include the operations of the Power Grids business. The description of our businesses and their main products in 2019 is as follows:
· Electrification: manufactures and sells products and solutions which are designed to provide smarter and safer electrical flow from the substation to the socket. The portfolio of increasingly digital and connected solutions includes electric vehicle charging infrastructure, solar 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. During 2019, we reached an agreement to sell our solar inverters business to FIMER S.p.A. and completed the sale in the first quarter of 2020.
· Industrial Automation: develops and sells integrated automation and electrification systems and solutions, such as process and discrete control solutions, advanced process control software and manufacturing execution systems, sensing, measurement and analytical instrumentation and solutions, electric ship propulsion systems, as well as large turbochargers. In addition, the business offers a comprehensive range of services ranging from repair to advanced services such as remote monitoring, preventive maintenance and cybersecurity services.
· Motion: manufactures and sells motors, generators, drives, wind converters, mechanical power transmissions, complete electrical powertrain systems and related services and digital solutions for a wide range of applications in industry, transportation, infrastructure, and utilities.
· Robotics & Discrete Automation: develops and sells robotics and machinery automation solutions, including robots, controllers, software, function packages, cells, programmable logic controllers (PLC), industrial PCs (IPC), servo motion, engineered manufacturing solutions, turn-key solutions and collaborative robot solutions for a wide range of applications. In addition, the business offers a comprehensive range of digital solutions as well as field and after sales service.
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· Power Grids: offers 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. These offerings address existing and evolving grid needs such as the integration of renewables, digital substations, network control solutions, microgrids and asset management. The division portfolio includes 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 new.abb.com/about/supplying/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 2019 calendar year:
| i. | based on an analysis of our global product offering, we have manufactured products containing conflict minerals and have determined that the use of these minerals is 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. We manufacture products in more than 500 product lines and have 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).
During 2019, we focused on increasing the quality 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. In 2019, the coverage of our supplier survey was expanded to include the acquired GE Industrial Solutions business, which was acquired in 2018. We also increased the level of quality required for a supplier response to be accepted and in several cases we removed uncooperative suppliers from the supply chain. The response rate from suppliers was higher in 2019 (94%) versus 2018 (91%) due to a increase in acceptable CMRT quality from suppliers, showing the results of our improved due diligence process and supplier training.
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.
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In 2019, we selected our suppliers for surveying based on the identification of components containing 3TG within ABB products. Based on this evaluation, we selected approximately 5,000 suppliers to be surveyed. We believe our current RCOI and the number of surveyed suppliers provides a sufficient level of coverage that we believe 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 by them 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 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 Web site at www.abb.com/investorrelations under “Quarterly results and annual reports”, “2019”, “SEC Filings”.
Section 2 - Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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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.
| ABB LTD | |||
| By: | /s/ Timo Ihamuotila | ||
| Date: May 27, 2020 | Name: | Timo Ihamuotila | |
| Title: | Executive Vice President and Chief Financial Officer | ||
| By: | /s/ Richard A. Brown | ||
| Date: May 27, 2020 | Name: | Richard A. Brown | |
| Title: | Group Senior Vice President and Chief Counsel Corporate & Finance | ||
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Exhibit 1.01
Conflict Minerals Report
ABB Ltd
For the year ended December 31, 2019
This Conflict Minerals Report (CMR) of ABB Ltd for the calendar year 2019 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.
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).
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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 2019, 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 now 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 communication channels including targeted communications to specific employee groups including the maintenance of articles and information 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 new.abb.com/about/supplying/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 Web site), 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. |
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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 as well as other corporate services including legal, technology, 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 2019, 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 various 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 Hotline, which is available for the reporting of any violations of our Supplier Code of Conduct by our suppliers, including requirements related to conflict minerals. The hotline 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 hotline can be reached by dialing +41-43-317-3367 or by using an internet-based interface at www.compliancestakeholder.com. |
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 2019, we aimed to identify the smelters/refiners in our supply chain through the survey of 4,745 relevant suppliers as described below. These suppliers identified 297 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 2019, 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 are evaluated, using ABB experts, including product engineers, material experts and research and development personnel, to determine if the component is likely to contain 3TG. These identified components are 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 covering 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.
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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 was 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. To assess the accuracy of each of the suppliers’ responses, we also compared the names of the reported smelters/refiners against a list received from the RMI of known smelters/refiners, including their conflict status.
For completed surveys, responses were evaluated against a pre-defined list of red flags to determine what corrective action, if any, would be 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 reflects guidance from the OECD Framework. When evaluating ongoing supplier relationships, the conflict minerals compliance status of the supplier was considered when determining the continuation of use for a supplier and in several cases, supplier relationships with non-cooperative suppliers were terminated.
Step 3: Design and implement a strategy to respond to identified risks
Report findings to designated senior management
Throughout the progress of the supplier survey process, a management reporting dashboard was available to the conflict minerals senior management team on a real-time basis. This provides timely summary statistics on the supplier survey responses as well as the status of our overall risk assessment process. The dashboard also provides a summary of the number of responses currently 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 also reported to the Steering Committee which evaluated the appropriateness of risk mitigation measures.
Devise and adopt a risk management plan
In 2019, 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 refuses to participate in the RMI’s RMAP.
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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 new.abb.com/investorrelations under “Quarterly results and annual reports”, “2019”, “SEC Filings”.
Section 3: Results of due diligence
In 2019, we received and accepted completed reporting templates from 81% of our surveyed suppliers (77% in 2018). We are in dialogue with the remaining suppliers who provided us with an incomplete or inconsistent response.
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 2019, our supplier responses identified 297 smelters/refiners as being the source of 3TG in their products (309 in 2018). 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.
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The following tables provide the number of smelters/refiners identified in our supply chain.
| Identified Smelters/Refiners | ||||||||||||||||||||||||
| RMAP Conformant Smelters/Refiners(1) | RMAP Participating Smelters/Refiners(2) | Other Smelters/Refiners(3) | Total identified | |||||||||||||||||||||
| 2018 | 2019 | 2018 | 2019 | 2018 | 2019 | 2018 | 2019 | |||||||||||||||||
| Gold | 102 | 107 | 7 | 7 | 32 | 36 | 141 | 150 | ||||||||||||||||
| Tantalum | 40 | 38 | - | - | - | - | 40 | 38 | ||||||||||||||||
| Tin | 77 | 47 | 2 | 2 | 7 | 9 | 86 | 58 | ||||||||||||||||
| Tungsten | 40 | 43 | 1 | 7 | 1 | 1 | 42 | 51 | ||||||||||||||||
| Total | 259 | 235 | 10 | 16 | 40 | 46 | 309 | 297 | ||||||||||||||||
| Identified Smelters/Refiners known to be sourcing from the covered countries | ||||||||||||||||||||||||
| RMAP Conformant Smelters/Refiners(1) | RMAP Participating Smelters/Refiners(2) | Other Smelters/Refiners(3) | Total identified | |||||||||||||||||||||
| 2018 | 2019 | 2018 | 2019 | 2018 | 2019 | 2018 | 2019 | |||||||||||||||||
| Gold | 3 | 9 | - | - | - | - | 3 | 9 | ||||||||||||||||
| Tantalum | 13 | 28 | - | - | - | - | 13 | 28 | ||||||||||||||||
| Tin | 2 | 5 | - | - | - | - | 2 | 5 | ||||||||||||||||
| Tungsten | 5 | 13 | - | - | - | - | 5 | 13 | ||||||||||||||||
| Total | 23 | 55 | - | - | - | - | 23 | 55 | ||||||||||||||||
| (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 2019 is 79% compared to 84% in 2018. The high percentage of RMAP conformant smelters/refiners reflects the strong participation of smelters/refiners in the RMI/RMAP audit process. In 2019 the smelters/refiners identified as sourcing from the covered countries reached a 100% rate of RMAP conformant status, which is the same rate as 2018.
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’”.
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Section 4: Continuous improvement efforts to mitigate risk
During 2019, our conflict minerals program achieved the following improvements:
| · | implemented a communication process for suppliers identified as sourcing from high-risk smelters/refiners, requesting them to encourage these smelters/refiners to become validated as conformant by RMI’s RMAP to remove such smelters/refiners from their supply chain, |
| · | utilized our customized systems to maintain a detailed listing of components which are likely to contain 3TG within each of our various product offerings, |
| · | utilized our conflict minerals data management systems to effectively assess supplier responses and to assist in making conclusions on the conflict free status of our products, |
| · | continued to maintain the awareness about the program inside the organization through training and communication, |
| · | removed several non-cooperative suppliers from our supply chain, |
| · | participated in the RMI Smelter Engagement Team focusing on gold, which seeks to bring legitimate non-certified gold smelters into the RMAP program and assess their compliance for certification as RMAP conformant smelters, |
| · | participated in audit visits and contacted a refiner who was not conformant and encouraged them to get audited, |
| · | invited suppliers to take our conflict minerals training, and |
| · | implemented a due diligence process to follow up with suppliers who are using smelters/refiners identified as being a high-risk of non-conformant sourcing practices in order to promote an ethical supply chain and reduce the risk that ABB has 3TG in its products from smelters that are not RMAP conformant. |
During 2020, we plan to take the following steps as part of our due diligence program:
| · | continue to increase the CMRT response rate and quality of supplier responses by: |
○ working directly with our suppliers on the completion of their CMRT including direct engagement of our largest and key suppliers,
○ providing additional conflict minerals training to suppliers who have been unable to provide sufficient response quality, and
○ reducing the number of invitations sent to suppliers who do not provide 3TG to us.
| · | continue to support the initiatives of the RMI through involvement in the RMI Smelter Engagement Team focusing on gold, seeking to bring legitimate non-certified gold smelters into the RMAP program and assess their compliance for certification as RMAP conformant smelters, |
| · | continue to include a conflict minerals clause in new or renewed supplier contracts that requires suppliers to provide us with necessary 3TG sourcing information, |
| · | continue to follow the OECD due diligence guidance and be involved in relevant trade associations in order to define and improve best practices and encourage responsible sourcing of 3TG, |
| · | for smelters/refiners which have been identified as being a high-risk of non-conformant sourcing practices, we plan to continue to enhance the due diligence process to follow up with our suppliers who are using these smelters/refiners. The purpose is to promote an ethical supply chain and reduce the risk that ABB has 3TG in its products which is not conflict-free, and |
| · | improve the CMRT response rate by continuing to encourage uncooperative suppliers to provide ABB with complete response templates. |
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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.
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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 the CMRT 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
| Metal | Smelter Name | Country |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Marsam Metals | Brazil |
| Gold | Umicore Brasil Ltda. | Brazil |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Royal Canadian Mint | Canada |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | SAAMP | France |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Aurubis AG | Germany |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | DODUCO Contacts and Refining GmbH | Germany |
| Gold | Heimerle + Meule GmbH | Germany |
| Page 10 of 18 |
| Metal | Smelter Name | Country |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Bangalore Refinery | India |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | 8853 S.p.A. | Italy |
| Gold | Chimet S.p.A. | Italy |
| Gold | Italpreziosi | Italy |
| Gold | Safimet S.p.A | Italy |
| Gold | T.C.A S.p.A | Italy |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Chugai Mining | Japan |
| Gold | Dowa | Japan |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Japan Mint | Japan |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Kazzinc | Kazakhstan |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| Gold | DS PRETECH Co., Ltd. | Korea, Republic Of |
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of |
| Page 11 of 18 |
| Metal | Smelter Name | Country |
| Gold | LT Metal Ltd. | Korea, Republic Of |
| Gold | Samduck Precious Metals | Korea, Republic Of |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of |
| Gold | Torecom | Korea, Republic Of |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | OJSC Novosibirsk Refinery | Russian Federation |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Boliden AB | Sweden |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | PAMP S.A. | Switzerland |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Advanced Chemical Company | United States |
| Gold | Asahi Refining USA Inc. | United States |
| Gold | Geib Refining Corporation | United States |
| Gold | Kennecott Utah Copper LLC | United States |
| Page 12 of 18 |
| Metal | Smelter Name | Country |
| Gold | Materion | United States |
| Gold | Metalor USA Refining Corporation | United States |
| Gold | United Precious Metal Refining, Inc. | United States |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Tantalum | LSM Brasil S.A. | Brazil |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Asaka Riken Co., Ltd. | Japan |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | KEMET Blue Metals | Mexico |
| Tantalum | PRG Dooel | North Macedonia, Republic Of |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | CP Metals Inc. | United States |
| Tantalum | D Block Metals, LLC | United States |
| Tantalum | Exotech Inc. | United States |
| Tantalum | Global Advanced Metals Boyertown | United States |
| Page 13 of 18 |
| Metal | Smelter Name | Country |
| Tantalum | H.C. Starck Inc. | United States |
| Tantalum | QuantumClean | United States |
| Tantalum | Telex Metals | United States |
| Tin | Metallo Belgium N.V. | Belgium |
| Tin | EM Vinto | Bolivia |
| Tin | Operaciones Metalurgicas S.A. | Bolivia |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Yunnan Tin Company Limited | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Timah Tbk Kundur | Indonesia |
| Tin | PT Timah Tbk Mentok | Indonesia |
| Tin | Dowa | Japan |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Minsur | Peru |
| Page 14 of 18 |
| Metal | Smelter Namet | Country |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Fenix Metals | Poland |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Tin | Metallo Spain S.L.U. | Spain |
| Tin | Rui Da Hung | Taiwan, Province Of China |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | Thaisarco | Thailand |
| Tin | Alpha | United States |
| Tin | Metallic Resources, Inc. | United States |
| Tin | Tin Technology & Refining | United States |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Tungsten | A.L.M.T. Corp. | Japan |
| Page 15 of 18 |
| Metal | Smelter Name | Country |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | KGETS Co., Ltd. | Korea, Republic Of |
| Tungsten | Woltech Korea Co., Ltd. | Korea, Republic Of |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China |
| Tungsten | Global Tungsten & Powders Corp. | United States |
| Tungsten | Kennametal Fallon | United States |
| Tungsten | Kennametal Huntsville | United States |
| Tungsten | Niagara Refining LLC | United States |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam |
| Page 16 of 18 |
RMAP participating smelters/refiners
| Metal | Smelter Name | Country |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | C.I Metales Procesados Industriales SAS | Colombia |
| Gold | SAFINA A.S. | Czechia |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Kundan Care Products Ltd. | India |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Precious Minerals and Smelting Limited | India |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | China Molybdenum Co., Ltd. | China |
| Tungsten | GEM Co., Ltd. | China |
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | China |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tungsten | CP Metals Inc. | United States |
| Page 17 of 18 |
Other smelters/refiners
| Metal | Smelter Name | Country |
| Gold | Tony Goetz NV | Belgium |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Gold Coast Refinery | Ghana |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | JALAN & Company | India |
| Gold | Sai Refinery | India |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Sovereign Metals | India |
| Gold | NH Recytech Company | Korea, Republic Of |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | African Gold Refinery | Uganda |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | Abington Reldan Metals, LLC | United States |
| Gold | Pease & Curren | United States |
| Gold | QG Refining, LLC | United States |
| Gold | Sabin Metal Corp. | United States |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Tin | Super Ligas | Brazil |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Page 18 of 18 |
| Based on country of origin information provided by the RMI for RMAP conformant processing facilities, countries of origin of the 3TG in our products may include: | ||
| Argentina | Guyana | Puerto Rico |
| Australia | Honduras | Russian Federation |
| Austria | India | Rwanda |
| Azerbaijan | Indonesia | Saudi Arabia |
| Benin | Iran | Senegal |
| Bolivia | Ivory Coast | Serbia |
| Botswana | Japan | Sierra Leone |
| Brazil | Kazakhstan | Slovakia |
| Burkina Faso | Kenya | Solomon Islands |
| Burundi | Laos | Somaliland |
| Canada | Liberia | South Africa |
| Chile | Madagascar | Spain |
| China | Malaysia | Suriname |
| Colombia | Mali | Swaziland |
| Congo, Democratic Republic of the | Mauritania | Sweden |
| Cuba | Mexico | Taiwan |
| Cyprus | Mongolia | Tajikistan |
| Dominican Republic | Morocco | Tanzania |
| Ecuador | Mozambique | Thailand |
| Egypt | Myanmar | Togo |
| Eritrea | Namibia | Turkey |
| Ethiopia | Netherlands | Uganda |
| Fiji | New Zealand | United Kingdom |
| Finland | Nicaragua | United States |
| France | Niger | Uruguay |
| Georgia | Nigeria | Uzbekistan |
| Germany | Papua New Guinea | Venezuela |
| Ghana | Peru | Vietnam |
| Guatemala | Phillipines | Zambia |
| Guinea | Portugal | Zimbabwe |