Form SD Alphabet Inc.
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E-mailUNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Alphabet Inc.
(Exact name of registrant as specified in its charter)
| Delaware | 001-37580 | 61-1767919 | ||||||
| (State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) | ||||||
| 1600 Amphitheatre Parkway, Mountain View, CA | 94043 | ||||
| (Address of principal executive offices) | (Zip code) | ||||
| Kenneth H. Yi (650) 253-0000 | ||
| (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, 2021.
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
A copy of Alphabet Inc.'s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available online at https://abc.xyz/conflictminerals.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
*************
SIGNATURE
Pursuant to the requirements of the Securities and Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| ALPHABET INC. | ||||||||
| Date: May 26, 2022 | By: | /s/ RUTH M. PORAT | ||||||
| Ruth M. Porat | ||||||||
| Senior Vice President and Chief Financial Officer | ||||||||
Exhibit 1.01
Alphabet Inc.
Conflict Minerals Report
For The Year Ended December 31, 2021
This Conflict Minerals Report for the year ended December 31, 2021 (this “CMR”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), which requires certain reporting and disclosure related to conflict minerals. Conflict minerals are currently defined as cassiterite, columbite-tantalite, wolframite, gold, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”)1 for the purpose of this assessment. These requirements apply to registrants whatever the geographic origin of their conflict minerals and whether or not their conflict minerals fund armed conflict. Please refer to the Rule, Form SD, and SEC Release No. 34-67716 for definitions to the terms used in this CMR, unless otherwise defined herein.
Statements in this CMR are based on our due diligence activities performed in good faith for the calendar year 2021 and are based on information available at the time of this filing, unless otherwise indicated. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter and/or refiner (collectively referred to as “smelter(s)”) data, errors or omissions by suppliers or smelters, ongoing certifications of smelters, continued guidance or amendments to the Rule, and other issues, including those resulting from the impact of the coronavirus pandemic (“COVID-19”). Additionally, this CMR may contain forward-looking statements that reflect what we strive to achieve in the future as we continue to improve our responsible sourcing program. These forward-looking statements are based on current expectations and assumptions that are subject to risks and uncertainties.
References to our websites and information available through these websites are not incorporated into this CMR.
Throughout this CMR, we use “Alphabet,” “we,” “our,” “us” and similar terms to refer to Alphabet Inc. and its subsidiaries (collectively, “Alphabet”), unless otherwise indicated, and use “Google” to refer to Google LLC, a wholly owned subsidiary of Alphabet.
1.Overview
(A) Company
Alphabet is a collection of businesses — the largest of which is Google — which we report as two segments: Google Services and Google Cloud; we also report all non-Google businesses collectively as Other Bets. Alphabet's structure is about helping each of our businesses prosper through strong leaders and independence.
Our Google Services and Google Cloud segments together represented approximately 99% of our consolidated revenues in 2021. Our Google Services segment generates revenues primarily by delivering both performance advertising and brand advertising. We continue to look to the future and are making long-term investments that
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
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we expect will grow revenues beyond advertising, including Google Play, hardware, and YouTube non-advertising services. Our Google Cloud segment generates revenues primarily from fees received for Google Cloud Platform services, Google Workspace collaboration tools and other enterprise services. Our Other Bets are emerging businesses at various stages of development, ranging from those in the research and development phase to those that are in the beginning stages of commercialization, and our goal is for them to become thriving, successful businesses in the medium to long term.
(B) In-Scope Products
Products assessed for the scoping of the CMR included tangible products that enter the stream of commerce as defined by the Rule. The hardware products considered in scope for this CMR pertain to consumer-facing devices such as healthcare technology, home devices, phones, wearable devices, streaming devices, tablets, video cameras, and, more specifically, the components of the hardware, such as circuit boards, chips, capacitors, alloys, motor components, and wires.
(C) Supply Chain
Our supply chain consists of a broad range of suppliers and several manufacturing models. The hardware components, such as those described in 1(B), were manufactured by other companies on our behalf. Whether we are working with Original Equipment Manufacturers or more closely with the product design, we do not directly purchase raw materials and are several tiers away from the smelter and country of origin of the 3TG used in our products. In addition, many of the suppliers we work with are not directly subject to the Rule and its corresponding requirements. To influence activities through multiple tiers of the supply chain, we actively engage with a variety of industry members, including the Responsible Minerals Initiative (the “RMI”). Our engagement with RMI includes using tools such as the Conflict Minerals Reporting Template (the “CMRT”) and participating in numerous workgroups and activities that support the RMI’s efforts, including the Responsible Minerals Assurance Process (the “RMAP”).
(D) Conflict Minerals Policy
We believe it is essential to establish validated conflict-free sources of 3TG within the Democratic Republic of the Congo (the “DRC”) and adjoining countries (together, with the DRC, the “Covered Countries”), so that these minerals can be procured in a way that contributes to economic growth and development in the region. To aid in this effort, we have established a conflict minerals policy and an internal team to implement the policy. Our conflict minerals policy is accessible on our website at https://abc.xyz/investor/conflictminerals/.
We expect our suppliers to assure the 3TG in our products are sourced from conformant conflict-free smelters, such as those audited through the RMI’s RMAP (http://www.responsiblemineralsinitiative.org), the London Bullion Market Association (LBMA) or the Responsible Jewellery Council, each of whom perform due diligence on the source and chain of custody of the 3TG used in our products and provide their due diligence measures to us upon request.
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2.Reasonable Country of Origin Inquiry
To identify which of our suppliers to survey regarding the source of the 3TG used in our products, we inventoried our products to determine which products were either manufactured or contracted for manufacture by us between January 1, 2021 and December 31, 2021, and if they were intended to enter the stream of commerce. For all products in scope, we identified and compiled a list of our suppliers (our “in-scope suppliers”) from whom we requested information regarding their sourcing of 3TG.
We requested that such identified in-scope suppliers provide us with information regarding their supply chain using the CMRT from the RMI. We also followed up with our own company-developed tools and templates to review CMRT completeness, ensure at least a base minimum of response across all respondents, and identify potential inconsistencies. The CMRT included questions about location or mine of origin of the 3TG in the products, and requested in-scope suppliers to make similar efforts to survey their supply chains and report the smelters and location or mine of origin of necessary 3TG. We reviewed and monitored responses from our in-scope suppliers and followed up if we identified information to be incomplete or inconsistent with the information we would expect from the supplier. Our follow-up actions included the following:
•If an in-scope supplier did not respond, we initiated a supplier escalation process until a response was received.
•If an in-scope supplier had inconsistent or incomplete information, we contacted the supplier and requested updated information, provided additional training resources, and reaffirmed our applicable supplier codes of conduct and conflict minerals policy expectations.
•We worked with suppliers to improve their responses and commitment to conflict-free sourcing at both company and product levels and sourcing from RMAP conformant smelters.
•We also encouraged suppliers to join industry collaborations to further support conflict-free sourcing.
We received a 100% response rate from our in-scope suppliers who provided data to us at either the company or product level. In-scope suppliers are continuously gathering information from their suppliers and we continue to work with them to ensure that suppliers are fully represented.
Some in-scope supplier responses indicated that some smelters used by them at various levels of our supply chain obtain 3TG from the Covered Countries. Some in-scope supplier responses also indicated sourcing 3TG from outside of the Covered Countries, from recycled or scrap sources, and/or from unknown origins. Based on the results of our supply chain survey and the nature of our supply chain as described in Section 1(C) above, we were unable to verify with certainty the source and chain of custody of all of the 3TG used by our suppliers and in our products. We completed due diligence on all smelters reported in our supply chain as described in Section 3 below.
3.Due Diligence
Our due diligence measures were designed to conform in all material respects to the five step framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, 2016 (“OECD Guidance”).
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Below is a description of our due diligence activities performed for the 2021 reporting year as they relate to the five-step framework set forth in the OECD Guidance.
OECD Step 1 - Establish strong company management systems
•Our conflict minerals policy described in Section 1(D) is publicly available on our Investor Relations website.
•Our governance structure includes senior management from our in-scope supply chains, legal and finance organizations who are responsible for monitoring our due diligence activities. Oversight of the program consists of our CFO, vice presidents from supply chain and business operations, finance, and legal.
•We include responsible sourcing and due diligence requirements in our applicable supplier codes of conduct and in supplier contract templates. Our suppliers are expected to source from conflict-free sources, and utilize the CMRT to disclose sourcing information about the 3TG in their products. We provide additional templates for follow-up, training and resources to our suppliers on our requirements.
•Our product areas utilize a system that includes online platforms for storing and managing our conflict minerals due diligence activities, communications, and results.
•We have a document retention policy for maintaining conflict minerals program documentation for a minimum of five years.
•We have a grievance mechanism for reporting violations of our policies.
•We participate in and review the grievances reported via the RMI Minerals Grievances Platform, which acts as a risk-awareness system (https://mineralsgrievanceplatform.org).
OECD Step 2 - Identify and assess risk in the supply chain
•We requested that our in-scope suppliers provide a CMRT in order to collect information about the smelters of 3TG used in our products.
•We assessed the CMRTs received from our in-scope suppliers for completeness, and reasonableness based on OECD Guidance for Conflict and High Risk Areas (CAHRAs) globally, including the Covered Countries.
•We validated each smelter disclosed by our in-scope suppliers by checking against the smelter data provided by the RMI.
•We provided conflict minerals feedback as needed to in-scope suppliers that were audited by our internal Responsible Supply Chain audit program.
•For the fifth consecutive year, we utilized an independent third party to provide an assessment of 100% of the smelters disclosed by our in-scope suppliers, to track data, and to identify risks in smelters that have not yet undergone the RMAP. This prompted additional direct follow-up with smelters and suppliers.
•We serve as the International Industry representative on the International Conference of the Great Lakes Region (ICGLR) Audit Committee, which manages the regional Third-Party Audit system and is composed of fourteen representatives from government, local and international industry, and local and international civil society. This role allows us to directly support the African Great Lakes countries (Angola, Burundi, Central African Republic, Republic of Congo, Democratic Republic of Congo, Kenya, Uganda, Rwanda, Republic of South Sudan, Sudan, Tanzania and Zambia) in assuring global market access of responsibly sourced minerals from the region. We reviewed and provided input on audit mechanisms and criteria, accreditation of auditors, and audits performed by the ICGLR. We participated virtually with the ICGLR Audit Committee during the 2021 audit cycle, and participated in person in the 20th ICGLR meeting in April 2022 in Tanzania.
•We communicated with in-scope suppliers that reported smelters which were not yet identified as RMAP conformant. We worked with in-scope suppliers to improve the completeness and accuracy of their
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responses and fostered their ongoing commitment to conflict-free minerals at both company and product levels. We also encouraged all suppliers to join industry collaborations.
•We developed a plan, for in-scope suppliers not sourcing exclusively from conformant smelters for products, to bring those smelters into conformance.
•We worked with our in-scope suppliers and reviewed the CMRT responses they received from their suppliers. This process helped to inform our direct suppliers on how to identify risks in the information they receive from their suppliers. As part of this process, we also encouraged suppliers to source from RMAP conformant smelters in the DRC and other CAHRAs.
OECD Step 3 - Design and implement a strategy to respond to identified risks
•We provided updates to our responsible supply chain team on our due diligence activities and CMR.
•We updated our Audit and Compliance Committee on our due diligence activities and CMR.
•We prepared an annual list of supplier performance for all suppliers that achieved conformance to in-scope product areas. We use this list to guide our continuing business with known conflict-free sourcing suppliers. This list is also utilized for product decisions to determine whether to discontinue sourcing relationships.
•We contacted standard smelters that were not yet conformant or active to emphasize the importance of being audited and found conformant to the RMAP by the RMI.
•We continued to support sourcing from the Covered Countries and supported in-region projects through our contributions to the Public-Private Alliance for Responsible Minerals Trade (PPA) and to the RMI. In 2021, we contributed to the RMI Audit Fund (an enhanced due diligence and traceability program collaboration with Better Mining) and an Artisanal and Small Scale Mining (ASM) Cross-Recognition Program intended to fund organizations working on the ground, as well as create a framework for fostering transparency and collaboration between local and global organizations.
•We encouraged suppliers to adopt policies supporting sourcing responsibly from the DRC and Covered Countries versus implementing policies that completely ban minerals from the DRC, and Covered Countries.
•We participated in the Governance Committee and the Projects and Resources Work Group of the PPA. We participated in seven RMI advisory and sub-committee groups (Smelter Engagement Team, ASM Working Group, Blockchain, Gold, CMRT, Multi-Stakeholder, and Grievance Platform), which focused on coordinating outreach to smelters and collaboration with RMI staff and suppliers. We also were elected to the board of the RMI Steering Committee to provide strategic guidance and support oversight of the RMI program and overall Responsible Business Alliance objectives.
•We provided third party assessment information on smelters that were not yet conformant to RMI for member dissemination.
•We reviewed known incidents and allegations in the supply chain and worked with suppliers to improve responsible sourcing outcomes. We also worked with industry stakeholders on public allegations and reviewed grievances on the Minerals Grievance Platform of RMI, and we continue to support increased transparency between upstream and downstream stakeholders.
•In collaboration with partners, we continued implementation of Congo Power, which we began in 2017 to provide clean energy resources to communities committed to responsible sourcing. The program supports alternative livelihoods and gender empowerment. We committed to five additional projects for Congo Power in 2021 for a total of fourteen projects.
•We continued our digital traceability blockchain work with Minsur in Peru and LuNa Smelter in Rwanda. We continued capacity building and support to LuNa Smelter to support audit readiness and traceability. This work is also intended to support the implementation of innovative and cost effective due diligence processes leveraging blockchain technology. LuNa has already brought more than 200 tons of tin from Rwanda into global markets, using QR codes generated by Minespider to trace its origin.
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•We completed the first phase of the PPA collaboration with the Panzi Foundation in 2021, which included focus on alternative livelihoods and program development with other partners, and a first phase of Congo Power projects. We joined the board of the Panzi Foundation and took on a strategic role in guiding collaboration with multiple stakeholders to support human rights and improve responsible sourcing outcomes in the covered countries. The second phase of the effort set a target of expanding clean power to 100% of Panzi’s 54 facilities, and to expand programming connections with alternative livelihoods.
•We funded IMPACT’s work to promote and provide technical assistance to national and provincial-level stakeholders in the Democratic Republic of Congo (Ituri province) on reforming the fiscal regime and export process for artisanal and small-scale gold. IMPACT’s mission is to transform how natural resources are managed in areas where security and human rights are at risk.
OECD Step 4 - Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain
•We joined the RMI in 2013 (member ID: GOOG), and we continue to be a member.
•We relied upon the RMI to validate that companies meet the criteria of a smelter, and then verify that they conform to the RMAP.
•We worked with a third party to provide an assessment of smelters not participating in RMI to give Alphabet visibility on all smelters identified in supplier outreach.
•We conducted sustainable supply chain audits with independent third parties on a portion of our suppliers, which included reviewing their conflict minerals programs.
•We continued activities to supplement the RMAP process and audits such as direct inquiries, communications and development of industry tools to support audit programs and reporting mechanisms. This allowed us to better understand issues smelters face in the compliance process and how we can best align to support management systems used for compliance and in-region due diligence.
•We continued our communication with civil society and NGOs with staff operating on the ground during the 2021 cycle. These communications helped us to better understand risks and opportunities, such as enhancing responsible supply chains.
OECD Step 5 - Report annually on supply chain due diligence
•We publish a CMR annually, and our reports are accessible on our Investor Relations website at https://abc.xyz/investor/conflictminerals/.
•We published our 2021 Supplier Responsibility Report, which also included an update on our conflict minerals program and industry collaborations (https://sustainability.google/reports/).
4.Due Diligence Results
Smelter Disclosure
Based on our due diligence of the information provided by our in-scope suppliers for the 2021 reporting period, we have reason to believe that a portion of the 3TG used in our products originated from the Covered Countries. While we have not identified any instances of sourcing that directly or indirectly supported conflict in the Covered Countries, we are not declaring any of our products to be “DRC Conflict Free.” In some instances, information provided by our in-scope suppliers was unverifiable or incomplete and, as such, we were unable to verify with certainty the source and chain of custody of all of the necessary 3TG in our products. Based on the due diligence performed, our suppliers identified 266 smelters and we evaluated each of them based on third party audits and/or assessments; 237 are considered “conformant” and 14 are considered “active” on the RMI website.
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Based on our third party assessment and RCOI, we identified an additional 15 smelters as not sourcing from the Covered Countries (or have no reason to believe they are sourcing from the Covered Countries) bringing the total number of smelters identified as “conformant”, “active” or not sourcing from the DRC to 266 (100%).
The results of our due diligence on the 3TG used in our in-scope products are noted below:
2021 Smelters | Tin | Tungsten | Tantalum | Gold | Total | ||||||||||||
Total number of smelters | 66 | 45 | 39 | 116 | 266 | ||||||||||||
| Number (%) of smelters listed as “conformant” by RMI | 54 (82%) | 43 (96%) | 38 (97%) | 102 (88%) | 237 (89%) | ||||||||||||
| Number (%) of smelters listed as “active” by RMI | 8 (12%) | 2 (4%) | 0 (0%) | 4 (3%) | 14 (5%) | ||||||||||||
| Number (%) of smelters confirmed by an independent third party to not be sourcing from the Covered Countries | 4 (6%) | 0 (0%) | 1 (3%) | 10 (9%) | 15 (6%) | ||||||||||||
| Number (%) of smelters that are conformant, active, or not sourced from the Covered Countries | 66 (100%) | 45 (100%) | 39 (100%) | 116 (100%) | 266 (100%) | ||||||||||||
Efforts to Determine Mine or Location of Origin
As part of our due diligence process described in Section 3 above, we worked to ensure that our efforts to identify mines and the countries of origin of the 3TG in our products have been reasonable and aligned with industry practices through our support of processes and tools developed by the RMI. Appendix II includes the country of origin data provided to the RMI for conformant smelters only.
5.Continuous Improvement in Understanding Source of Material
We recognize that efforts to reduce violence associated with conflict minerals are ongoing and are required to continually adapt to changing situations. We are committed to reviewing our compliance processes as well as actively engaging upstream directly in-region for opportunities to improve our processes.
We include more detail on our policies and our results in our Supplier Responsibility Report, including work in other minerals and materials, such as cobalt.
We will continue to review our compliance processes including, but not limited to, taking the following steps for the 2022 reporting year:
•We will continue to engage with in-scope suppliers to gain better visibility of the country of origin and chain of custody of the 3TG used in our in-scope products. As travel restrictions are lifted, we plan to continue visiting smelters and mine sites to better understand issues smelters face in the compliance process, and how best to align support for management systems used for compliance and in-region due diligence.
•We will use and encourage our in-scope suppliers to use publicly available tools from the RMI.
•We will continue to work with our in-scope suppliers and engage with our supply chain to increase the quality of the data provided to us.
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•We will continue to be a member of the RMI, including actively participating in the RMI Steering Committee, and contribute to the various initiatives, as described above.
•We will continue to encourage our in-scope suppliers to source from conflict-free smelters that are listed as conformant by the RMI.
•As we enter into contracts with new suppliers and renew contracts with existing suppliers, we will continue to include requirements that our suppliers support our conflict minerals policy and due diligence efforts.
•We will continue to explore additional opportunities to support livelihoods and health, improve conservation outcomes, improve stability, and support renewable energy projects to enhance conflict-free mining communities.
•We will continue to support education campaigns around responsible minerals sourcing to engage consumers and supply chain partners in awareness and action that builds on our work with Responsible Artisanal Gold Solutions Forums (RAGS), RMI, and the PPA.
•We will continue to expand on the Congo Power program with stakeholders - including governments, non-governmental organizations, civil society, industries, and local communities.
•We will continue to address incidents and allegations through collaboration with relevant stakeholders while also working to support stronger chain of custody and traceability systems.
•We will continue to build on our prior blockchain project in Peru and Rwanda and provide capacity building and support to additional smelters and the RMI RMAP to support the implementation of innovative, cost effective, and transparent due diligence processes leveraging blockchain technology.
•We will maintain our ongoing participation in the ICGLR Audit Committee as the international industry representative, the Panzi Foundation board, the Action Kivu board, as an advisor to the City of Joy, and the RMI Steering Committee.
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APPENDIX I Smelter List
Metal | Smelter Name | Smelter Location Country | ||||||
Gold | 8853 S.p.A. | ITALY | ||||||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
Gold | Agosi AG | GERMANY | ||||||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
Gold | Alexy Metals | UNITED STATES OF AMERICA | ||||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
Gold | Argor-Heraeus S.A. | SWITZERLAND | ||||||
Gold | Asahi Pretec Corp. | JAPAN | ||||||
Gold | Asahi Refining Canada Ltd. | CANADA | ||||||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
Gold | Asaka Riken Co., Ltd. | JAPAN | ||||||
Gold | AU Traders and Refiners | SOUTH AFRICA | ||||||
Gold | Augmont Enterprises Private Limited | INDIA | ||||||
Gold | Aurubis AG | GERMANY | ||||||
Gold | Bangalore Refinery | INDIA | ||||||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
Gold | Boliden AB | SWEDEN | ||||||
Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
Gold | Chimet S.p.A. | ITALY | ||||||
Gold | Chugai Mining | JAPAN | ||||||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
Gold | Dowa | JAPAN | ||||||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
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 | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
Gold | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | ||||||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
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Gold | Istanbul Gold Refinery | TURKEY | ||||||
Gold | Italpreziosi | ITALY | ||||||
Gold | Japan Mint | JAPAN | ||||||
Gold | Jiangxi Copper Co., Ltd. | CHINA | ||||||
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||||||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||||||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
Gold | Kazzinc | KAZAKHSTAN | ||||||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
Gold | L'Orfebre S.A. | ANDORRA | ||||||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||||
Gold | Marsam Metals | BRAZIL | ||||||
Gold | Materion | UNITED STATES OF AMERICA | ||||||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||||||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
Gold | Metalor Technologies S.A. | SWITZERLAND | ||||||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
Gold | Mitsubishi Materials Corporation | JAPAN | ||||||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||||||
Gold | Nihon Material Co., Ltd. | JAPAN | ||||||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||||||
Gold | PAMP S.A. | SWITZERLAND | ||||||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||||||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||||||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
Gold | PX Precinox S.A. | SWITZERLAND | ||||||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
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Gold | REMONDIS PMR B.V. | NETHERLANDS | ||||||
Gold | Royal Canadian Mint | CANADA | ||||||
Gold | SAAMP | FRANCE | ||||||
Gold | Safimet S.p.A | ITALY | ||||||
Gold | SAFINA A.S. | CZECHIA | ||||||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | ||||||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||||||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||||||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Gold | T.C.A S.p.A | ITALY | ||||||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
Gold | Torecom | KOREA, REPUBLIC OF | ||||||
Gold | Umicore Precious Metals Thailand | THAILAND | ||||||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
Gold | Valcambi S.A. | SWITZERLAND | ||||||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||||
Gold | Yamakin Co., Ltd. | JAPAN | ||||||
Gold | Yokohama Metal Co., Ltd. | JAPAN | ||||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
| Tantalum | AMG Brasil | BRAZIL | ||||||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
Tantalum | F&X Electro-Materials Ltd. | CHINA | ||||||
Tantalum | FIR Metals & Resource Ltd. | CHINA | ||||||
Tantalum | Global Advanced Metals Aizu | JAPAN | ||||||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||||||
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | ||||||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
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 | ||||||
11
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
Tantalum | KEMET de Mexico | MEXICO | ||||||
Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | ||||||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||||||
Tantalum | Mineracao Taboca S.A. | BRAZIL | ||||||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||||||
Tantalum | NPM Silmet AS | ESTONIA | ||||||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||||||
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | ||||||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||||||
Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | ||||||
| Tantalum | TANIOBIS GmbH | GERMANY | ||||||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||||||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | ||||||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||||||
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
Tin | Alpha | UNITED STATES OF AMERICA | ||||||
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 | CRM Fundicao De Metais E Comercio De Equipamentos Electronicos Do Brasil Ltda | BRAZIL | ||||||
Tin | CRM Synergies | SPAIN | ||||||
Tin | CV Venus Inti Perkasa | INDONESIA | ||||||
Tin | Dowa | JAPAN | ||||||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | ||||||
Tin | Fenix Metals | POLAND | ||||||
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 | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
12
| Tin | Luna Smelter, Ltd. | RWANDA | ||||||
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | ||||||
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
Tin | Melt Metais e Ligas S.A. | BRAZIL | ||||||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
Tin | Metallo Belgium N.V. | BELGIUM | ||||||
Tin | Metallo Spain S.L.U. | SPAIN | ||||||
Tin | Mineracao Taboca S.A. | BRAZIL | ||||||
Tin | Minsur | PERU | ||||||
Tin | Mitsubishi Materials Corporation | JAPAN | ||||||
Tin | Modeltech Sdn Bhd | MALAYSIA | ||||||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
Tin | PT Babel Inti Perkasa | INDONESIA | ||||||
Tin | PT Babel Surya Alam Lestari | INDONESIA | ||||||
Tin | PT Bangka Serumpun | INDONESIA | ||||||
Tin | PT Bukit Timah | INDONESIA | ||||||
Tin | PT Menara Cipta Mulia | INDONESIA | ||||||
Tin | PT Mitra Stania Prima | INDONESIA | ||||||
Tin | PT Mitra Sukses Globalindo | INDONESIA | ||||||
Tin | PT Prima Timah Utama | INDONESIA | ||||||
Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||||||
Tin | PT Rajehan Ariq | INDONESIA | ||||||
Tin | PT Refined Bangka Tin | INDONESIA | ||||||
Tin | PT Sariwiguna Binasentosa | INDONESIA | ||||||
Tin | PT Stanindo Inti Perkasa | INDONESIA | ||||||
Tin | PT Sukses Inti Makmur | INDONESIA | ||||||
Tin | PT Timah Nusantara | INDONESIA | ||||||
Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
Tin | PT Tinindo Inter Nusa | INDONESIA | ||||||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
Tin | Soft Metais Ltda. | BRAZIL | ||||||
Tin | Super Ligas | BRAZIL | ||||||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
Tin | Thaisarco | THAILAND | ||||||
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | ||||||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
13
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
Tungsten | A.L.M.T. Corp. | JAPAN | ||||||
Tungsten | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | ||||||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | ||||||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
Tungsten | Fujian Xinlu 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 | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||||||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||||||
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 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Masan High-Tech Materials | VIET NAM | ||||||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||||||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
14
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||
15
APPENDIX II Country of Origin List2
| Countries of Origin | ||||||||
| Argentina | Guinea | Peru | ||||||
| Armenia | Guyana | Philippines | ||||||
| Australia | Honduras | Portugal | ||||||
| Austria | India | Russian Federation | ||||||
| Azerbaijan | Indonesia | Rwanda | ||||||
| Benin | Ivory Coast | Saudi Arabia | ||||||
| Bolivia | Japan | Senegal | ||||||
| Botswana | Kazakhstan | Sierra Leone | ||||||
| Brazil | Kenya | Slovakia | ||||||
| Burkina Faso | Kyrgyzstan | South Africa | ||||||
| Burundi | Laos | South Korea | ||||||
| Canada | Liberia | Spain | ||||||
| Chile | Madagascar | Sudan | ||||||
| China | Malaysia | Suriname | ||||||
| Colombia | Mali | Swaziland | ||||||
| Congo, Democratic Republic of the | Mauritania | Sweden | ||||||
| Cuba | Mexico | Taiwan | ||||||
| Dominican Republic | Mongolia | Tanzania | ||||||
| Ecuador | Morocco | Thailand | ||||||
| Egypt | Mozambique | Turkey | ||||||
| Eritrea | Myanmar | Uganda | ||||||
| Ethiopia | Namibia | United Kingdom of Great Britain and Northern Ireland | ||||||
| Fiji | New Zealand | United States of America | ||||||
| Finland | Nicaragua | Uzbekistan | ||||||
| France | Niger | Venezuela | ||||||
| French Guiana | Nigeria | Vietnam | ||||||
| Germany | Oman | Zambia | ||||||
2 The RMI does not provide a specific country of origin of the conflict minerals processed by conformant smelters. Due to business confidentiality reasons, the country of origin data is provided in an aggregated way based on country risk level. Thus, we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed conformant smelters. The list is the possible counties the material may have come from and references the plausible list of mineral mine production by country (RMI report published March 2020, Mineral Mine Production Country”). The list is based on the country of origin data provided by the RMI for RMAP LBMA, and RJC conformant smelters only.
16
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