UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
STMicroelectronics
N.V.
(Exact name of the registrant as specified in
its charter)
| The Netherlands |
1-13546 |
|
(State or other jurisdiction of
incorporation or organization) |
(Commission
File Number) |
| WTC Schiphol Airport |
|
| Schiphol Boulevard 265 |
|
| 1118 BH Schiphol |
|
| The Netherlands |
N/A |
| (Address of principal executive offices) |
(Zip code) |
Steven Rose, +41 22 929 29 29
(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:
| _√__ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023 |
| ____ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended_________. |
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report;
Exhibit
The Company has filed as an exhibit to this Form SD a Conflict Minerals
Report. This Form SD and Conflict Minerals Report are available on our website at the following address: http://investors.st.com.
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 SD.
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.
| Date: May 15, 2024 |
|
STMicroelectronics N.V. |
| |
|
|
| |
By: |
/s/ Jean-Marc Chery |
| |
Name: |
Jean-Marc Chery |
| |
Title: |
President and Chief Executive Officer and Sole Member of our Managing Board |
| |
|
|
Conflict
Minerals Report of STMicroelectronics N.V.
in accordance
with
Rule
13p-1 under the Securities Exchange Act of 1934
EU Regulation
2017/821
This Conflict Minerals Report (the “Report”)
for the year ended December 31, 2023, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 and guidance in
relation thereto promulgated by the Securities and Exchange Commission (the “SEC”) (collectively, the “Rule”)
and EU Regulation 2017/821 laying down supply chain due diligence obligations for European Union importers of tin, tantalum and tungsten,
their ores, and gold originating from conflict-affected and high-risk areas (the “Regulation”).
In this Report, references to “ST”,
“we”, “us” and “Company” are to STMicroelectronics N.V. together with its consolidated subsidiaries,
which includes its manufacturing facilities in and outside the European Union. Furthermore, the SEC defines “conflict minerals”
as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten.
The Regulation is applicable to European Union importers of certain minerals or metals, whereby (i) the minerals refer to ores and concentrates
containing tin, tantalum, tungsten or gold and (ii) the metals refer to metals containing or consisting of tin, tantalum, tungsten or
gold, specifically where these minerals or metals potentially originate from, or are linked to, conflict-affected and high-risk areas
(“CAHRAs”) as defined by the Organisation of Economic Co-Operation and Development (the "OECD") Due Diligence Guidance
for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance").
The term “conflict minerals” throughout
this Report refers to the minerals and metals as covered by the Rule and the Regulation, regardless of such metals’ and minerals’
country of origin or whether they are financing or benefiting armed conflict or contributing to violations of international law, including
human rights abuses. Further definitions are included in Annex I hereto.
The content of any website referenced in this
Report is included for general information only and is not incorporated by reference in this Report.
In accordance with the Rule and the Regulation, this Report is available
on our website at the following address: https://investors.st.com/financial-information/sec-filings.
Business and products
We are a global semiconductor company that designs,
develops, manufactures and markets a broad range of products used in a wide variety of applications for the four end-markets we address:
automotive, industrial, personal electronics and communications equipment, computers and peripherals.
At December
31 2023, our reportable segments were[1]
are as follows:
| · | Automotive and Discrete Group (ADG) comprised of dedicated
automotive integrated circuits (“ICs”), and discrete and power transistor products; |
| · | Analog, MEMS and Sensors Group (AMS), comprised of analog,
smart power, MEMS sensors and actuators, and optical sensing solutions; and |
1
We derive less than 0.075% of our total annual revenue from sales
of promotional evaluation and development boards assembled by third party subcontractors, which represent prototypical system-level applications
that include our integrated circuit products as well as components originating from third parties. These boards are useful to demonstrate
the features and functionality of our semiconductor products and assist our customers in transitioning from initial prototype designs
to final production releases. References herein to our “products” are to our integrated circuit products (excluding such boards)
representing more than 99.9% of our total annual revenue.
| · | Microcontrollers and Digital ICs Group (MDG), comprised of
general-purpose microcontrollers and microprocessors,
connected security products (e.g. embedded secured elements and NFC readers), memories (e.g. serial and page EEPROM) and RF and Communications
products. |
Effective as of February 5, 2024, we re-organized
our product groups and reportable
segments to further accelerate our time-to-market
and speed of product development innovation and efficiency and we have moved from three product groups and three reportable segments
(ADG, AMS and MDG), to two product groups and
four reportable segments, as follows:
| · | Analog, Power & Discrete, MEMS and Sensors, including
two reportable segments (Analog Products, MEMS and Sensors and Power and Discrete Products); and |
| · | Microcontrollers, Digital ICs and RF products, including two
reportable segments (Microcontrollers, and Digital ICs and RF Products). |
A more detailed description of our product categories
and the products relating to each category is contained in our Annual Report on Form 20-F and Dutch Annual Report in relation to the 2023
calendar year which was filed with the SEC on February 22, 2024, and the AFM (Dutch Financial Market Authority) on March 21, 2024, respectively.
Manufacturing processes
The manufacture of semiconductor products requires,
among other things, the mastery of the properties of conductivity, isolation and/or amplification. The manufacturing of an integrated
circuit can be divided into two phases. The first, wafer fabrication, is the extremely sophisticated and intricate process of manufacturing
the silicon chip. The second, assembly, is the highly precise and automated process of packaging the silicon chip. Those two phases are
commonly known respectively as “Front-End” and “Back-End”.
The manufacturing process of semiconductor products
requires various materials, gases, and chemicals. We have identified tin, tantalum, tungsten, and gold (collectively, “3TG”)
as being among the materials necessary to the functionality or production of certain of our products manufactured during the 2023 calendar
year.
Supply chain
We are not engaged in the mining and trade of
minerals, nor in any refining or smelting activities. We purchase materials, commodities, chemicals, and gases which potentially contain
minerals and/or metals covered in the Rule and the Regulation as part of their composition. In general, we do not conduct business directly
with smelters and refiners.
Because of our large size, the complexity of our
products, and the depth, breadth, and constant evolution of our global supply chain, it is difficult and resource-intensive to identify
actors upstream from our direct suppliers. Accordingly, we participate in several industry-wide initiatives as described in Section 2
below.
I. Establish strong company management systems
Conflict minerals policy
ST began to address the conflict minerals issue
as early as 2007 by requiring our tantalum suppliers to confirm they were not sourcing metals from conflict areas. We are a member of
the Responsible Business Alliance (the “RBA”), commit to the RBA’s Code of Conduct and integrate its principles in our
internal policies and participate in the Responsible Minerals Initiative (the “RMI”). We require all our suppliers and subcontractors
to provide evidence that they are not sourcing 3TG through any channels that fund armed groups or security forces or contribute to widespread
and systematic violations of international law, including, human rights abuses.
Our Policy Statement on Conflict Minerals and
Responsible Minerals Sourcing (our “Policy Statement”) is regularly provided to our suppliers and is available at: www.st.com/conflict-free_minerals.
Our “Conflict Mineral Report” is issued
annually and published on our website: https://investors.st.com/financial-information/sec-filings.
We also report on our conflict minerals program
in our annual Sustainability Report which is available at: https://www.st.com/content/st_com/en/about/st_approach_to_sustainability/sustainability-reports.html.
Furthermore,
the relevant Conflict Minerals Reporting Template (the “CMRT”) and the Extended Mineral Reporting Template (the “EMRT”)
are provided on demand upon request of our customers through our online support portal https://ols.st.com/s/
The respective websites of the RBA and the RMI
are accessible at http://www.responsiblebusiness.org/ and http://www.responsiblemineralsinitiative.org/.
Any
grievance related to conflict minerals linked to ST can be reported through our Ethics Hotline. Operated by an independent third-party
provider, it is reachable 24/7 online or by phone (with a multilingual offering): https://secure.ethicspoint.eu/domain/media/en/gui/104021/index.html.
Furthermore,
generic grievances can be reported through the RMI grievance mechanism: https://www.responsiblemineralsinitiative.org/rmap/grievance-mechanism/.
Design of due diligence
Our due diligence measures have been designed
to conform, in all material respects, to the framework in the OECD Guidance and the related supplements for tin, tantalum, tungsten and
gold, as well as related RBA recommendations. The OECD is an international organization that is endorsed by the United Nations and currently
offers the only recognized framework available for such use.
Management system
In addition to implementing our Policy Statement
as outlined above, evidencing our senior management’s commitment to our conflict minerals program, we have implemented our conflict
minerals management system in alignment with the OECD Guidance. We have established roles and duties within the Company’s relevant
internal organizations involved in the program. The roles and duties established for several key internal organizations are outlined below.
Our Corporate Quality and Social Responsibility
organizations are responsible for the following:
| · | proactively working with our customers to define the scope and form of our
conflict minerals disclosures; |
| · | defining the strategy and annual objectives related to the implementation
of the conflict minerals program within the Company and the coordination thereof with the appropriate internal organizations responsible
for sourcing and purchasing materials and subcontracted services and products (including our Global Procurement Organization); |
| · | establishing the appropriate internal and external communication content
on these programs through the relevant and necessary media and in accordance with our internal processes, including, without limitation,
our Policy Statement and dedicated content in our annual Sustainability Report, both of which are made available on our website; and |
| · | reviewing and updating our conflict minerals management procedures on a
regular basis. |
Our Global Procurement Organization helps
to implement our conflict minerals program by supporting the communication of Company requirements to our suppliers and monitoring our
suppliers’ engagement and progress in relation to our conflict minerals program. As part of the engagement with our suppliers they
commit to respond to our requests with regard to, amongst others, their adherence to the requirements of our conflict minerals program.
Our Global Outsourcing Business Management
group helps to implement our conflict minerals program by supporting the communication of Company requirements to Back-End subcontractors
and monitoring our subcontractors’ engagement and progress in relation to our conflict minerals program.
Our Wafer Foundry group supports our conflict
minerals program by communicating our requirements to wafer foundries and by monitoring our subcontractors’ engagement and progress
in relation to our conflict minerals program.
In addition, our conflict minerals program is
included as part of our sustainability and quality strategies and is highlighted as a key objective for each of our relevant internal
organizations, in addition to the key internal groups discussed above, as applicable within the scope of their respective activities.
A working group with representatives from the principal organizations involved, regularly reviews the progress of the implementation of
our conflict minerals program. Based on our needs and as appropriate for the situation, such working group implements the appropriate
risk mitigation measures.
Industry wide initiatives
As we are a participating member of the RBA, we
employ due diligence methodologies defined by a joint working group comprised of RBA and the Global e-Sustainability Initiative (the “GeSI”)
representatives. Tools available for participants in the RBA include a template known as the CMRT. The CMRT was developed to facilitate
disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The CMRT is used
by many companies in their due diligence processes related to conflict minerals.
In addition, the RBA and the GeSI developed the
RMI in 2010, which is a voluntary initiative in which an independent third-party audits smelter procurement and processing activities
and determines if the smelter has provided sufficient documentation to demonstrate with reasonable confidence that the minerals it processed
originated from conflict-free sources. In 2012, the RMI, the London Bullion Market Association (the “LBMA”) and the Responsible
Jewellery Council (the “RJC”) announced their mutual cross-recognition of gold refiner audits. All three programs focus on
independent third-party audits of refiners’ due diligence in conformity with the OECD Guidance, which recognizes refiners as a key
“choke point” in the gold supply chain.
We, along with other leading participants in the
electronics industry, rely on the RMI’s Responsible Minerals Assurance Process (the “RMAP”) or an equivalent industry-wide
program for audits of smelters and/or refiners. Further details on this program are available on the RMI’s website at the address
referenced above.
As a key element of our strategy, we only engage
suppliers who declare to use minerals sourced from RMAP conformant smelters.
In previous years we had reported on additional
initiatives undertaken directly towards certain smelters, which at that time did not yet participate in the RMAP conformant smelters program,
to influence them to seek full RMAP conformant smelters validation. Currently as the market has reached a sufficient maturity as it regards
RMAP conformant smelters, and we require our suppliers and subcontractors to only source materials for us from RMAP conformant smelters
we do not need to undertake such additional initiatives anymore.
II. Identify and assess risks in the supply
chain
Risk definition
We have identified the following risks:
Main downstream risks
| · | Supplier not providing material composition |
| · | Supplier not conducting proper due diligence |
| · | Supplier declaring smelters list not linked to material sold (effects of
multi-sourcing) |
| · | Use non-conformant smelters |
Main upstream risks
| · | Serious abuses associated with the extraction, transport, or trade of minerals: |
| - | Any form of torture, cruel, inhuman, and degrading treatment |
| - | Any form of forced or compulsory labor |
| - | The worst forms of child labor |
| - | Other gross human rights violations and abuses, such as widespread sexual
violence |
| - | War crimes or other serious violations of international humanitarian law,
crimes against humanity or genocide |
| · | Direct or indirect support to non-state armed groups |
| · | Direct or indirect support to public or private security forces |
| · | Bribery and fraudulent misrepresentation of the origin of minerals: |
| - | Non-payment of taxes, fees, and royalties to governments |
Main additional risks
| · | Environment (pollution, water consumption abstraction, tailings) |
| · | Health & Safety (occupational health and safety, community health and
safety) |
Risks related to red flag situations (situation
where risks in supply chain are more likely to be found)
| · | Red flag locations of mineral origin and transit: |
| - | The minerals originate from or have been transported via a conflict-affected
or high-risk area; |
| - | The minerals are claimed to originate from a country that has limited known
reserves, likely resources or expected production levels of the mineral in question (i.e., the declared volumes of mineral from that country
are out of keeping with its known reserves or expected production levels); and |
| - | The minerals are claimed to originate from a country in which minerals from
conflict-affected and high-risk areas are known to transit. |
| - | The company’s suppliers or other known upstream companies have shareholder
or other interests in companies that supply minerals from or operate in one of the above-mentioned red flag locations of mineral origin
and transit; and |
| - | The company’s suppliers or other known upstream companies are known
to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months. |
Risk identification processes and tools
We have identified the above risks using the processes
and tools as described below.
| Risk |
Risk
identification |
| a) Main risk related to the Downstream supply chain |
·
Material Composition collection
·
Responsible Minerals Statement
·
Downstream Assessment Program (“DAP”) |
| b) Main risk related to the Upstream supply chain |
·
CMRT
·
Smelters Audits (“RMAP”) |
| c) Additional risks |
·
RMI & ST Grievance portal
·
Web watch |
| d) Red flag situations |
·
Reasonable Country of Origin Inquiry (“RCOI”) list
·
Smelters Audit (“RMAP”) |
| |
|
|
Risk identification methods
Below is a description of our risk identification
methods:
| · | Material Composition collection |
We periodically ask our suppliers to
provide the detailed material composition of the materials used in our manufacturing processes. That data allows us to identify the materials
in scope of the RMI program.
If we do not receive this information
from our suppliers, we check the material specification to find any useful information to determine the material composition.
In case the material specification
does not disclose the presence of substances in scope of the RMI program, we check the material family to assess if the materials could
potentially contain substances in scope of the RMI program.
| · | Responsible Minerals Statement |
During our annual survey, we deploy
a questionnaire to our suppliers which allows us to:
| - | Identify substances and suppliers in scope of the RMI program; |
| - | Check supplier’s alignment with our requirements; and |
| - | Assess risks at supplier level. |
| · | Downstream Assessment Program (“DAP”) |
We are one of the first semi-conductor
manufacturers to receive the DAP recognition for 3TG. In November 2021, we received the RMI’s DAP recognition, with a two-year validity,
which validated our responsible minerals sourcing due diligence and practices.We were reassessed in November 2023 and revalidated beginning
of 2024.
This
international assessment organized by the RMI, offers independent third-party assurance for companies importing, amongst others, 3TG-containing
products into the EU considering the Regulation.
A further description of this assessment and the list of facilities that have completed it are accessible
here: https://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/downstream -program/.
Furthermore, we request our suppliers,
in scope of the RMI program to pass the DAP to validate their Responsible Minerals Sourcing due diligence practices.
| · | Conflict Minerals Reporting Template (“CMRT”) |
We require a CMRT to our suppliers
in three cases:
| - | During our annual survey; |
| - | When a smelter’s conformance status changes; and |
| - | We require our suppliers to send us an updated CMRT in case their smelters
list changes. |
In the “Responsible Minerals
Statement”, we detail our requirements related to the CMRT.
As an RMI member, we benefit from third-party
audits organized by the RMI, the LBMA and the RJC. During the Smelters Audit, OECD red flag identification and mitigation are assessed.
The audit results are aggregated in a list maintained by the RMI named the RMAP list. We crosscheck our suppliers’ CMRT with the
RMAP list to identify any non-conformant smelters. Furthermore, we periodically receive notification from the RMI to highlight a smelter’s
conformance change.
In our “Responsible Minerals
Statement,” we encourage suppliers to initiate a grievance on the RMI portal, as referenced in Section 2.II. above, if they become
aware of a violation of the OECD Guidance Annex II or other critical risk (https://mineralsgrievanceplatform.org/).
Anyone can issue a grievance related
to ST via our “Ethics Hotline”, as referenced in Section 2.II. above, which is operated by a third-party in order to guarantee
an independent and objective process.
We use the RCOI list to identify the
countries of origin of the minerals and the related risk classification. The RCOI list allows us to identify Red Flags associated to CAHRAs
(including the Democratic Republic of the Congo and adjoining countries).
CMRT inquiry responses 2023
We conducted an inquiry, using the CMRT, with
all the suppliers and subcontractors which we identified within our conflict mineral supply chain. All such suppliers and subcontractors
responded to our due diligence inquiry. The below table shows the supplier responses and completion rate since 2017 as of December 31
of each year:
| CMRT
inquiry responses 2023 |
2023 |
2022 |
2021 |
2020 |
2019 |
2018 |
2017 |
Supplier
Template Completion Rate |
100% |
100% |
100% |
100% |
100% |
100% |
100% |
| 141 |
154 |
137 |
124 |
124 |
128 |
126 |
We reviewed the responses received against criteria
developed to determine which responses required further engagement with our suppliers. These criteria included untimely or incomplete
responses as well as inconsistencies within the data reported in the CMRT.
We rely on the good faith efforts of our suppliers
and subcontractors to provide us with reasonable representations of the processing facilities used to supply the necessary conflict minerals
in our products. As a result of our inquiry via the CMRT, our suppliers and subcontractors reported to us a total of 230 smelters as sources
of 3TG during the 2023 calendar year, 20 of which we had discontinued as sources as of December 31, 2023, as reflected in the Table 2
in section IV below.
The table below indicates the CMRT inquiry responses
as of December 31 of each of the relevant years, indicating per metal: (i) the number of smelters declared; (ii) the percentage of declared
smelters which were RMAP conformant; (iii) the percentage of declared active smelters; and (iv) the percentage of smelters not identified
or not listed. Information relating to RMAP conformant smelters is extracted from the RBA/RMI database. The information presented in the
below table represents the state of affairs as of December 31 of each relevant year but should not be interpreted as necessarily having
applied consistently throughout the entire calendar year. Although we have received, and regularly continue to receive, updates to the
RMAP conformance information presented in this table, we have presented it as of December 31 of each relevant year. Information on the
smelters that we discontinued as sources during the calendar year, but before December 31, of each of the years 2017-2021 can be found
in our conflict minerals report filed with the SEC as an exhibit to Form SD for that relevant year.
| Year |
Metal |
Number of smelters declared |
Percentage of smelters RMAP conformant declared |
Percentage of active smelters declared |
Percentage of smelters not identified or not listed |
| 2023 |
Gold |
86 |
100% |
0% |
0% |
| Tantalum |
32 |
100% |
0% |
0% |
| Tin |
60 |
100% |
0% |
0% |
| Tungsten |
32 |
100% |
0% |
0% |
| 2022 |
Gold |
98 |
100% |
0% |
0% |
| Tantalum |
34 |
100% |
0% |
0% |
| Tin |
58 |
100% |
0% |
0% |
| Tungsten |
39 |
100% |
0% |
0% |
| 2021 |
Gold |
63 |
100% |
0% |
0% |
| Tantalum |
33 |
100% |
0% |
0% |
| Tin |
54 |
98.15% |
1.85% |
0% |
| Tungsten |
39 |
100% |
0% |
0% |
| 2020 |
Gold |
107 |
100% |
0% |
0% |
| Tantalum |
37 |
100% |
0% |
0% |
| Tin |
53 |
100% |
0% |
0% |
| Tungsten |
42 |
100% |
0% |
0% |
| 2019 |
Gold |
102 |
100% |
0% |
0% |
| Tantalum |
39 |
100% |
0% |
0% |
| Tin |
72 |
100% |
0% |
0% |
| Tungsten |
40 |
100% |
0% |
0% |
| 2018 |
Gold |
99 |
100% |
0% |
0% |
| Tantalum |
39 |
100% |
0% |
0% |
| Tin |
73 |
100% |
0% |
0% |
| Tungsten |
40 |
100% |
0% |
0% |
| 2017 |
Gold |
86 |
100% |
0% |
0% |
| Tantalum |
17 |
100% |
0% |
0% |
| Tin |
62 |
100% |
0% |
0% |
| Tungsten |
32 |
100% |
0% |
0% |
The below table shows the status of all declared
and identified smelters and refiners for the relevant years as per December 31 of each relevant year:
| |
2023 |
2022 |
2021 |
2020 |
2019 |
2018 |
2017 |
| Percentage
of smelters certified RMAP conformant |
100% |
100% |
99.47% |
100% |
100% |
100% |
100% |
| (210/210) |
(229/229) |
(188/189) |
(239/239) |
(253/253) |
(251/251) |
(197/197) |
| Currently
participating, in communication or agreed to participate in audit process |
N/A |
N/A |
0.53% |
N/A |
N/A |
N/A |
N/A |
| |
|
(1/189) |
|
|
|
|
| Outreach
Required |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
| |
|
|
|
|
|
|
Analysis of our products considering due diligence
results
From the figures in the above table, we can conclude
that 100% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2023,
were validated by the RMAP as being conformant as of December 31, 2023. We have included in Table 1 in section IV below a list of these
processing facilities as well as their identification number as used by the RMAP.
20 of the 230 smelters declared to us by our suppliers
and subcontractors were RMAP conformant at some point during calendar year 2023 but no longer qualified as such as of December 31, 2023
and 20 were therefore removed from our authorized sources of 3TG as of such date. We are not in a position to know whether a certain 3TG
material which was used in the manufacture of a product during 2023 originated with one of such smelters before or after it lost its status
as RMAP conformant. We have identified these smelters and the month during which we were notified of their removal from the RMAP conformance
list in Table 2 in section IV below.
III. Design and implement a strategy to respond to identified risks
A key requirement to our supply chain, is to use
only RMAP conformant smelters. By doing this we ensure that most of the risks identified are addressed. The following section details
our mitigation strategy per identified risk.
Risk mitigation
We have a risk mitigation plan to address the
risks identified. In this plan, mitigation actions are detailed per category of identified risks.
We mitigate risks identified “upstream”
by only working with RMAP conformant smelters and relying on the smelter audits. In case a smelter becomes non-conformant we remove it
from our supply chain.
We mitigate risks identified “downstream”
by continuously assessing and training our suppliers to ensure the reliability of their due diligence.
On a quarterly
basis a standard report is communicated to our Sustainability Council, consisting of representatives of the following organizations within
ST: Corporate Social Responsibility, Internal Communication, External Communication, Quality, Product Groups, Manufacturing, Sales, Compliance
& Business Ethics, Procurement, Investor Relations and Finance.
This report
details (i) the conflict minerals-related risks identified during the quarter, (ii) the mitigation actions taken and (iii) the conformance
status and a list of delinquent suppliers which do not meet our mandatory requirements despite several risk mitigation efforts attempted
from our side. The Sustainability Council should indicate further action to be taken to treat delinquent suppliers, which may include
disengaging with a delinquent supplier after failed attempts at risk mitigation, although the latter has not yet been the case.
IV. Independent third-party audit of smelters
100% of the smelters declared to us by our suppliers
and subcontractors which remained as our sources of 3TG as of December 31, 2023, were validated by the RMAP as being conformant based
on independent third-party audits performed on these smelters. Included in the below table is a summary of the independent third-party
audits performed on the processing facilities that were identified to us by our suppliers as potentially in our supply chain for 2023.
The presence of a facility on this list does not mean that our products necessarily contained 3TGs processed by that facility. Location
information for each processing facility is as reported by the RMAP as of December 31, 2023.
Lists of Processing Facilities
Table 1: Processing facilities, listed by smelter
identification number, reported in our supply chain in relation to calendar year 2023 which were validated by the RMAP conformant smelters
program as of December 31, 2023:
| Smelter
Identification |
Metal
|
Smelter
Name |
Smelter
Country |
Auditor
Name |
| CID000035 |
Gold |
Agosi AG |
GERMANY |
LBMA RG / RJC |
| CID000019 |
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID000041 |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
LBMA RG |
| CID000058 |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
BRAZIL |
LBMA RG |
| CID000077 |
Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
LBMA RG / RJC |
| CID000082 |
Gold |
Asahi Pretec Corp. |
JAPAN |
LBMA RG |
| CID000924 |
Gold |
Asahi Refining Canada Ltd. |
CANADA |
LBMA RG |
| CID000920 |
Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA |
LBMA RG |
| CID000090 |
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID000113 |
Gold |
Aurubis AG |
GERMANY |
LBMA RG |
| CID000128 |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
LBMA RG |
| CID000157 |
Gold |
Boliden AB |
SWEDEN |
LBMA RG |
| CID000176 |
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
LBMA RG / RJC |
| CID000185 |
Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
LBMA RG |
| CID000233 |
Gold |
Chimet S.p.A. |
ITALY |
LBMA RG |
| CID000264 |
Gold |
Chugai Mining |
JAPAN |
RMI (members / partners) |
| CID000401 |
Gold |
Dowa |
JAPAN |
RMI (members / partners) |
| CID000359 |
Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
RMI (members / partners) |
| CID000425 |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
JAPAN |
RMI (members / partners) |
| CID003424 |
Gold |
Eco-System Recycling Co., Ltd. North Plant |
JAPAN |
RMI (members / partners) |
| CID003425 |
Gold |
Eco-System Recycling Co., Ltd. West Plant |
JAPAN |
RMI (members / partners) |
| CID002243 |
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
CHINA |
LBMA RG |
| CID000694 |
Gold |
Heimerle + Meule GmbH |
GERMANY |
LBMA RG |
| CID000711 |
Gold |
Heraeus Germany GmbH Co. KG |
GERMANY |
RMI (members / partners) |
| CID000707 |
Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
LBMA RG / RJC |
| CID000801 |
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
LBMA RG |
| CID000807 |
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
LBMA RG |
| CID000814 |
Gold |
Istanbul Gold Refinery |
TURKEY |
LBMA RG |
| CID002765 |
Gold |
Italpreziosi |
ITALY |
LBMA RG / RJC |
| CID000823 |
Gold |
Japan Mint |
JAPAN |
LBMA RG |
| CID000855 |
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
LBMA RG |
| CID000937 |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
LBMA RG |
| CID000957 |
Gold |
Kazzinc |
KAZAKHSTAN |
LBMA RG |
| CID000969 |
Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA |
LBMA RG |
| CID002511 |
Gold |
KGHM Polska Miedz Spolka Akcyjna |
POLAND |
LBMA RG |
| CID000981 |
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID002605 |
Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
RMI (members / partners) |
| Smelter
Identification |
Metal
|
Smelter
Name |
Smelter
Country |
Auditor
Name |
| CID002762 |
Gold |
L'Orfebre S.A. |
ANDORRA |
RMI (members / partners) |
| CID001078 |
Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
LBMA RG |
| CID000689 |
Gold |
LT Metal Ltd. |
KOREA, REPUBLIC OF |
RMI (members / partners) |
| CID001113 |
Gold |
Materion |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID001119 |
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
LBMA RG |
| CID003575 |
Gold |
Metal Concentrators SA (Pty) Ltd. |
SOUTH AFRICA |
RJC |
| CID001149 |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
LBMA RG / RJC |
| CID001152 |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
LBMA RG / RJC |
| CID001147 |
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
LBMA RG / RJC |
| CID001153 |
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
LBMA RG / RJC |
| CID001157 |
Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA |
LBMA RG / RJC |
| CID001161 |
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
MEXICO |
LBMA RG |
| CID001188 |
Gold |
Mitsubishi Materials Corporation |
JAPAN |
LBMA RG |
| CID001193 |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
LBMA RG |
| CID001352 |
Gold |
MKS PAMP SA |
SWITZERLAND |
LBMA RG |
| CID002509 |
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
LBMA RG |
| CID001220 |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
TURKEY |
LBMA RG |
| CID001236 |
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
LBMA RG |
| CID003189 |
Gold |
NH Recytech Company |
KOREA, REPUBLIC OF |
RMI (members / partners) |
| CID001259 |
Gold |
Nihon Material Co., Ltd. |
JAPAN |
LBMA RG |
| CID002779 |
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
RJC |
| CID001325 |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID002919 |
Gold |
Planta Recuperadora de Metales SpA |
CHILE |
RMI (members / partners) |
| CID001397 |
Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
LBMA RG |
| CID001498 |
Gold |
PX Precinox S.A. |
SWITZERLAND |
LBMA RG |
| CID001512 |
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
LBMA RG |
| CID002582 |
Gold |
REMONDIS PMR B.V. |
NETHERLANDS |
RMI (members / partners) |
| CID001534 |
Gold |
Royal Canadian Mint |
CANADA |
LBMA RG |
| CID002290 |
Gold |
SAFINA A.S. |
CZECHIA |
RMI (members / partners) |
| CID001585 |
Gold |
SEMPSA Joyeria Plateria S.A. |
SPAIN |
LBMA RG / RJC |
| CID001916 |
Gold |
Shandong Gold Smelting Co., Ltd. |
CHINA |
LBMA RG |
| CID001622 |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
LBMA RG |
| CID001736 |
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA |
LBMA RG |
| CID001761 |
Gold |
Solar Applied Materials Technology Corp. |
TAIWAN, PROVINCE OF CHINA |
LBMA RG |
| CID001798 |
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
LBMA RG |
| CID002918 |
Gold |
SungEel HiMetal Co., Ltd. |
KOREA, REPUBLIC OF |
RMI (members / partners) |
| CID002580 |
Gold |
T.C.A S.p.A |
ITALY |
LBMA RG |
| CID001875 |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
LBMA RG |
| CID001938 |
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
LBMA RG |
| CID002615 |
Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
LBMA RG |
| Smelter
Identification |
Metal
|
Smelter
Name |
Smelter
Country |
Auditor
Name |
| CID001955 |
Gold |
Torecom |
KOREA, REPUBLIC OF |
RMI (members / partners) |
| CID001980 |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
LBMA RG |
| CID001993 |
Gold |
United Precious Metal Refining, Inc. |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID002003 |
Gold |
Valcambi S.A. |
SWITZERLAND |
LBMA RG / RJC |
| CID002030 |
Gold |
Western Australian Mint (T/a The Perth Mint) |
AUSTRALIA |
LBMA RG |
| CID002778 |
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
RJC |
| CID002100 |
Gold |
Yamakin Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID002129 |
Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID002224 |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
LBMA RG |
| CID001076 |
Tantalum |
AMG Brasil |
BRAZIL |
RMI (members / partners) |
| CID002504 |
Tantalum |
D Block Metals, LLC |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID000460 |
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
RMI (members / partners) |
| CID002505 |
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
RMI (members / partners) |
| CID002558 |
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
RMI (members / partners) |
| CID002557 |
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID002492 |
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002512 |
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002842 |
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
RMI (members / partners) |
| CID000914 |
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000917 |
Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002506 |
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002539 |
Tantalum |
KEMET de Mexico |
MEXICO |
RMI (members / partners) |
| CID002548 |
Tantalum |
Materion Newton Inc. |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID001163 |
Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
RMI (members / partners) |
| CID001175 |
Tantalum |
Mineracao Taboca S.A. |
BRAZIL |
RMI (members / partners) |
| CID001192 |
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID001277 |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID001200 |
Tantalum |
NPM Silmet AS |
ESTONIA |
RMI (members / partners) |
| CID001508 |
Tantalum |
QuantumClean |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID002707 |
Tantalum |
Resind Industria e Comercio Ltda. |
BRAZIL |
RMI (members / partners) |
| CID003583 |
Tantalum |
RFH Yancheng Jinye New Material Technology Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID001869 |
Tantalum |
Taki Chemical Co., Ltd. |
JAPAN |
RMI (members / partners) |
| Smelter
Identification |
Metal
|
Smelter
Name |
Smelter
Country |
Auditor
Name |
| CID002544 |
Tantalum |
TANIOBIS Co., Ltd. |
THAILAND |
RMI (members / partners) |
| CID002545 |
Tantalum |
TANIOBIS GmbH |
GERMANY |
RMI (members / partners) |
| CID002549 |
Tantalum |
TANIOBIS Japan Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID002550 |
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
RMI (members / partners) |
| CID001891 |
Tantalum |
Telex Metals |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID001969 |
Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
RMI (members / partners) |
| CID000616 |
Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED |
CHINA |
RMI (members / partners) |
| CID002508 |
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID001522 |
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000292 |
Tin |
Alpha |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID002773 |
Tin |
Aurubis Beerse |
BELGIUM |
RMI (members / partners) |
| CID002774 |
Tin |
Aurubis Berango |
SPAIN |
RMI (members / partners) |
| CID000228 |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID003190 |
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID001070 |
Tin |
China Tin Group Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID003486 |
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
BRAZIL |
RMI (members / partners) |
| CID003524 |
Tin |
CRM Synergies |
SPAIN |
RMI (members / partners) |
| CID002570 |
Tin |
CV Ayi Jaya |
INDONESIA |
RMI (members / partners) |
| CID002455 |
Tin |
CV Venus Inti Perkasa |
INDONESIA |
RMI (members / partners) |
| CID000402 |
Tin |
Dowa |
JAPAN |
RMI (members / partners) |
| CID003831 |
Tin |
DS Myanmar |
MYANMAR |
RMI (members / partners) |
| CID000438 |
Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) |
RMI (members / partners) |
| CID000448 |
Tin |
Estanho de Rondonia S.A. |
BRAZIL |
RMI (members / partners) |
| CID003582 |
Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
BRAZIL |
RMI (members / partners) |
| CID000468 |
Tin |
Fenix Metals |
POLAND |
RMI (members / partners) |
| CID000538 |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID003116 |
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002844 |
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID001231 |
Tin |
Jiangxi New Nanshan Technology Ltd. |
CHINA |
RMI (members / partners) |
| CID003387 |
Tin |
Luna Smelter, Ltd. |
RWANDA |
RMI (members / partners) |
| CID002468 |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
RMI (members / partners) |
| Smelter
Identification |
Metal
|
Smelter
Name |
Smelter
Country |
Auditor
Name |
| CID001105 |
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
RMI (members / partners) |
| CID001142 |
Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID001173 |
Tin |
Mineracao Taboca S.A. |
BRAZIL |
RMI (members / partners) |
| CID001182 |
Tin |
Minsur |
PERU |
RMI (members / partners) |
| CID001191 |
Tin |
Mitsubishi Materials Corporation |
JAPAN |
RMI (members / partners) |
| CID001314 |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
RMI (members / partners) |
| CID002517 |
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
RMI (members / partners) |
| CID001337 |
Tin |
Operaciones Metalurgicas S.A. |
BOLIVIA (PLURINATIONAL STATE OF) |
RMI (members / partners) |
| CID000309 |
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
RMI (members / partners) |
| CID001399 |
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
RMI (members / partners) |
| CID002503 |
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
RMI (members / partners) |
| CID001402 |
Tin |
PT Babel Inti Perkasa |
INDONESIA |
RMI (members / partners) |
| CID001406 |
Tin |
PT Babel Surya Alam Lestari |
INDONESIA |
RMI (members / partners) |
| CID003205 |
Tin |
PT Bangka Serumpun |
INDONESIA |
RMI (members / partners) |
| CID001428 |
Tin |
PT Bukit Timah |
INDONESIA |
RMI (members / partners) |
| CID002696 |
Tin |
PT Cipta Persada Mulia |
INDONESIA |
RMI (members / partners) |
| CID002835 |
Tin |
PT Menara Cipta Mulia |
INDONESIA |
RMI (members / partners) |
| CID001453 |
Tin |
PT Mitra Stania Prima |
INDONESIA |
RMI (members / partners) |
| CID003449 |
Tin |
PT Mitra Sukses Globalindo |
INDONESIA |
RMI (members / partners) |
| CID001458 |
Tin |
PT Prima Timah Utama |
INDONESIA |
RMI (members / partners) |
| CID003868 |
Tin |
PT Putera Sarana Shakti (PT PSS) |
INDONESIA |
RMI (members / partners) |
| CID003381 |
Tin |
PT Rajawali Rimba Perkasa |
INDONESIA |
RMI (members / partners) |
| CID002593 |
Tin |
PT Rajehan Ariq |
INDONESIA |
RMI (members / partners) |
| CID001460 |
Tin |
PT Refined Bangka Tin |
INDONESIA |
RMI (members / partners) |
| CID001463 |
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
RMI (members / partners) |
| CID001468 |
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
RMI (members / partners) |
| CID002816 |
Tin |
PT Sukses Inti Makmur |
INDONESIA |
RMI (members / partners) |
| CID001486 |
Tin |
PT Timah Nusantara |
INDONESIA |
RMI (members / partners) |
| CID001477 |
Tin |
PT Timah Tbk Kundur |
INDONESIA |
RMI (members / partners) |
| CID001482 |
Tin |
PT Timah Tbk Mentok |
INDONESIA |
RMI (members / partners) |
| CID001493 |
Tin |
PT Tommy Utama |
INDONESIA |
RMI (members / partners) |
| Smelter
Identification |
Metal
|
Smelter
Name |
Smelter
Country |
Auditor
Name |
| CID002706 |
Tin |
Resind Industria e Comercio Ltda. |
BRAZIL |
RMI (members / partners) |
| CID001539 |
Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA |
RMI (members / partners) |
| CID001898 |
Tin |
Thaisarco |
THAILAND |
RMI (members / partners) |
| CID002180 |
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID003325 |
Tin |
Tin Technology & Refining |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID002036 |
Tin |
White Solder Metalurgia e Mineracao Ltda. |
BRAZIL |
RMI (members / partners) |
| CID002158 |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000004 |
Tungsten |
A.L.M.T. Corp. |
JAPAN |
RMI (members / partners) |
| CID002502 |
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
RMI (members / partners) |
| CID002641 |
Tungsten |
China Molybdenum Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000258 |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID003468 |
Tungsten |
Cronimet Brasil Ltda |
BRAZIL |
RMI (members / partners) |
| CID003609 |
Tungsten |
Fujian Xinlu Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002645 |
Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002315 |
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002494 |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000568 |
Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID000218 |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002541 |
Tungsten |
H.C. Starck Tungsten GmbH |
GERMANY |
RMI (members / partners) |
| CID003417 |
Tungsten |
Hubei Green Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000766 |
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002513 |
Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
CHINA |
RMI (members / partners) |
| CID000825 |
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
RMI (members / partners) |
| CID002551 |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002321 |
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002318 |
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002317 |
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002316 |
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID000966 |
Tungsten |
Kennametal Fallon |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID000105 |
Tungsten |
Kennametal Huntsville |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID003407 |
Tungsten |
Lianyou Metals Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
RMI (members / partners) |
| Smelter Identification |
Metal |
Smelter Name |
Smelter Country |
Auditor Name |
| CID002319 |
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002543 |
Tungsten |
Masan High-Tech Materials |
VIET NAM |
RMI (members / partners) |
| CID002589 |
Tungsten |
Niagara Refining LLC |
UNITED STATES OF AMERICA |
RMI (members / partners) |
| CID002827 |
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
RMI (members / partners) |
| CID002542 |
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
RMI (members / partners) |
| CID002044 |
Tungsten |
Wolfram Bergbau und Hutten AG |
AUSTRIA |
RMI (members / partners) |
| CID002320 |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
RMI (members / partners) |
| CID002082 |
Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
RMI (members / partners) |
Table 2: Processing facilities, listed
by smelter identification number, reported in our supply chain in relation to calendar year 2023 which no longer qualified as RMAP conformant
or eligible as of December 31, 2023, and from which we have discontinued the sourcing of materials as of such date:
| RMAP
Smelter Identification Number |
Metal
|
Smelter
Name |
Smelter
Country |
Month
of communication Effective date reported by RMI (all in 2023) |
Reason
for non-conformance or non-eligibility |
| CID002763 |
Gold |
8853 S.p.A. |
ITALY |
January |
Non Conformant |
| CID002833 |
Tungsten |
ACL Metais Eireli |
BRAZIL |
January |
Non Conformant |
| CID000189 |
Gold |
Cendres + Metaux S.A. |
SWITZERLAND |
January |
Non Conformant |
| CID000555 |
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
January |
Non Conformant |
| CID002845 |
Tungsten |
Moliren Ltd. |
RUSSIAN FEDERATION |
January |
RMI Due Diligence Review - Unable to Proceed |
| CID002973 |
Gold |
Safimet S.p.A |
ITALY |
January |
Non Conformant |
| CID002516 |
Gold |
Singway Technology Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
January |
Non Conformant |
| CID001555 |
Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
February |
Non Conformant |
| CID002314 |
Gold |
Umicore Precious Metals Thailand |
THAILAND |
March |
Non Conformant |
| CID000769 |
Tungsten |
Hunan Jintai New Material Co., Ltd. |
CHINA |
April |
Non Conformant |
| CID000015 |
Gold |
Advanced Chemical Company |
UNITED STATES OF AMERICA |
May |
Non Conformant |
| CID003401 |
Tungsten |
Fujian Ganmin RareMetal Co., Ltd. |
CHINA |
July |
Ceased Operations |
| CID000875 |
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
July |
Ceased Operations |
| CID002547 |
Tantalum |
QSIL Metals Hermsdorf GmbH |
GERMANY |
July |
Ceased Operations |
| CID002761 |
Gold |
SAAMP |
FRANCE |
July |
Non Conformant |
| CID002830 |
Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CHINA |
July |
Ceased Operations |
| CID002561 |
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
July |
Non Conformant |
| CID002863 |
Gold |
Bangalore Refinery |
INDIA |
August |
Non Conformant |
| CID002560 |
Gold |
Al Etihad Gold Refinery DMCC |
UNITED ARAB EMIRATES |
August |
Non Conformant |
| CID003379 |
Tin |
Ma'anshan Weitai Tin Co., Ltd. |
CHINA |
September |
Non Conformant |
V. Reporting
We report on our responsible minerals program
and performance through different channels, as highlighted in the below table:
| Availability |
|
Policy statement |
CMRT |
EMRT |
Sustainability report |
DFA (CMR) |
Annual responsible mineral report |
| Public |
st.com |
x |
|
|
x |
x |
x |
| Public |
Inspectie Leefomgeving en Transport – Inspection living environment and transportation |
|
|
|
|
|
x |
| Public |
SEC |
|
|
|
x |
x |
|
| On demand |
|
|
x |
x |
|
|
|
ANNEX I
DEFINITIONS
| Acronym |
Definition |
| CAHRA |
Conflict-Affected and High-Risk Area |
| CMRT |
Conflict Minerals Reporting Template |
| DAP |
Downstream Assessment Program |
| LBMA |
London Bullion Market Association |
| RJC |
Responsible Jewellery Council |
| RMAP |
Responsible Minerals Assurance Process |
| RMI |
Responsible Minerals Initiative |
| RCOI |
Reasonable Country of Origin Inquiry |
| Term |
Definition |
| Conflict Minerals Reporting Template |
The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. The template also facilitates the identification of new smelters and refiners to potentially undergo an audit via the RMI’s Responsible Minerals Assurance Process (RMAP). |
| Downstream Assessment Program |
The RMI Downstream Assessment Program provides a mechanism for companies to obtain independent validation of responsible sourcing practices. The assessment is based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. |
| Downstream |
The metal supply chain from the stage following the smelters and refiners to the final product. |
| London Bullion Market Association |
The LBMA set standards from the purity, form and provenance of the bars to the way in which they are traded. |
| Reasonable Country of Origin Inquiry |
The purpose of a RCOI is to determine the origin of the conflict mineral, so the determination of whether it came from a covered country can be made. |
| Responsible Jewellery Council |
RJC is the world’s leading standard-setting organization for the entire jewellery and watch industry. |
| Responsible Minerals Assurance Process |
The RMAP uses an independent third-party assessment of smelter/refiner management systems and sourcing practices to validate conformance with RMAP standards. |
| Responsible Minerals operator |
Person in charge to manage operationally the responsible minerals program. |
| Responsible Minerals Statement |
Questionnaire deployed to our suppliers to check their alignment with requirements and evaluate some downstream risks. |
| RMAP standards |
The RMAP standards are developed to meet the requirements of the OECD Due Diligence Guidance, the Regulation (EU) 2017/821 of the European Parliament and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. |
| Smelter / Refiner |
According to the EU regulation, smelter and refiner means any natural or legal person performing forms of extractive metallurgy involving processing steps with the aim to produce a metal from a mineral. |
| Upstream |
The mineral supply chain from the extraction sites to the smelters and refiners, inclusive. |
21
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