0001413329-22-000049.txt : 20220517 0001413329-22-000049.hdr.sgml : 20220517 20220517065235 ACCESSION NUMBER: 0001413329-22-000049 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20211231 1.02 20211231 FILED AS OF DATE: 20220517 DATE AS OF CHANGE: 20220517 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Philip Morris International Inc. CENTRAL INDEX KEY: 0001413329 STANDARD INDUSTRIAL CLASSIFICATION: CIGARETTES [2111] IRS NUMBER: 133435103 STATE OF INCORPORATION: VA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-33708 FILM NUMBER: 22932197 BUSINESS ADDRESS: STREET 1: 120 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10017 BUSINESS PHONE: (917) 663-2000 MAIL ADDRESS: STREET 1: 120 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10017 SD 1 formsd2022-05x17.htm SD Document

Washington, D.C. 20549
Specialized Disclosure Report

Philip Morris International Inc.
(Exact name of registrant as specified in its charter)

(State or other jurisdiction
of incorporation)
File Number)
(I.R.S. Employer
Identification No.)
120 Park Avenue, New York, New York
(Address of principal executive offices)
(Zip Code)

Massimo Andolina
Senior Vice President Operations PMI
+41 (58) 242 6710
(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:
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.

Section 1 – Conflict Minerals Disclosure
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report
    This Specialized Disclosure Report (“Form SD”) for Philip Morris International Inc. (“PMI”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1, 2021 to December 31, 2021. A copy of the Conflict Minerals Report is attached as Exhibit 1.01 to this Form SD and is also publicly available on PMI's website at https://www.pmi.com/home/our-views-and-standards/standards/transparency.

Section 2 – Exhibits
Item 2.01 – Exhibits
    The following exhibit is filed as part of this Report.

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 undersigned hereunto duly authorized.

Massimo Andolina
Senior Vice President, Operations
DATE: May 17, 2021

EX-1.01 2 cmr2022-05x17.htm EX-1.01 Document

Exhibit 1.01

Philip Morris International Inc., a Virginia holding company, was incorporated in 1987. Our subsidiaries and affiliates and their licensees are engaged in the manufacture and sale of cigarettes, other tobacco products and other nicotine-containing products, including reduced-risk products2, in markets outside of the United States of America.
This Conflict Minerals Report (the “Report”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”), for the reporting period from January 1 to December 31, 2021.
Conflict Minerals are defined by the Securities and Exchange Commission (the “SEC”) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “3TGs”). During the reporting period, we contracted to manufacture the following products within the meaning of Rule 13p-1:
Platform 1 – a precisely controlled heating device incorporating our IQOS HeatControl Technology, commercialized under the IQOS brand name, into which a specially designed and proprietary tobacco unit is inserted and heated to create an aerosol, and also includes related accessories and parts; and
Platform 4 – includes battery powered e-vapor products that produce an aerosol by vaporizing a nicotine-containing liquid solution. In 2021, our e-vapor products comprised devices with our e-vapor mesh technology designed to ensure the consistency and quality of the generated aerosol compared to the products with the “coil and wick” technology. In 2020, we discontinued the commercialization of devices with the “coil and wick” technology.  In 2021, our e-vapor mesh technology products were commercialized using the IQOS VEEV or VEEV brand names.
In this report, we refer to Platform 1 and Platform 4 products as “Covered Products.”

In 2021, we sourced our Covered Products from five direct suppliers (the “Direct Suppliers”). The electronic components of the Covered Products contain one or more 3TGs. The 3TGs used in the Covered Products are necessary for the functionality or production of the Covered Products.
1 In this report, “PMI,” “Company,” “we,” “us,” and “our” refers to Philip Morris International Inc. and its subsidiaries. Trademarks and science marks in this report are the intellectual property of, or licensed by, the subsidiaries of Philip Morris International Inc. and are italicized.
2 Reduced-risk products (“RRPs”) is the term PMI uses to refer to products that present, are likely to present, or have the potential to present less risk of harm to smokers who switch to these products versus continuing smoking.  PMI has a range of RRPs in various stages of development, scientific assessment and commercialization.

We have implemented policies, procedures and due diligence processes to determine whether any of the 3TGs contained in the Covered Products are sourced from the Democratic Republic of the Congo (“DRC”) or any of its adjoining countries (“Covered Countries”), and contribute to the financing of armed conflict in the region. In order to support the economic activity in the region, we have communicated to our Direct Suppliers that we do not discourage them from sourcing 3TGs from the Covered Countries under our Conflict Minerals Policy (also referred to in this report as the “Policy”), so long as they are sourced in accordance with our Responsible Sourcing Principles (“RSP”).
We are far removed from the sources of ores from which the 3TGs contained in the Covered Products are procured, and the smelters and refiners that process those ores (“SORs”). Therefore, the efforts to identify the countries of origin for the 3TGs reflect both (i) our downstream position in the supply chain3; and (ii) the applicable OECD Guidance (as defined below).


A.Design of Our Due Diligence Measures

In 2021, our Conflict Minerals due diligence processes were performed in line with the internationally recognized due diligence framework provided by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”), as applicable for 3TGs and downstream companies (as the term “downstream companies” is defined in the OECD Guidance)4. As described below, our due diligence measures in relation to Covered Products included:
1.Establishing a process managed by members of management, including a dedicated cross-functional team for carrying out Conflict Minerals supply chain due diligence and reporting compliance (the “Conflict Minerals Team”);
2.Identifying and assessing Conflict Minerals risks in our supply chain;
3.Designing and implementing strategies to respond to Conflict Minerals risks to the extent identified; and
4.Encouraging the reliance by our Direct Suppliers on an independent third-party audit protocol for assessing the due diligence practices of SORs relevant to Covered Products.
3 As a result of our downstream position in the supply chain, our due diligence processes involve PMI seeking data from our Direct Suppliers and those suppliers seeking similar information in their respective supply chains to identify the original sources of the applicable Conflict Minerals. We also rely, to a large extent, on information collected and provided by third-party validation programs. Because our diligence processes rely on information provided by third parties, they may yield inaccurate or incomplete information.
4 “Downstream companies” include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers and retailers.

B. Due Diligence Program Elements
1.Processes Implemented by Company Management
Conflict Minerals Policy

We have a Conflict Minerals Policy which is communicated it to our Direct Suppliers to help achieve responsible sourcing of 3TGs in our supply chain. We are committed to operating with integrity and are focused on the responsible sourcing of 3TGs. Our Policy, which is reviewed annually by the Conflict Minerals Team, is attached to this Report as Appendix A, and is also publicly available on our website at: https://www.pmi.com/principles-and-positions/standards/transparency.
Internal Team

Under the oversight of our Senior Vice President, Operations, our Conflict Minerals Team is comprised by representatives from our operations, finance and legal functions. The Conflict Minerals Team has the overall responsibility for developing and implementing our Conflict Minerals compliance strategy, as well as for reviewing the ongoing progress and effectiveness of the Conflict Minerals reporting. In addition, from time-to time, this cross-functional team engages with specialists in other functions throughout PMI to review and analyze the information relevant to PMI’s Conflict Minerals due diligence processes and reporting.
As part of our organizational framework, our Product Compliance Team, which is part of the Life Sciences Department reporting to our Chief Life Sciences Officer, also verifies ingredients and materials used in the direct materials for our Covered Products. Any Conflict Minerals reporting and compliance matters that arise during this verification process are analyzed and addressed by the Conflict Minerals Team.
Furthermore, members of the Conflict Minerals Team with expertise in supply chain management and sustainability also interact with our Direct Suppliers to further improve the quality of their Conflict Minerals due diligence and reporting.
Our senior management and our Board of Directors are informed of the results of our due diligence efforts, supply chain integrity and relationships with our Direct Suppliers.
Supply Chain Transparency Framework

To support PMI’s Conflict Minerals compliance program, PMI’s supply chain transparency framework combines internal activities, collaboration with our Direct Suppliers and reliance on the information published by industry programs such as the Responsible Minerals Initiative (the “RMI”). The RMI is a global, non-governmental organization that was founded in 2008 by members of the Responsible Business Alliance (the “RBA”) and the Global e-Sustainability Initiative. It is comprised by

over 400 companies and associations from over ten industries. The RMI focuses on the sourcing of minerals responsibly and developing best practices and other services to support such responsible minerals sourcing.
As part of our Conflict Minerals due diligence processes, we required our Direct Suppliers to use RMI’s Conflict Minerals Reporting Template (“CMRT”) to collect and retain the necessary information on the chain of custody of the 3TGs contained in the parts of the Covered Products that they respectively supplied to us, including information about the SORs from which those 3TGs were sourced. The CMRT is generally regarded as the most widely-used standard form to collect information
about Conflict Minerals through the supply chain.
Supplier Engagement and Other Compliance Efforts

Our agreements with our Direct Suppliers also include Conflict Minerals-related provisions that: (i) are consistent with our Conflict Minerals Policy, (ii) require our Direct Suppliers to comply with our due diligence requests; and (iii) encourage our Direct Suppliers to participate in industry-wide or material-specific supply chain mapping initiatives.
In addition, and consistent with our efforts as described in the Conflict Minerals report for the period ended December 31, 2020 (the “2020 Report”), in 2021, we continued to undertake the following efforts to further improve due diligence and supplier engagement:

We continued our online employee training programs, especially in light of the COVID-19 pandemic. These programs addressed various procurement activities, including the sourcing of minerals, compliance with our Conflict Minerals Policy and the underlying SEC regulations.
Our employees continued to communicate to our Direct Suppliers our Policy and our Responsible Sourcing Principles, our commitment to responsible sourcing, compliance expectations and information requirements, including grievance mechanisms. These communications focused on ensuring that our Direct Suppliers understand the regulations and reporting requirements pertaining to the sourcing of Conflict Minerals in their respective supply chains. In addition, our communications also encouraged our Direct Suppliers to review their supply chain due diligence processes related to Conflict Minerals sourcing in terms of accuracy and timeliness of responses, and continue to improve compliance.

As a result of these efforts, in 2021, we continued to see satisfactory levels of both timeliness and completeness of the information submitted to us by our Direct Suppliers. In addition, in 2021:

We joined the RBA in January 2021;
We deployed the RBA due diligence process to manage our supply chain – this program includes self-assessment questionnaires and a validated assurance program (that includes on-site audits) to monitor the sourcing of conflict minerals from our Direct Suppliers;
We conducted conflict minerals orientation seminars to two new Direct Suppliers, and we held monthly meetings with all our Direct Suppliers to discuss the requirements;
We used our supplier due diligence program to assess our Direct Suppliers’ compliance with our Responsible Sourcing Principles, which also cover the responsible sourcing of the 3TGs;
We communicated to our Direct Suppliers our expectation that they use SORs certified as compliant with the Responsible Minerals Assurance Process (“Compliant SORs”)5 for the manufacture of the Covered Products, and have held online conferences with our Direct Suppliers to reinforce this expectation. Please see “Section C” below for additional information;
We continued to mandate conflict minerals due diligence based on the OECD Guidance and training as a prerequisite to engagement with any new direct suppliers of electronics;
We continued to support our due diligence efforts with appropriate record retention practices; and
We engaged a third-party that specializes in human rights to help us identify and assess human rights risks across our electronics supply chain, including those that may be related to Conflict Minerals (the “Assessment Study”). This Assessment Study was completed in early 2021, and we are currently evaluating the conclusions drawn by the Assessment Study in relation to Conflict Minerals.

5 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process (“RMAP”) and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of the audit, such SORs are then designated as RMAP-Compliant SORs.

Grievance Mechanism
We have a grievance mechanism that allows our employees to report any suspected violation of PMI´s principles and practices to the senior management or the Ethics & Compliance Department. Reports can be made through face-to-face discussions or via email if the employee prefers to remain anonymous. We maintain both a dedicated email address: PMI.EthicsandCompliance@pmi.com, and an independently operated and confidential Compliance Helpline, that operates a phone line and a webline. Concerns can also be reported by our employees confidentially or anonymously. Any such reports related to Conflict Minerals are to be forwarded to the Conflict Minerals Team that will review them and help design appropriate response measures. In addition, we encourage our suppliers to establish their own grievance mechanisms.

2. Identify and Assess Risk in the Supply Chain
We reviewed the answers to the CMRT received from our Direct Suppliers and assessed their completeness, clarity and consistency. We worked with our Direct Suppliers to understand their due diligence process, confirmed that they have established a Conflict Minerals policy and obtained a list of SORs in their respective supply chains for the Covered Products.
Our Direct Suppliers confirmed that some of the SORs in their supply chain may source 3TGs from the Covered Countries and that the 3TGs may not be from recycled or scrap sources. As part of our risk assessment, we checked whether these SORs were Compliant SORs by comparing the facilities identified by our Direct Suppliers against the list provided by the RMI and its Responsible Minerals Assurance Process (“RMAP”), as well as the list provided by the London Bullion Market Association (“LBMA”). We also followed up with additional information requests to obtain the necessary details to better assess the reliability of the responses and the risks in our supply chain in instances where the responses received were not clear or where the SORs were not certified as RMAP- compliant.
Please also see Section B.1 for the discussion of our efforts in 2021 to help identify and assess risk in our supply chain related to 3TG sourcing.

3. Design and Implement a Strategy to Respond to Risks in the Supply Chain
We designed a strategy to respond to risks related to Conflict Minerals in our supply chain. When the members of the Conflict Minerals Team become aware that the due diligence of our direct or indirect suppliers needs improvement, it provides feedback, asks clarifying questions and demands corrective actions where necessary. The members of the Conflict Minerals Team have, and will continue to provide information and training to our Direct Suppliers, and will determine appropriate follow-up actions, if any, to mitigate any identified risks. Follow-up actions may include, but are not limited to, finding alternate sources of supply or terminating existing supplier relationships, as appropriate. We have communicated to

our Direct Suppliers that they should further implement, and communicate to their suppliers to implement, the due diligence standards that reflect the OECD Guidance. Steps to improve the accuracy of the due diligence process are described in Sections B.1 above and D below. For 2021, we found no instances where it was necessary to find replacement sources of supply of Covered Products or terminate a supplier relationship due to a failure to comply with Conflict Minerals requirements. To the extent we expand our supplier base for the relevant products, Conflict Minerals compliance, commitment and our assessment of the readiness to embrace our Responsible Sourcing Practices are among our criteria for selecting new suppliers.

4. Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We rely on the RMI’s Responsible Minerals Assurance Process for the performance of third-party audits of SORs. To the extent possible, we review whether any 3TGs sourced from the Covered Countries are “DRC conflict-free” based on the information provided by our Direct Suppliers and the information available on the RMI’s website. We encourage our suppliers to join the RBA. In addition, as described above, we have communicated to our Direct Suppliers our expectation that they use Compliant SORs for the manufacture of our Covered Products.

Report on Supply Chain Due Diligence

This Report will be filed with the SEC and will also be publicly available at https://www.pmi.com/principles-and- positions/standards/transparency.

C. Reasonable Country of Origin Inquiry ("RCOI") and Due Diligence on the Source and Chain of Custody

We asked our Direct Suppliers to provide answers to the CMRT to ascertain whether any 3TGs contained in the Covered Products originated from Covered Countries. Based on the evaluation of our Direct Suppliers’ responses to their CMRT, we had reason to believe that some of the 3TGs in the Covered Products manufactured in 2021 may have originated in the Covered Countries and were not entirely from recycled or scrap sources.

With respect to the Covered Products, through the CMRT, our Direct Suppliers informed us that, for 2021: (i) 100% of their suppliers provided responses to the CMRT; (ii) 3TGs contained in some Covered Products may have originated from the

Covered Countries; (iii) no 3TGs contained in the Covered Products come from recycled or scrap resources; (iv) 100% of the SORs supplying 3TGs contained in the Covered Products and their locations were identified and reported; and (v) all Direct Suppliers reported that they used Compliant or Active smelters for the respective Covered Products. We compared the facilities that the Direct Suppliers identified in their respective CMRTs to the list of SORs that are certified as RMAP-compliant. While sixteen SORs identified by our Direct Suppliers were not on the RMI list of Compliant SORs at the time of our review, we followed up with the relevant Direct Suppliers and, based on information supplied by our Direct Suppliers, we believe that these SORs were Active SORs during the reporting period.6

6 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of such audit, such SORs would become Compliant SORs.

D. Steps to Further Improve Due Diligence

In line with our commitment to Responsible Sourcing Principles, in January 2021, we joined the Responsible Minerals Initiative (“RMI”). We plan to be an active participant of RMI. In addition, we plan to concentrate on the following steps in the future:
As part of our Responsible Sourcing Principles framework, continue to engage with our Direct Suppliers to             communicate our expectation that they source 3TGs for our products from Compliant SORs;
Encourage our Direct Suppliers to further strengthen due diligence and training efforts consistent with the OECD Guidance, thereby improving the quality and completeness of supply chain information available to us;
Encourage our Direct Suppliers to continue to enforce their respective Conflict Minerals policies;
Continue to communicate and provide training on our Policy, grievance mechanism requirements, compliance expectations and information to our present Direct Suppliers and future direct suppliers;
Introduce RBA tools into our due diligence program to assist in our determination of our Direct Suppliers' compliance with our RSP;
Continue training our employees responsible for the procurement of electronics and those in related supporting roles, including through programs made available by RMI;
Continue to enhance our data assurance process with our Direct Suppliers;
Encourage our Direct Suppliers to receive training and other information on Conflict Minerals made available by RMI or RBA; and
We will consider the conclusions of the Assessment Study in our review of the due diligence practices for Conflict Minerals.

E. Independent Private Sector Audit

An independent private sector audit is not required for this Report.

Appendix A

Conflict Minerals Policy

The SEC requires our company to disclose if our products contain certain minerals (gold, tin, tungsten, and tantalum, which are referred to as “conflict minerals”) that:

Originate in one of the Covered Countries; and 
Contribute to the financing of armed groups that are committing human rights abuses.

PMI’s policy and due diligence process on conflict minerals prescribes that PMI:

1.Not to knowingly procure conflict minerals that originate from a Covered Country; and
2.Demand that our direct suppliers undertake reasonable due diligence in their respective supply chains to assure the same

unless those minerals are determined to be compliant by the Responsible Minerals Assurance Process.

Appendix B - List of SORs identified by our Direct Suppliers as part of the supply chain for Covered Products7

Subject MineralSmelter or Refiner NameCountry Location of Smelter or Refiner
Gold8853 S.p.A.*ITALY
GoldAdvanced Chemical Company*UNITED STATES OF AMERICA
GoldAida Chemical Industries Co., Ltd. *JAPAN
GoldAlmalyk Mining and Metallurgical Complex (AMMC) *UZBEKISTAN
GoldAngloGold Ashanti Corrego do Sitio Mineracao*BRAZIL
GoldArgor-Heraeus S.A. *SWITZERLAND
GoldAsahi Pretec Corp. *JAPAN
GoldAsahi Refining Canada Ltd. *CANADA
GoldAsaka Riken Co., Ltd. *JAPAN
GoldAugmont Enterprises Private Limited**INDIA
GoldBangalore Refinery*INDIA
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines) *PHILIPPINES
GoldBoliden AB*SWEDEN
GoldC. Hafner GmbH + Co. KG*GERMANY
GoldC.I Metales Procesados Industriales SAS**COLOMBIA
GoldCCR Refinery - Glencore Canada Corporation*CANADA
GoldCendres + Metaux S.A. *SWITZERLAND
GoldChimet S.p.A. *ITALY
GoldChugai Mining*JAPAN
GoldDODUCO Contacts and Refining GmbH*GERMANY
GoldDSC (Do Sung Corporation) *SOUTH KOREA
GoldEco-System Recycling Co., Ltd. East Plant*JAPAN
GoldEco-System Recycling Co., Ltd. North Plant*JAPAN
GoldEco-System Recycling Co., Ltd. West Plant*JAPAN
GoldGeib Refining Corporation*UNITED STATES OF AMERICA
GoldGGC Gujrat Gold Centre Pvt. Ltd.**INDIA
GoldGold Refinery of Zijin Mining Group Co., Ltd.*CHINA
GoldHeimerle + Meule GmbH*GERMANY
GoldHeraeus Germany GmbH Co. KG*GERMANY
GoldHeraeus Metals Hong Kong Ltd. *CHINA
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. *CHINA
GoldIshifuku Metal Industry Co., Ltd. *JAPAN
GoldIstanbul Gold Refinery*TURKEY
GoldJapan Mint*JAPAN
GoldJiangxi Copper Co., Ltd. *CHINA
GoldJSC Novosibirsk Refinery*RUSSIAN FEDERATION

GoldJX Nippon Mining & Metals Co., Ltd. *JAPAN
GoldKGHM Polska Miedz Spolka Akcyjna*POLAND
GoldKojima Chemicals Co., Ltd. *JAPAN
GoldKorea Zinc Co., Ltd.*SOUTH KOREA
GoldL'Orfebre S.A.*ANDORRA
GoldLT Metal Ltd. *SOUTH KOREA
GoldMarsam Metals*BRAZIL
GoldMatsuda Sangyo Co., Ltd.*JAPAN
GoldMetal Concentrators SA (Pty) Ltd.*SOUTH AFRICA
GoldMetalor Technologies (Hong Kong) Ltd.*CHINA
GoldMetalor Technologies (Singapore) Pte., Ltd.*SINGAPORE
GoldMetalor Technologies (Suzhou) Ltd.*CHINA
GoldMetalor Technologies S.A.*SWITZERLAND
GoldMetalor USA Refining Corporation*UNITED STATES OF AMERICA
GoldMetalurgica Met-Mex Penoles S.A. De C.V.*MEXICO
GoldMitsubishi Materials Corporation*JAPAN
GoldMitsui Mining and Smelting Co., Ltd.*JAPAN
GoldMMTC-PAMP India Pvt., Ltd.*INDIA
GoldMoscow Special Alloys Processing Plant*RUSSIAN FEDERATION
GoldNadir Metal Rafineri San. Ve Tic. A.S.*TURKEY
GoldNavoi Mining and Metallurgical Combinat*UZBEKISTAN
GoldNH Recytech Company*SOUTH KOREA
GoldNihon Material Co., Ltd.*JAPAN
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbH*AUSTRIA
GoldOhura Precious Metal Industry Co., Ltd.*JAPAN
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*RUSSIAN FEDERATION
GoldPlanta Recuperadora de Metales SpA*CHILE
GoldPrioksky Plant of Non-Ferrous Metals*RUSSIAN FEDERATION
GoldPT Aneka Tambang (Persero) Tbk*INDONESIA
GoldRand Refinery (Pty) Ltd.*SOUTH AFRICA
GoldRoyal Canadian Mint*CANADA
GoldSafimet S.p.A*ITALY
GoldSamduck Precious Metals*SOUTH KOREA
GoldSAXONIA Edelmetalle GmbH*GERMANY
GoldSEMPSA Joyeria Plateria S.A.*SPAIN
GoldShandong Gold Smelting Co., Ltd.*CHINA
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.*CHINA

GoldSichuan Tianze Precious Metals Co., Ltd.*CHINA
GoldSingway Technology Co., Ltd.*TAIWAN, REPUBLIC OF
GoldSOE Shyolkovsky Factory of Secondary Precious Metals*RUSSIAN FEDERATION
GoldSolar Applied Materials Technology Corp.*TAIWAN, REPUBLIC OF
GoldSumitomo Metal Mining Co., Ltd.*JAPAN
GoldSungEel HiMetal Co., Ltd.*SOUTH KOREA
GoldTanaka Kikinzoku Kogyo K.K. *JAPAN
GoldTokuriki Honten Co., Ltd.*JAPAN
GoldUmicore Precious Metals Thailand*THAILAND
GoldUmicore S.A. Business Unit Precious Metals Refining*BELGIUM
GoldUnited Precious Metal Refining, Inc.*UNITED STATES OF AMERICA
GoldWestern Australian Mint (T/a The Perth Mint)*AUSTRALIA
GoldWIELAND Edelmetalle GmbH*GERMANY
GoldYamakin Co., Ltd.*JAPAN
GoldYokohama Metal Co., Ltd.*JAPAN
GoldZhongyuan Gold Smelter of Zhongjin Gold Corporation*CHINA
TantalumAMG Brasil*BRAZIL
TantalumAsaka Riken Co., Ltd.*JAPAN
TantalumChangsha South Tantalum Niobium Co., Ltd.*CHINA
TantalumF&X Electro-Materials Ltd.*CHINA
TantalumFIR Metals & Resource Ltd.*CHINA
TantalumGlobal Advanced Metals Aizu*JAPAN
TantalumGlobal Advanced Metals Boyertown*UNITED STATES OF AMERICA
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.*CHINA
TantalumH.C. Starck Hermsdorf GmbH*GERMANY
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.*CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.*CHINA
TantalumJiangxi Tuohong New Raw Material*CHINA
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.*CHINA
TantalumJiujiang Tanbre Co., Ltd.*CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.*CHINA
TantalumKEMET de Mexico*MEXICO
TantalumMetallurgical Products India Pvt., Ltd.*INDIA
TantalumMineracao Taboca S.A.*BRAZIL
TantalumMitsui Mining and Smelting Co., Ltd.*JAPAN
TantalumNingxia Orient Tantalum Industry Co., Ltd.*CHINA
TantalumNPM Silmet AS*ESTONIA
TantalumResind Industria e Comercio Ltda.*BRAZIL

TantalumSolikamsk Magnesium Works OAO*RUSSIAN FEDERATION
TantalumTaki Chemical Co., Ltd.*JAPAN
TantalumTANIOBIS Japan Co., Ltd.*JAPAN
TantalumTANIOBIS Smelting GmbH & Co. KG*GERMANY
TantalumUlba Metallurgical Plant JSC*KAZAKHSTAN
TantalumXinXing HaoRong Electronic Material Co., Ltd.*CHINA
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.*CHINA
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.*CHINA
TinChifeng Dajingzi Tin Industry Co., Ltd.*CHINA
TinChina Tin Group Co., Ltd.*CHINA
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda**BRAZIL
TinCRM Synergies*SPAIN
TinCV Venus Inti Perkasa**INDONESIA
TinEstanho de Rondonia S.A.**BRAZIL
TinFenix Metals*POLAND
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinGejiu Non-Ferrous Metal Processing Co., Ltd.*CHINA
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.*CHINA
TinGejiu Zili Mining And Metallurgy Co., Ltd.*CHINA
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.*CHINA
TinHuichang Jinshunda Tin Co., Ltd.*CHINA
TinHuiChang Hill Tin Industry Co., Ltd.*CHINA
TinJiangxi New Nanshan Technology Ltd.*CHINA
TinLuna Smelter, Ltd.*RWANDA
TinMa'anshan Weitai Tin Co., Ltd.*CHINA
TinMagnu's Minerais Metais e Ligas Ltda.*BRAZIL
TinMalaysia Smelting Corporation (MSC)*MALAYSIA
TinMelt Metais e Ligas S.A.*BRAZIL
TinMetallic Resources, Inc.*UNITED STATES OF AMERICA
TinMetallo Belgium N.V.*BELGIUM
TinMetallo Spain S.L.U.*SPAIN
TinMineracao Taboca S.A.*BRAZIL
TinMitsubishi Materials Corporation*JAPAN
TinO.M. Manufacturing (Thailand) Co., Ltd.*THAILAND
TinO.M. Manufacturing Philippines, Inc.*PHILIPPINES
TinOperaciones Metalurgicas S.A.*BOLIVIA
TinPT Artha Cipta Langgeng*INDONESIA
TinPT ATD Makmur Mandiri Jaya*INDONESIA
TinPT Babel Inti Perkasa*INDONESIA

TinPT Babel Surya Alam Lestari*INDONESIA
TinPT Bangka Serumpun*INDONESIA
TinPT Bukit Timah**INDONESIA
TinPT Menara Cipta Mulia*INDONESIA
TinPT Mitra Stania Prima*INDONESIA
TinPT Mitra Sukses Globalindo**INDONESIA
TinPT Prima Timah Utama*INDONESIA
TinPT Rajawali Rimba Perkasa*INDONESIA
TinPT Rajehan Ariq*INDONESIA
TinPT Refined Bangka Tin*INDONESIA
TinPT Sariwiguna Binasentosa*INDONESIA
TinPT Stanindo Inti Perkasa*INDONESIA
TinPT Sukses Inti Makmur**INDONESIA
TinPT Timah Nusantara**INDONESIA
TinPT Timah Tbk Kundur*INDONESIA
TinPT Timah Tbk Mentok*INDONESIA
TinPT Tinindo Inter Nusa*INDONESIA
TinResind Industria e Comercio Ltda.*BRAZIL
TinSoft Metais Ltda.*BRAZIL
TinSuper Ligas**BRAZIL
TinThai Nguyen Mining and Metallurgy Co., Ltd.*VIETNAM
TinTin Smelting Branch of Yunnan Tin Co., Ltd.**CHINA
TinTin Technology & Refining*UNITED STATES OF AMERICA
TinWhite Solder Metalurgia e Mineracao Ltda.*BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.*CHINA
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.*CHINA
TungstenA.L.M.T. Corp.*JAPAN
TungstenACL Metais Eireli*BRAZIL
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.**BRAZIL
TungstenAsia Tungsten Products Vietnam Ltd.*VIETNAM
TungstenChenzhou Diamond Tungsten Products Co., Ltd.*CHINA
TungstenChina Molybdenum Tungsten Co., Ltd.*CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.*CHINA
TungstenCronimet Brasil Ltda*BRAZIL
TungstenFujian Ganmin RareMetal Co., Ltd.*CHINA
TungstenGanzhou Haichuang Tungsten Co., Ltd.*CHINA
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.*CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.*CHINA
TungstenGanzhou Seadragon W & Mo Co., Ltd.*CHINA
TungstenGlobal Tungsten & Powders Corp.*UNITED STATES OF AMERICA
TungstenGuangdong Xianglu Tungsten Co., Ltd.*CHINA
TungstenH.C. Starck Tungsten GmbH*GERMANY
TungstenHunan Chenzhou Mining Co., Ltd.*CHINA
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*CHINA
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.*CHINA
TungstenHydrometallurg, JSC*RUSSIAN FEDERATION

TungstenJapan New Metals Co., Ltd.*JAPAN
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.*CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.*CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.*CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.*CHINA
TungstenJingmen Dewei GEM Tungsten Resources Recycling Co., Ltd.**CHINA
TungstenJSC "Kirovgrad Hard Alloys Plant"*RUSSIAN FEDERATION
TungstenKennametal Fallon*UNITED STATES OF AMERICA
TungstenKennametal Huntsville*UNITED STATES OF AMERICA
TungstenLianyou Metals Co., Ltd.*TAIWAN, REPUBLIC OF
TungstenMalipo Haiyu Tungsten Co., Ltd.*CHINA
TungstenMasan High-Tech Materials*VIETNAM
TungstenPhilippine Chuangxin Industrial Co., Inc.*PHILIPPINES
TungstenTANIOBIS Smelting GmbH & Co. KG*GERMANY
TungstenUnecha Refractory metals plant*RUSSIAN FEDERATION
TungstenWolfram Bergbau und Hutten AG*AUSTRIA
TungstenWoltech Korea Co., Ltd.*SOUTH KOREA
TungstenXiamen Tungsten (H.C.) Co., Ltd.*CHINA
TungstenXiamen Tungsten Co., Ltd.*CHINA
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*CHINA
7 SORs that were designated, to our knowledge, as Compliant as of December 31, 2021 are marked with an asterisk (unless stated otherwise). SORs that were designated, to our knowledge, as Active as of December 31, 2021 are marked with two asterisks (unless stated otherwise).