EX-1.01 2 conflictmineralsreport.htm EXHIBIT 1.01 Exhibit


Keurig Dr Pepper Inc.
Conflict Minerals Report
For the reporting period from January 1, 2018 to December 31, 2018

Introduction

Keurig Dr Pepper, Inc. (the “Company” or “KDP”) is committed to sourcing products, components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. To that end, we are committed to the ethical sourcing of minerals including tin, tantalum, tungsten and gold. There is concern that 3TG, often referred to as “Conflict Minerals,” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.

KDP has prepared this Conflict Minerals Report (this “Report”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2018 to December 31, 2018 (the “Reporting Period”).

This Report describes KDP’s due diligence process and compliance with the Rule’s requirements. The Rule requires disclosure of certain information when a reporting company manufactures, or contracts to manufacture, products which contain the minerals specified in the Rule, if those minerals are necessary to the functionality or production of such products. The specified minerals, which the Company collectively refers to in this Report as “3TG”, are gold, columbite-tantalite (coltan), cassiterite and wolframite and their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

Background

On January 29, 2018, Dr Pepper Snapple Group, Inc. (“DPS”) entered into an Agreement and Plan of Merger (the “Merger Agreement”) by and among DPS, Maple Parent Holdings Corp. (“Maple”) and Salt Merger Sub, Inc. (“Merger Sub”), whereby Merger Sub merged with and into Maple, with Maple surviving the merger as a wholly owned subsidiary of DPS (the “Merger”). Maple is a holding company that conducts substantially all of its business through Keurig Green Mountain, Inc. (“Keurig”). Prior to the closing of the Merger, Keurig was a privately-held corporation, and DPS a publicly traded company. The Merger was consummated on July 9, 2018 (the “Merger Date”), at which time DPS changed its name to “Keurig Dr Pepper Inc.” and began trading on the New York Stock Exchange under the symbol “KDP”.

This Report covers the activities of the legacy-Keurig business during the Reporting Period, both from January 1, 2018 up to the Merger Date, as well as from the Merger Date through the end of the Reporting Period. There are no products that legacy-DPS business contracted to manufacture, or manufactured, during the Reporting Period which are considered in-scope products according to the Rule.



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Reporting Scope

As described in this Report, certain 3TG are necessary to the functionality or production of products that the Company contracted to manufacture, or manufactured, during the Reporting Period. These products are Keurig’s brewers, as well as products manufactured and sold by the business formerly known as VKI Technologies Inc. (“VKI”) which is owned by Keurig Canada Inc., an indirect wholly-owned subsidiary of Keurig (collectively, Keurig’s and VKI’s in-scope products, the “Covered Products”).

Our Approach

KDP uses components and materials containing 3TG in its Covered Products but does not purchase 3TG directly from mines, smelters, or refiners. Therefore, we must collaborate with suppliers, industry peers, and other stakeholders as described in this Report.

KDP is a member of the Responsible Minerals Initiative (“RMI”), a multi-industry initiative addressing Conflict Minerals issues in the supply chain (unique member code KEUR). The RMI’s Conflict Minerals Reporting Template (“CMRT”) is a widely-used standard form to collect information through the supply chain, including the names of 3TG smelters and refiners (“SORs”). RMI also manages the Responsible Minerals Assurance Process (“RMAP”), which uses independent third-party audits to assess whether 3TG SORs have systems in place to source 3TG in conformance with 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 (“OECD Guidance”)1. We use the CMRT to survey our suppliers and identify SORs in our supply chain, and the RMAP to determine the country of origin and conformance status of minerals.

In accordance with the Rule, KDP has in good faith conducted a reasonable country of origin inquiry (“RCOI”) regarding 3TG. This country of origin inquiry was designed to determine whether any of the 3TG used in the Covered Products originated in the Covered Countries and whether any of such 3TG may be from recycled or scrap sources. The Company also performed due diligence on the source and chain of custody of such 3TG as described in more detail below. KDP’s due diligence process is based on the OECD Guidance, referenced above.

Reasonable Country of Origin Inquiry

In 2018, KDP identified its direct suppliers of Covered Products, as well as one indirect supplier of Covered Products whom KDP engages with directly (such direct suppliers and indirect supplier, collectively, the “Suppliers”). KDP requested that each Supplier submit information to KDP using the CMRT.

The information submitted by KDP’s Suppliers in their CMRTs included information gathered by those Suppliers about the smelters and refiners identified in their own supply chains which KDP utilized to conduct further due diligence. As described in more detail below, KDP’s Responsible Sourcing team reviewed and analyzed each CMRT received.







___________________
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition, 2016; https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf

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KDP compared the list of SORs reported by Suppliers against the RMI’s Smelter Database2 to first determine which of the reported entities are known to be true smelters or refiners of 3TG (“Eligible SORs”). The list of Eligible SORs that our Suppliers reported as being in their supply chains is set forth in Annex I. The list of countries from which KDP believes the 3TG in its Covered Products may have originated is set forth in Annex II. This information was obtained through KDP’s membership in the RMI, using the RCOI report dated March 29, 2019 that is available to KDP as a member of RMI. Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP. Through our RCOI, we found that:
–
Some 3TG is sourced through SORs that are not yet RMAP-Conformant and therefore we have not yet determined the country of origin of those minerals;
–
Some 3TG is sourced from RMAP-Conformant SORs, including SORs that source responsibly from the Covered Countries; and
–
Some 3TG also may have originated from recycled or scrap sources.

In addition to the RMI RCOI data available to KDP, select Suppliers reported to KDP that they source from the Covered Countries in their CMRTs:
–
Several Suppliers reported that they source from the Covered Countries and reported to KDP the names of the SORs found to source from the Covered Counties. KDP referenced the RMI Smelter Database and confirmed that the SOR names provided are RMAP Conformant.
–
Two Suppliers provided SOR names that we confirmed have ceased operations or have been re-classified as non-smelters by the RMI.
–
One Supplier reported that they source from the Covered Countries but did not provide the corresponding SOR names. In this case, KDP could not cross reference Smelter Database for SOR Conformance status.
Ultimately, KDP relies on the RMI RCOI data as the most accurate information for our RCOI.

The information obtained from our Suppliers indicated that there was reason to believe that a portion of 3TG used in the Covered Products may have originated in the Covered Countries and were not exclusively from recycled or scrap sources, triggering the due diligence steps described in the following sections.

Due Diligence

Design of Due Diligence

KDP designed its due diligence measures in accordance with the OECD Guidance.

The OECD Guidance utilizes a five-step process for due diligence:

Step 1: Establish Strong Company Management Systems
Step 2: Identify and Assess Risks in the Supply Chain
Step 3: Design and Implement a Strategy to Respond to Identified Risks
Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices
Step 5: Report Annually on Supply Chain Due Diligence





___________________
2 The RMI Smelter Database was exported and referenced as of our cutoff date of April 29, 2019:
http://www.responsiblemineralsinitiative.org/members/smelter-database/

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Below is a description of KDP’s due diligence measures performed for the Reporting Period.

Due Diligence Measures Performed

Step 1: Establish Strong Company Management Systems:

Prior to the Merger Keurig adopted a policy which remains in effect relating to 3TG incorporating the standards set forth in the OECD Guidance (the “Conflict Minerals Policy”) in its Responsible Sourcing Supplier Guidelines. All of Keurig’s Suppliers are required to adhere to its Responsible Sourcing Supplier Guidelines, which are available on its website at www.KeurigGreenMountain.com/SupplierGuidelines. KDP is in the process of developing a company-wide Supplier Code of Conduct which will be in place by December 31, 2019 and will cover all of KDP’s Suppliers.

Keurig’s Conflict Minerals Policy states in part that Keurig is committed to: (1) supporting the aims and objectives of the U.S. legislation on the disclosure of 3TG; (2) not knowingly procuring 3TG that originates from facilities in the Covered Countries that are not considered conflict free; and (3) ensuring compliance with the Keurig Conflict Minerals Policy.

Members from the Company’s Procurement, Legal, and Sustainability Teams were involved in the due diligence process, which was led by the Company’s Responsible Sourcing Team. Members of our Executive Leadership Team were briefed on the Company’s due diligence procedures and results, and reviewed and approved this report.

Requirements related to Conflict Minerals and related due diligence activities are generally included in our material Keurig Supplier contracts.

KDP has established a system of controls and transparency to determine the SORs in its 3TG supply chain by creating a process to engage Suppliers. KDP uses a third party software platform to collect, store, analyze and aggregate Supplier data for reporting purposes. It is also used to send automated reminders to Suppliers throughout the due diligence process.

KDP provided Suppliers with links to the RMI e-learning academy and other resources. There were two new Suppliers included in our due diligence process this year. Both Suppliers completed a series of four supplier training modules through the RMI e-learning platform including the following topics: 1. Introduction to Conflict Minerals Due Diligence, 2. Supplier Survey, 3. Risk Assessment, and 4. Strong Management Systems. Throughout the due diligence process, KDP also engaged in ongoing communication and provided support to its Suppliers to facilitate the completion of their CMRTs.

Suppliers and employees are encouraged to report any ethical concerns or violations by any KDP employee or agent acting on behalf of the supplier or KDP. Concerns or violations may be reported in the following ways:
•
Call: 800-349-4248 (U.S. & Canada) or 001-888-243-8076 (Mexico).
•
Mail: Attn: General Counsel | Keurig Dr Pepper | 5301 Legacy Drive | Plano, TX 75024.
•
Web: www.integrity-helpline.com/kdp.jsp


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KDP retains Conflict Minerals documentation materials for five years after receipt.

Step 2: Identify and Assess Risks in the Supply Chain:

As described above, as part of its due diligence process KDP identified in scope Suppliers and requested that the Suppliers submit a completed CMRT.

Via our software platform, KDP then reviewed Suppliers’ completed CMRTs against a set of internally developed criteria for completeness and consistency. While 100% of Suppliers surveyed submitted a CMRT this year, there were several CMRTs that were incomplete, or where we identified inconsistencies which we were unable to resolve with the supplier before our cutoff date of April 29, 2019 despite numerous follow up requests. We intend to work with these suppliers to improve their responses year over year.

For Suppliers that indicated in their responses that they or a supplier in their supply chain did use 3TG in their part(s) and/or product(s) during the Reporting Period and provided the applicable smelter or refiner information, the Company reconciled the reported SORs against the RMI Smelter Database, which contains RMAP SOR Conformance status. (Available to RMI members at http://www.responsiblemineralsinitiative.org/members/smelter-database/)

Step 3: Design and Implement a Strategy to Respond to Identified Risks:

Where SORs were reported that are not RMAP-Conformant or Active (engaged in the RMAP program but not yet audited), KDP sent a notice via the platform asking applicable Suppliers to either work with their supply-chain to request the smelter to participate in the RMAP audit program, and/or work to transition away from the smelter, depending on level of identified risk. Further, there were also instances where inaccurate or outdated SOR information was reported to us, for example: smelters no longer in operation, or entities that could not be identified as known SORs. In these cases, we sent a notification to Suppliers asking them to work with their supply chain to obtain accurate smelter information. Our smelter action requests specified that we expect to see continuous improvement year over year in the reported smelter information.

In addition to the above, we also review our Suppliers’ CMRTs for due diligence activities, such as whether they have their own Conflict Minerals Policy. See below the Due Diligence Results section below where we report on the number of Suppliers who provided a policy that indicates a commitment to reasonably ensuring that only conflict-free materials and components are used in products/parts that are sold to KDP.

Lastly, several Suppliers indicated in their responses that they have not received complete information from their suppliers. When this happened, we requested that they work to improve their response rate.

Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices

As a member of the RMI, KDP leverages information from the independent third party audits of the SORs facilitated by initiatives such as the RMI’s RMAP and the London Bullion Market Association (LBMA), or Responsible Jewelry Council (RJC).

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Step 5: Report Annually on Supply Chain Due Diligence:

As discussed above, KDP is reporting on supply chain due diligence by publishing a Conflict Minerals Report for the Reporting Period on KDP’s corporate website (https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance).

Due Diligence Results

Many of our Supplier responses represented their supply chain at a company level rather than being product specific. Therefore, the list of SORs contained in this report may contain more SORs than those that actually process the conflict minerals contained in our products.

The total number of unique entities reported as SORs by the KDP supply base as a result of the 2018 survey was 348. Of these:
–
310 have been confirmed as being Eligible SORs by the RMI
–
32 were known to not be Eligible SORs, and
–
6 reported entities’ status could not be confirmed as of our cutoff date of April 29, 2019. This is compared to 52 entities in the prior year, a significant improvement.

Of the 310 Eligible SORs reported by KDP Suppliers:
–
251, or 81% had been validated by the RMI RMAP program as Conformant to an RMI recognized audit protocol (RMAP, LBMA, or RJC), a 1% increase from the prior year.
–
8 were in process or communication with RMAP, but had not achieved Conformant status as of April 26, 2019.
–
The remaining 51 have not been validated by the RMAP program as Conformant.
A list of all 310 of the Eligible SORs identified during the due diligence process is included in Annex I to this Report.

The 32 entities reported by our Suppliers that are not currently considered Eligible SORs fell into two categories:
–
8 companies that had been reclassified by RMI due to better understanding of their business (group company or did not meet the definition of a smelter), and
–
24 Eligible SORs that had either temporarily or permanently suspended operations.

As described above, we also requested Suppliers provide a policy that indicates a commitment to reasonably ensuring that only conflict free materials and components are used in products/parts sold to KDP. 40% of Suppliers provided a policy that meets this criterion, up from 37% in the prior year.

Future Due Diligence Improvements

KDP plans to continue to improve its due diligence measures by taking the following steps, among others:
–
Continuing to engage with Suppliers to obtain current, accurate and complete information about our supply chain;
–
Continuing to encourage Suppliers to build up their own due diligence processes including their own conflict minerals policy; and
–
Continuing to encourage Suppliers to request non-Conformant smelters to participate in the RMAP audit program, and/or work to transition away from such SORs.


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Determination

Based on the information obtained pursuant to the due diligence process described above, KDP believes that the SORs that may have been used to process the 3TG in KDP products include the SORs listed in Annex I below. The list of countries from which KDP believes the 3TG in their products may have originated as well as any materials from recycled and scrap sources, is set forth in Annex II. The SOR information collected from our Suppliers continued to include a number of SORs that had not been audited and determined to be RMAP Conformant by the RMI, or any other recognized organization. The possible existence of such SORs in our supply chain is sufficient to prevent us from declaring with certainty that no armed groups directly or indirectly benefited as a result of the mining, transport or processing of 3TG in our products.
   
KDP has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Keurig’s Conflict Minerals Policy, may affect KDP’s future determinations.

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Annex I
List of Smelters and Refiners

The table below represents a consolidated list of SORs (310 in total) identified by KDP’s Suppliers. The results are based on:
•
Information provided by KDP’s Suppliers in their CMRTs; and
•
The Conformance status indicated in the RMI Smelter Database as of April 29, 2019

“SOR Country” refers to the location of the SOR, not the source of minerals. Refer to Annex II for the list of countries from which 3TG may have originated.

SORs that have been validated by the RMAP program as Conformant:

Metal
SOR Name
SOR Country
SOR ID
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
CID000015
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000058
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000920
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Gold
Aurubis AG
GERMANY
CID000113
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Boliden AB
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Gold
Cendres + Metaux S.A.
SWITZERLAND
CID000189
Gold
Chimet S.p.A.
ITALY
CID000233
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Gold
Dowa
JAPAN
CID000401
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID003195
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002459

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Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
CID000689
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Gold
Italpreziosi
ITALY
CID002765
Gold
Japan Mint
JAPAN
CID000823
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Gold
Kazzinc
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID000969
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Gold
Marsam Metals
BRAZIL
CID002606
Gold
Materion
UNITED STATES OF AMERICA
CID001113
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001157
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001220
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326

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Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
PAMP S.A.
SWITZERLAND
CID001352
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Gold
PX Precinox S.A.
SWITZERLAND
CID001498
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Gold
REMONDIS PMR B.V.
NETHERLANDS
CID002582
Gold
Royal Canadian Mint
CANADA
CID001534
Gold
SAAMP
FRANCE
CID002761
Gold
Safimet S.p.A
ITALY
CID002973
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001585
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001761
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
CID002918
Gold
T.C.A S.p.A
ITALY
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID001993
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002030
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Gold
Yamakin Co., Ltd.
JAPAN
CID002100
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID002504
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000456

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Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID002557
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002548
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID003191
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
CID002568
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
CID002847
Tantalum
QuantumClean
UNITED STATES OF AMERICA
CID001508
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001869
Tantalum
Telex Metals
UNITED STATES OF AMERICA
CID001891
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID001522
Tin
Alpha
UNITED STATES OF AMERICA
CID000292

11


Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Tin
CV Ayi Jaya
INDONESIA
CID002570
Tin
CV Dua Sekawan
INDONESIA
CID002592
Tin
CV Gita Pesona
INDONESIA
CID000306
Tin
CV United Smelting
INDONESIA
CID000315
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Tin
Dowa
JAPAN
CID000402

12


Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000438
Tin
Fenix Metals
POLAND
CID000468
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID001142
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Tin
Minsur
PERU
CID001182
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID001337
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Tin
PT Babel Surya Alam Lestari
INDONESIA
CID001406
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Tin
PT Bukit Timah
INDONESIA
CID001428
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Tin
PT Karimun Mining
INDONESIA
CID001448
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829

13


Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Tin
PT Rajehan Ariq
INDONESIA
CID002593
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Tin
PT Timah Tbk Kundur
INDONESIA
CID001477
Tin
PT Timah Tbk Mentok
INDONESIA
CID001482
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Tin
PT Tommy Utama
INDONESIA
CID001493
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001539
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Tin
Thaisarco
THAILAND
CID001898
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID003325
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Tungsten
A.L.M.T. Corp.
JAPAN
CID000004
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645


14


Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002542
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000966
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID000105
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
CID002543
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002845
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002589
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002044
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095



15


SORs that have not been validated by the RMAP program as Conformant:

Metal
SOR Name
SOR Country
SOR ID
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
CID002708
Gold
African Gold Refinery
UGANDA
CID003185
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Gold
Bangalore Refinery
INDIA
CID002863
Gold
Caridad
MEXICO
CID000180
Gold
Chugai Mining
JAPAN
CID000264
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
CID000773
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
CID000778
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Gold
Morris and Watson
NEW ZEALAND
CID002282
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID002866
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
Gold
Pease & Curren
UNITED STATES OF AMERICA
CID002872
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
CID003324

16


Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
CID001546
Gold
SAFINA A.S.
CZECHIA
CID002290
Gold
Sai Refinery
INDIA
CID002853
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
CID001562
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Gold
Sudan Gold Refinery
SUDAN
CID002567
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Gold
Tony Goetz NV
BELGIUM
CID002587
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC
VIET NAM
CID002572
Tin
Estanho de Rondonia S.A.
BRAZIL
CID000448
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Tin
Pongpipat Company Limited
MYANMAR
CID003208
Tin
Super Ligas
BRAZIL
CID002756
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313








17


Annex II
Countries from which the minerals in the Covered Products may have originated
    
Based on RMI’s Reasonable Country of Origin Inquiry report dated March 29, 2019, the countries of origin of the 3TG processed by SORs listed in ANNEX I are believed to include the following Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP:

Gold:
Argentina
 
Finland
 
Niger
Armenia
 
Georgia
 
Papua New Guinea
Australia
 
Ghana
 
Peru
Azerbaijan
 
Guatemala
 
Philippines
Benin
 
Guinea
 
Puerto Rico
Bolivia (Plurinational-State of)
 
Guyana
 
Russian Federation
Brazil
 
Honduras
 
Saudi Arabia
Burkina Faso
 
Indonesia
 
Senegal
Canada
 
Iran
 
Slovakia
Chile
 
Ivory Coast
 
Solomon Islands
China
 
Kazakhstan
 
South Africa
Colombia
 
Kenya
 
Spain
Congo, Democratic Republic of the
 
Kyrgyzstan
 
Suriname
Cyprus
 
Laos
 
Swaziland
Dominican Republic
 
Lebanon
 
Sweden
Ecuador
 
Malaysia
 
Tanzania
Egypt
 
Mali
 
Thailand
Eritrea
 
Mauritania
 
Togo
Ethiopia
 
Mauritius
 
Turkey
 
 
Mexico
 
United States of America
 
 
Mongolia
 
Uruguay
 
 
Morocco
 
Uzbekistan
 
 
Namibia
 
Zambia
 
 
Nicaragua
 
 

Tantalum:
Australia
 
Colombia
 
Malaysia
Austria
 
Congo, Democratic-Republic of the
 
Mozambique
Bolivia (Plurinational-State of)
 
Ethiopia
 
Nigeria
Brazil
 
Guinea
 
Russian Federation
Burundi
 
India
 
Rwanda
China
 
Madagascar
 
Sierra Leone
 
 
 
 
Thailand


18


Tin:
Australia
 
Guinea
 
Russian Federation
Bolivia (Plurinational-State of)
 
Indonesia
 
Rwanda
Brazil
 
Laos
 
Taiwan
Burundi
 
Malaysia
 
Thailand
China
 
Mongolia
 
Uganda
Congo, Democratic-Republic of the
 
Myanmar
 
United Kingdom of Great-Britain and Northern Ireland
 
 
Nigeria
 
Venezuela
 
 
Peru
 
 
 
 
Portugal
 
 

Tungsten:
Australia
 
Mongolia
Bolivia (Plurinational-State of)
 
Myanmar
Brazil
 
Nigeria
Burundi
 
Peru
China
 
Russian Federation
Congo, Democratic-Republic of the
 
Rwanda
Guinea
 
Taiwan
Indonesia
 
Thailand
Laos
 
United Kingdom of Great-Britain and Northern Ireland
Malaysia
 
United States of America



19