EX-1.01 2 a2018exhibit101.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01
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Adient plc
Conflict Minerals Report
For the Calendar Year Ended December 31, 2018

I.Background

The Securities and Exchange Commission (the “SEC”), through Section 13(p) of the Securities Exchange Act of 1934, imposes reporting requirements (the “Rule”) on SEC issuers concerning the use of Conflict Minerals and the metals derived from such minerals, as described below, that originate in the Democratic Republic of the Congo (the “DRC”) or the adjoining countries (collectively, the “Covered Countries”).

The term “Conflict Mineral” is defined to include cassiterite, columbite-tantalite, gold, and wolframite and their derivatives, including tantalum, tin and tungsten ("3TG”) regardless of their source.

This is the Conflict Minerals Report (“Report”) of Adient plc (“Adient”) for calendar year 2018 and covers all activities conducted for the calendar year ended December 31, 2018.

II.Adient Overview

Adient is the world’s largest automotive seating supplier and has relationships with the largest global auto manufacturers. Adient designs, manufactures and markets a full range of seating systems and components for passenger cars, commercial vehicles and light trucks, including vans, pick-up trucks and sport/crossover utility vehicles. Adient’s proprietary technologies extend into virtually every area of automotive seating solutions, including complete seating systems, frames, mechanisms, foam, head restraints, armrests, trim covers and fabrics.

As used in this Report, and except where the context otherwise requires, “we” and “our” refer to Adient and its majority-owned subsidiaries and variable interest entities that are required to be consolidated.

III.Product Overview

As noted above, our products include complete seating systems, frames, mechanisms, foam, head restraints, armrests, trim covers and fabrics.

IV.Supply Chain Description

Adient is committed to the responsible sourcing of Conflict Minerals and is a member of the Responsible Minerals Initiative (“RMI”). RMI was founded by members of the Responsible Business Alliance (“RBA”). Adient encourages its suppliers to conduct conflict-free sourcing from RMI certified smelters.

As a large multinational company, Adient has a complex, multi-tiered supply chain. The products that Adient manufactures are typically highly engineered, complex and contain thousands of parts from a vast network of globally dispersed suppliers.

As a downstream consumer with many tiers in its supply chain, Adient generally does not have a direct relationship with smelters and refiners. In most instances, Adient obtains products containing 3TG from unrelated third-party suppliers with their own independent supply chains. Accordingly, Adient must rely on its direct suppliers to provide information on the origin of any Conflict Minerals contained in the components and parts supplied to Adient.













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V.Reasonable Country of Origin Inquiry (“RCOI”)

A.Process Summary

In 2018 Adient continued its efforts to improve the transparency in its supply chain. Adient's good faith global scoping exercise was reviewed and adapted to reflect recent changes in internal processes, which were mainly related to the quality of data available about Adient's suppliers. The identification of suppliers that were subject to the RCOI (“In-Scope Suppliers”) was closely linked not only to the presence of 3TGs in the products but also to contractual agreements to determine the amount of influence that Adient has on In-Scope suppliers regarding the sourcing decisions taken in the supply chain. Supplier communications were tailored to ensure that suppliers understood and followed Adient’s Conflict Minerals Policy and the sourcing requirements laid down in its general terms and conditions.

Due to the complexity of Adient’s supply chain, Adient relied on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in components and parts supplied to Adient. In addition, Adient sent the RMI Conflict Minerals Reporting Template (the “CMRT”) to these suppliers to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.

Adient elected to utilize, without alteration, the CMRT, as well as a survey tool to facilitate its RCOI. The questions on the CMRT include, but are not limited to, the use of Conflict Minerals and their necessity to product functionality or production, the origin of such Conflict Minerals, and whether smelters have been validated as compliant in accordance with the RMI. Adient communicated with In-Scope Suppliers, notifying them of the RCOI and Adient’s expectations, and it also provided instructions to assist with the completion of the CMRT.

In addition to the RCOI efforts described above, Adient undertook the following measures to determine the mine or country of origin of any Conflict Minerals:
Ÿ
As part of its global scoping exercise, Adient considered the following supply base categories as the scope universe for RCOI purposes: manufactured products, products contracted to be manufactured, and spare parts.
 
 
 
Ÿ
Adient reviewed its scoping guideline and implemented the process changes related to the identification of suppliers. A risk level of “High,” “Low” or “None” based on the likelihood of the presence of Conflict Minerals in each component was assigned to each In-Scope Supplier as result of the joint effort between our procurement and engineering groups. Suppliers providing components with risk rankings of High and Low were considered in-scope for RCOI procedures.
 
 
 
Ÿ
Adient required each supplier deemed to be in-scope to provide information regarding the use of Conflict Minerals from their suppliers, who, in turn, were expected to solicit that information from their next tier of suppliers. The Conflict Minerals Supplier Letter that was sent to each In-Scope Supplier can be found on Adient’s website at:
http://www.adient.com/suppliers/corporate-responsibility.
 
 
 
Ÿ
Adient provided explanations and on-demand training to its suppliers regarding the relevant requirements of the Rule and its obligations under the Rule, and reiterated Adient’s expectation that suppliers cooperate to support Adient’s compliance efforts. Refer to “Supplier Engagement and Training” below for more information.
 
 
 
Ÿ
The responses received from the In-Scope Suppliers about the country of origin of any Conflict Minerals necessary to functionality or production of products supplied to Adient were reviewed for accuracy and completeness, and, if necessary, were red flagged for additional follow up and/or due diligence.
 
 
 
Ÿ
Suppliers who sent incomplete or inconsistent responses were asked to review their responses and resubmit their surveys.
 
 
 
Ÿ
Adient implemented the following escalation process for suppliers that did not respond:
 
 
 
 
§
Step 1: For a selection of suppliers with risk ratings of High that did not respond, an escalation letter was sent.
 
 
 
 
§

Step 2: Commodity managers/buyers contacted the suppliers with risk ratings of High that did not respond to the escalation letter (either by phone or in written form) to request survey completion.
 
 
 
 
§

Step 3: If the supplier still did not respond, the relevant Vice President(s) of Procurement sent a written letter to the supplier requesting completion of the survey.





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B.RCOI Results

Adient determined there were 1,004 In-Scope Suppliers for calendar year 2018, which represented 30% of Adient’s total direct suppliers. Adient sent communications to all of its In-Scope Suppliers notifying them of the upcoming RCOI and received receipt confirmations from 86% of those In-Scope Suppliers.

Of the In-Scope Suppliers surveyed, the overall response rate was 50%, including 295 responses that were received and accepted (representing 34% of the suppliers who confirmed receipt of the survey). Adient considers a response as received and accepted when a completed CMRT has been returned to Adient and the CMRT has been validated as accurate by its compliance specialists. Below are the results of the RCOI survey:
RCOI Survey Results
No 3TG
71%
Acknowledged 3TG Sourced from the Covered Countries
18%
Acknowledged 3TG Not Sourced from the Covered Countries
10%
3TG Origin Uncertain or Unknown
1%

C.Improvement Measures to Be Taken

During 2018 Adient developed and implemented additional steps into its internal process to ensure that pertinent information is elicited about potential sourcing from the Covered Countries. These situations require a tailored approach supported by Adient’s Compliance and Supply Chain Management Departments to cover suppliers directly sourced by Adient and customer directed suppliers.

Adient plans to continue to improve its processes, including, but not limited to, the following:
Ÿ
Engage with suppliers that have not responded to Adient’s request for Conflict Minerals information with focus on directed buy arrangements;
 
 
Ÿ
Require vendor code information from every In-Scope Supplier to reduce the amount of redundant requests
 
 
Ÿ

Reconsider supply arrangements and potentially implement remedies for suppliers that refuse to cooperate with Adient’s compliance efforts or do not conduct conflict-free sourcing from the Covered Countries;
 
 
Ÿ
Raise concerns resulting from customer-directed buy arrangements with the respective customer
 
 
Ÿ
Continue refining Adient’s strategy for managing and mitigating Conflict Minerals risk in the supply chain by sharing information about smelters of concern with affected suppliers in order to raise awareness and by requesting that affected suppliers encourage smelters in their supply chains to participate in certification schemes;
 
 
Ÿ
Refine the evaluation process to improve the information gathered regarding, and the handling of, smelters potentially affected by other compliance related matters;
 
 
Ÿ
Further refine and continue to provide online training materials for suppliers, in addition to personal instruction, and
 
 
Ÿ
Report identified smelting facilities without a smelter ID to the RMI.













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VI.Conflict Minerals Due Diligence

A.Compliance Framework

i.Framework Design and Overview

Adient designed a compliance framework that conforms to the primary principles of the internationally recognized due diligence framework developed by the Organisation for Economic Co-operation and Development (“OECD”) entitled “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected Areas and High-Risk Areas” and related supplements for each of the Conflict Minerals. Our compliance framework included the following elements: 1) establish strong company management systems; 2) identify and assess risk in the supply chain; 3) design and implement a strategy to respond to identified risks; 4) carry out independent third-party audit of smelters’/refiners’ due diligence practices; and 5) report annually on supply chain due diligence.

ii.Establish Strong Company Management Systems

Conflict Minerals Policy

Adient is committed to the responsible sourcing of Conflict Minerals and it supports the humanitarian goal of ending violent conflict in the Covered Countries. Our Conflict Minerals Policy Statement expresses that we continue to promote and encourage suppliers to conduct conflict-free sourcing from the Covered Countries, and to use responsible sourcing practices. We expect our suppliers to conduct due diligence on their respective supply chains and to assist us with our compliance efforts. To the extent that a supplier refuses to cooperate with our compliance efforts or does not conduct conflict-free sourcing from the Covered Countries, we may reconsider our supply arrangement and/or implement remedies available to us. Our Conflict Minerals Policy Statement is publicly available on Adient’s website at:

http://www.adient.com/-/media/adient/shared/suppliers/corporate-responsibility/conflict-minerals/newadientconflictmineralspolicystatement_nov-2016.ashx.

Internal Management System

Adient maintains an internal management system, where senior management, having the necessary expertise, knowledge and experience, oversee the RCOI and due diligence process. We continue to seek ways to address risk in our supply chain process through initiatives that often involve stakeholder engagement or consultation with outside experts.

Adient maintains a Conflict Minerals Executive Steering Committee (“Steering Committee”) comprised of leaders from Procurement, Legal, Engineering, Communications, Information Technology, Internal Audit and Finance. The Steering Committee oversees and supports Adient’s Conflict Minerals compliance program carried out by Adient’s global Project Management Organization (“PMO”). The global PMO includes representatives from each of the applicable departments involved in preparing and publishing this Report. The Steering Committee and PMO each meet to develop and monitor plans to comply with the reporting requirements of the Rule.

This Report was also reviewed by Adient’s Disclosure Committee, which is comprised of Adient’s Chief Executive Officer; Chief Financial Officer; General Counsel; Corporate Treasurer; Corporate Controller; Assistant Corporate Controller; Vice President, Tax; Vice President, Internal Audit; Vice President, Investor Relations; Executive Director - Commercial, Finance; and Director - Corporate Governance & Securities.

System of Controls and Transparency

Due to the complexity of Adient’s supply chain, Adient relies on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in materials supplied to Adient. Adient’s RCOI and due diligence processes are designed to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.




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Supplier Engagement and Training

Adient provides a Conflict Minerals presentation as part of the initial communication package to the In-Scope Suppliers that summarizes the relevant requirements of the Rule, as well as our obligations under the Rule, and reiterates Adient’s expectation that our suppliers cooperate to support our Conflict Minerals compliance efforts. The presentation is posted on our website at: http://www.adient.com/suppliers/corporate-responsibility. Suppliers are encouraged to ask questions to our compliance specialists to enhance their understanding of the Rule and our expectations.

Adient also provides the In-Scope Suppliers with instructions for responding to the survey, and our compliance specialists have scripts to help explain our requests and the reason behind the requests. Communications sent to suppliers also contain reference links to the Rule and additional guidance from the SEC, Automotive Industry Action Group (“AIAG”), RMI, and OECD. To help suppliers identify and address smelters of concern, Adient provides links to other non-governmental organization (“NGO”) resources such as Global Witness or Amnesty International for smelter information.

Adient publicly shares its position on responsible sourcing of Conflict Minerals through its Conflict Minerals Policy Statement. In addition, as Adient renews or enters into new agreements with suppliers, Adient includes a Conflict Minerals compliance provision when appropriate. The provision requires suppliers to conduct and document inquiries of smelters and refiners of Conflict Minerals included in the products supplied to Adient, including inquiries as to the country of origin. Adient’s Global Supplier Standards Manual reflects these expectations.

Internal Training

Adient has a web-based training module specifically for its Sales, Procurement and Engineering functions in order to increase awareness and education about the relevant requirements of the Rule, Adient’s obligations under the Rule, and the processes Adient uses to evaluate and respond to the related risks in our supply chain. Awareness sessions are mandatory for new employees at Adient facilities that perform engineering and design activities related to the use of Conflict Minerals

Records Management

Adient retains relevant Conflict Minerals documentation in accordance with its existing corporate retention policy and procedures.

Grievance Mechanism

Adient maintains a web- and telephone-based, 24-hour Integrity Helpline (information is available at: http://adient.ethicspoint.com/), providing any interested party (employees, customers, suppliers or other external third parties) with a confidential reporting mechanism to communicate potential violations of the law, regulations, professional standards, policy, the Ethics Policy or the Conflict Minerals Policy, as well as concerns regarding Adient’s supply chain. Incoming reports follow Adient’s Investigations Protocol, whereby incoming cases are either investigated by Adient’s Legal Department or transferred to the responsible group inside Adient. The Legal Department monitors the investigation and resolution of cases reported through the helpline or escalated through other channels.


















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iii.Identify and Assess Risk in the Supply Chain

Adient’s RCOI was designed to determine whether the Conflict Minerals necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by Adient originated in the Covered Countries, or were from recycled or scrap sources. Through communications with the In-Scope suppliers, Adient attempted to identify smelters and refiners of Conflict Minerals that may be utilized in its products.

Adient followed up, and continues to follow up, with suppliers who indicated that they might be sourcing Conflict Minerals from the Covered Countries or non-certified smelters in order to exercise due diligence on the source and chain of custody of the Conflict Minerals, inquiring of such suppliers whether they:
Ÿ
provided information on all smelters and the country of origin of the Conflict Minerals;
 
 
Ÿ
performed due diligence procedures for non-certified smelters; and
 
 
Ÿ
were able to determine if the Conflict Minerals financed or benefited armed groups in the Covered Countries.

iv.Design and Implement a Strategy to Respond to Identified Risks

Adient has established due diligence guidelines to be followed if Adient identifies a risk or a red flag that a supplier may have sourced Conflict Minerals from the Covered Countries through a review of the received CMRT.

Once an In-Scope Supplier identified in its response that it might be sourcing Conflict Minerals from the Covered Countries, Adient initiated due diligence procedures to collect more detailed information from that supplier, which included engaging with such supplier and validating information with other reliable sources. Suppliers reporting RMI-certified smelters from the Covered Countries were generally exempt from further due diligence as long as there were no incident reports available from NGOs or other reliable sources regarding the listed smelter(s) or refiner(s).

Survey findings were discussed with Adient’s Procurement Leadership Team. Adient created a list of suppliers identified as using Conflict Minerals from a Covered Country as well as the indicated smelters. This list was compared to the RMI smelter listing to verify the accuracy of the supplier responses as well as the source of the Conflict Minerals, and then shared it with the responsible procurement team.

In addition, Adient engaged and actively cooperated with industry groups, including RMI and AIAG. Adient also invested in systems and processes to manage risk identified in its supply chain.

v.Carry Out Independent Third-Party Audit of Smelters’/Refiners’ Due Diligence Practices

Adient supports independent third-party audits by being a member of the RMI. In connection with our due diligence efforts, we rely on the RMI’s Conflict-Free Smelter Program to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. However, Adient is a downstream consumer of Conflict Minerals and is many steps removed from the mining of Conflict Minerals. Adient does not purchase raw ore or unrefined Conflict Minerals, and, to the best of its knowledge, conducts no purchasing activities directly in the Covered Countries. Adient evaluates the received supplier reports by using the smelter database from RMI and reports any unknown smelter or smelters that have not been certified to the RMI for further investigation and inclusion in the smelter certification scheme.

vi.Report Annually on Supply Chain Due Diligence

This Report (and the related Form SD) was filed with the SEC and is available on our website at:

http://www.adient.com/suppliers/corporate-responsibility.








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B.Due Diligence Results

i.Facilities Used to Process Necessary 3TG Originating from Covered Countries

The RCOI, including the use of the CMRT, and Adient’s due diligence efforts described above were designed to provide Adient with information on the smelters and refiners that the In-Scope Suppliers used to process Conflict Minerals in the products supplied to Adient. As previously discussed, Adient is a downstream consumer of 3TG and generally does not have a direct relationship with smelters and refiners; as a result, it must rely on responses from its suppliers in order to determine the facilities used to process Conflict Minerals. Similar to Adient, our suppliers generally do not have a direct relationship with the facilities used to process Conflict Minerals; therefore, some suppliers responded that they were unable to provide smelter and refiner information at this time. Accordingly, for this reporting period, Adient does not know all the facilities used to process, or the country of origin of, all the Conflict Minerals included in its products.
Based on a review of the received and accepted responses, 10% of the suppliers indicated that they did not source from the Covered Countries and 18% of the suppliers acknowledged that they sourced 3TG from the Covered Countries. The suppliers sourcing from the Covered Countries indicated that they only sourced from smelters that the RMI identifies as DRC conflict free. Even though none of the responses acknowledged that 3TG was sourced from smelters or mines that financed or benefited armed groups, after reviewing information from NGOs and other sources, Adient found evidence with respect to two of the smelters identified by its suppliers that raised concerns. Adient contacted each impacted supplier to encourage them to review their respective supply chain and to work with their suppliers to eliminate the affected smelter from their supply chain. Further actions with respect to these or other suppliers using smelters or refiners that raise concerns could include reconsidering supply arrangements and potentially implementing remedies for suppliers that refuse to cooperate with Adient’s compliance efforts in accordance with its existing procurement processes and policies.

ii.Smelter Lists (Appendix A)

Adient compared the smelter lists provided in responses from its In-Scope Suppliers with the RMI list of compliant smelters to determine which smelters the RMI identifies as DRC conflict free. The information provided by our suppliers was used to conduct our due diligence, including assessing reports for completeness and consistency.

Appendix A includes a list of the smelters identified by our In-Scope suppliers as part of our RCOI and due diligence efforts. A total of 278 smelters were identified by our suppliers and 252 or approximately 90%, are RMI certified. The percentage of certified smelters increased by 16 percentage points as compared to 2017. Six smelters have not been certified by the RMI with one of those smelters reported using only recycled or scrap feedstock. Through our efforts, we learned that 16 smelters ceased operations during the reporting year.















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C.Risk Mitigation Measures

In order to mitigate risk related to Conflict Minerals in Adient’s supply chain, Adient’s current processes and procedures include:
Ÿ
Membership in the RMI, which has allowed for the comparison of all supplier responses to the RMI smelter listing to confirm the accuracy of supplier responses;
 
 
Ÿ
Updating and adapting our scoping and due diligence guidelines as well as the escalation process to reflect organizational changes inside Adient; and
 
 
Ÿ
Reviewing and utilizing our inhouse information technology systems and tools to increase process reliability and apply best business practices.

Adient is aware of a decreasing willingness on the part of certain smelters to undergo or renew the certification with the RMI or other certification schemes, which it believes is due to external factors, such as guidance related to the application of the Rule; however, Adient is committed to responsible sourcing practices. Adient is committed to complying with the OECD Guidance and the Rule in such a way that it believes mitigates such concerns through the implementation of our Conflict Minerals Policy Statement. In order to further mitigate the risk that Conflict Minerals in the supply chain benefited armed groups in the Covered Countries and to identify the origin of those minerals, Adient will continue its efforts with its In-Scope Suppliers to improve the response rate and the completeness of the surveys. In addition, Adient will:
Ÿ
Continue to direct suppliers to Adient’s Conflict Minerals Policy Statement, which emphasizes the responsible sourcing of Conflict Minerals;
 
 
Ÿ
Strive to improve supplier awareness to identify potential risks at an early stage by improving our supplier training and sending out detailed feedback related to information received from suppliers;
 
 
Ÿ
Continue to follow up with suppliers that source Conflict Minerals from, or were identified as potentially sourcing from, smelters and refiners not participating in certification schemes;
 
 
Ÿ
Strive to improve the effectiveness of the escalation process to enhance supplier communications and the quality of responses by addressing concerns related to customer buy arrangements to the affected customer;
 
 
Ÿ
Seek to enhance our RCOI and due diligence measures, as well as the review process for existing and new suppliers included in the scoping guidelines;
 
 
Ÿ
Continue to work with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD guidance; and
 
 
Ÿ
Work with the RMI smelter engagement team to support their engagement and certification efforts.













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VII.Determination

For calendar year 2018, Adient is unable to determine the mine or country of origin of its necessary Conflict Minerals or the facilities used to process Conflict Minerals in its supply chain with the greatest possible specificity due to either a lack of survey responses or inconclusive survey responses from its In-Scope Suppliers. As such, Adient is currently unable to determine whether products manufactured, or contracted to be manufactured, by Adient in the 2018 calendar year, which include those listed in “III. Product Overview” above, have been found to be free of necessary Conflict Minerals that directly or indirectly financed or benefited armed groups in the Covered Countries. See Appendix A for a list of smelters for each of the Conflict Minerals identified as part of Adient’s efforts and country of origin information.

Cautionary Statement Regarding Forward-Looking Statements:

Adient has made statements in this Report that are forward-looking and, therefore, are subject to risks and uncertainties. All statements in this Report other than statements of historical fact are statements that are, or could be, deemed “forward looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. In this document, statements regarding Adient’s future plans, objectives, outlook, targets, guidance or goals are forward-looking statements. Words such as “may,” “will,” “expect,” “intend,” “estimate,” “anticipate,” “believe,” “should,” “forecast,” “project” or “plan” or terms of similar meaning are also generally intended to identify forward-looking statements. Adient cautions that these statements are subject to numerous important risks, uncertainties, assumptions and other factors, some of which are beyond Adient's control, that could cause Adient’s actual results to differ materially from those expressed or implied by such forward-looking statements. These risks and uncertainties are difficult to predict accurately and may include (but are not limited to) regulatory changes and other developments relating to Conflict Minerals disclosures, changes in or developments related to Adient’s products or Adient’s supply chain, changes to Adient’s supplier base and industry developments relating to supply chain diligence, disclosure and other practices. A detailed discussion of risks related to Adient’s business is included in the section entitled “Risk Factors” in Adient's Annual Report on Form 10-K for the fiscal year ended September 30, 2018 and in its quarterly reports on Form 10-Q as well as other filings with the SEC, available at www.sec.gov. The forward-looking statements included in this Report are made only as of the date of this Report and, except as required by law, Adient assumes no obligation, and disclaims any obligation, to update such statements.






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Appendix A - Smelters by mineral


The attached smelter information refers to data available in the RMI smelter database in March 2019. Any changes to the RMI smelter database that took place after March 2019 are not covered.

List 1: Smelters and Refiners reported in Adient’s supply chain as of December 31, 2018

Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Tin
Alpha
UNITED STATES OF AMERICA
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dowa
JAPAN
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Fenix Metals
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Metallo Belgium N.V.
BELGIUM
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Aries Kencana Sejahtera
INDONESIA

Appendix A
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Exhibit 1.01
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Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Babel Surya Alarm Lestari
INDONESIA
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
CV Tiga Sekawan
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA

Appendix A
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Exhibit 1.01
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Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA

Appendix A
Page 3

Exhibit 1.01
adienta60.jpg


Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY

Appendix A
Page 4

Exhibit 1.01
adienta60.jpg


Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
Aurubis AG
GERMANY
Gold
Bangalore Refinery
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Italpreziosi
ITALY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN

Appendix A
Page 5

Exhibit 1.01
adienta60.jpg


Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
L'Orfebre S.A.
ANDORRA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Marsam Metals
BRAZIL
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
PAMP S.A.
SWITZERLAND
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE
Gold
Safimet S.p.A
ITALY
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION

Appendix A
Page 6

Exhibit 1.01
adienta60.jpg


Conflict Mineral
Smelter or Refiner Name
Location of Smelter or Refiner
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
BRAZIL
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Modeltech Sdn Bhd
MALAYSIA

List 2: Smelters and Refiners reported in Adient’s supply chain but identified as having ceased operation prior to December 31, 2018
Conflict Mineral
Location of Smelter or Refiner
Location of Smelter or Refiner
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tin
Cooperativa Metalurgica de Rondonia Ltda.
BRAZIL
Tin
Gejiu Jinye Mineral Company
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Tin
PT Bangka Kudai Tin
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
PT Timah Nusantara
INDONESIA
Tin
PT Bangka Putra Karya
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Gold
Schone Edelmetaal B.V.
NETHERLANDS





Appendix A
Page 7

Exhibit 1.01
adienta60.jpg


Potential Countries of Origin of Conflict Minerals:

Argentina
India
Senegal
Armenia
Indonesia
Sierra Leone
Australia
Iran**
Slovakia
Austria
Ivory Coast
Solomon Islands
Azerbaijan
Kazakhstan
South Africa
Benin
Kenya
Spain
Bolivia
Laos
Suriname
Bolivia (Plurinational State of)
Lebanon
Swaziland
Botswana
Madagascar
Sweden
Brazil
Malaysia
Taiwan
Burkino Faso
Mali
Tanzania*
Burundi*
Mauritania
Thailand
Canada
Mauritius
Togo
Chile
Mexico
Turkey
China
Mongolia
Uganda*
Colombia
Morocco
United Kingdom of Great Britain and Northern Ireland
Congo, Democratic Republic of the*
Mozambique
United States of America
Cyprus
Myanmar
Uruguay
Dominican Republic
Namibia
Uzbekistan
Ecuador
Nicaraqua
Venezuela
Egypt
Niger
Zambia*
Eritrea
Nigeria
Zimbabwe
Ethiopia
Papua New Guinea
 
Finland
Peru
 
Georgia
Philippines
 
Ghana
Portugal
 
Guatemala
Puerto Rico
 
Guinea
Russian Federation
 
Guyana
Rwanda*
 
Honduras
Saudi Arabia
 

*
DRC and adjoining countries
**
Adient’s review of the recent conflict minerals surveys received from its suppliers and related conflict minerals reports found information indicating that some of the smelters in its supply chain identified Iran as a possible sourcing location. The information regarding these Iranian-origin metals came from these third-party suppliers, which in turn obtained the information through their own suppliers in these highly-attenuated, multi-tiered global supply chains. Adient did not knowingly source metals from Iranian parties, did not conduct transactions with any Iranian parties, and has robust economic sanctions screening procedures that would have identified and blocked prospective business with any Iranian parties before they occurred. The information currently available to Adient from its third-party suppliers indicates that minerals from Iran were substantially transformed before being sold to Adient or otherwise incorporated into finished products.


Appendix A
Page 8