EX-1.01 2 a2019exhibit101.htm EX-1.01 Document
Exhibit 1.01
image21.jpg

Adient plc
Conflict Minerals Report
For the Calendar Year Ended December 31, 2019


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 2019 and covers all activities conducted for the calendar year ended December 31, 2019.

II. Adient Overview

Adient is one of the world’s largest automotive seating suppliers 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.

Page 1


Exhibit 1.01
adienta601.jpg


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

A.Process Summary

Adient designed and implemented a compliance framework that conforms to the process steps enumerated in the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected Areas and High-Risk Areas” and related supplements issued by the Organization for Economic Co-Operation and Development (OECD).

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 use the unaltered CMRT and 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 provided them with instructions to assist with the completion of the CMRT.

In addition to the RCOI efforts described above, Adient undertook the following supplemental measures to determine the mine or country of origin of any Conflict Minerals:

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.
Adient then assigned a risk level of “High,” “Low” or “None” to each In-Scope Supplier based on the likelihood of the presence of Conflict Minerals in each component. This risk rating process was the 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. Adient uses these risk ratings to prioritize the Supply Chain Management department’s activities and implement escalation measures for unresponsive suppliers.
After completing the risk ratings, 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 own suppliers. The Conflict Minerals Supplier Letter that was sent to each In-Scope Supplier can be found on Adient’s website at:
www.adient.com/suppliers/corporate-responsibility.
Adient provided explanations as well as additional 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 In-Scope Suppliers support Adient’s compliance and reporting requirements. Please refer to the “Supplier Engagement and Training” section below for more information.
Adient reviewed the responses received from the In-Scope Suppliers about the country of origin of any Conflict Minerals necessary for product functionality or production of products supplied to Adient for accuracy and completeness. Potentially problematic responses were then flagged for additional follow up and/or due diligence.
Suppliers who sent incomplete or inconsistent responses were asked to review their responses and resubmit their surveys. Adient implemented the following escalation process for suppliers that did not respond:
Step 1: Adient sent an escalation letter to a selection of suppliers with risk ratings of High that did not respond.

Page 2


Exhibit 1.01
adienta601.jpg

Step 2: Adient 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, then the relevant Vice President(s) of Procurement sent a written letter to the supplier requesting completion of the survey.

In addition to these steps, Adient implemented several measures in 2019 designed to strengthen its internal conflict minerals process. These included online training for third-party suppliers, better coordination with our Global Customs & Trade Compliance department, and enhanced escalation procedures for unresponsive high-risk suppliers. We believe that these changes improved the reporting quality and slightly increased the supplier response rate. Our response rate was still lower than industry averages, however, and we will continue to review our escalation process to consider further adjustments in the future.

B.RCOI Results

Adient determined there were 1,167 In-Scope Suppliers for calendar year 2019, which represented 35% of Adient’s total direct suppliers. Adient sent communications to all of these In-Scope Suppliers notifying them of the RCOI and received receipt confirmations from 99% of that cohort.

The overall response rate for the In-Scope Suppliers surveyed was 57%, including 409 responses that were received and accepted (representing 35% 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 3TG72 %
Acknowledged 3TG Sourced from the Covered Countries16 %
Acknowledged 3TG Not Sourced from the Covered Countries11 %
3TG Origin Uncertain or Unknown— %

C.Proposed Improvements

Adient’s response rate of 57% for In-Scope Suppliers in 2019 was lower than industry averages. Although we performed additional escalation procedures specifically designed to encourage non-respondent suppliers to provide outstanding CMRTs the results show that further process improvements are needed to raise the response rate to the desired level. As a result, we will continue to focus on improving the escalation process in the upcoming year. Anticipated changes include:

Strengthen coordination with Adient’s Purchasing Department to review supplier response rate for directed and Adient-controlled suppliers by country or region. This will help Adient identify new strategies for encouraging suppliers to comply with our CM program;
Reconsider supply arrangements and potentially implement remedies for suppliers that refuse to cooperate with Adient’s compliance efforts;
Improve the content and language of the supplier communication letters.







Page 3


Exhibit 1.01
adienta601.jpg

VI. Conflict Minerals Due Diligence

A.Compliance Framework

i.Framework Design and Overview

As noted above, Adient designed and implement a compliance framework that conforms to the principles enumerated in the OECD’s internationally recognized Conflict Minerals due diligence standards. 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. Each of these elements are described below.

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

Internal Management System

Adient maintains an internal management system where senior management with the necessary expertise, knowledge and experience oversee the RCOI and due diligence process. These managers continue to develop strategies that address supply chain risks through initiatives that often involve stakeholder engagement or consultation with outside experts.

Adient also maintains a Conflict Minerals Executive Steering Committee (“Steering Committee”) comprised of leaders from the Procurement, Legal, Engineering, Communications and Finance Departments. The Steering Committee oversees and supports Adient’s Conflict Minerals compliance program. The Steering Committee meets 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; Chief Accounting Officer; Vice President, Tax; Vice President, Internal Audit; Vice President, Investor Relations; Vice President, Regional Finance; Global Director of Financial, Planning and Analysis. This broad oversight promotes a rigorous review and reporting process.

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 the materials they supply. Adient’s RCOI and due diligence

Page 4


Exhibit 1.01
adienta601.jpg

processes are also designed to gather information on the chain of custody of the necessary Conflict Minerals that could potentially appear in Adient’s products.

Supplier Engagement and Training

Adient provides an online supplier training as part of the initial communication package to the In-Scope Suppliers. This training summarizes the relevant requirements of the Rule (including Adient's obligations) and reiterates Adient’s expectation that our suppliers cooperate to support our Conflict Minerals compliance efforts. Suppliers are encouraged to ask questions to our compliance specialists to enhance their understanding of the Rule and our expectations. Additional training is also provided to suppliers on demand. The training is available on our website at: www.adient.com/suppliers/corporate-responsibility.

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 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 organizations (“NGO”) like Global Witness or Amnesty International that compile smelter information.

Adient publicly shares its position on responsible sourcing of Conflict Minerals through its Conflict Minerals Policy Statement. Adient also includes a Conflict Minerals compliance provision in new (or renewed) supplier agreements when appropriate. This provision requires suppliers to conduct and document inquiries into Conflict Minerals appearing in the products supplied to Adient, including inquiries as to the smelter, refiner, and country of origin. Adient’s Global Supplier Standards Manual reflects these same 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: adient.ethicspoint.com), providing any interested party (including employees, customers, suppliers or other external third parties) with a confidential mechanism to report 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 and 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 issues reported through the helpline or escalated through other channels.

iii.Identify and Assess Risk in the Supply Chain


Page 5


Exhibit 1.01
adienta601.jpg

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 that may provide Conflict Minerals used in its products.

Adient follows up, and continues to follow up, with suppliers who indicate that they might be sourcing Conflict Minerals from the Covered Countries or non-certified smelters. This due diligence on the source and chain of custody of the Conflict Minerals asks such suppliers whether they:

provided information on all smelters and the country of origin of the Conflict Minerals;
performed due diligence procedures for non-certified smelters; and
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 information indicating that a supplier may have sourced Conflict Minerals from the Covered Countries during its review of the received CMRTs. Once an In-Scope Supplier indicates that it might be sourcing Conflict Minerals from the Covered Countries, Adient engages with the supplier to collect more detailed information and seeks to validate that information through 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).

Adient then creates a list of suppliers identified as using Conflict Minerals from a Covered Country as well as the indicated smelters. This list is 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 engages and actively cooperates with industry groups, including RMI and AIAG.

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

Adient supports independent third-party audits through its RMI membership. We rely on the RMI’s Conflict-Free Smelter Program in our due diligence to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. Adient evaluates the reports received from suppliers using the RMI smelter database and reports any unknown smelter or smelters that have not been certified to RMI for further investigation and inclusion in the smelter certification scheme. Adient is a downstream consumer of Conflict Minerals, however, and is many steps removed from the mining of Conflict Minerals. Consequently, 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.

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

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

Page 6


Exhibit 1.01
adienta601.jpg

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, we must rely on responses from its suppliers in order to identify the facilities used to process Conflict Minerals.

Based on a review of the received and accepted responses, 11% of the suppliers indicated that they did not source from the Covered Countries and 16% 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. 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.

It is also important to note that our suppliers generally do not have a direct relationship with the facilities used to process Conflict Minerals. Indeed, one of our suppliers responded to our survey by stating they were unable to provide any smelter and refiner information at this time. Between this response and the low overall response rate for this reporting period, Adient was not able to identify each of the facilities or countries of origins associated with all the Conflict Minerals that could potentially appear in its products.

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, which included reviewing 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. Our suppliers identified a total of 332 smelters, including 230 (or approximately 70%) that are RMI certified. The percentage of certified smelters identified by our suppliers in 2019 decreased by 20 percentage points as compared to 2018. Five of these smelters indicated that they were not interested in participating in a smelter registration and audit scheme. Another 26 smelters had not been contacted by the respective upstream supplier to participate in the RMI certification scheme at the time our survey occurred and, consequently, were not certified during the reporting year. Eight smelters are currently undergoing certification, while 6 smelters did not conform to the RMI audit scheme. We also learned that 57 smelters ceased operations during the reporting year.

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:

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;
Updating and adapting our scoping and due diligence guidelines as well as the escalation process to reflect organizational changes inside Adient; and
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 RMI certification or participate in other certification schemes. This trend appears to be due to external factors, including guidance related to the application of the Rule. Adient is committed to responsible sourcing practices, however, and will continue to implement standards articulated under the Rule, the OECD Guidance and in a manner consistent with our Conflict Minerals Policy Statement. In order to identify the origin of those minerals and further mitigate the risk that Conflict Minerals in the supply chain benefited armed groups in the Covered Countries, Adient will continue its

Page 7


Exhibit 1.01
adienta601.jpg

efforts with its In-Scope Suppliers to improve the response rate and the completeness of the surveys. In addition, Adient will:

Continue to direct suppliers to Adient’s Conflict Minerals Policy Statement, which emphasizes the responsible sourcing of Conflict Minerals;
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;
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;
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;
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;
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
Work with the RMI smelter engagement team to support their engagement and certification efforts.

VII. Determination

For calendar year 2019, 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 2019 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. Please 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, 2019 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.

Page 8


Exhibit 1.01
adienta601.jpg

Appendix A - Smelters by mineral


The attached smelter information refers to data available in the RMI smelter database in March 2020. Any changes to the RMI smelter database that took place after March 2020 are not covered.

List 1: Smelters and Refiners reported in Adient’s supply chain as of December 31, 2019

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Tantalum (Ta)Asaka Riken Co., Ltd.JAPAN
Tantalum (Ta)Changsha South Tantalum Niobium Co., Ltd.CHINA
Tantalum (Ta)D Block Metals, LLCUNITED STATES OF AMERICA
Tantalum (Ta)Exotech Inc.UNITED STATES OF AMERICA
Tantalum (Ta)F&X Electro-Materials Ltd.CHINA
Tantalum (Ta)FIR Metals & Resource Ltd.CHINA
Tantalum (Ta)Global Advanced Metals AizuJAPAN
Tantalum (Ta)Global Advanced Metals BoyertownUNITED STATES OF AMERICA
Tantalum (Ta)Guangdong Zhiyuan New Material Co., Ltd.CHINA
Tantalum (Ta)H.C. Starck Co., Ltd.THAILAND
Tantalum (Ta)H.C. Starck Hermsdorf GmbHGERMANY
Tantalum (Ta)H.C. Starck Inc.UNITED STATES OF AMERICA
Tantalum (Ta)H.C. Starck Ltd.JAPAN
Tantalum (Ta)H.C. Starck Smelting GmbH & Co. KGGERMANY
Tantalum (Ta)H.C. Starck Tantalum and Niobium GmbHGERMANY
Tantalum (Ta)Hengyang King Xing Lifeng New Materials Co., Ltd.CHINA
Tantalum (Ta)Jiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
Tantalum (Ta)Jiangxi Tuohong New Raw MaterialCHINA
Tantalum (Ta)JiuJiang JinXin Nonferrous Metals Co., Ltd.CHINA
Tantalum (Ta)Jiujiang Tanbre Co., Ltd.CHINA
Tantalum (Ta)Jiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
Tantalum (Ta)KEMET Blue MetalsMEXICO
Tantalum (Ta)KEMET Blue PowderUNITED STATES OF AMERICA
Tantalum (Ta)LSM Brasil S.A.BRAZIL
Tantalum (Ta)Metallurgical Products India Pvt., Ltd.INDIA
Tantalum (Ta)Mineracao Taboca S.A.BRAZIL
Tantalum (Ta)Mitsui Mining and Smelting Co., Ltd.JAPAN
Tantalum (Ta)Ningxia Orient Tantalum Industry Co., Ltd.CHINA
Tantalum (Ta)NPM Silmet ASESTONIA
Tantalum (Ta)Power Resources Ltd.MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum (Ta)QuantumCleanUNITED STATES OF AMERICA
Tantalum (Ta)Resind Industria e Comercio Ltda.BRAZIL
Tantalum (Ta)RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.CHINA
Tantalum (Ta)Solikamsk Magnesium Works OAORUSSIAN FEDERATION
Tantalum (Ta)Taki Chemical Co., Ltd.JAPAN
Tantalum (Ta)Telex MetalsUNITED STATES OF AMERICA
Appendix A
1

Exhibit 1.01
adienta601.jpg

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Tantalum (Ta)Ulba Metallurgical Plant JSCKAZAKHSTAN
Tantalum (Ta)XinXing HaoRong Electronic Material Co., Ltd.CHINA
Tin (Sn)AlphaUNITED STATES OF AMERICA
Tin (Sn)Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
Tin (Sn)Chifeng Dajingzi Tin Industry Co., Ltd.CHINA
Tin (Sn)China Tin Group Co., Ltd.CHINA
Tin (Sn)DowaJAPAN
Tin (Sn)EM VintoBOLIVIA (PLURINATIONAL STATE OF)
Tin (Sn)Fenix MetalsPOLAND
Tin (Sn)Gejiu Kai Meng Industry and Trade LLCCHINA
Tin (Sn)Gejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
Tin (Sn)Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINA
Tin (Sn)Gejiu Zili Mining And Metallurgy Co., Ltd.CHINA
Tin (Sn)Guangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINA
Tin (Sn)Guanyang Guida Nonferrous Metal Smelting PlantCHINA
Tin (Sn)HuiChang Hill Tin Industry Co., Ltd.CHINA
Tin (Sn)Huichang Jinshunda Tin Co., Ltd.CHINA
Tin (Sn)Jiangxi New Nanshan Technology Ltd.CHINA
Tin (Sn)Ma'anshan Weitai Tin Co., Ltd.CHINA
Tin (Sn)Magnu's Minerais Metais e Ligas Ltda.BRAZIL
Tin (Sn)Malaysia Smelting Corporation (MSC)MALAYSIA
Tin (Sn)Melt Metais e Ligas S.A.BRAZIL
Tin (Sn)Metallic Resources, Inc.UNITED STATES OF AMERICA
Tin (Sn)Metallo Belgium N.V.BELGIUM
Tin (Sn)Metallo Spain S.L.U.SPAIN
Tin (Sn)Mineracao Taboca S.A.BRAZIL
Tin (Sn)MinsurPERU
Tin (Sn)Mitsubishi Materials CorporationJAPAN
Tin (Sn)O.M. Manufacturing (Thailand) Co., Ltd.THAILAND
Tin (Sn)O.M. Manufacturing Philippines, Inc.PHILIPPINES
Tin (Sn)Operaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)
Tin (Sn)PT Artha Cipta LanggengINDONESIA
Tin (Sn)PT ATD Makmur Mandiri JayaINDONESIA
Tin (Sn)PT Mitra Stania PrimaINDONESIA
Tin (Sn)PT Refined Bangka TinINDONESIA
Tin (Sn)PT Timah Tbk KundurINDONESIA
Tin (Sn)PT Timah Tbk MentokINDONESIA
Tin (Sn)Resind Industria e Comercio Ltda.BRAZIL
Tin (Sn)Rui Da HungTAIWAN, PROVINCE OF CHINA
Tin (Sn)Soft Metais Ltda.BRAZIL
Tin (Sn)Thai Nguyen Mining and Metallurgy Co., Ltd.VIET NAM
Tin (Sn)ThaisarcoTHAILAND
Appendix A
2

Exhibit 1.01
adienta601.jpg

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Tin (Sn)Tin Technology & RefiningUNITED STATES OF AMERICA
Tin (Sn)White Solder Metalurgia e Mineracao Ltda.BRAZIL
Tin (Sn)Yunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
Tin (Sn)Yunnan Tin Company LimitedCHINA
Tin (Sn)Yunnan Yunfan Non-ferrous Metals Co., Ltd.CHINA
Tin (Sn)An Vinh Joint Stock Mineral Processing CompanyVIET NAM
Tin (Sn)Dongguan CiEXPO Environmental Engineering Co., Ltd.CHINA
Tin (Sn)Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAM
Tin (Sn)Estanho de Rondonia S.A.BRAZIL
Tin (Sn)Modeltech Sdn BhdMALAYSIA
Tin (Sn)Nghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAM
Tin (Sn)Pongpipat Company LimitedMYANMAR
Tin (Sn)PT Lautan Harmonis SejahteraINDONESIA
Tin (Sn)Super LigasBRAZIL
Tin (Sn)Tuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAM
Tungsten (W)A.L.M.T. Corp.JAPAN
Tungsten (W)ACL Metais EireliBRAZIL
Tungsten (W)Asia Tungsten Product Vietnam Ltd.VIET NAM
Tungsten (W)Chenzhou Diamond Tungsten Products Co., Ltd.CHINA
Tungsten (W)Chongyi Zhangyuan Tungsten Co., Ltd.CHINA
Tungsten (W)Fujian Jinxin Tungsten Co., Ltd.CHINA
Tungsten (W)Ganzhou Haichuang Tungsten Co., Ltd.CHINA
Tungsten (W)Ganzhou Huaxing Tungsten Products Co., Ltd.CHINA
Tungsten (W)Ganzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
Tungsten (W)Ganzhou Seadragon W & Mo Co., Ltd.CHINA
Tungsten (W)Global Tungsten & Powders Corp.UNITED STATES OF AMERICA
Tungsten (W)Guangdong Xianglu Tungsten Co., Ltd.CHINA
Tungsten (W)H.C. Starck Smelting GmbH & Co. KGGERMANY
Tungsten (W)H.C. Starck Tungsten GmbHGERMANY
Tungsten (W)Hunan Chenzhou Mining Co., Ltd.CHINA
Tungsten (W)Hunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINA
Tungsten (W)Hunan Chunchang Nonferrous Metals Co., Ltd.CHINA
Tungsten (W)Hunan Litian Tungsten Industry Co., Ltd.CHINA
Tungsten (W)Hydrometallurg, JSCRUSSIAN FEDERATION
Tungsten (W)Japan New Metals Co., Ltd.JAPAN
Tungsten (W)Jiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
Tungsten (W)Jiangxi Dayu Longxintai Tungsten Co., Ltd.CHINA
Tungsten (W)Jiangxi Gan Bei Tungsten Co., Ltd.CHINA
Tungsten (W)Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
Tungsten (W)Jiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
Tungsten (W)Jiangxi Yaosheng Tungsten Co., Ltd.CHINA
Tungsten (W)Kennametal FallonUNITED STATES OF AMERICA
Appendix A
3

Exhibit 1.01
adienta601.jpg

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Tungsten (W)Kennametal HuntsvilleUNITED STATES OF AMERICA
Tungsten (W)KGETS Co., Ltd.KOREA, REPUBLIC OF
Tungsten (W)Lianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINA
Tungsten (W)Malipo Haiyu Tungsten Co., Ltd.CHINA
Tungsten (W)Masan Tungsten Chemical LLC (MTC)VIET NAM
Tungsten (W)Moliren Ltd.RUSSIAN FEDERATION
Tungsten (W)Niagara Refining LLCUNITED STATES OF AMERICA
Tungsten (W)Philippine Chuangxin Industrial Co., Inc.PHILIPPINES
Tungsten (W)Tejing (Vietnam) Tungsten Co., Ltd.VIET NAM
Tungsten (W)Unecha Refractory metals plantRUSSIAN FEDERATION
Tungsten (W)Wolfram Bergbau und Hutten AGAUSTRIA
Tungsten (W)Woltech Korea Co., Ltd.KOREA, REPUBLIC OF
Tungsten (W)Xiamen Tungsten (H.C.) Co., Ltd.CHINA
Tungsten (W)Xiamen Tungsten Co., Ltd.CHINA
Tungsten (W)Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINA
Tungsten (W)Xinhai Rendan Shaoguan Tungsten Co., Ltd.CHINA
Tungsten (W)Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA
Gold (Au)8853 S.p.A.ITALY
Gold (Au)Advanced Chemical CompanyUNITED STATES OF AMERICA
Gold (Au)Aida Chemical Industries Co., Ltd.JAPAN
Gold (Au)Allgemeine Gold-und Silberscheideanstalt A.G.GERMANY
Gold (Au)Almalyk Mining and Metallurgical Complex (AMMC)UZBEKISTAN
Gold (Au)AngloGold Ashanti Corrego do Sitio MineracaoBRAZIL
Gold (Au)Argor-Heraeus S.A.SWITZERLAND
Gold (Au)Asahi Pretec Corp.JAPAN
Gold (Au)Asahi Refining Canada Ltd.CANADA
Gold (Au)Asahi Refining USA Inc.UNITED STATES OF AMERICA
Gold (Au)Asaka Riken Co., Ltd.JAPAN
Gold (Au)AU Traders and RefinersSOUTH AFRICA
Gold (Au)Aurubis AGGERMANY
Gold (Au)Bangalore RefineryINDIA
Gold (Au)Bangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINES
Gold (Au)Boliden ABSWEDEN
Gold (Au)C. Hafner GmbH + Co. KGGERMANY
Gold (Au)CCR Refinery - Glencore Canada CorporationCANADA
Gold (Au)Cendres + Metaux S.A.SWITZERLAND
Gold (Au)Chimet S.p.A.ITALY
Gold (Au)Chugai MiningJAPAN
Gold (Au)DODUCO Contacts and Refining GmbHGERMANY
Gold (Au)DowaJAPAN
Gold (Au)DS PRETECH Co., Ltd.KOREA, REPUBLIC OF
Gold (Au)DSC (Do Sung Corporation)KOREA, REPUBLIC OF
Gold (Au)Eco-System Recycling Co., Ltd.JAPAN
Appendix A
4

Exhibit 1.01
adienta601.jpg

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Gold (Au)Emirates Gold DMCCUNITED ARAB EMIRATES
Gold (Au)Geib Refining CorporationUNITED STATES OF AMERICA
Gold (Au)Gold Refinery of Zijin Mining Group Co., Ltd.CHINA
Gold (Au)HeeSung Metal Ltd.KOREA, REPUBLIC OF
Gold (Au)Heimerle + Meule GmbHGERMANY
Gold (Au)Heraeus Metals Hong Kong Ltd.CHINA
Gold (Au)Heraeus Precious Metals GmbH & Co. KGGERMANY
Gold (Au)Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINA
Gold (Au)Ishifuku Metal Industry Co., Ltd.JAPAN
Gold (Au)Istanbul Gold RefineryTURKEY
Gold (Au)ItalpreziosiITALY
Gold (Au)Japan MintJAPAN
Gold (Au)Jiangxi Copper Co., Ltd.CHINA
Gold (Au)JSC UralelectromedRUSSIAN FEDERATION
Gold (Au)JX Nippon Mining & Metals Co., Ltd.JAPAN
Gold (Au)KazzincKAZAKHSTAN
Gold (Au)Kennecott Utah Copper LLCUNITED STATES OF AMERICA
Gold (Au)KGHM Polska Miedz Spolka AkcyjnaPOLAND
Gold (Au)Kojima Chemicals Co., Ltd.JAPAN
Gold (Au)Korea Zinc Co., Ltd.KOREA, REPUBLIC OF
Gold (Au)Kyrgyzaltyn JSCKYRGYZSTAN
Gold (Au)L'Orfebre S.A.ANDORRA
Gold (Au)LS-NIKKO Copper Inc.KOREA, REPUBLIC OF
Gold (Au)Marsam MetalsBRAZIL
Gold (Au)MaterionUNITED STATES OF AMERICA
Gold (Au)Matsuda Sangyo Co., Ltd.JAPAN
Gold (Au)Metalor Technologies (Hong Kong) Ltd.CHINA
Gold (Au)Metalor Technologies (Singapore) Pte., Ltd.SINGAPORE
Gold (Au)Metalor Technologies (Suzhou) Ltd.CHINA
Gold (Au)Metalor Technologies S.A.SWITZERLAND
Gold (Au)Metalor USA Refining CorporationUNITED STATES OF AMERICA
Gold (Au)Metalurgica Met-Mex Penoles S.A. De C.V.MEXICO
Gold (Au)Mitsubishi Materials CorporationJAPAN
Gold (Au)Mitsui Mining and Smelting Co., Ltd.JAPAN
Gold (Au)MMTC-PAMP India Pvt., Ltd.INDIA
Gold (Au)Moscow Special Alloys Processing PlantRUSSIAN FEDERATION
Gold (Au)Nadir Metal Rafineri San. Ve Tic. A.S.TURKEY
Gold (Au)Nihon Material Co., Ltd.JAPAN
Gold (Au)Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIA
Gold (Au)Ohura Precious Metal Industry Co., Ltd.JAPAN
Gold (Au)OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATION
Gold (Au)OJSC Novosibirsk RefineryRUSSIAN FEDERATION
Appendix A
5

Exhibit 1.01
adienta601.jpg

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Gold (Au)PAMP S.A.SWITZERLAND
Gold (Au)Planta Recuperadora de Metales SpACHILE
Gold (Au)Prioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
Gold (Au)PT Aneka Tambang (Persero) TbkINDONESIA
Gold (Au)PX Precinox S.A.SWITZERLAND
Gold (Au)Rand Refinery (Pty) Ltd.SOUTH AFRICA
Gold (Au)REMONDIS PMR B.V.NETHERLANDS
Gold (Au)Royal Canadian MintCANADA
Gold (Au)SAAMPFRANCE
Gold (Au)Safimet S.p.AITALY
Gold (Au)Samduck Precious MetalsKOREA, REPUBLIC OF
Gold (Au)SAXONIA Edelmetalle GmbHGERMANY
Gold (Au)SEMPSA Joyeria Plateria S.A.SPAIN
Gold (Au)Shandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
Gold (Au)Sichuan Tianze Precious Metals Co., Ltd.CHINA
Gold (Au)Singway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
Gold (Au)SOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
Gold (Au)Solar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINA
Gold (Au)Sumitomo Metal Mining Co., Ltd.JAPAN
Gold (Au)SungEel HiMetal Co., Ltd.KOREA, REPUBLIC OF
Gold (Au)T.C.A S.p.AITALY
Gold (Au)Tanaka Kikinzoku Kogyo K.K.JAPAN
Gold (Au)The Refinery of Shandong Gold Mining Co., Ltd.CHINA
Gold (Au)Tokuriki Honten Co., Ltd.JAPAN
Gold (Au)TorecomKOREA, REPUBLIC OF
Gold (Au)Umicore Brasil Ltda.BRAZIL
Gold (Au)Umicore Precious Metals ThailandTHAILAND
Gold (Au)Umicore S.A. Business Unit Precious Metals RefiningBELGIUM
Gold (Au)United Precious Metal Refining, Inc.UNITED STATES OF AMERICA
Gold (Au)Valcambi S.A.SWITZERLAND
Gold (Au)Western Australian Mint (T/a The Perth Mint)AUSTRALIA
Gold (Au)WIELAND Edelmetalle GmbHGERMANY
Gold (Au)Yamakin Co., Ltd.JAPAN
Gold (Au)Yokohama Metal Co., Ltd.JAPAN
Gold (Au)Zhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
Gold (Au)Al Etihad Gold Refinery DMCCUNITED ARAB EMIRATES
Gold (Au)Atasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEY
Gold (Au)CaridadMEXICO
Gold (Au)Daye Non-Ferrous Metals Mining Ltd.CHINA
Gold (Au)Degussa Sonne / Mond Goldhandel GmbHGERMANY
Gold (Au)Fidelity Printers and Refiners Ltd.ZIMBABWE
Gold (Au)GCC Gujrat Gold Centre Pvt. Ltd.INDIA
Gold (Au)Great Wall Precious Metals Co., Ltd. of CBPMCHINA
Gold (Au)Guangdong Jinding Gold LimitedCHINA
Appendix A
6

Exhibit 1.01
adienta601.jpg

Conflict MineralSmelter or Refiner NameLocation of Smelter or Refiner
Gold (Au)Guoda Safina High-Tech Environmental Refinery Co., Ltd.CHINA
Gold (Au)Hangzhou Fuchunjiang Smelting Co., Ltd.CHINA
Gold (Au)Hunan Chenzhou Mining Co., Ltd.CHINA
Gold (Au)HwaSeong CJ CO., LTD.KOREA, REPUBLIC OF
Gold (Au)Kaloti Precious MetalsUNITED ARAB EMIRATES
Gold (Au)Kazakhmys Smelting LLCKAZAKHSTAN
Gold (Au)Kyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATION
Gold (Au)L'azurde Company For JewelrySAUDI ARABIA
Gold (Au)Lingbao Gold Co., Ltd.CHINA
Gold (Au)Lingbao Jinyuan Tonghui Refinery Co., Ltd.CHINA
Gold (Au)Luoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINA
Gold (Au)Modeltech Sdn BhdMALAYSIA
Gold (Au)Morris and WatsonNEW ZEALAND
Gold (Au)Navoi Mining and Metallurgical CombinatUZBEKISTAN
Gold (Au)NH Recytech CompanyKOREA, REPUBLIC OF
Gold (Au)Pease & CurrenUNITED STATES OF AMERICA
Gold (Au)Penglai Penggang Gold Industry Co., Ltd.CHINA
Gold (Au)Refinery of Seemine Gold Co., Ltd.CHINA
Gold (Au)Sabin Metal Corp.UNITED STATES OF AMERICA
Gold (Au)Sai RefineryINDIA
Gold (Au)Samwon Metals Corp.KOREA, REPUBLIC OF
Gold (Au)Shandong Tiancheng Biological Gold Industrial Co., Ltd.CHINA
Gold (Au)State Research Institute Center for Physical Sciences and TechnologyLITHUANIA
Gold (Au)Tongling Nonferrous Metals Group Co., Ltd.CHINA
Gold (Au)TOO Tau-Ken-AltynKAZAKHSTAN
Gold (Au)Yunnan Copper Industry Co., Ltd.CHINA

Appendix A
7

Exhibit 1.01
adienta601.jpg


List 2: Smelters and Refiners reported in Adient’s supply chain but identified as having ceased operation prior to December 31, 2019
Conflict MineralLocation of Smelter or RefinerLocation of Smelter or Refiner
Tantalum (Ta)DuoluoshanCHINA
Tantalum (Ta)Guangdong Rising Rare Metals-EO Materials Ltd.CHINA
Tantalum (Ta)Hi-Temp Specialty Metals, Inc.UNITED STATES OF AMERICA
Tantalum (Ta)King-Tan Tantalum Industry Ltd.CHINA
Tantalum (Ta)Yichun Jin Yang Rare Metal Co., Ltd.CHINA
Tin (Sn)CNMC (Guangxi) PGMA Co., Ltd.CHINA
Tin (Sn)Cooperativa Metalurgica de Rondonia Ltda.BRAZIL
Tin (Sn)CV Ayi JayaINDONESIA
Tin (Sn)CV Dua SekawanINDONESIA
Tin (Sn)CV Gita PesonaINDONESIA
Tin (Sn)CV United SmeltingINDONESIA
Tin (Sn)CV Venus Inti PerkasaINDONESIA
Tin (Sn)Da Nang Processing Import and Export Joint StockVIET NAM
Tin (Sn)Gejiu Fengming Metallurgy Chemical PlantCHINA
Tin (Sn)Gejiu Jinye Mineral CompanyCHINA
Tin (Sn)Jiangxi Ketai Advanced Material Co., Ltd.CHINA
Tin (Sn)PT Aries Kencana SejahteraINDONESIA
Tin (Sn)PT Babel Inti PerkasaINDONESIA
Tin (Sn)PT Babel Surya Alam LestariINDONESIA
Tin (Sn)PT Bangka Prima TinINDONESIA
Tin (Sn)PT Bangka SerumpunINDONESIA
Tin (Sn)PT Bangka Tin IndustryINDONESIA
Tin (Sn)PT Belitung Industri SejahteraINDONESIA
Tin (Sn)PT Bukit TimahINDONESIA
Tin (Sn)PT Cipta Persada MuliaINDONESIA
Tin (Sn)PT DS Jaya AbadiINDONESIA
Tin (Sn)PT Eunindo Usaha MandiriINDONESIA
Tin (Sn)PT Inti Stania PrimaINDONESIA
Tin (Sn)PT JustindoINDONESIA
Tin (Sn)PT Karimun MiningINDONESIA
Tin (Sn)PT Kijang Jaya MandiriINDONESIA
Tin (Sn)PT Lautan Harmonis SejahteraINDONESIA
Tin (Sn)PT Menara Cipta MuliaINDONESIA
Tin (Sn)PT Panca Mega PersadaINDONESIA
Tin (Sn)PT Premium Tin IndonesiaINDONESIA
Tin (Sn)PT Prima Timah UtamaINDONESIA
Tin (Sn)PT Rajawali Rimba PerkasaINDONESIA
Tin (Sn)PT Rajehan AriqINDONESIA
Tin (Sn)PT Sariwiguna BinasentosaINDONESIA
Tin (Sn)PT Stanindo Inti PerkasaINDONESIA
Appendix A
8

Exhibit 1.01
adienta601.jpg

Conflict MineralLocation of Smelter or RefinerLocation of Smelter or Refiner
Tin (Sn)PT Sukses Inti MakmurINDONESIA
Tin (Sn)PT Sumber Jaya IndahINDONESIA
Tin (Sn)PT Timah NusantaraINDONESIA
Tin (Sn)PT Tinindo Inter NusaINDONESIA
Tin (Sn)PT Tirus Putra MandiriINDONESIA
Tin (Sn)PT Tommy UtamaINDONESIA
Tin (Sn)PT Wahana Perkit JayaINDONESIA
Tin (Sn)PT Bangka Putra KaryaINDONESIA
Tungsten (W)Ganzhou Yatai Tungsten Co., Ltd.CHINA
Tungsten (W)Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.CHINA
Tungsten (W)South-East Nonferrous Metal Company Limited of Hengyang CityCHINA
Tungsten (W)Vietnam Youngsun Tungsten Industry Co., Ltd.VIET NAM
Gold (Au)Daejin Indus Co., Ltd.KOREA, REPUBLIC OF
Gold (Au)Elemetal Refining, LLCUNITED STATES OF AMERICA
Gold (Au)Morris and Watson Gold CoastAUSTRALIA
Gold (Au)Republic Metals CorporationUNITED STATES OF AMERICA
Gold (Au)Schone Edelmetaal B.V.NETHERLANDS

Appendix A
9

Exhibit 1.01
adienta601.jpg

Potential Countries of Origin of Conflict Minerals:

ArgentinaIndiaSenegal
ArmeniaIndonesiaSierra Leone
AustraliaIran**Slovakia
AustriaIvory CoastSolomon Islands
AzerbaijanKazakhstanSouth Africa
BeninKenyaSpain
BoliviaLaosSuriname
Bolivia (Plurinational State of)LebanonSwaziland
BotswanaMadagascarSweden
BrazilMalaysiaTaiwan
Burkina FasoMaliTanzania*
Burundi*MauritaniaThailand
CanadaMauritiusTogo
ChileMexicoTurkey
ChinaMongoliaUganda*
ColombiaMoroccoUnited Kingdom of Great Britain and Northern Ireland
Congo, Democratic Republic of the*MozambiqueUnited States of America
CyprusMyanmarUruguay
Dominican RepublicNamibiaUzbekistan
EcuadorNicaraguaVenezuela**
EgyptNigerZambia*
EritreaNigeriaZimbabwe
EthiopiaPapua New Guinea
FinlandPeru
GeorgiaPhilippines
GhanaPortugal
GuatemalaPuerto Rico
GuineaRussian Federation***
GuyanaRwanda*
HondurasSaudi Arabia

* DRC and adjoining countries
**  Adient includes Iran and Venezuela in this list of potential countries of origin based on information obtained from RMI’s smelter database. RMI obtains the information appearing in that database from third-party sources that rely on information obtained from other, unrelated parties participating in highly-attenuated, multi-tiered global supply chains. It is also important to note that the information appearing in RMI’s smelter database identifies Iran and Venezuela within the “L1” risk-rating category, which includes over 120 jurisdictions including the United States. None of the conflict minerals surveys returned by Adient’s suppliers identified any discernable connection to Iran or Iranian-origin materials. Adient does not knowingly source metals directly or indirectly from sanctioned countries or parties, does not conduct transactions with sanctioned countries or parties, and has robust economic sanctions screening procedures designed to prevent business with sanctioned countries or parties before it occurs. To the extent that Adient might have unknowingly received metals from such sources, these materials would have been substantially transformed before being sold to Adient or otherwise incorporated into finished products.
*** Information from suppliers CMRTs identified JSC Ekaterinburg Non-Ferrous Metal Processing Plant (“JSC Ekaterinburg”) as a potential source of metals used by Adient’s third-party suppliers. JSC Ekaterinburg is owned by a sanctioned Russian party. Adient prohibits suppliers from sourcing materials from JSC Ekaterinburg, and none of the completed and accepted
Appendix A
10

Exhibit 1.01
adienta601.jpg

conflict minerals surveys returned by our suppliers indicated that they did so during this reporting period. As explained above, Adient does not knowingly source metals directly or indirectly from sanctioned countries or parties, does not conduct transactions with sanctioned countries or parties, and has robust economic sanctions screening procedures designed to prevent business with sanctioned countries or parties before it occurs. To the extent that Adient might have unknowingly received metals from JSC Ekaterinburg, these materials would have been substantially transformed before being sold to Adient or otherwise incorporated into finished products.
Appendix A
11