Exhibit 1.01
Adient plc
Conflict Minerals Report
For the Calendar Year Ended December 31, 2021
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 reporting year (“RY”) 2021 and covers all activities conducted for the calendar year ended December 31, 2021.
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 and 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, and trim covers.
Adient operates 208 wholly-owned and majority-owned manufacturing or assembly facilities in 33 countries, and employs approximately 75,000 employees worldwide. Its products are incorporated into more than 20 million vehicles each year.
As used in this Report, and except where the context otherwise requires, the terms “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, and trim covers.
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 sourced 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
Page 1
suppliers with their own independent supply chains. Accordingly, Adient must rely on its first-tier suppliers to provide information regarding the origin of any Conflict Minerals contained in the components and parts they supply to Adient.
V. Reasonable Country of Origin Inquiry (“RCOI”) | ||
A.Process Summary
Adient designed and implemented a compliance framework that follows the process steps set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected Areas and High-Risk Areas (“OECD Guidance”) 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 (as defined below), notifying them of the RCOI and Adient’s expectations, and also provided such suppliers with 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:
■As part of its global scoping exercise, Adient considered the following supply base categories as the relevant universe for RCOI purposes: manufactured products, products contracted to be manufactured, and spare parts. Identification of suppliers that were subject to the RCOI (“In-Scope Suppliers”) was closely linked not only to the presence of 3TG 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.
■Adient then assigned a risk level of “High,” “Low” or “None” based on the likelihood of the presence of Conflict Minerals in each component to each In-Scope Supplier as result of the joint effort between our Procurement and Engineering Departments. Suppliers providing components with risk rankings of High and Low were considered in-scope for RCOI procedures. The risk level is used during escalation activities for non-responding suppliers to prioritize activities by the Procurement Department.
■Adient required each In-Scope Supplier 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: https://www.adient.com/suppliers/corporate-responsibility.
■In addition to the online training course available on https://www.adient.com/suppliers/corporate-responsibility, Adient provided support to its suppliers during the RY, including explanations regarding the relevant requirements of the Rule and their 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.
■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 were reviewed for accuracy and completeness, and, if necessary, were flagged for additional follow-up and/or due diligence.
Page 2
■In-Scope Suppliers who sent incomplete or inconsistent responses were asked to review their responses and resubmit their surveys.
■Adient documented its escalation process for In-Scope Suppliers in 2021 to include additional process steps. The new process includes:
▪a revised timeline for following up on information requests from non-responsive suppliers;
▪a new escalation process for suppliers reporting smelters of concern; and
▪a process for evaluating and addressing suppliers with potential economic sanctions and embargo issues.
Consistent with the additional steps outlined above, Adient continued to work with particular attention on suppliers that reported sourcing from Russian smelters that could potentially be subject to U.S. economic sanctions programs. Adient strictly prohibits sourcing from any sanctioned countries or parties, and the CMRTs identifying such smelters included smelters that were not present in Adient’s own supply chain. Nonetheless, Adient undertook a review process to request additional information from suppliers, evaluate potential exposure to sanctioned smelters, and better understand its suppliers’ supply chains. Suppliers responding to Adient’s information requests consistently indicated that they were unable to determine whether they sourced products indirectly from such smelters given the complex, multi-layered, and highly-attenuated nature of their supply chains.
B.RCOI Results
Adient determined there were 1091 In-Scope Suppliers for calendar year 2021. Adient sent communications to its In-Scope Suppliers notifying them of the RCOI and received delivery confirmation receipts from 94% of those In-Scope Suppliers.
The overall response rate among the In-Scope Suppliers surveyed was 66%, including 670 responses that were received and accepted (representing 65% 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 | 67 | % | |||
| Acknowledged 3TG Sourced from the Covered Countries | 5 | % | |||
| Acknowledged 3TG Not Sourced from the Covered Countries | 5 | % | |||
| 3TG Origin Uncertain or Unknown | 23 | % | |||
C.Improvement Measures to be Taken
Although Adient experienced an increased response rate of 66% for in-Scope Suppliers in RY 2021, there is still room for improvement. Consistent with its internal Environmental, Sustainability, and Governance (“ESG”) strategies and initiatives, Adient recently launched a new Request for Proposals (“RFP”) process for a comprehensive supplier management tool that would facilitate the evaluation of Tier I suppliers’ own ESG data – including data related to conflict minerals and so-called “critical minerals.” Depending on the available resources, Adient eventually plans to rate suppliers according to their overall sustainability performance and sourcing practices. Adient anticipates that these steps will positively impact supplier response rates in the future.
VI. Conflict Minerals Due Diligence | ||
A.Compliance Framework
i.Framework Design and Overview
Page 3
Adient designed and implemented a compliance framework that conforms to the primary principles of the OECD Guidance, which is the internationally recognized due diligence framework developed by the OECD. Our compliance framework includes elements drawn from those principles and the corresponding supplements for each of the four conflict minerals. These include: 1) establishing strong company management systems; 2) identifying and assessing risk in the supply chain; 3) designing and implementing a strategy to respond to identified risks; 4) carrying out an independent third-party audit of smelters’/refiners’ due diligence practices; and 5) reporting annually on supply chain due diligence. We described each of these elements further 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 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:
https://www.adient.com/wp-content/uploads/2021/11/AdientConflictMineralsPolicyStatement2021.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 continuously seek new ways to evaluate and address potential risk in our supply chain process 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 company’s 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 shared with Adient’s Disclosure Committee, which is comprised of Adient’s Chief Executive Officer; Chief Financial Officer; Chief Legal and Human Resources Officer; Chief Accounting Officer; Vice President and General Counsel, Commercial Transactions; Vice President, Finance; Vice President, Tax; Vice President, Internal Audit; Vice President, Investor Relations, Treasury and Communications; Vice Presidents and Executive Directors, Regional Finance; and Vice President, Global Financial, Planning and Analysis.
System of Controls and Transparency
Due to the complexity of Adient’s global 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.
Supplier Engagement and Training
Adient provides an online training for suppliers as part of the initial communication package to the In-Scope Suppliers that explains the relevant requirements of the Rule, Adient’s obligations under the Rule, and Adient’s
Page 4
expectation that our suppliers support our Conflict Minerals compliance efforts. The training is posted on our website at: https://www.adient.com/suppliers/corporate-responsibility. Adient encourages its suppliers to confer with its compliance team and strengthen their understanding of the Rule and our expectations. Adient also provides additional training to suppliers on request.
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. Where appropriate, Adient also includes a Conflict Minerals compliance provision when it renews or enters into new agreements with suppliers. The provision requires suppliers to conduct and document inquiries of smelters and refiners of any Conflict Minerals incorporated into the products supplied to Adient, including inquiries into the country of origin. Adient’s Global Supplier Standards Manual further reflects and reinforces these expectations.
Internal Training
Adient maintains a web-based training module designed specifically for employees within its Sales, Procurement and Engineering Departments. This training educates employees about the relevant requirements of the Rule, Adient’s obligations under the Rule, and the processes Adient uses to evaluate and respond to related supply chain risks. Training 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 records retention procedures.
Complaint Mechanism
Adient maintains a web- and telephone-based, 24-hour Integrity Helpline (information is available at: https://adient.ethicspoint.com/). The Integrity Helpline provides any interested party (e.g., employees, customers, suppliers, or other external third parties) with a confidential mechanism to report potential violations of the law, regulations, professional standards, and policies (including Adient’s Ethics Policy and its Conflict Minerals Policy Statement), as well as concerns regarding Adient’s supply chain. Credible reports follow Adient’s internal investigations protocol, whereby incoming reports are either investigated by Adient’s Legal Department or transferred to another responsible group inside Adient for investigation. The Legal Department monitors these internal investigations and the resolution of cases escalated through other channels.
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 used in its products.
Page 5
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, asking 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 it identifies information indicating that a supplier may have sourced Conflict Minerals from the Covered Countries through a review of the received CMRT.
Once an In-Scope Supplier indicates that it might be sourcing Conflict Minerals from the Covered Countries, Adient initiates due diligence procedures to collect more detailed information from that supplier. This 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).
Any findings from the due diligence procedures are discussed with Adient’s Procurement Department. Based on this information, Adient created a list of suppliers identified as using Conflict Minerals from a Covered Country as well as the indicated smelters. This list was then 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 with the responsible procurement team.
In addition to these measures, Adient engaged and actively cooperated with industry groups, including RMI and AIAG. Adient provides its smelter list to the RMI to support RMI’s risk assessments.
v.Carry Out Independent Third-Party Audit of Smelters’/Refiners’ Due Diligence Practices
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. Instead, Adient is a downstream consumer of Conflict Minerals and is many steps removed from the mining of Conflict Minerals. In order to meet its obligations under the Rule, Adient supports independent third-party audits by being a member of the RMI and relies on the RMI’s Conflict-Free Smelter Program in connection with our due diligence efforts.
This program helps Adient to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. Adient evaluates the supplier reports it receives using the RMI smelter database and then 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: https://www.adient.com/suppliers/corporate-responsibility.
B.Due Diligence Results
i.Facilities Used to Process Necessary 3TG Originating from Covered Countries
Page 6
Each of the measures described above was designed to provide Adient with information on the smelters and refiners that the In-Scope Suppliers used to process Conflict Minerals incorporated into the products they supply to Adient. As previously discussed, Adient is a downstream consumer of 3TG and generally does not have a direct relationship with smelters and refiners. Consequently, it must rely on responses from its suppliers in order to determine the facilities used to process Conflict Minerals. Much like Adient, our suppliers generally have their own highly attenuated global supply chains and do not have direct relationships with the smelters or other facilities that process Conflict Minerals.
Due to changes in the supplier CMRT evaluation process, the amount of CMRTs still in process at the end of the RY has been reduced to zero. Adient’s updated evaluation rules enabled the internal Conflict Minerals team to re-categorize CMRTs as “3TG origin uncertain or unknown’” in those instances where suppliers did not provide RCOI information for uncertified smelters on the smelter list, and in cases where supplier RCOI data appears to be incorrect.
In RY 2021, only 2 suppliers responded they were unable to provide smelter and refiner information – an amount that accounts for less than 1% of our In-Scope Suppliers. 160 suppliers (24%) reported not certified smelters and were consequently rated as “3TG uncertain or unknown”. Only 31 suppliers (5%) stated that they do not source from DRC or adjoining countries. Given this response and the low response rate for this reporting period, Adient does not know all of the countries of origin or the facilities used to process all the Conflict Minerals incorporated into its products.
Another 5% acknowledged that they sourced 3TG from one or more Covered Countries. The suppliers sourcing from the Covered Countries indicated that they only sourced from smelters that the RMI identifies as DRC conflict free, except for one supplier who reported a smelter that lost its certification during the reporting year. 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.
ii.Smelter Lists (Appendix A)
As explained above, 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 363 smelters were identified by our suppliers and 260, or approximately 72%, are RMI certified. The percentage of certified smelters increased by 4% as compared to 2020. Eight smelters indicated that they were not interested in participating in a smelter registration and audit scheme. Two of these smelters were not subject to U.S. economic sanctions during the reporting year, but now appear to be owned by parties sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) following the Russian Government’s invasion of Ukraine. Suppliers reporting these and other potentially problematic smelters in RY 2022 will be subject to an escalation process. Fifty-five smelters have not yet been contacted by the respective upstream supplier to participate in the RMI certification scheme and were not certified during the reporting year. Eleven smelters do not conform with the RMI audit scheme. Twelve smelters suppliers did not provide RCOI data but there we found no reason to believe that there was any support of armed groups. We also learned that 29 smelters ceased operations during the reporting year.
Page 7
C.Risk Mitigation Measures
Adient’s current processes and procedures for mitigating Conflict Minerals supply chain risks include the following:
■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, due diligence and escalation guidelines;
■Reviewing and utilizing our internal information technology systems and tools to increase process reliability and apply best business practices; and
■Identifying other unrelated risks during the Conflict Minerals reporting process and addressing them through the responsible Adient departments.
The purpose of these processes is to encourage smelters to make responsible sourcing decisions, and to reduce the likelihood that the sale of these Conflict Minerals will benefit armed groups in the Covered Countries.
Adient is committed to promoting these same objectives by complying with the OECD Guidance and the Rule in a manner consistent with our Conflict Minerals Policy Statement. To that end, Adient will continue its efforts with its In-Scope Suppliers to improve the response rate and the completeness of the surveys. These efforts include:
■Directing suppliers to Adient’s Conflict Minerals Policy Statement, which emphasizes the responsible sourcing of Conflict Minerals;
■Striving 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;
■Following-up with suppliers that source Conflict Minerals from, or were identified as potentially sourcing from, smelters and refiners not participating in certification schemes;
■Striving 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;
■Enhancing our RCOI and due diligence measures, as well as the review process for existing and new suppliers included in the scoping guidelines;
■Working with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance; and
■Working with the RMI smelter engagement team to support their engagement and certification efforts.
VII. Determination | ||
For RY 2021, Adient is unable to determine the mine or country of origin for each 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 conclusively whether all products manufactured, or contracted to be manufactured, by Adient in RY 2021 have been found to be free of necessary Conflict Minerals that directly or indirectly financed or benefited armed groups in the Covered Countries. These products include those identified in “Part III. Product Overview” above. 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
Page 8
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, 2021 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 9
Appendix A - Smelters by Mineral
The below smelter information refers to data available in the RMI smelter database in March 2022. Any changes to the RMI smelter database that took place after March 2022 are not covered.
List 1: Smelters and Refiners reported to have been included in Adient’s supply chain as of December 31, 2021:
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
| 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 | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | ||||||
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
| Tantalum | TANIOBIS 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 JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | KEMET de Mexico | MEXICO | ||||||
| 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 | QuantumClean | UNITED STATES OF AMERICA | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tantalum | 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 | ||||||
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | CHINA | ||||||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
Appendix A
1
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | ||||||
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | ||||||
| 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 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||||||
| Tin | CRM Synergies | SPAIN | ||||||
| Tin | CV Venus Inti Perkasa | INDONESIA | ||||||
| Tin | Dowa | JAPAN | ||||||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Fenix Metals | POLAND | ||||||
| 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 | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
| Tin | Luna Smelter, Ltd. | RWANDA | ||||||
| Tin | Ma'anshan Weitai Tin Co., 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 | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
| Tin | PT Babel Inti Perkasa | INDONESIA | ||||||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | ||||||
| Tin | PT Bangka Serumpun | INDONESIA | ||||||
| Tin | PT Bukit Timah | INDONESIA | ||||||
Appendix A
2
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tin | PT Cipta Persada Mulia | INDONESIA | ||||||
| Tin | PT Masbro Alam Stania | INDONESIA | ||||||
| Tin | PT Menara Cipta Mulia | INDONESIA | ||||||
| Tin | PT Mitra Stania Prima | INDONESIA | ||||||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | ||||||
| Tin | PT Prima Timah Utama | INDONESIA | ||||||
| Tin | PT Rajawali Rimba Perkasa | 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 Timah Nusantara | INDONESIA | ||||||
| Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
| Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
| Tin | PT Tinindo Inter Nusa | INDONESIA | ||||||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
| Tin | Soft Metais Ltda. | BRAZIL | ||||||
| Tin | Super Ligas | BRAZIL | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
| 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 | CV Ayi Jaya | INDONESIA | ||||||
| Tin | CV Dua Sekawan | INDONESIA | ||||||
| Tin | CV Gita Pesona | INDONESIA | ||||||
| Tin | CV United Smelting | INDONESIA | ||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||||||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | Pongpipat Company Limited | MYANMAR | ||||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
| Tin | PT Bangka Prima Tin | INDONESIA | ||||||
| Tin | PT Bangka Tin Industry | INDONESIA | ||||||
Appendix A
3
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tin | PT Belitung Industri Sejahtera | 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 Panca Mega Persada | INDONESIA | ||||||
| Tin | PT Rajehan Ariq | INDONESIA | ||||||
| Tin | PT Sumber Jaya Indah | INDONESIA | ||||||
| Tin | PT Tommy Utama | INDONESIA | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin | Precious Minerals and Smelting Limited | INDIA | ||||||
| Tungsten | A.L.M.T. Corp. | JAPAN | ||||||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
| Tungsten | Fujian Xinlu Tungsten | CHINA | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
| Tungsten | GEM Co., Ltd. | CHINA | ||||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals 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 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
Appendix A
4
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Masan High-Tech Materials | VIET NAM | ||||||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||||||
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | ||||||
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
| 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 | Artek LLC | RUSSIAN FEDERATION | ||||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||||||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||||||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||||
| Gold | 8853 S.p.A. | ITALY | ||||||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Alexy Metals | UNITED STATES OF AMERICA | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
| 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 | Augmont Enterprises Private Limited | INDIA | ||||||
| Gold | Aurubis AG | GERMANY | ||||||
| Gold | Bangalore Refinery | INDIA | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
Appendix A
5
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold | Boliden AB | SWEDEN | ||||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
| Gold | Chimet S.p.A. | ITALY | ||||||
| Gold | Chugai Mining | JAPAN | ||||||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
| Gold | Dowa | JAPAN | ||||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
| Gold | Heraeus Germany 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 Ekaterinburg | RUSSIAN FEDERATION | ||||||
| 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 | ||||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| 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 | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
Appendix A
6
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| 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 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
| 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 | JSC 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 PMR B.V. | NETHERLANDS | ||||||
| Gold | Royal Canadian Mint | CANADA | ||||||
| Gold | SAAMP | FRANCE | ||||||
| Gold | Safimet S.p.A | ITALY | ||||||
| Gold | SAFINA A.S. | CZECHIA | ||||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | ||||||
| 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 | ||||||
| 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 | Shandong Gold Smelting Co., Ltd. | CHINA | ||||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
Appendix A
7
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||||
| 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 | WEEEREFINING | FRANCE | ||||||
| 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 | AU Traders and Refiners | SOUTH AFRICA | ||||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||||||
| Gold | Lingbao Gold Co., Ltd. | CHINA | ||||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Gold | Morris and Watson | NEW ZEALAND | ||||||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | ||||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||||||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||||||
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | ||||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||||
| Gold | Umicore Brasil Ltda. | BRAZIL | ||||||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||||||
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | ||||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||||
| Gold | Gold Coast Refinery | GHANA | ||||||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||||
Appendix A
8
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | ||||||
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | Shirpur Gold Refinery Ltd. | INDIA | ||||||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||||||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | ||||||
| Gold | Sovereign Metals | INDIA | ||||||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||||||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||||||
| Gold | Caridad | MEXICO | ||||||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||||||
| Gold | JALAN & Company | INDIA | ||||||
| Gold | Sai Refinery | INDIA | ||||||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||||||
| Gold | Kundan Care Products Ltd. | INDIA | ||||||
| Gold | K.A. Rasmussen | NORWAY | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | ||||||
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | ||||||
| Gold | Sellem Industries Ltd. | MAURITANIA | ||||||
| Gold | MD Overseas | INDIA | ||||||
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||||
| Gold | Industrial Refining Company | BELGIUM | ||||||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||||
| Gold | Sudan Gold Refinery | SUDAN | ||||||
| Gold | African Gold Refinery | UGANDA | ||||||
* Country names according to ISO 3166-1
Appendix A
9
List 2: Smelters and Refiners reported to have been included in Adient’s supply chain but identified as having ceased operation prior to December 31, 2021:
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* | ||||||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | ||||||
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | ||||||
| Tin | CV Ayi Jaya | INDONESIA | ||||||
| Tin | CV Dua Sekawan | INDONESIA | ||||||
| Tin | CV Gita Pesona | INDONESIA | ||||||
| Tin | CV United Smelting | INDONESIA | ||||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
| Tin | PT Bangka Prima Tin | INDONESIA | ||||||
| Tin | PT Bangka Tin Industry | 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 Rajehan Ariq | INDONESIA | ||||||
| Tin | PT Sumber Jaya Indah | INDONESIA | ||||||
| Tin | PT Tommy Utama | INDONESIA | ||||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||||||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||||||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | ||||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Umicore Brasil Ltda. | BRAZIL | ||||||
Appendix A
10
Potential Countries of Origin of Conflict Minerals:
| Argentina | Guinea | Sierra Leone | ||||||
| Australia | Guyana | South Africa | ||||||
| Austria | India | South Korea | ||||||
| Belgium | Indonesia | Spain | ||||||
| Benin | Japan | Swaziland | ||||||
| Bolivia | Laos | Sweden | ||||||
| Bolivia (Plurinational State of) | Madagascar | Taiwan, Province of China | ||||||
| Brazil | Malaysia | Tanzania* | ||||||
| Burundi* | Mexico | Thailand | ||||||
| Canada | Mongolia | Uganda | ||||||
| China | Mozambique | United Kingdom of Great Britain and Northern Ireland | ||||||
| Colombia | Myanmar | United States of America | ||||||
| Congo, Democratic Republic of the * | Namibia | Uzbekistan | ||||||
| Cuba*** | Niger | Venezuela (Bolivarian Republic of)*** | ||||||
| Ecuador | Nigeria | Vietnam | ||||||
| Eritrea | Peru | Zambia* | ||||||
| Ethiopia | Philippines | Zimbabwe | ||||||
| France | Portugal | |||||||
| Germany | Russian Federation** | |||||||
| Ghana | Rwanda | |||||||
| * | DRC and adjoining countries | ||||
| ** | 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. Publicly available sources indicate that JSC Ekaterinburg was previously owned by a sanctioned Russian party. Adient previously prohibited its suppliers from sourcing materials from JSC Ekaterinburg, and none of the completed and accepted conflict minerals surveys returned by our suppliers indicated that they did so during this reporting period. The potential risk of sanctioned party sourcing is further diminished by newly available information indicating that JSC Ekaterinburg’s new owners are not subject to U.S. economic sanctions programs. 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 before its recent ownership change, these materials would have been substantially transformed before being sold to Adient or otherwise incorporated into finished products. | ||||
| *** | As explained above, Adient does not knowingly source directly or indirectly from sanctioned countries or parties. Nonetheless, we include Cuba 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 Venezuela within the “L1” risk-rating category, which includes over 120 jurisdictions including the United States. Adient further notes that Cuba is considered a low risk country under the applicable European Commission Conflict Minerals regulations. These facts further diminish the potential conflict minerals risks associated with the RMI smelter data used to prepare this summary. | ||||
Appendix A
11