EX-1.01 2 lyft-conflictmineralsreport.htm EX-1.01 Document

INTRODUCTION & SUMMARY

COMPANY OVERVIEW

This report has been prepared by the management of Lyft, Inc. (herein referred to as the “Lyft”, “Company”, “we”, “us”, or “our”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated.

Lyft is a ridesharing marketplace that connects drivers with riders via the Lyft mobile application in cities across the United States and in select cities in Canada. To complement its software offering, Lyft designs and contracts to manufacture equipment in Lyft’s micro-mobility network including bicycles, e-bicycles, scooters, bike stations, and vehicle accessories (Lyft Glow in-car emblem and Halo vehicle rooftop digital screens).

FORWARD LOOKING STATEMENTS

This Conflict Minerals Report contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lyft’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to conflict minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and Lyft assumes no obligation to update such statements.

INTRODUCTION

For the 2021 calendar year, Lyft determined that tin, tungsten, tantalum and/or gold (“3TGs”) were necessary to the functionality or production of products that were manufactured or contracted to be manufactured by Lyft. Therefore, Lyft conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs in Covered Products (as defined below) originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, Lyft believes that its Covered Products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), performed due diligence on the source and chain of custody of the 3TGs in question to determine whether its Covered Products are “DRC Conflict Free.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework in The Organization for Economic Co-Operation and Development



(“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).

Lyft is committed to upholding responsible sourcing practices. As such, the Company has implemented a Supplier Code of Conduct (the “Supplier Code”) to formalize its efforts to uphold human rights and responsible practices across the supply chain. Lyft’s Supplier Code encompasses regulatory, compliance, and ethical requirements and covers human rights and labor, health and safety, environmental, ethics (which covers responsible sourcing of minerals), and intellectual property categories and also provides for an audit, investigations and reporting mechanism.

CONFLICT MINERALS PROGRAM

Lyft’s requirement for responsible sourcing of minerals is incorporated into our Supplier Code, and is available online at https://www.lyft.com/suppliers/code-of-conduct. Lyft has adopted additional practices and procedures to implement the standard set forth in our Supplier Code, including pre-onboarding due diligence of higher-risk suppliers.

To determine Lyft’s products that may contain 3TGs, we screened our Enterprise Resource Planning (“ERP”) database for metal parts and printed circuit board assemblies (“PCBAs”). As required under the Rule, these are the products that Lyft manufactured or contracted others to manufacture and that are covered in this Report (collectively, the “Covered Products”).

REASONABLE COUNTRY OF ORIGIN INQUIRY

To determine whether necessary 3TGs in Covered Products originated in Covered Countries, Lyft contracted Assent, a third-party service provider, to assist us in reviewing the supply chain and identifying risks. We provided a list of suppliers and parts associated with the Covered Products to Assent for upload to the Assent Compliance Manager (“ACM”).

To collect data on the materials’ sources of origin procured by the supply chain, Lyft utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.10 to conduct a survey of all suppliers that provide Covered Products to Lyft since only those parts could contain 3TGs (“in-scope suppliers”).

During the supplier survey, we contacted suppliers via the ACM, a platform provided by Assent that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

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Via the ACM and Assent team, we requested that all in-scope suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency.

Our program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the suppliers who sell parts directly to Lyft (“Tier 1 suppliers”). The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted forms are accepted and classified as valid or invalid so that data is retained. Invalid CMRTs include non-responsive, incomplete or contradicting answers. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Lyft tracks program gaps to account for future improvement opportunities. As of May 20, 2022, there were 0 invalid supplier submissions that could not be corrected.

As of May 20, 2022, there were 34 in-scope suppliers and 13 provided a completed CMRT. Lyft’s total response rate for this reporting year was 38%. These metrics are summarized in the table below:

YearIn Scope Suppliers% of In-Scope Suppliers that Responded with Valid Submissions% of In-Scope Suppliers that Provided Invalid Submissions
20213438%0%

DESIGN OF DUE DILIGENCE

Lyft designed its due diligence measures to conform, in all material respects, with the framework
in the OECD Guidance. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to assess opportunities for improvement.

Due diligence requires our necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be controlled by Lyft. However, Lyft’s due diligence process, including the outreach and process validation conducted by Assent, conforms with the OECD’s guidance as it relates to Lyft’s position as a downstream purchaser.

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DUE DILIGENCE PERFORMED

1)ESTABLISH STRONG COMPANY MANAGEMENT SYSTEMS

Internal Compliance Team

Lyft established a cross-functional Conflict Minerals Compliance Team led by our Legal Team.
The Conflict Minerals Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.

Lyft also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company undertakes with suppliers in regards to conflict minerals.

We leverage Assent’s Managed Services in order to work with dedicated program specialists
who support Lyft’s conflict minerals program. We communicate regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team
is trained in conflict minerals compliance and the relevant OECD requirements, and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.

Control Systems

Lyft expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Lyft are DRC Conflict Free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. The Company relies on direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.

Lyft’s Supplier Code applies to all direct suppliers and outlines certain expected behaviors and practices. The Supplier Code is based on industry and internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. Lyft’s Supplier Code is available on our website to all suppliers. We have the right to terminate relationships with the suppliers who do not meet Lyft’s requirements. The Supplier Code is reviewed regularly to ensure it continues to align with industry best practices.

Supplier Engagement

Lyft has a strong relationship with Tier 1 suppliers. We have leveraged processes and educational opportunities to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. Lyft’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.

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With respect to the OECD requirement to strengthen engagement with suppliers, we
have developed an internal procedure that includes steps of supplier engagement escalation including establishing a designated conflict mineral compliance communications channel, conflict mineral reporting questionnaire follow-up and in person meetings, as appropriate.

In addition, in our supplier contracts and in purchase orders, we require suppliers to comply with our Supplier Code, which includes an obligation to supply DRC Conflict-Free minerals. Acceptance of these terms is a condition of doing business with Lyft.

Lyft places a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to Assent’s library of conflict minerals training and support resources.

We believe that the combination of the Supplier Code and engagement with suppliers for conflict minerals training and requests constitute a strong supplier engagement program.

Grievance Mechanisms

Lyft has established a mechanism whereby employees and suppliers can report violations of our policies, including with respect to conflict minerals. Suppliers and others outside of Lyft may contact Lyft’s Compliance team to report grievances or other issues by making a submission through Lyft’s Compliance & Ethics Hotline (the “Hotline”). A link to the Hotline is included in Lyft’s Supplier Code. The Hotline also includes toll-free telephone contact numbers and operators who speak the languages of the jurisdictions in which we operate.

Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (“RMI”) directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.

Maintain Records

Lyft has adopted a policy to retain relevant conflict minerals documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. We store all of the information and findings from this process in a database that can be audited by internal or external parties.

2)IDENTIFY & ASSESS RISK IN THE SUPPLY CHAIN

Risks associated with supplier CMRT content are identified automatically in the ACM based on Assent’s acceptance criteria for a valid supplier response. These risks are addressed by Assent staff and members of Lyft’s internal Conflict Minerals Compliance Team, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

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Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at the company level. In those cases where a company-level CMRT (such as when a company declares there are 3TGs in some of its products) is submitted, we are unable to determine if all of the specified smelters and refiners were used for 3TGs in the products supplied to us.

Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2021 calendar year.

Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance such as the Responsible Minerals Assurance Process (“RMAP”). Lyft does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters that have completed an RMAP audit are considered to be DRC Conflict Free.

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to redflag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
Geographic proximity to the Covered Countries;
Known mineral source country of origin;
RMAP audit status;
Credible evidence of unethical or conflict sourcing; and
Peer assessments conducted by credible third-party sources.

Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent’s automated email receipts, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Lyft. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

3) DESIGN & IMPLEMENT A STRATEGY TO RESPOND TO RISKS
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Together with Assent, Lyft has developed processes to assess and respond to the conflict minerals risk identified in the supply chain. Escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance with the conflict minerals rules and the Company’s expectations. Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs.

In cases where suppliers have been non-responsive or are not committed to corrective action plans, Lyft will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Compliance Team and Lyft’s Leadership Team to ensure transparency within the Company.

4)CARRY OUT INDEPENDENT THIRD-PARTY AUDIT OF SUPPLY CHAIN DUE DILIGENCE AT IDENTIFIED POINTS IN THE SUPPLY CHAIN

Lyft does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

5)REPORT ANNUALLY ON SUPPLY CHAIN DUE DILIGENCE

Lyft has published the Form SD for the year ended December 31, 2021. This report is available on the Company’s website at https://investor.lyft.com/financials-and-reports/esg/default.aspx. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. Lyft has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission. This year we have also considered the impacts from the European Union Conflict Minerals Rule when disclosing details with regard to due diligence efforts. We will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public report.

Due Diligence Results

Supply chain outreach is required to identify the upstream sources of origin of 3TGs. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Lyft for the 2021 reporting year.




Supply Chain Outreach Metrics
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Number of In-Scope SuppliersResponse rateValid response Rate
3438%38%

Upstream Data Transparency

All smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which of Lyft’s product lines the materials may end up in. As a result, those providing the smelters and refiners may list all smelters and refiners they may purchase from within the reporting period. Therefore, the smelters or refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters or refiners which actually processed the 3TGs contained in our products.

Although the potential for over-reporting is understood, Lyft has taken measures to validate these sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners. From the gathered responses, 6 smelters out of 214 surveyed potentially posed a risk due to the presence of some red flag. 207 smelters were RMAP-conformant, 6 non-conformant, and 1 not enrolled into RMAP.

Countries of Origin

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by Lyft, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.

Risk Mitigation Plan

As of the date of this filing, Lyft has taken, or intends to take, the following steps to improve the due diligence conducted to further mitigate risk that the necessary 3TGs in the Company’s products could benefit armed groups in the Covered Countries:
Through Assent, continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to using a comprehensive smelter and refiner library with detailed status and notes for each listing; scanning for credible information on each smelter and refiner to flag risk issues; and comparing the list of smelters and refiners against government watch and denied parties lists.
Engage with suppliers more closely, and provide more information and training resources regarding responsible sourcing of 3TGs.
Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.
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Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis.





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APPENDIX A: SMELTER LIST
Includes: Mineral, smelter/refinery name, location


MetalSmelter NameSmelter Facility LocationSmelter ID
Gold8853 S.p.A.ItalyCID002763
GoldAdvanced Chemical CompanyU.S.A.CID000015
GoldAida Chemical Industries Co., Ltd.JapanCID000019
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesCID002560
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GermanyCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilCID000058
GoldArgor-Heraeus S.A.SwitzerlandCID000077
GoldAsahi Pretec Corp.JapanCID000082
GoldAsahi Refining Canada Ltd.CanadaCID000924
GoldAsahi Refining USA Inc.U.S.A.CID000920
GoldAsaka Riken Co., Ltd.JapanCID000090
GoldAurubis AGGermanyCID000113
GoldBangalore RefineryIndiaCID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesCID000128
GoldBoliden ABSwedenCID000157
GoldC. Hafner GmbH + Co. KGGermanyCID000176
GoldCCR Refinery - Glencore Canada CorporationCanadaCID000185
GoldCendres + Metaux S.A.SwitzerlandCID000189
GoldChimet S.p.A.ItalyCID000233
GoldChugai MiningJapanCID000264
GoldDowaJapanCID000401
GoldDSC (Do Sung Corporation)Korea, Republic OfCID000359
GoldEco-System Recycling Co., Ltd. East PlantJapanCID000425
GoldEmirates Gold DMCCUnited Arab EmiratesCID002561
GoldGeib Refining CorporationU.S.A.CID002459
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaCID002243
GoldHeimerle + Meule GmbHGermanyCID000694
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707
GoldHeraeus Precious Metals GmbH & Co. KGGermanyCID000711
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaCID000801
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807
GoldIstanbul Gold RefineryTurkeyCID000814
GoldItalpreziosiItalyCID002765
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GoldJapan MintJapanCID000823
GoldJiangxi Copper Co., Ltd.ChinaCID000855
GoldJSC UralelectromedRussian FederationCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937
GoldKazzincKazakhstanCID000957
GoldKennecott Utah Copper LLCU.S.A.CID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPolandCID002511
GoldKojima Chemicals Co., Ltd.JapanCID000981
GoldKorea Zinc Co., Ltd.Korea, Republic OfCID002605
GoldL'Orfebre S.A.AndorraCID002762
GoldLS-NIKKO Copper Inc.Korea, Republic OfCID001078
GoldLT Metal Ltd.Korea, Republic OfCID000689
GoldMarsam MetalsBrazilCID002606
GoldMaterionU.S.A.CID001113
GoldMatsuda Sangyo Co., Ltd.JapanCID001119
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147
GoldMetalor Technologies S.A.SwitzerlandCID001153
GoldMetalor USA Refining CorporationU.S.A.CID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoCID001161
GoldMitsubishi Materials CorporationJapanCID001188
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193
GoldMMTC-PAMP India Pvt., Ltd.IndiaCID002509
GoldMoscow Special Alloys Processing PlantRussian FederationCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyCID001220
GoldNavoi Mining and Metallurgical CombinatUzbekistanCID001236
GoldNihon Material Co., Ltd.JapanCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaCID002779
GoldOhura Precious Metal Industry Co., Ltd.JapanCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationCID001326
GoldOJSC Novosibirsk RefineryRussian FederationCID000493
GoldPAMP S.A.SwitzerlandCID001352
GoldPlanta Recuperadora de Metales SpAChileCID002919
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationCID001386
GoldPT Aneka Tambang (Persero) TbkIndonesiaCID001397
GoldPX Precinox S.A.SwitzerlandCID001498
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GoldRand Refinery (Pty) Ltd.South AfricaCID001512
GoldREMONDIS PMR B.V.NetherlandsCID002582
GoldRoyal Canadian MintCanadaCID001534
GoldSAAMPFranceCID002761
GoldSafimet S.p.AItalyCID002973
GoldSAFINA A.S.CzechiaCID002290
GoldSamduck Precious MetalsKorea, Republic OfCID001555
GoldSEMPSA Joyeria Plateria S.A.SpainCID001585
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaCID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaCID001761
GoldSumitomo Metal Mining Co., Ltd.JapanCID001798
GoldSungEel HiMetal Co., Ltd.Korea, Republic OfCID002918
GoldT.C.A S.p.AItalyCID002580
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875
GoldThe Refinery of Shandong Gold Mining Co., Ltd.ChinaCID001916
GoldTokuriki Honten Co., Ltd.JapanCID001938
GoldTOO Tau-Ken-AltynKazakhstanCID002615
GoldTorecomKorea, Republic OfCID001955
GoldUmicore Precious Metals ThailandThailandCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumCID001980
GoldUnited Precious Metal Refining, Inc.U.S.A.CID001993
GoldValcambi S.A.SwitzerlandCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030
GoldWIELAND Edelmetalle GmbHGermanyCID002778
GoldYamakin Co., Ltd.JapanCID002100
GoldYokohama Metal Co., Ltd.JapanCID002129
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaCID000211
TantalumD Block Metals, LLCU.S.A.CID002504
TantalumF&X Electro-Materials Ltd.ChinaCID000460
TantalumFIR Metals & Resource Ltd.ChinaCID002505
TantalumGlobal Advanced Metals AizuJapanCID002558
TantalumGlobal Advanced Metals BoyertownU.S.A.CID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.ChinaCID000616
TantalumH.C. Starck Co., Ltd.ThailandCID002544
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TantalumH.C. Starck Hermsdorf GmbHGermanyCID002547
TantalumH.C. Starck Inc.U.S.A.CID002548
TantalumH.C. Starck Ltd.JapanCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGermanyCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGermanyCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaCID002512
TantalumJiangxi Tuohong New Raw MaterialChinaCID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506
TantalumKEMET Blue MetalsMexicoCID002539
TantalumLSM Brasil S.A.BrazilCID001076
TantalumMetallurgical Products India Pvt., Ltd.IndiaCID001163
TantalumMineracao Taboca S.A.BrazilCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277
TantalumNPM Silmet ASEstoniaCID001200
TantalumQuantumCleanU.S.A.CID001508
TantalumResind Industria e Comercio Ltda.BrazilCID002707
TantalumSolikamsk Magnesium Works OAORussian FederationCID001769
TantalumTaki Chemical Co., Ltd.JapanCID001869
TantalumTelex MetalsU.S.A.CID001891
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaCID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522
TinAlphaU.S.A.CID000292
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190
TinChina Tin Group Co., Ltd.ChinaCID001070
TinDowaJapanCID000402
TinEM VintoBolivia (Plurinational State Of)CID000438
TinFenix MetalsPolandCID000468
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaCID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231
TinMa'anshan Weitai Tin Co., Ltd.ChinaCID003379
TinMagnu's Minerais Metais e Ligas Ltda.BrazilCID002468
TinMalaysia Smelting Corporation (MSC)MalaysiaCID001105
TinMelt Metais e Ligas S.A.BrazilCID002500
TinMetallic Resources, Inc.U.S.A.CID001142
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TinMetallo Belgium N.V.BelgiumCID002773
TinMetallo Spain S.L.U.SpainCID002774
TinMineracao Taboca S.A.BrazilCID001173
TinMinsurPeruCID001182
TinMitsubishi Materials CorporationJapanCID001191
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandCID001314
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337
TinPT Artha Cipta LanggengIndonesiaCID001399
TinPT ATD Makmur Mandiri JayaIndonesiaCID002503
TinPT Menara Cipta MuliaIndonesiaCID002835
TinPT Mitra Stania PrimaIndonesiaCID001453
TinPT Prima Timah UtamaIndonesiaCID001458
TinPT Refined Bangka TinIndonesiaCID001460
TinPT Stanindo Inti PerkasaIndonesiaCID001468
TinPT Timah Tbk KundurIndonesiaCID001477
TinPT Timah Tbk MentokIndonesiaCID001482
TinPT Tinindo Inter NusaIndonesiaCID001490
TinResind Industria e Comercio Ltda.BrazilCID002706
TinRui Da HungTaiwan, Province Of ChinaCID001539
TinSoft Metais Ltda.BrazilCID001758
TinThaisarcoThailandCID001898
TinTin Technology & RefiningU.S.A.CID003325
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158
TinYunnan Tin Company LimitedChinaCID002180
TungstenA.L.M.T. Corp.JapanCID000004
TungstenACL Metais EireliBrazilCID002833
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.ChinaCID002513
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaCID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaCID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaCID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494
TungstenGlobal Tungsten & Powders Corp.U.S.A.CID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaCID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGermanyCID002542
TungstenH.C. Starck Tungsten GmbHGermanyCID002541
TungstenHunan Chenzhou Mining Co., Ltd.ChinaCID000766
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.ChinaCID000769
5


TungstenHydrometallurg, JSCRussian FederationCID002649
TungstenJapan New Metals Co., Ltd.JapanCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaCID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaCID002321
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaCID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaCID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316
TungstenKennametal FallonU.S.A.CID000966
TungstenKennametal HuntsvilleU.S.A.CID000105
TungstenKGETS Co., Ltd.Korea, Republic OfCID003388
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of ChinaCID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaCID002319
TungstenMasan Tungsten Chemical LLC (MTC)Viet NamCID002543
TungstenMoliren Ltd.Russian FederationCID002845
TungstenNiagara Refining LLCU.S.A.CID002589
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesCID002827
TungstenUnecha Refractory metals plantRussian FederationCID002724
TungstenWolfram Bergbau und Hutten AGAustriaCID002044
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.ChinaCID002830


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7


APPENDIX B: COUNTRIES OF ORIGIN
Includes: List of countries that declared smelters are known to source from.

Country List
Afghanistan
Åland Islands
Albania
American Samoa
Andorra
Angola
Argentina
Armenia
Australia
Austria
Belarus
Belgium
Bermuda
Bolivia (Plurinational State of)
Brazil
Bulgaria
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Congo
Democratic Republic of Congo
Djibouti
Dominica
Dominican Republic
Ecuador
Egypt
Eritrea
Estonia
Ethiopia
Finland
France
Germany
Ghana
Guinea
Guyana
Hong Kong
Hungary
1


India
Indonesia
Ireland
Israel
Italy
Japan
Kazakhstan
Kenya
Korea
Kyrgyzstan
Liberia
Luxembourg
Madagascar
Malaysia
Mali
Mauritania
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
New Zealand
Niger
Nigeria
Panama
Papua New Guinea
Peru
Philippines
Poland
Portugal
Russian Federation
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
Slovenia
South Africa
South Sudan
Spain
Sudan
Suriname
Sweden
2


Switzerland
Taiwan
Tajikistan
Tanzania
Thailand
Turkey
Uganda
United Arab Emirates
United Kingdom
United States
Uzbekistan
Viet Nam
Zambia
Zimbabwe





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