EX-1.01 2 cmr2018exhibit101.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01
        

Johnson & Johnson
Conflict Minerals Report
For the Calendar Year Ended December 31, 2018

Introduction

Johnson & Johnson is the parent company of various consolidated subsidiaries (together, the “Company”) engaged in the manufacture and sale of a broad range of products in the health care field across three business segments: Consumer, Pharmaceutical and Medical Devices.

Pursuant to the requirements of Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the “Rule”), this Conflict Minerals Report describes, for the period from January 1, 2018 to December 31, 2018, the measures the Company has taken to conduct due diligence on the source and chain of custody of the conflict minerals contained in, and necessary to the functionality or production of, the products in its supply chain. Under the Rule, “conflict minerals” are defined as columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten, and gold (or “3TG”).

Products and Supply Chain    

All product lines manufactured or contracted to be manufactured by the Company throughout its three business segments were assessed to determine whether they potentially contain 3TG. Through the screening process, product teams determined, to the best of their knowledge, that the following product lines (the “in-scope products”) contain 3TG or have a high likelihood of containing 3TG: (i) in the Company’s Pharmaceutical and Consumer segments, a small number of products that contain electronic components, including pharmaceutical diagnostics products and consumer plug-in and/or battery-operated devices; and (ii) in the Medical Devices segment, many categories of medical devices due to the presence of metal alloys and electronic components, including, but not limited to:

orthopaedic, trauma and spine products;
surgery and energy products;
products to treat cardiovascular disease, including electrophysiology products;
vision surgical products; and
sterilization and disinfection products to reduce surgical infection.

The broad and complex range of in-scope products may contain necessary conflict minerals within the following components:
    
Tantalum, used in capacitors and certain alloys;
Tin, used in soldered components;
Tungsten, used in coatings and certain alloys; and
Gold, used in circuit boards and electronic components.

The Company’s supply chains are complex and fragmented. As a “downstream” company, the Company is many tiers removed in the minerals supply chain from smelters or refiners (“SORs”) that process the metals found in its final products, and there are many intervening third parties between the original sources of conflict minerals and the Company. The Company, therefore, must rely on its immediate suppliers, with which it has business relationships, to provide information regarding the sourcing of 3TG in the in-scope products. The Company’s immediate suppliers, in turn, typically are also downstream in the minerals supply chain and have similar challenges in achieving supply chain transparency.

1




In addition, because the Company manufactures and sells highly-regulated health care products, its existing suppliers have gone through lengthy, rigorous, and multi-level regulatory and quality assessments and approvals. Therefore, it can be very difficult to switch to another supplier if an existing supplier is not responsive to the Company’s conflict minerals program.

Reasonable Country of Origin Inquiry

The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG in materials, components and finished goods supplied to the Company, including the following steps:

With the assistance of a third-party vendor (the “Vendor”) with expertise in supply chain due diligence, the Company engaged its 347 immediate, potential in-scope 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. These suppliers were asked to complete and submit the Conflict Minerals Reporting Template v.5.11 (“CMRT”). The CMRT is a standardized reporting survey form developed by the Conflict-Free Sourcing Initiative, now the Responsible Minerals Initiative (“RMI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the SORs in the 3TG supply chain.

The Vendor followed up with all unresponsive suppliers via both automated emails and one-on-one emails, including offering assistance and further information about the requirements of the Rule and the Company’s expectations. If after these outreach efforts, a supplier still did not respond to the survey, the relevant Company supplier relationship manager (“SRM”) was asked to directly contact the supplier to request a response.

The Vendor identified and followed up on incomplete or contradictory answers in each CMRT form submitted.

Suppliers that responded that the materials or goods they supplied to the Company did not contain 3TG were removed from the scope of the survey only after verification of this information from Company SRMs with support from a cross-functional team.

The Company’s conflict minerals team focused additional engagement efforts on potential 3TG suppliers deemed higher-priority based on spend volume.

The Company received responses from approximately 71% of all final in-scope suppliers, not including suppliers who responded but did not report for the full 2018 calendar year, provided an invalid version, or an incomplete response.

The Vendor verified whether the metals processors identified by suppliers in their survey responses are actual SORs or recyclers of 3TG by comparing the alleged SOR names to RMI’s Standard Smelter List, resulting in a list of 316 SORs verified to exist.

The Vendor researched and reviewed mine information for the verified SORs to determine, to the best of its knowledge, the country of origin of the minerals processed by those SORs. This information was also compared to the country of origin data available to the Company as a member of RMI.

On the basis of its RCOI, the Company has reason to believe that at least some of the 3TG contained in the in-scope products originated in the Democratic Republic of Congo (DRC) or an adjoining country (together, the “covered countries”), and not from recycled or scrap sources. Accordingly, the Company conducted due diligence on the source and chain of custody of these conflict minerals.

2




Due Diligence

The Company’s due diligence measures, described below, were designed to conform, in all material respects, with the internationally recognized due diligence framework set forth 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, including the Supplements on 3T and gold. These measures took into account the OECD’s recommendations for companies in the downstream segments of the supply chain, which typically are several tiers removed from, and have no direct relationships with, SORs.
    
1.    Company Management Systems

The Company has implemented a conflict minerals compliance program (the “Program”) with the following components:

Policy Statement
    
In January 2018, the Company updated its Statement on Conflict Minerals, which can be found on the Johnson & Johnson website at: https://www.jnj.com/about-jnj/company-statements/statement-on-conflict-minerals, and which sets forth the expectation that the Company’s suppliers source materials from suppliers that also source responsibly, including from conformant mines in the covered countries.

Internal Team

For several years, the Company has had an established, centralized, cross-functional conflict minerals governance team (the “Core Team”) to oversee the implementation of the Program. The Core Team includes representation from the following functions: Procurement; Legal; Environment, Health, Safety & Sustainability (EHS&S); Product Stewardship and Corporate Internal Audit. The Core Team reports to senior management on Program developments and progress.

Members of the Core Team participate in industry groups, forums, and conferences focused on compliance with the Rule and responsible sourcing of conflict minerals.

Control Systems and Supply Chain Transparency

The Company has engaged the Vendor to facilitate supplier engagement and assist the Company in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Program.

To further strengthen the Program and supply chain due diligence, the Company continues to be a member of RMI, a cross-industry organization that provides resources, tools and information to help companies source conformant minerals, including a list of confirmed SORs and RMI’s Responsible Minerals Assurance Process (the “RMAP”), which validates SORs as conformant based on independent third-party audits.

Based on learnings from the prior years’ conflict minerals campaigns, members of the Core Team monitored and provided input to the Vendor’s activities and analyses related to the 2018 CMRT survey process.

The Core Team and the Vendor maintain electronic records of product and supply chain information collected through their due diligence activities carried out under the Program. Documentation related to the annual supplier surveys is retained for at least five years.




3



Supplier Engagement

In support of its Statement on Conflict Minerals, the Company has incorporated conflict mineral provisions into the standard terms of its Supply Chain master supply agreement template. Because most supply contracts have multi-year terms, it will take multiple years to integrate these provisions into supplier contracts as new supplier relationships are formed and existing suppliers renew their contracts.

The Company has also revised and communicated its Responsibility Standards for Suppliers (https://www.jnj.com/partners/responsibility-standards-for-suppliers), which requires all suppliers to be compliant with the requirements in the Johnson & Johnson Statement on Conflict Minerals.

To promote more timely and accurate responses from suppliers, members of the Core Team created an internal training program that requires all internal SRMs who have direct relationships with the Company’s immediate, potential 3TG suppliers to participate in a training module to educate them on conflict minerals, the conflict minerals reporting requirements, and the Program.

To ensure suppliers understand its expectations, the Company has, through the Vendor, provided video and written training on conflict minerals and the CMRT. This training includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel, as needed.

Grievance Mechanism

The Company has a dedicated conflict minerals electronic mailbox used for communications with suppliers. In addition, the Company has a hotline (www.CredoHotline.com) that provides a mechanism for anyone to anonymously report conduct they know or believe is in violation of Company guidelines or policies, including any concerns related to the conflict minerals supply chain.

2.    Risk Identification and Assessment

Although the Company requested information at a product level, a substantial majority of all supplier survey responses consisted of information at a company level-i.e., the supplier provided information about SORs in its supply chain generally, not just for the products or components supplied to the Company. Information in those surveys, therefore, may not be relevant to any of the Company’s products and may identify SORs that are not actually in the Company’s supply chain. The percentage of product-level supplier survey responses was similar to the previous year. Although the information provided in these product-level responses may be incomplete and has not been confirmed, the Company believes that there is a greater likelihood that the SORs listed in these responses are in the Company’s supply chain, compared to the SORs listed in company-level survey responses.

The Vendor attempted to match each verified SOR from the supplier survey responses to lists of conformant SORs (i.e., SORs validated or certified as conformant under internationally-recognized programs such as the RMAP, the London Bullion Market Association Good Delivery program (LBMA) and the Responsible Jewelery Council Chain-of-Custody Certification program (RJC)). SORs classified as actively pursuing conformance under the RMAP also were identified. For the 2018 reporting year, 24 SORs listed in suppliers’ survey responses were confirmed to source from covered countries, and all 24 of these SORS were validated as conformant.

To further assess the potential risk that 3TG in its supply chain could be associated with armed conflict, the Company focused on the verified SORs that are not conformant or actively seeking conformant status, and (a) are confirmed to source from countries with a high risk of supporting armed conflict, including the covered countries, or (b) whose country of origin sourcing is unknown. Such SORs are considered to be higher risk.

The Vendor also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities sourcing practices on behalf of its compliance partners. The Company was a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.

4




3.     Risk Response Strategy

Through its membership in RMI, the Company encourages and supports independent third-party audits of SORs’ supply chain due diligence practices. For any SOR that has not been validated through such an audit and which the Company determines to be of particular high risk-for example, because of reliable evidence of sourcing from covered countries-the Company (a) seeks to confirm from its relevant immediate suppliers whether 3TG processed by the SOR is in fact in its supply chain, and (b) places additional emphasis on advocating for the SOR to participate in a conformance assessment program such as the RMAP.

If the sourcing due diligence practices of a non-validated, high-risk SOR confirmed to be in the Company’s supply chain do not improve, the Company will work to develop corrective action, which may include encouraging its immediate suppliers to transition sourcing away from that SOR.

4.     Audit of Due Diligence Practices of SORs

The Company supports internationally-recognized assessment programs, such as the RMAP, that facilitate and confirm independent third-party audits of SORs’ supply chain due diligence practices.

5.     Annual Reporting on Supply Chain Due Diligence

The Company reports annually on its supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC.

Determinations

Based on the above-described due diligence efforts, the Company does not have conclusive information regarding the country of origin of, or facilities used to process, the necessary conflict minerals in its products for the 2018 reporting period.

Set forth in Annex A is a list of (a) SORs reported in product-level supplier survey responses which, although not confirmed, are believed to have a greater likelihood of being in the Company’s supply chain, and (b) SORs reported in company-level supplier survey responses for which there is reliable data regarding country of origin sourcing or conformant (or actively seeking conformant) status, based on RMI data as of April 12, 2019. The Company is unable to determine whether any of the facilities listed in Annex A in fact processed conflict minerals in its products.

Based on RMI’s country of origin data as of March 29, 2019, which is organized by risk-based categories, Annex B provides an aggregated list of the countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, in addition to recycled and scrap sources.

The Company’s efforts to determine the mine or location of origin of the necessary conflict minerals in its products with the greatest possible specificity consisted of the implementation of the Program and due diligence measures described above in this Conflict Minerals Report.

Risk Mitigation Steps

The Company believes that it will take time for the various supply chain and industry participants to institute programs and agreed processes to gather verifiable information on conflict minerals sourcing and chain of custody. Accordingly, the Company’s due diligence is an iterative process and progress is expected to be incremental over time. To work toward this progress:
    
Seek to Improve Supplier Engagement. With the goal of increasing the response rate and quality of survey responses, including increasing the number of product-level survey responses, the Company

5



plans to continue to reach out to suppliers, support education and training for suppliers, and integrate expectations regarding the Program into new supplier contracts and those coming up for renewal.

Continue to Enhance and Refine Due Diligence Processes. Based on learnings from the 2018 supplier survey process, the Core Team plans to continue to work internally and with the Vendor to enhance its supplier survey and due diligence processes.

Support Efforts to Encourage SOR Participation in RMAP. The Company expects to continue to participate as a member of RMI to support programs, such as the RMAP, that facilitate and validate independent third-party audits of SORs’ supply chain due diligence practices.





6





ANNEX A

The following is a list of (a) SORs reported in product-level supplier surveys, and (b) SORs reported in company-level supplier surveys for which country of origin sourcing is known or which have conformed (or actively seeking conformance) status, based on RMI data as of April 12, 2019. SORs that have been validated by RMI to have conformant sourcing, are in the process of being validated or are certified by LBMA and/or RJC, are indicated by asterisk. The Company is unable to determine whether any of the facilities listed below in fact processed conflict minerals in its products.

Metal
SOR Name
Smelter Facility
Gold
8853 S.p.A.*
ITALY
Gold
Abington Reldan Metals, LLC
UNITED STATES
Gold
Advanced Chemical Company*
UNITED STATES
Gold
African Gold Refinery
UGANDA
Gold
Aida Chemical Industries Co., Ltd.*
JAPAN
Gold
Al Etihad Gold LLC*
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)*
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração*
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
Gold
Asaka Riken Co., Ltd.*
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.*
TURKEY
Gold
AU Traders and Refiners*
SOUTH AFRICA
Gold
Aurubis AG*
GERMANY
Gold
Bangalore Refinery*
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
PHILIPPINES
Gold
Boliden AB*
SWEDEN
Gold
C. Hafner GmbH + Co. KG*
GERMANY
Gold
Caridad
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation*
CANADA
Gold
Cendres + Métaux S.A.*
SWITZERLAND
Gold
Chimet S.p.A.*
ITALY
Gold
Chugai Mining*
JAPAN
Gold
Daejin Indus Co., Ltd.*
KOREA, REPUBLIC OF
Gold
Daye Non-Ferrous Metals Mining Ltd.*
CHINA
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
DODUCO Contacts and Refining GmbH*
GERMANY
Gold
Dowa*
JAPAN
Gold
DS PRETECH Co., Ltd.*
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)*
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.*
JAPAN
Gold
Emirates Gold DMCC*
UNITED ARAB EMIRATES

7



Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Geib Refining Corporation*
UNITED STATES
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.*
CHINA
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
HeeSung*
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH*
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.*
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG*
GERMANY
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
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 Non-Ferrous Metal Processing Plant*
RUSSIAN FEDERATION
Gold
JSC Uralelectromed*
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.*
JAPAN
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc*
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC*
UNITED STATES
Gold
KGHM Polska Miedz Spolka Akcyjna*
POLAND
Gold
Kojima Chemicals Co., Ltd.*
JAPAN
Gold
Korea Zinc Co., Ltd.*
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC*
KYRGYZSTAN
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry*
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
L'Orfebre S.A.*
ANDORRA
Gold
LS-NIKKO Copper Inc.*
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Marsam Metals*
BRAZIL
Gold
Materion*
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.*
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.*
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.*
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.*
CHINA

8



Gold
Metalor Technologies S.A.*
SWITZERLAND
Gold
Metalor USA Refining Corporation*
UNITED STATES
Gold
Metalúrgica Met-Mex Peñoles 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
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Morris and Watson Gold Coast
AUSTRALIA
Gold
Moscow Special Alloys Processing Plant*
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.*
TURKEY
Gold
Navoi Mining and Metallurgical Combinat*
UZBEKISTAN
Gold
NH Recytech Company*
KOREA, REPUBLIC OF
Gold
Nihon Material Co., Ltd.*
JAPAN
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.*
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery*
RUSSIAN FEDERATION
Gold
PAMP S.A.*
SWITZERLAND
Gold
Pease & Curren
UNITED STATES
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
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 Précinox S.A.*
SWITZERLAND
Gold
QG Refining, LLC
UNITED STATES
Gold
Rand Refinery (Pty) Ltd.*
SOUTH AFRICA
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
Remondis Argentia B.V.*
NETHERLANDS
Gold
Republic Metals Corporation*
UNITED STATES
Gold
Royal Canadian Mint*
CANADA
Gold
SAAMP*
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES
Gold
Safimet S.p.A*
ITALY
Gold
SAFINA A.S.
CZECH REPUBLIC
Gold
Sai Refinery
INDIA
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH*
GERMANY
Gold
SEMPSA Joyería Platería S.A.*
SPAIN
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
CHINA
Gold
Shangdong Humon Smelting Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
CHINA
Gold
Singway Technology Co., Ltd.*
TAIWAN

9



Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.*
TAIWAN
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
Sudan Gold Refinery
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.*
JAPAN
Gold
SungEel HiTech*
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A*
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.*
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.*
CHINA
Gold
Tokuriki Honten Co., Ltd.*
JAPAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
Tony Goetz NV
BELGIUM
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom*
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.*
BRAZIL
Gold
Umicore Precious Metals Thailand*
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining*
BELGIUM
Gold
United Precious Metal Refining, Inc.*
UNITED STATES
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
Valcambi S.A.*
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint*
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH*
GERMANY
Gold
Yamamoto Precious Metal Co., Ltd.*
JAPAN
Gold
Yokohama Metal Co., Ltd.*
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
CHINA
Tantalum
Asaka Riken Co., Ltd.*
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
CHINA
Tantalum
D Block Metals, LLC*
UNITED STATES
Tantalum
Exotech Inc.*
UNITED STATES
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
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.*
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
CHINA
Tantalum
H.C. Starck Co., Ltd.*
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH*
GERMANY
Tantalum
H.C. Starck Inc.*
UNITED STATES
Tantalum
H.C. Starck Ltd.*
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG*
GERMANY
Tantalum
H.C. Starck Tantalum and Niobium GmbH*
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
CHINA
Tantalum
Jiangxi Tuohong New Raw Material*
CHINA
Tantalum
Jiujiang Janny New Material Co., Ltd.*
CHINA

10



Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.*
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
CHINA
Tantalum
KEMET Blue Metals*
MEXICO
Tantalum
KEMET Blue Powder*
UNITED STATES
Tantalum
LSM Brasil S.A.*
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.*
INDIA
Tantalum
Mineracao Taboca S.A.*
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
CHINA
Tantalum
NPM Silmet AS*
ESTONIA
Tantalum
Power Resources Ltd.*
MACEDONIA
Tantalum
QuantumClean*
UNITED STATES
Tantalum
Resind Industria e Comercio Ltda.*
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.*
CHINA
Tantalum
Solikamsk Magnesium Works OAO*
RUSSIAN FEDERATION
Tantalum
Taki Chemicals*
JAPAN
Tantalum
Telex Metals*
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC*
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.*
CHINA
Tin
Alpha*
UNITED STATES
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.*
CHINA
Tin
China Tin Group Co., Ltd.*
CHINA
Tin
CV Ayi Jaya*
INDONESIA
Tin
CV Dua Sekawan*
INDONESIA
Tin
CV Gita Pesona*
INDONESIA
Tin
CV Tiga Sekawan*
INDONESIA
Tin
CV United Smelting*
INDONESIA
Tin
CV Venus Inti Perkasa*
INDONESIA
Tin
Dowa*
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
EM Vinto*
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Fenix Metals*
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant*
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC*
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.*
CHINA
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company*
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.*
CHINA

11



Tin
Jiangxi New Nanshan Technology Ltd.*
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.*
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)*
MALAYSIA
Tin
Melt Metais e Ligas S.A.*
BRAZIL
Tin
Metallic Resources, Inc.*
UNITED STATES
Tin
Metallo Belgium N.V.*
BELGIUM
Tin
Metallo Spain S.L.U.*
SPAIN
Tin
Mineracao Taboca S.A.*
BRAZIL
Tin
Minsur*
PERU
Tin
Mitsubishi Materials Corporation*
JAPAN
Tin
Modeltech Sdn Bhd*
MALAYSIA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.*
PHILIPPINES
Tin
Operaciones Metalurgical S.A.*
BOLIVIA
Tin
Pongpipat Company Limited
MYANMAR
Tin
PT Aries Kencana Sejahtera*
INDONESIA
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 Prima Tin*
INDONESIA
Tin
PT Bangka Serumpun*
INDONESIA
Tin
PT Bangka Tin Industry*
INDONESIA
Tin
PT Belitung Industri Sejahtera*
INDONESIA
Tin
PT Bukit Timah*
INDONESIA
Tin
PT DS Jaya Abadi*
INDONESIA
Tin
PT Inti Stania Prima*
INDONESIA
Tin
PT Karimun Mining*
INDONESIA
Tin
PT Kijang Jaya Mandiri*
INDONESIA
Tin
PT Lautan Harmonis Sejahtera*
INDONESIA
Tin
PT Menara Cipta Mulia*
INDONESIA
Tin
PT Mitra Stania Prima*
INDONESIA
Tin
PT Panca Mega Persada*
INDONESIA
Tin
PT Premium Tin Indonesia*
INDONESIA
Tin
PT Prima Timah Utama*
INDONESIA
Tin
PT Refined Bangka Tin*
INDONESIA
Tin
PT Sariwiguna Binasentosa*
INDONESIA
Tin
PT Stanindo Inti Perkasa*
INDONESIA
Tin
PT Sukses Inti Makmur*
INDONESIA
Tin
PT Sumber Jaya Indah*
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur*
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok*
INDONESIA
Tin
PT Tinindo Inter Nusa*
INDONESIA
Tin
PT Tirus Putra Mandiri*
INDONESIA
Tin
PT Tommy Utama*
INDONESIA

12



Tin
Resind Industria e Comercio Ltda.*
BRAZIL
Tin
Rui Da Hung*
TAIWAN
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
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
White Solder Metalurgia e Mineração Ltda.*
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
CHINA
Tin
Yunnan Tin Company Limited*
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.*
JAPAN
Tungsten
ACL Metais Eireli*
BRAZIL
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.*
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co.KG*
GERMANY
Tungsten
H.C. Starck Tungsten GmbH*
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.*
CHINA
Tungsten
Hydrometallurg, JSC*
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.*
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.*
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.*
CHINA
Tungsten
Kennametal Fallon*
UNITED STATES
Tungsten
Kennametal Huntsville*
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
CHINA
Tungsten
Moliren Ltd*
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC*
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
VIET NAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City*
CHINA

13



Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
VIET NAM
Tungsten
Unecha Refractory metals plant*
RUSSIAN FEDERATION
Tungsten
Wolfram Bergbau und Hütten AG*
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.*
KOREA, REPUBLIC OF
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.*
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
CHINA


















14




ANNEX B

Countries of Origin

Below is an aggregated list of countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, based on data available from RMI as of March 29, 2019.

Australia
Mauritania
Austria
Mongolia
Benin
Mozambique
Bolivia
Myanmar
Brazil
Nicaragua
Burundi
Niger
Chile
Nigeria
China
Peru
Colombia
Portugal
Democratic Republic of Congo
Russia Federation
Ecuador
Rwanda
Eritrea
Sierra Leone
Ethiopia
South Africa
Ghana
Swaziland
Guinea
Taiwan
Guyana
Tanzania
India
Thailand
Indonesia
Togo
Laos
Uganda
Madagascar
United Kingdom
Malaysia
United States of America
Mali
Venezuela
 
 








15