EX-1.01 2 cmreport.htm HASBRO, INC. CONFLICT MINERALS REPORT  

 

Exhibit 1.01 - Conflict Minerals Report (CMR)

 

Conflict Minerals Report of Hasbro, Inc.

 

 

Section 1: Introduction

 

This is the Conflict Minerals Report of Hasbro, Inc. (herein referred to as "Hasbro," the Company, "we," " us," or "our ") for calendar year 2017 prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1"). Numerous terms in this report are defined in Rule 13p-1 and Form SD and the reader is invited to refer to those sources for complete definitions of these terms.

Hasbro marketed products based on owned, controlled and licensed intellectual properties within our brand architecture under the following four product categories during 2017, each of which product categories may include products containing 3TG: (1) Franchise Brands; (2) Partner Brands; (3) Hasbro Gaming; and (4) Emerging Brands:

 

Franchise Brands:  Franchise Brands are Hasbro’s most significant owned or controlled properties which we believe can deliver significant revenues and growth over the long-term. In 2017 our seven Franchise Brands were LITTLEST PET SHOP, MAGIC: THE GATHERING, MONOPOLY, MY LITTLE PONY, NERF, PLAY-DOH and TRANSFORMERS. As reported, net revenues from Franchise Brands grew 10% in 2017, and 2% in 2016. In 2017, 2016 and 2015, Franchise Brands were 49%, 46% and 52% of total net revenues, respectively. Beginning in 2018, Emerging Brand BABY ALIVE will replace LITTLEST PET SHOP in the Franchise Brands line-up based on the historical strength of the BABY ALIVE brand and the Company’s belief in the sustainability of the brand’s success.  We are moving LITTLEST PET SHOP to the Emerging Brands category to allow us to take a more entrepreneurial approach to that brand and better allow us to re-invent that brand.

 

Partner Brands  Partner Brands include those licensed brands for which Hasbro develops toy and game products. Significant Partner Brands include MARVEL, including SPIDER-MAN and THE AVENGERS, STAR WARS, DISNEY PRINCESS and DISNEY FROZEN, DISNEY’S DESCENDANTS, BEYBLADE, DREAMWORKS’ TROLLS, SESAME STREET and YO-KAI WATCH. Partner brands MARVEL, STAR WARS, DISNEY’S DESCENDANTS, DISNEY PRINCESS and DISNEY FROZEN are all owned by The Walt Disney Company (“Disney”).

 

In 2017, Hasbro sold product lines supported by the following theatrical releases from our partners: Marvel’s GUARDIANS OF THE GALAXY VOL. 2 in May, SPIDER-MAN: HOMECOMING in July, THOR: RAGNAROK in November and STAR WARS: THE LAST JEDI in December.

 

Hasbro Gaming: Hasbro continues to revolutionize game play through our strong portfolio of Gaming Brands, digital integration, the mining of social media trends to garner consumer insights and capitalize on popular gaming themes, and the rapid introduction of innovative new gaming brands and play experiences. Hasbro Gaming includes brands such as DUNGEONS & DRAGONS, JENGA, THE GAME OF LIFE, OPERATION, PIE FACE, SCRABBLE, TRIVIAL PURSUIT and TWISTER, social games including FANTASTIC GYMNASTICS, SPEAK OUT and TOILET TROUBLE, and many other well-known game brands. To successfully execute our gaming strategy, we focus on brands which may capitalize on existing trends, are continually evolving our approach to gaming using consumer insights and seek to offer gaming experiences relevant to consumer demand for face to face, trading card and digital game experiences played as board, off-the-board, digital, card, electronic, trading card and role-playing games.

 

Emerging Brands: Emerging Brands are those owned or controlled Hasbro brands which have not achieved Franchise Brand status, but many of which the Company believes have the potential to do so over time with investment and further development. Through 2017, these included brands such as BABY ALIVE, FURBY, FURREAL FRIENDS, HANAZUKI, PLAYSKOOL and PLAYSKOOL HEROES. Beginning in 2018, the BABY ALIVE brand is moving to Franchise Brands and LITTLEST PET SHOP will be included in Emerging Brands. The Emerging Brands portfolio also includes new brands being developed by the Company, as well as other brands not captured in our other three categories.

 

Section 2: Due diligence framework

 

Hasbro designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (OECD, 2016) ("OECD Framework") and related supplements for gold and for tin, tantalum and tungsten.

 

 


 

Section 3: Due diligence measures undertaken

 

Hasbro's due diligence efforts for 2017 included the following steps:

 

Establish company management systems:   As part of our continuing improvement process, we:

 

•  Engaged a third party to complete a comprehensive review of our products and conflict minerals program.  Among the improvements we implemented were (i) enhanced product/supplier screening methods, (ii) an updated conflict minerals policy and (iii) improved smelter/refiner verification and country of origin identification/plausibility assessments.

 

•   Updated our 2013 conflict minerals policy statement with respect to sourcing of minerals from the Democratic Republic of Congo ("DRC") and its adjoining countries (collectively the “Covered Countries”) and published this statement online at the following internet address {http://csr.hasbro.com/en-us/csr/conflict-minerals-policy}. This policy was updated in 2017 to require that any 3TG included in our products be sourced from smelters that are identified as conflict free through the Conflict Free Sourcing Initiative/Responsible Minerals Assurance Process. To the extent that we identified non-compliance with the policy, such as through one of our contract manufacturers identifying potential use of a smelter that is not certified, we contact the contract manufacturer requiring them to: a) contact the identified smelter(s) and request that they participate in the conflict minerals audit program; and b) engage their suppliers to request that they also contact the identified smelter(s) with the same request.  

             

•  Continued operating under our internal governance structure created in 2013 that since then has been overseen by members of our senior management team, and includes a cross functional conflict minerals steering committee and working group comprised of representatives from the Global Government and Regulatory Affairs, Corporate Social Responsibility, Global Sourcing, Legal, Finance and Internal Audit functions of Hasbro.

             

•  Continued to engage with contract manufacturers that Hasbro believed were most likely to supply products containing 3TG, informing them at the start of the RCOI that Hasbro is subject to Section 1502 of the Dodd-Frank Act, and that their cooperation in responding to the survey and in complying with Hasbro’s Conflict Minerals Policy is expected.

             

•  Conducted supply chain surveys using a third-party platform based on the RBA/GeSI conflict minerals questionnaire. Surveys were sent to the 28 contract manufacturers identified during our applicability assessment and RCOI as potentially producing items containing 3TG  for our products.  Similar to last year, we employed separate surveys for each of the Company’s four product categories: Franchise Brands, Partner Brands, Hasbro Gaming and Emerging Brands, for all relevant contract manufacturers, such that all applicable contract manufacturers could receive up to four individual surveys if they were providing products in each of the Company’s four product categories.

             

•  Provided surveyed contract manufacturers with training presentations that included an overview of the conflict minerals rules under the Dodd-Frank Act, as well as trainings on how to complete the survey.

             

•  Continued to maintain our grievance mechanism in 2017 to enable the reporting of grievances via the Hasbro Conflict Minerals email box.

 

•  Continued to retain conflict minerals program documentation for 5 years.

 

Identify and assess risks in the supply chain

                 

•  Contract manufacturers surveyed were asked to identify smelters and refiners that process conflict minerals contained in our products, including country of origin of the 3TG, based on the RBA/GeSI conflict minerals questionnaire.

                 

•  Every survey was entered into our third-party technology platform and then reviewed by the technology platform, a third-party consultant and, where deemed necessary, Hasbro personnel.

                 

 


 

•  Non-responsive contract manufacturers and survey responses that we believed to be incomplete or inconsistent were identified for additional follow-up during the RCOI. Reasons for follow-up with contract manufacturers included, but were not limited to, that the contract manufacturer did not provide technical product content information consistent with Hasbro’s product knowledge, a complete or accurate smelter list or did not receive complete 3TG sourcing information from all of its relevant suppliers or inconsistencies were identified in the answers contract manufacturers provided within the survey.

                 

•  Smelters identified by contract manufacturers surveyed by Hasbro were compared against lists maintained by the technology platform provider, the current smelter/refiner lists on the Conflict Free Sourcing Initiative/Responsible Minerals Assurance Process and our external consultant.  This was done to confirm the validity of smelters/refiners and the plausibility of the countries of origin.

 

Design and implement a strategy to respond to identified risks

 

•  Executive members of the steering committee met three times during the 2017 conflict minerals due diligence period to review the results of the applicability assessment, survey review and associated risks. 

 

•  Contract manufacturers that did not respond to Hasbro's initial survey request were sent escalation letters directing that they provide the information requested.  In cases where additional follow-up was needed, emails were sent by the technology platform, by our third-party consultant and by Hasbro management.  Phone calls were also made when necessary by key Hasbro staff/business unit representatives.

 

•  Contract manufacturers who provided survey responses identifying smelters not on the RMAP’s active or compliant smelter lists or who did not provide country of origin information were sent corrective action letters that note that Hasbro requires them to source 3TG from RMAP-compliant smelters. In the corrective action letters, Hasbro requested that contract manufacturers that source from non-RMAP-compliant smelters conduct their own supply chain due diligence to clarify whether 3TG from unaudited smelters/refiners are contained in the products supplied to Hasbro.

 

•  In a change from previous years, Hasbro updated our process for identifying and reviewing countries of origin.  For 2017, Hasbro conducted our own research into countries of origin and the plausibility of the identified countries as sources of 3TG.  We believe this improved the quality of our country of origin disclosures.

 

Carry out independent third-party audit of smelter/refiner due diligence practices

 

Hasbro is a downstream consumer of 3TG and is many steps removed from smelters and refiners who provide minerals and ores. Hasbro does not purchase raw minerals or ores, and does not directly purchase 3TG from any of the Covered Countries. Therefore, Hasbro does not perform or direct audits of smelters and refiners within the supply chain.  Rather, as a member of the RMAP we rely on and support the audits carried out by that organization.

 

Report annually on supply chain due diligence

 

This report and the associated Form SD are available online at the following internet address http://csr.hasbro.com/has17-conflict-minerals-report.php.

 

Section 4: Determination

 

Based on the due diligence described above for 2017, Hasbro was not able to determine if the 3TG used by our contract manufacturers for Hasbro products did or did not originate in the Covered Countries or are from recycled or scrap sources.  

 

 


 

As a downstream consumer of 3TG, Hasbro must rely on its contract manufacturers to gather information about smelters and refiners in the supply chain. Hasbro has received responses from 100% of the contract manufacturers it surveyed (the survey included all 28 contract manufacturers identified as potentially incorporating 3TG into products supplied to Hasbro).  The relevant contract manufacturers declared a total of 247 unique smelter/refiner names as the source of 3TG in Hasbro products.  Of the 247 declared smelters/refiners, 243 (98%) have been designated as conflict free under the RMAP.  The remaining 4 (2%) smelters/refiners are not currently RMAP compliant or actively pursuing such designation.  Our vendors indicated they are pursuing alternative sources for these smelters and are encouraging them to obtain an audit.  The source of 3TG from those smelters/refiners is undetermined at this time and we are not able to determine currently whether 3TG from any of those smelters/refiners were used in our products.  Set forth in Annex 1 is a list of the unique smelter/refiner names disclosed to us by contract manufacturers broken down by metal. Based on the information provided by Hasbro’s contract manufacturers, from the RMAP and other sources, Hasbro believes that the countries of origin of the 3TG contained in some of our products might include Covered Countries, as well as recycled and scrap sources, but we are not able to make that determination at this time for all products or sources.  The aggregated list of Countries of Origin reported to us by our contract manufacturers is set forth in Annex 2.

 

The Hasbro sourcing model is designed to provide Hasbro flexibility to move production of products among contract manufacturers based on contract manufacturer capacities and product demand.  Consequently, there may be instances where the same Hasbro branded product is manufactured by multiple contract manufacturers, which increases the complexity in linking a product with specific smelters. With the level of information Hasbro has received from its contract manufacturers and its current technology infrastructure, Hasbro has made progress from 2016 in its ability to connect specific smelters or refiners to our contract manufacturers for Hasbro product categories.

 

Section 5: Independent audit

 

Hasbro has determined that for 2017 an independent private sector audit is not required.

 

Section 6: Continuous improvement efforts to mitigate risk

 

Hasbro took the following steps to improve our program overall, improve the number and quality of responses in the 2017 compliance period and mitigate risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:

 

•  Issued a response request letter from Hasbro’s Executive Vice President, Chief Global Operations Officer to all contract manufacturers for the 2017 reporting year survey.

•  Achieved a 100% response rate from all applicable contract manufacturers.

•  Updated our conflict minerals policy to require that any 3TG included in our products be sourced from smelters that are identified as conflict free through the Conflict Free Sourcing Initiative/Responsible Minerals Assurance Process.

•  Continued to use contract terms and conditions for new contracts requiring contract manufacturers to respond to inquiries regarding 3TG in a timely manner, such as through incorporation of conflict minerals requirements into Hasbro’s Vendor Manual, which is incorporated into Hasbro’s Master Agreements with contract manufacturers.

 

•  Increased our ability to link specific contract manufacturers to particular smelters and product categories through surveying all applicable contract manufacturers at the product-level in 2017, which we believe resulted in improvements in identifying smelters/refiners applicable to Hasbro and is a reason for the increase in the number of smelters/refiners reported over last year.

•  Rather than relying on contract manufacturers to provide country of origin information, we undertook our own efforts to identify countries of origin using our third-party technology provider.  Our external consultant conducted a further plausibility review to ensure that the identified countries have known 3TG ore mining operations or proven mineral reserves.

 


 

•  Continued to work with contract manufacturers to help them understand the importance of this initiative to Hasbro and to encourage their participation in the conflict minerals survey through trainings for relevant contract manufacturers. Since most of our contract manufacturers are based in the People’s Republic of China, Hasbro conducted in-person training sessions with our Chinese contract manufacturers.   We believe this resulted in improvements in identifying smelters/refiners applicable to Hasbro and is a reason for the increase in the number of smelters/refiners reported over last year.

•  Through our membership in RMAP, communicated to them about smelters/refiners identified that have not undergone the RMAP audit process.  

 

In the next compliance period, Hasbro intends to take the following steps to further improve the number and quality of contract manufacturer responses and to mitigate the risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:

 

•  Continue to use contract terms and conditions for new contracts requiring contract manufacturers to respond to inquiries regarding conflict minerals in a timely manner.

                 

•  Continue engaging with contract manufacturers, with the objective of maintaining a 100% response rate from all applicable contract manufacturers and obtaining complete lists and the ability to link specific contract manufacturers to particular smelters and to particular product categories.

                 

•  Continue to work with contract manufacturers to identify to the extent possible the source of 3TG used in Hasbro's products.

                 

•  Build capabilities with active and new contract manufacturers by helping them understand the importance of this initiative to Hasbro and to encourage their participation through contract manufacturer trainings.

 

•  Continue to require that any 3TG included in our products be sourced from smelters that are identified as conflict free through the Conflict Free Sourcing Initiative/Responsible Minerals Assurance Process.

 

•  Continue working with our contract manufacturers to better understand how individual sources of 3TG may apply to our individual product categories.

•  As a result of becoming a full RBA (formerly EICC) member in October 2016, Hasbro will continue to utilize an annual RBA Validated Audit Process (VAP) or Customer Managed Audit (CMA) audit for 100% of our contract manufacturers, which includes verifying that a manufacturer has a documented, effective and communicated conflict minerals policy and management program.

 

Certain statements in this Conflict Minerals Report contain "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements include expectations concerning the Company's future actions to engage contract manufacturers, to identify to the extent possible the source of 3TG minerals in its products and to take other actions regarding its product sourcing. The Company's actual actions or results may differ materially from those expected or anticipated in the forward-looking statements due to both known and unknown risks and uncertainties including, but not limited to, decisions to make changes in the Company’s continual improvement efforts and delays or difficulties in engaging contract manufacturers and identifying the source of 3TG contained in the Company’s products.

 

  

 


 

 

Annex 1

 

 

Identified Smelters/Refiners – RMAP Compliant Unless Otherwise Indicated 

(of the 247 smelters, 243 are RMAP compliant)

  

 

 

 

CMRT Smelter Name

Metal

Advanced Chemical Company

Gold

Aida Chemical Industries Co., Ltd.

Gold

Al Etihad Gold LLC

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

Gold

Argor-Heraeus S.A.

Gold

Asahi Pretec Corp.

Gold

Asahi Refining Canada Ltd.

Gold

Asahi Refining USA Inc.

Gold

Asaka Riken Co., Ltd.

Gold

AU Traders and Refiners

Gold

Aurubis AG

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Gold

Boliden AB

Gold

CCR Refinery - Glencore Canada Corporation

Gold

C. Hafner GmbH + Co. KG

Gold

Chimet S.p.A.

Gold

Daejin Indus Co., Ltd.

Gold

DODUCO Contacts and Refining GmbH

Gold

Dowa

Gold

DSC (Do Sung Corporation)

Gold

Eco-System Recycling Co., Ltd.

Gold

Emirates Gold DMCC

Gold

Geib Refining Corporation

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

Gold

Guangdong Jinding Gold Limited*

Gold

Heimerle + Meule GmbH

Gold

Heraeus Precious Metals GmbH & Co. KG

Gold

Heraeus Metals Hong Kong Ltd.

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

Gold

Ishifuku Metal Industry Co., Ltd.

Gold

Istanbul Gold Refinery

Gold

Japan Mint

Gold

Jiangxi Copper Co., Ltd.

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Gold

JSC Uralelectromed

Gold

JX Nippon Mining & Metals Co., Ltd.

Gold

Kazzinc

Gold

Kennecott Utah Copper LLC

Gold

Kojima Chemicals Co., Ltd.

Gold

Korea Zinc Co., Ltd.

Gold

Kyrgyzaltyn JSC

Gold

LS-NIKKO Copper Inc.

Gold

Materion

Gold

Matsuda Sangyo Co., Ltd.

Gold

Metalor Technologies (Suzhou) Ltd.

Gold

Metalor Technologies (Hong Kong) Ltd.

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Gold

Metalor Technologies S.A.

Gold

Metalor USA Refining Corporation

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

Gold

Mitsubishi Materials Corporation

Gold

Mitsui Mining and Smelting Co., Ltd.

Gold

MMTC-PAMP India Pvt., Ltd.

Gold

Moscow Special Alloys Processing Plant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

Gold

Nihon Material Co., Ltd.

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

Gold

Ohura Precious Metal Industry Co., Ltd.

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

Gold

OJSC Novosibirsk Refinery

Gold

PAMP S.A.

Gold

Prioksky Plant of Non-Ferrous Metals

Gold

PT Aneka Tambang (Persero) Tbk

Gold

PX Precinox S.A.

Gold

Rand Refinery (Pty) Ltd.

Gold

Republic Metals Corporation

Gold

Royal Canadian Mint

Gold

SAAMP

Gold

Samduck Precious Metals

Gold

SAXONIA Edelmetalle GmbH

Gold

Singway Technology Co., Ltd.

Gold

Schone Edelmetaal B.V.

Gold

SEMPSA Joyeria Plateria S.A.

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

Gold

Sichuan Tianze Precious Metals Co., Ltd.

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Gold

Solar Applied Materials Technology Corp.

Gold

Sumitomo Metal Mining Co., Ltd.

Gold

T.C.A S.p.A

Gold

Tanaka Kikinzoku Kogyo K.K.

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

Gold

Tokuriki Honten Co., Ltd.

Gold

Torecom

Gold

Umicore Brasil Ltda.

Gold

Umicore Precious Metals Thailand

Gold

Umicore S.A. Business Unit Precious Metals Refining

Gold

United Precious Metal Refining, Inc.

Gold

Valcambi S.A.

Gold

WIELAND Edelmetalle GmbH

Gold

Western Australian Mint (T/a The Perth Mint)

Gold

Yamakin Co., Ltd.

Gold

Yokohama Metal Co., Ltd.

Gold

Yunnan Copper Industry Co., Ltd.

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

Gold

Changsha South Tantalum Niobium Co., Ltd.

Tantalum

D Block Metals, LLC

Tantalum

Exotech Inc.

Tantalum

F&X Electro-Materials Ltd.

Tantalum

FIR Metals & Resource Ltd.

Tantalum

Global Advanced Metals Aizu

Tantalum

Global Advanced Metals Boyertown

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

Tantalum

H.C. Starck Co., Ltd.

Tantalum

H.C. Starck Hermsdorf GmbH

Tantalum

H.C. Starck Inc.

Tantalum

H.C. Starck Ltd.

Tantalum

H.C. Starck Smelting GmbH & Co. KG

Tantalum

H.C. Starck Tantalum and Niobium GmbH

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

Tantalum

Jiangxi Tuohong New Raw Material

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

Tantalum

Jiujiang Nonferrous Metals Smelting Company Limited

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

Tantalum

KEMET Blue Metals

Tantalum

Kemet Blue Powder

Tantalum

King-Tan Tantalum Industry Ltd.*

Tantalum

LSM Brasil S.A.

Tantalum

Metallurgical Products India Pvt., Ltd.

Tantalum

Mineracao Taboca S.A.

Tantalum

Mitsui Mining and Smelting Co., Ltd.

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

Tantalum

NPM Silmet AS

Tantalum

Power Resources Ltd.

Tantalum

QuantumClean

Tantalum

XinXing Haorong Electronic Material Co., Ltd.

Tantalum

RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.

Tantalum

Solikamsk Magnesium Works OAO

Tantalum

Taki Chemical Co., Ltd.

Tantalum

Telex Metals

Tantalum

Ulba Metallurgical Plant JSC

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd.

Tantalum

Alpha

Tin

An Vinh Joint Stock Mineral Processing Company*

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

Tin

CV Ayi Jaya

Tin

CV Dua Sekawan

Tin

CV Gita Pesona

Tin

PT Premium Tin Indonesia

Tin

CV Tiga Sekawan

Tin

CV United Smelting

Tin

CV Venus Inti Perkasa

Tin

Dowa

Tin

EM Vinto

Tin

Fenix Metals

Tin

Gejiu Fengming Metallurgy Chemical Plant

Tin

Gejiu Jinye Mineral Company

Tin

Gejiu Kai Meng Industry and Trade LLC

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

Tin

China Tin Group Co., Ltd.

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

Tin

Huichang Jinshunda Tin Co., Ltd.

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

Tin

Magnu's Minerais Metais e Ligas Ltda.

Tin

Melt Metais e Ligas S.A.

Tin

Metallic Resources, Inc.

Tin

Metallo Belgium N.V.

Tin

Metallo Spain S.L.U.

Tin

Mineracao Taboca S.A.

Tin

Minsur

Tin

Mitsubishi Materials Corporation

Tin

Malaysia Smelting Corporation (MSC)

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

Tin

O.M. Manufacturing Philippines, Inc.

Tin

Operaciones Metalurgical S.A.

Tin

PT Aries Kencana Sejahtera

Tin

PT Artha Cipta Langgeng

Tin

PT ATD Makmur Mandiri Jaya

Tin

PT Babel Inti Perkasa

Tin

PT Bangka Prima Tin

Tin

PT Bangka Serumpun

Tin

PT Bangka Tin Industry

Tin

PT Belitung Industri Sejahtera

Tin

PT Bukit Timah

Tin

PT DS Jaya Abadi

Tin

PT Eunindo Usaha Mandiri

Tin

PT Inti Stania Prima

Tin

PT Karimun Mining

Tin

PT Kijang Jaya Mandiri

Tin

PT Lautan Harmonis Sejahtera

Tin

PT Menara Cipta Mulia

Tin

PT Mitra Stania Prima

Tin

PT O.M. Indonesia*

Tin

PT Panca Mega Persada

Tin

PT Prima Timah Utama

Tin

PT Refined Bangka Tin

Tin

PT Sariwiguna Binasentosa

Tin

PT Stanindo Inti Perkasa

Tin

PT Sukses Inti Makmur

Tin

PT Sumber Jaya Indah

Tin

PT Timah (Persero) Tbk Kundur

Tin

PT Timah (Persero) Tbk Mentok

Tin

PT Tinindo Inter Nusa

Tin

PT Tommy Utama

Tin

Resind Industria e Comercio Ltda.

Tin

Rui Da Hung

Tin

Soft Metais Ltda.

Tin

Thaisarco

Tin

White Solder Metalurgia e Mineracao Ltda.

Tin

Yunnan Tin Company Limited

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

Tin

A.L.M.T. TUNGSTEN Corp.

Tungsten

ACL Metais Eireli

Tungsten

Asia Tungsten Products Vietnam Ltd.

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

Tungsten

Global Tungsten & Powders Corp.

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

Tungsten

H.C. Starck Smelting GmbH & Co. KG

Tungsten

H.C. Starck Tungsten GmbH

Tungsten

Hunan Chenzhou Mining Co., Ltd.

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

Tungsten

Hydrometallurg, JSC

Tungsten

Japan New Metals Co., Ltd.

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

Tungsten

Kennametal Fallon

Tungsten

Kennametal Huntsville

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

Tungsten

Moliren Ltd.

Tungsten

Niagara Refining LLC

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

Tungsten

Philippine Chuangxin Industrial Co., Inc.

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

Tungsten

Unecha Refractory Metals Plant

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

Tungsten

Wolfram Bergbau und Hutten AG

Tungsten

Woltech Korea Co., Ltd.

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

Tungsten

Xiamen Tungsten Co., Ltd.

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

Tungsten

*  Smelter/refiner not audited by RMAP or equivalent program.

 

 

 

Annex 2

 

 

Countries of Origin

 

 

Countries of Origin

Angola

 

Argentina

 

Armenia

 

Australia

 

Austria

 

Bolivia

 

Brazil

 

Burundi

 

Cambodia

 

Canada

 

Central African Republic

 

Chile

 

China

 

Colombia

 

Congo (Brazzaville)

 

Czech Republic

 

Djibouti

 

DRC- Congo (Kinshasa)

 

Ecuador

 

Egypt

 

Estonia

 

Ethiopia

 

Finland

 

France

 

Germany

 

Ghana

 

Guinea

 

Guyana

 

India

 

Indonesia

 

Ireland

 

Ivory Coast

 

Japan

 

Jersey

 

Kazakhstan

 

Kenya

 

Korea, Republic of

 

Kyrgyzstan

 

Laos

 

Madagascar

 

Malaysia

 

Mali

 

Mexico

 

Mongolia

 

Morocco

 

Mozambique

 

Myanmar

 

Namibia

 

Niger

 

Nigeria

 

Papua New Guinea

 

Peru

 

Philippines

 

Poland

 

Portugal

 

Recycle/Scrap

 

Russian Federation

 

Rwanda

 

Saudi Arabia

 

Sierra Leone

 

Slovakia

 

South Africa

 

South Sudan

 

Spain

 

Suriname

 

Sweden

 

Switzerland

 

Taiwan

 

Tajikistan

 

Tanzania

 

Thailand

 

Turkey

 

Uganda

 

United Kingdom

 

United States

 

Uzbekistan

 

Viet Nam

 

Zambia

 

Zimbabwe