EX-1.01 2 exhibit101.htm CONFLICT MINERALS REPORT FOR THE CALENDAR YEAR ENDED DECEMBER 31, 2021

EXHIBIT 1.01

Conflict Minerals Report

  

Kohl’s Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for calendar year 2021, as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 25, 2022.

 

Unless the context indicates otherwise, the terms “Kohl’s,” “we,” “us” and “our” refer to Kohl’s Corporation and its consolidated subsidiaries.

 

As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.

 

Forward-Looking Statements

 

This document contains “forward-looking statements” made within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “believes,” “anticipates,” “plans,” “may,” “intends,” “will,” “should,” “expects” and similar expressions or the use of the future tense are intended to identify forward-looking statements. In addition, any statements that do not relate to historical or current facts or matters are forward-looking statements. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements within this document include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG benefit armed groups.

 

Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to: (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all; (2) whether smelters and refiners and other market participants responsibly source 3TG; and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”), the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of the filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of the filing of this document or to reflect the occurrence of unanticipated events.

Applicability of the Conflict Minerals Rule to Our Company

 

As of January 29, 2022, we operated 1,165 Kohl's stores and a website (www.Kohls.com). Our Kohl's stores and website sell moderately-priced private and national brand apparel, footwear, accessories, beauty, and home products. Our Kohl's stores generally carry a consistent merchandise assortment with some differences attributable to local preferences, store size, and Sephora. Our website includes merchandise which is available in our stores, as well as merchandise that is available only online.

Our merchandise mix includes both national brands and private brands that are available only at Kohl's. Our private portfolio includes well-known established brands such as Apt. 9, Croft & Barrow, Jumping Beans, SO, and Sonoma Goods for Life, and exclusive brands that are developed and marketed through agreements with nationally-recognized brands such as Food Network, LC Lauren Conrad, Nine West, and Simply Vera Vera Wang.

 

 


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We believe that we are subject to the Conflict Minerals Rule because of the degree of influence that we exercise over some of the materials, parts or components of some of the private portfolio products that are manufactured for us and that contain necessary 3TG. However, for some of our private portfolio products, we exercise no influence over the materials, parts or components of the products. Our involvement with those products is limited to having the manufacturer affix our portfolio brand name to the products. Those products and the related suppliers are therefore not in-scope for purposes of our compliance with the Conflict Minerals Rule. We do not manufacture any products.

 

We do not directly source 3TG from mines, smelters or refiners and believe that we are many levels removed from these market participants. However, through the efforts described below, we seek to ensure that our private portfolio suppliers’ sourcing practices are consistent with our Conflict Minerals Policy described below.

 

For 2021, notwithstanding our due diligence efforts discussed herein, we were unable to determine the origin of at least a portion of the necessary 3TG in each of the products that we contracted to manufacture. However, none of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in a Covered Country. We did not conclude that any of our products were “DRC conflict free.” The terms “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

 

Our Conflict Minerals Policy

 

We are committed to sourcing products from companies that share our values around human rights, ethics and environmental responsibility. To this end, we have adopted a company policy for the 3TG that are in our supply chain (“Conflict Minerals Policy”). The Conflict Minerals Policy includes, but is not limited to, our expectations that our suppliers:

 

1.Adopt and maintain a policy to reasonably assure that the 3TG in the products supplied to Kohl’s are conflict free. 

2.Establish their own due diligence programs to ensure conflict-free supply chains and take any other steps necessary to abide by the contractual certifications, warranties, covenants and representations provided to Kohl’s. Supplier due diligence programs are expected to be designed in conformity with the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 

3.Cooperate with our 3TG due diligence process, including by providing us, from time to time, with written certifications and other information concerning the origin of 3TG included in products supplied to Kohl’s. As part of our process, suppliers of Kohl’s proprietary-brand products will be expected to complete the Responsible Minerals Initiative’s (the “RMI”) Conflict Minerals Reporting Template (“CMRT”). 

4.Support industry efforts to enhance traceability and responsible practices in global mineral supply chains. 

Under our Conflict Minerals Policy, we reserve the right to require from any supplier at any time such additional information, certifications and documentation as we deem necessary to monitor or assess compliance with the Conflict Minerals Policy or other contractual certifications, warranties, covenants and representations provided to us.

We do not seek to embargo the Covered Countries and encourage our suppliers to continue to source responsibly from the Covered Countries.


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Reasonable Country of Origin Inquiry Information

As required by the Conflict Minerals Rule, for 2021, we conducted a “reasonable country of origin inquiry” (“RCOI”). For our RCOI, to the extent applicable, we utilized the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the design framework contemplated in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”).  The OECD Guidance is described below in this Conflict Minerals Report. The specific goal of our RCOI was to determine whether the 3TG in our in-scope products originated in a Covered Country.

 

Inquiries were made of all suppliers that provided Kohl’s with private portfolio products during 2021, regardless of whether the degree of influence we actually exercised over the materials, parts or components of the products brought them in-scope for purposes of our compliance with the Conflict Minerals Rule. We refer below to our suppliers of private portfolio products for 2021 as “Suppliers.” For 2021, we reached out to 325 Suppliers.

The Suppliers identified to us 202 different smelters and refiners as potentially having processed the necessary 3TG contained in our potentially in-scope products. 150 of the smelters and refiners were listed as Conformant (as defined herein) by the RMI. Based on our RCOI, we concluded that 76 of these 202 smelters and refiners sourced entirely from outside of the Covered Countries. Our conclusion was based on information made available by the RMI to its members.

Based on the results of our RCOI, we conducted due diligence for 2021. These due diligence efforts are discussed below.

We use a third-party service provider (the “Service Provider”) to assist us with the collection, review, validation and analysis of the information received from the Suppliers. Some of the compliance activities described in this Conflict Minerals Report were performed by the Service Provider on our behalf.

Due Diligence Measures

 

Design Framework

 

We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the OECD Guidance.

  

Selected Elements of Design Framework and Due Diligence Program

 

The OECD Guidance established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our due diligence program are discussed below. However, these are not all of the elements of the program that we have put in place to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps.

 

1.OECD Guidance Step One: “Establish strong company management systems” 

a.We have a Conflict Minerals Policy. The Conflict Minerals Policy is posted on our website at https://corporate.kohls.com/content/dam/kohlscorp/investors/corporate-governance/ConflictMineralsPolicyMay2014.pdf. The information contained on our website is not incorporated by reference into this Conflict Minerals Report or the Form SD and should not be considered part of this Conflict Minerals Report or the Form SD. The Conflict Minerals Policy is summarized earlier in this Conflict Minerals Report. 


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b.We have a working group led by our Legal team at the direction of our Senior Executive Vice President, General Counsel. Some of the functional areas participating in the working group include Legal, Global Sourcing, Production & Product Services and Factory Compliance. We also include merchants and sourcing personnel in the compliance process. We supplement our compliance efforts with specialist outside counsel and the Service Provider. 

c.We communicate to our relevant merchants and other selected internal personnel our commitment to compliance with the Conflict Minerals Rule. We do so by email, telephone and in-person meetings. In addition, our senior leadership, selected Product Development team members, merchants and selected other internal personnel are educated and briefed on the Conflict Minerals Rule and our compliance plan. 

d.Kohl’s Terms of Engagement and our Merchandise Purchase Order Terms & Conditions, pursuant to which Kohl’s purchases products, contain terms to clarify our 3TG compliance expectations and drive compliance, including a provision requiring all suppliers to certify, warrant, covenant and represent that all merchandise sold to Kohl’s will be free of any 3TG financing conflict in a Covered Country. 

e.Through the Service Provider, we use the CMRT developed by the RMI to identify smelters and refiners in our supply chain. 

f.Records of due diligence processes, findings and resulting decisions and any other business records relating to 3TG due diligence are retained for at least five years. These records are retained on our behalf by the Service Provider and are generally stored in an electronic format. 

g.We have mechanisms for employees, suppliers and other interested parties to report potential violations of our Conflict Minerals Policy, including web-based and telephone hotline reporting mechanisms. The web address is kohlsintegrity.com and the hotline number is (800) 837-7297. 

2.OECD Guidance Step Two: “Identify and assess risk in the supply chain” 

a.For 2021, the Service Provider requested by email that the Suppliers provide us with information, through the completion of a CMRT, concerning the usage and source of 3TG in their products, as well as information concerning the Suppliers’ related compliance measures. Both we and the Service Provider followed up multiple times, if required, by email or phone with Suppliers that did not respond to the request within the specified time frame.  

b.Through the Service Provider, compliance training and other compliance resources were made available to the Suppliers. The training program was intended to help ensure the quality and completeness of the CMRTs received from the Suppliers. An email also was sent to Suppliers that described our compliance program requirements and included a link to the Service Provider’s on-line supplier education portal and contact email addresses and telephone numbers for obtaining answers to questions and/or guidance on completing our survey request. 

c.The Service Provider reviewed the responses received from Suppliers for plausibility, consistency and gaps. It follows up by email or phone with Suppliers that submitted a response that triggered any one of seven specified quality control flags. Responses were received from 95% of the Suppliers.   

d.Smelter and refiner information provided by Suppliers was reviewed against the Service Provider's internal database. To the extent not in that database, it requests that the supplier confirm that the listed entity is a smelter or refiner. 


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e.Smelter and refiner information also was reviewed by the Service Provider against the lists of Conformant and Active (as defined herein), or the equivalent, smelters and refiners published by the RMI, the London Bullion Market Association (“LBMA”) and the Responsible Jewellery Council (“RJC”). 

f.To the extent that a smelter or refiner identified by a supplier is not listed as Conformant or the equivalent by an independent third-party, the Service Provider attempts to contact the smelter or refiner to gain more information about its sourcing practices, including countries of origin and transfer and whether there are internal due diligence procedures in place or other processes that the smelter or refiner takes to track the chain of custody on the source of its 3TG. Internet research is also performed to determine whether there are any outside sources of information regarding the smelter’s or refiner’s sourcing practices. For 2021, of the 202 smelters and refiners identified by Suppliers as having potentially supplied 3TG contained in our in-scope products, 152 were listed as Conformant by the RMI according to information furnished by the Service Provider on April 14, 2022. 

g.Based on the information furnished by our suppliers, the Service Provider and other information known to us, we assess the risks of adverse impacts. 

3.OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” 

a.Our Senior Executive Vice President, General Counsel charged with managing our 3TG compliance strategy periodically reports the findings of our supply chain risk assessment to other members of our senior leadership and to our Board of Directors or its Audit Committee. 

b.We address identified risks on a case-by-case basis. This flexible approach enables us to tailor the response to the risks identified. 

c.In addition, to the extent that identified smelters and refiners are not listed as Conformant, we seek to exercise leverage over these smelters and refiners to become Conformant through our participation in and support of the RMI. In addition, we also utilize information provided by the RMI to its members to monitor smelter and refiner improvement. 

4.OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” 

a.In connection with our due diligence, we utilize and rely on information made available by the RMI concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence and to determine whether the smelter or refiner is Conformant. 

b.We also support independent third-party audits by being a member of the RMI. 

5.OECD Guidance Step 5: “Report on supply chain due diligence” 

a.We file a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission, and make available on our website information from the Form SD and the Conflict Minerals Report. 

b.We include information concerning 3TG compliance in our Environmental, Social & Governance Report, which we make publicly available on our website. 

 


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Product and Smelter and Refiner Information

 

In-Scope Products

 

See “Applicability of the Conflict Minerals Rule to Our Company” for further information concerning our potentially in-scope products. For a further discussion of our products generally, see our Annual Report on Form 10-K for the fiscal year ended January 29, 2022. The information contained in our Form 10-K is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or our Form SD.

 

Identified Smelters and Refiners

 

The following table summarizes the smelter and refiner information provided by the Suppliers. See Annex A for a list of identified smelters and refiners and country of origin information. Annex A also contains additional information relating to the data presented in the table.

 

 

Conformant

Active

Smelter Look-Up Tab List Only

Tantalum

1

0

0

Tin

50

3

8

Tungsten

2

0

0

Gold

97

1

40

 

We endeavored to determine the mine or location of origin of the necessary 3TG contained in our in-scope products by requesting that the Suppliers provide us with a completed CMRT and through the other procedures followed by us and the Service Provider that are described in this Conflict Minerals Report.

 

None of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the Covered Countries. However, we did not have sufficient information to determine whether or not any of our products were “DRC conflict free.” The terms “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

 

Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our suppliers for accurate smelter and refiner information and our RCOI and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products.

 

Future Risk Mitigation Efforts

 

We intend to take the following additional steps for 2022, either directly or through the Service Provider, to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:

 

1.Continue to encourage Suppliers that provided company level information for 2021 to provide product level information for 2022; 

2.Continue to engage with Suppliers that provided incomplete responses or that did not provide responses for 2021 to help ensure that they provide requested information for 2022; and 


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3.Continue to communicate to new in-scope supplier our sourcing expectations, including through the dissemination of the Conflict Minerals Policy to them. 

All of the foregoing steps are in addition to the other steps that we took in respect of 2021, which we intend to continue to take in respect of 2022, to the extent applicable.

 


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Annex A

Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.

Smelters and Refiners

In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below as having potentially processed the necessary 3TG contained in our in-scope products in 2021. Please see the notes that accompany the table for additional information concerning the data in the table.

Mineral

Smelter or Refiner Name

 

SOR Location

 

Status

Gold

8853 S.p.A.

Italy

Conformant

Gold

Abington Reldan Metals, LLC

United States

Smelter Look-Up List Tab Only

Gold

Advanced Chemical Company

United States

Conformant

Gold

Aida Chemical Industries Co., Ltd.

Japan

Conformant

Gold

Al Etihad Gold Refinery DMCC

United Arab Emirates

Conformant

Gold

Agosi AG

Germany

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

Conformant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

Brazil

Conformant

Gold

Argor-Heraeus S.A.

Switzerland

Conformant

Gold

Asahi Pretec Corp.

Japan

Conformant

Gold

Asahi Refining Canada Ltd.

Canada

Conformant

Gold

Asahi Refining USA Inc.

United States

Conformant

Gold

Asaka Riken Co., Ltd.

Japan

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Turkey

Smelter Look-Up List Tab Only

Gold

AU Traders and Refiners

South Africa

Smelter Look-Up List Tab Only

Gold

Aurubis AG

Germany

Conformant

Gold

Bangalore Refinery

India

Conformant


A-1



Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Philippines

Conformant

Gold

Boliden AB

Sweden

Conformant

Gold

C. Hafner GmbH + Co. KG

Germany

Conformant

Gold

Caridad

Mexico

Smelter Look-Up List Tab Only

Gold

CCR Refinery - Glencore Canada Corporation

Canada

Conformant

Gold

Cendres + Metaux S.A.

Switzerland

Conformant

Gold

Chimet S.p.A.

Italy

Conformant

Gold

Chugai Mining

Japan

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

China

Smelter Look-Up List Tab Only

Gold

Degussa Sonne / Mond Goldhandel GmbH

Germany

Smelter Look-Up List Tab Only

Gold

DODUCO Contacts and Refining GmbH

Germany

Conformant

Gold

Dowa

Japan

Conformant

Gold

DSC (Do Sung Corporation)

Korea, Republic of

Conformant

Gold

Eco-System Recycling Co., Ltd. East Plant

Japan

Conformant

Gold

Eco-System Recycling Co., Ltd. North Plant

Japan

Conformant

Gold

Eco-System Recycling Co., Ltd. West Plant

Japan

Conformant

Gold

Emirates Gold DMCC

United Arab Emirates

Conformant

Gold

Fidelity Printers and Refiners Ltd.

Zimbabwe

Smelter Look-Up List Tab Only

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

India

Active

Gold

Geib Refining Corporation

United States

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

China

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

China

Smelter Look-Up List Tab Only

Gold

Guangdong Jinding Gold Limited

China

Smelter Look-Up List Tab Only

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

China

Smelter Look-Up List Tab Only


A-2



Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

Heimerle + Meule GmbH.

Germany

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

China

Conformant

Gold

Hunan Chenzhou Mining Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

HwaSeong CJ CO., LTD.

Korea, Republic of

Smelter Look-Up List Tab Only

Gold

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

China

Conformant

Gold

Ishifuku Metal Industry Co., Ltd.

Japan

Conformant

Gold

Istanbul Gold Refinery

Turkey

Conformant

Gold

Italpreziosi

Italy

Conformant

Gold

Japan Mint

Japan

Conformant

Gold

Jiangxi Copper Co., Ltd.

China

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Russian Federation

Smelter Look-Up List Tab Only

Gold

JSC Uralelectromed

Russian Federation

Smelter Look-Up List Tab Only

Gold

JX Nippon Mining & Metals Co., Ltd.

Japan

Conformant

Gold

Kaloti Precious Metals

United Arab Emirates

Smelter Look-Up List Tab Only

Gold

Kazakhmys Smelting LLC

Kazakhstan

Smelter Look-Up List Tab Only

Gold

Kazzinc

Kazakhstan

Conformant

Gold

Kennecott Utah Copper LLC

United States

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

Poland

Conformant

Gold

Kojima Chemicals Co., Ltd.

Japan

Conformant

Gold

Korea Zinc Co., Ltd.

Korea, Republic of

Conformant

Gold

Kyrgyzaltyn JSC

Kyrgyzstan

Smelter Look-Up List Tab Only

Gold

L'azurde Company For Jewelry

Saudi Arabia

Smelter Look-Up List Tab Only


A-3



Gold

Lingbao Gold Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

L'Orfebre S.A.

Andorra

Conformant

Gold

LS-NIKKO Copper Inc.

Korea, Republic of

Conformant

Gold

LT Metal Ltd.

Korea, Republic of

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

Marsam Metals

Brazil

Conformant

Gold

Materion

United States

Conformant

Gold

Matsuda Sangyo Co., Ltd.

Japan

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

China

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Singapore

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

China

Conformant

Gold

Metalor Technologies S.A.

Switzerland

Conformant

Gold

Metalor USA Refining Corporation

United States

Conformant

Gold

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

Mexico

Conformant

Gold

Mitsubishi Materials Corporation

Japan

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

Japan

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

India

Conformant

Gold

Modeltech Sdn Bhd

Malaysia

Smelter Look-Up List Tab Only

Gold

Morris and Watson

New Zealand

Smelter Look-Up List Tab Only

Gold

Moscow Special Alloys Processing Plant

Russian Federation

Smelter Look-Up List Tab Only

Gold

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

Turkey

Conformant

Gold

Navoi Mining and Metallurgical Combinat

Uzbekistan

Conformant

Gold

Nihon Material Co., Ltd.

Japan

Conformant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

Austria

Conformant


A-4



Gold

Ohura Precious Metal Industry Co., Ltd.

Japan

Conformant

Gold

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

Russian Federation

Smelter Look-Up List Tab Only

Gold

OJSC Novosibirsk Refinery

Russian Federation

Smelter Look-Up List Tab Only

Gold

PAMP S.A.

Switzerland

Conformant

Gold

Pease & Curren

United States

Smelter Look-Up List Tab Only

Gold

Penglai Penggang Gold Industry Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

Planta Recuperadora de Metales SpA

Chile

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

Russian Federation

Smelter Look-Up List Tab Only

Gold

PT Aneka Tambang (Persero) Tbk

Indonesia

Conformant

Gold

PX Precinox S.A.

Switzerland

Conformant

Gold

Rand Refinery (Pty) Ltd.

South Africa

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

REMONDIS PMR B.V.

Netherlands

Conformant

Gold

Royal Canadian Mint

Canada

Conformant

Gold

SAAMP

France

Conformant

Gold

Sabin Metal Corp.

United States

Smelter Look-Up List Tab Only

Gold

Safimet S.p.A

Italy

Conformant

Gold

SAFINA A.S.

Czech Republic

Conformant

Gold

Sai Refinery

India

Smelter Look-Up List Tab Only

Gold

Samduck Precious Metals

Korea, Republic of

Conformant

Gold

SAMWON METALS Corp.

Korea, Republic of

Smelter Look-Up List Tab Only

Gold

SAXONIA Edelmetalle GmbH

Germany

Smelter Look-Up List Tab Only

Gold

SEMPSA Joyeria Plateria S.A.

Spain

Conformant


A-5



Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

China

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

China

Conformant

Gold

Singway Technology Co., Ltd.

Taiwan

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Russian Federation

Smelter Look-Up List Tab Only

Gold

Solar Applied Materials Technology Corp.

Taiwan

Conformant

Gold

Sudan Gold Refinery

Sudan

Smelter Look-Up List Tab Only

Gold

Sumitomo Metal Mining Co., Ltd.

Japan

Conformant

Gold

SungEel HiMetal Co., Ltd.

Korea, Republic of

Conformant

Gold

T.C.A S.p.A

Italy

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

Japan

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

China

Conformant

Gold

Tokuriki Honten Co., Ltd.

Japan

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

China

Smelter Look-Up List Tab Only

Gold

TOO Tau-Ken-Altyn

Kazakhstan

Conformant

Gold

Torecom

Korea, Republic of

Conformant

Gold

Umicore Precious Metals Thailand

Thailand

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

Belgium

Conformant

Gold

United Precious Metal Refining, Inc.

United States

Conformant

Gold

Valcambi S.A.

Switzerland

Conformant

Gold

Western Australian Mint (T/a The Perth Mint)

Australia

Conformant

Gold

WIELAND Edelmetalle GmbH

Germany

Conformant

Gold

Yamakin Co., Ltd.

Japan

Conformant

Gold

Yokohama Metal Co., Ltd.

Japan

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

China

Smelter Look-Up List Tab Only


A-6



Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

China

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

Conformant

Tin

Alpha

United States

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

Viet Nam

Smelter Look-Up List Tab Only

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

China

Conformant

Tin

China Tin Group Co., Ltd.

China

Conformant

Tin

CV Venus Inti Perkasa

Indonesia

Active

Tin

Dowa

Japan

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Viet Nam

Smelter Look-Up List Tab Only

Tin

EM Vinto

Bolivia

Conformant

Tin

Estanho de Rondonia S.A.

Brazil

Conformant

Tin

Fenix Metals

Poland

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

China

Smelter Look-Up List Tab Only

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

China

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

Conformant

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

China

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

China

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

China

Conformant

Tin

Luna Smelter, Ltd.

Rwanda

Conformant

Tin

Ma'anshan Weitai Tin Co., Ltd.

China

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

Brazil

Conformant

Tin

Malaysia Smelting Corporation (MSC)

Malaysia

Conformant

Tin

Melt Metais e Ligas S.A.

Brazil

Smelter Look-Up List Tab Only

Tin

Metallic Resources, Inc.

United States

Conformant


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Tin

Metallo Belgium N.V.

Belgium

Conformant

Tin

Metallo Spain S.L.U.

Spain

Conformant

Tin

Mineracao Taboca S.A.

Brazil

Conformant

Tin

Minsur

Peru

Conformant

Tin

Mitsubishi Materials Corporation

Japan

Conformant

Tin

Modeltech Sdn Bhd

Malaysia

Smelter Look-Up List Tab Only

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Viet Nam

Smelter Look-Up List Tab Only

Tin

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

Thailand

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

Philippines

Conformant

Tin

Operaciones Metalurgicas S.A.

Bolivia

Conformant

Tin

PT Aries Kencana Sejahtera

Indonesia

Active

Tin

PT Artha Cipta Langgeng

Indonesia

Conformant

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

Conformant

Tin

PT Babel Inti Perkasa

Indonesia

Conformant

Tin

PT Babel Surya Alam Lestari

Indonesia

Conformant

Tin

PT Bangka Serumpun

Indonesia

Conformant

Tin

PT Bukit Timah

Indonesia

Active

Tin

PT Menara Cipta Mulia

Indonesia

Conformant

Tin

PT Mitra Stania Prima

Indonesia

Conformant

Tin

PT Prima Timah Utama

Indonesia

Conformant

Tin

PT Rajawali Rimba Perkasa

Indonesia

Conformant

Tin

PT Refined Bangka Tin

Indonesia

Conformant

Tin

PT Stanindo Inti Perkasa

Indonesia

Conformant

Tin

PT Timah Tbk Kundur

Indonesia

Conformant

Tin

PT Timah Tbk Mentok

Indonesia

Conformant

Tin

PT Tinindo Inter Nusa

Indonesia

Conformant

Tin

Resind Industria e Comercio Ltda.

Brazil

Conformant

Tin

Rui Da Hung

Taiwan

Conformant


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Tin

Soft Metais Ltda.

Brazil

Conformant

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

Viet Nam

Conformant

Tin

Thaisarco

Thailand

Conformant

Tin

Tin Technology & Refining

United States

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Viet Nam

Smelter Look-Up List Tab Only

Tin

White Solder Metalurgia e Mineracao Ltda.

Brazil

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

Conformant

Tin

Yunnan Tin Company Limited

China

Conformant

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

China

Smelter Look-Up List Tab Only

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

China

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

China

Conformant

 

We note the following in connection with the above table:

 

a)Not all of the included smelters and refiners may have processed the necessary 3TG contained in our in-scope products, since most Suppliers reported at a “company level,” meaning that they reported the 3TG contained in all of their products, not just those in the products they sold to us. Some Suppliers also may have reported smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. In addition, the smelters and refiners reflected above may not include all of the smelters and refiners in our supply chain, since some Suppliers did not identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products, and not all of the Suppliers responded to our inquiries. 

 

b)The table only includes entities that were listed as smelters or refiners by the RMI. 

 

c)Smelter or refiner status information in the table is from information furnished by the Service Provider on April 14, 2022. 

 

d)“Conformant” means that a smelter has successfully completed an assessment against the applicable Responsible Minerals Assurance Process (“RMAP”) standard or an equivalent cross-recognized assessment. Smelters and refiners listed as “re-audit in progress” are still considered to be Conformant. Included smelters and refiners were not necessarily Conformant for all or part of 2021 and may not continue to be Conformant for any future period. 

 

e)“Active” means that the smelter or refiner is currently engaged in the RMAP but a conformance determination has yet to be made. 

 

f)“Smelter Look-up List Tab Only” means that a smelter or refiner is listed on the Smelter Look-up tab list of the CMRT, but is not listed as “Conformant” or “Active.” The RMI notes on its website that the operational impacts of COVID-19 have led to postponements of some RMAP assessments. The RMI website also notes that, due to the eligibility criteria for an RMAP assessment, smelters are sometimes  


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removed from the Conformant list because they are no longer operational and not because they are non-conformant to the standard.  

 

g)Smelter or refiner status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us. 

 

h)Smelter and refiner country location is based on information published by the RMI, without independent verification by us. 

 

Country of Origin Information

 

The identified countries of origin of the 3TG processed by the Conformant smelters and refiners listed in the table above may have included the countries listed below, as well as other countries, based on information provided by the RMI to its members. The Company has not been able to reliably determine the country of origin of any of the other smelters or refiners listed in the table.

 

Argentina

Germany

Niger

Uganda*

Armenia

Ghana

Nigeria

United Kingdom

Australia

Guatemala

Oman

United States of America

Austria

Guinea

Papua New Guinea

Uruguay

Azerbaijan

Guyana

Peru

Uzbekistan

Belgium

Honduras

Philippines

Vietnam

Benin

India

Portugal

Zimbabwe

Bolivia

Indonesia

Russia

 

Botswana

Ivory Coast

Rwanda*

 

Brazil

Japan

Saudi Arabia

 

Bulgaria

Kazakhstan

Senegal

 

Burkina Faso

Kenya

Serbia

 

Burundi*

Krygyzstan

Sierra Leone

 

Canada

Laos

Singapore

 

Chile

Liberia

Slovakia

 

China

Madagascar

Solomon Islands

 


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Colombia

Malaysia

South Africa

 

Costa Rica

Mali

South Korea

 

Cyprus

Mauritania

Spain

 

Democratic Republic of the Congo*

Mexico

Sudan

 

Dominican Republic

Mongolia

Suriname

 

Ecuador

Montenegro

Swaziland

 

Eritrea

Morocco

Sweden

 

Ethiopia

Mozambique

Taiwan

 

Fiji

Myanmar

Tajikistan

 

Finland

Namibia

Tanzania*

 

French Guiana

New Zealand

Thailand

 

Georgia

Nicaragua

Turkey

 

 

 

* Represents a Covered Country.

 

Alternatively, or in addition, some of the Conformant smelters and refiners may have sourced from recycled or scrap sources.

 

 


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