EXHIBIT 1.01
Conflict Minerals Report of Helen of Troy Limited
In accord with Rule 13p-1 under the Securities Exchange Act of 1934
This is the Conflict Minerals Report of Helen of Troy Limited (“Helen of Troy”, the “Company”) for calendar year 2019 (excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accord with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”).
1. Introduction
Helen of Troy is a leading global consumer products company offering creative solutions for our customers through a diversified portfolio of well-recognized and widely trusted brands. The Company has built leading market positions through new product innovation, product quality and competitive pricing. Helen of Troy was incorporated as Helen of Troy Corporation in Texas in 1968 and reorganized as Helen of Troy Limited in Bermuda in 1994. Helen of Troy has three business segments: Housewares, Health & Home, and Beauty. The Housewares segment provides a broad range of products to help with food preparation, cooking, cleaning, organization, beverage service, and other tasks to ease everyday living for families. Sales for the segment are primarily to retailers, with some direct-to-consumer product distribution. The Health & Home segment provides healthcare and home comfort products. Sales for the segment are primarily to retailers, with some direct-to-consumer product distribution. The Beauty segment provides personal care, beauty care and wellness products including hair styling appliances; grooming tools; decorative haircare accessories; and liquid-, solid- and powder-based personal care products. This segment sells primarily to retailers and beauty supply wholesalers. Helen of Troy purchases its products from unaffiliated manufacturers, most of which are located in China, Mexico and the United States.
Helen of Troy contracts to have products manufactured that may contain gold, tantalum, tin and tungsten ("3TG"). As these materials may be necessary to Helen of Troy’s products, the Company has embarked on a process to trace the origin of these metals to determine whether its sourcing practices support conflict or human rights abuses in the Democratic Republic of Congo ("DRC") and the surrounding area (the "Covered Countries"). The intent of this Conflict Minerals Report ("CMR") is to describe this due diligence process.
2. Product Description
Helen of Troy contracts to have products manufactured that may contain 3TG, such as houseware, health, home, and beauty consumer products. Helen of Troy purchases finished product and is therefore several tiers removed from the mining operations. The Company does not purchase any materials directly from smelters or refiners, so Helen of Troy must rely on its suppliers to provide reliable and accurate information about 3TG.
Helen of Troy’s suppliers were requested to use the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (CMRT) to identify gold, tantalum, tin and tungsten smelters or refiners (SORs) and associated countries of origin. Verified SORs were matched against available lists of processors that have been certified by internationally-recognized industry validation schemes, such as the Responsible Minerals Assurance Process (RMAP), the London Bullion Market Association Good Delivery Program (LBMA), and the Responsible Jewelry Council Chain-of-Custody Certification (RJC). Conflict free certification information is current as of April 1, 2020.
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3. | Reasonable Country of Origin Inquiry Description |
Helen of Troy obtained the aforementioned product information by implementing a Reasonable Country of Origin Inquiry ("RCOI"). Helen of Troy assembled an internal team comprised of representatives from Helen of Troy’s finance, legal and supply chain departments. Helen of Troy engaged Source Intelligence ("SI"), a third party information management service provider, to gather information from suppliers and establish a system of controls and transparency over its supply chain. This is the seventh consecutive year the Company worked with SI. Helen of Troy’s Tier 1 suppliers were engaged by SI to collect information regarding the presence and sourcing of 3TG used in the products supplied to them. Information was collected and stored using an online platform provided by SI.
Supplier Engagement
As in previous years, the RCOI began with an introduction email from Helen of Troy to suppliers describing its conflict minerals reporting requirements. Following that introduction email, a subsequent email was sent to suppliers containing a registration and survey request link to the online data collection platform. In an effort to increase awareness of the Company’s conflict minerals reporting requirements, supporting regulation, and frequently asked questions (FAQs) concerning 3TG mineral tracing, Helen of Troy’s suppliers were given access to an online Supplier Resource Center. The Supplier Resource Center provided educational information to facilitate a deeper understanding of conflict minerals and to inform suppliers as to why information was being requested.
Subsequent engagement followed these steps:
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• | Following the initial introductions to the program and information request, up to three reminder emails were sent to each non-responsive supplier requesting survey completion. |
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• | Suppliers who remained non-responsive to these email reminders were contacted by telephone and offered assistance. This assistance included, but was not limited to, further information about the Conflict Minerals Compliance Program, an explanation of why the information was being collected, a review of how the information would be used, and clarification regarding how the information could be provided. |
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• | If, after these efforts, a given supplier still did not register with the system or provide the information requested, an escalation process was initiated. The escalation process consisted of direct outreach by Helen of Troy. Specifically, Helen of Troy contacted these suppliers by email to request their participation in the program. Source Intelligence followed up with an email in a timely manner. |
Information Requested
Suppliers were asked to provide information regarding the sourcing of their materials with the ultimate goal of identifying the 3TG SORs and associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT were asked to upload this document into the online data collection platform or to provide this information in the online survey version. Suppliers were given nine language options to choose from when submitting the CMRT.
Where a supplier was unable to provide a CMRT, Source Intelligence requested information on its suppliers of products or components which may require 3TG for their production or functionality. These Tier 2 suppliers, and subsequent tiers of suppliers as needed, were then engaged following the contact procedures explained above. When contact information was provided, Tier 2 and beyond suppliers were contacted via email or phone in order to build a chain-of-custody back to the 3TG SOR.
Suppliers had the ability to share information at a level with which they are most comfortable, i.e. company, product or user-defined, but the declaration scope had to be specified. Supplier responses were evaluated for plausibility, consistency, and gaps. Additional supplier contacts were conducted as needed. At all times during the above steps, Helen of Troy’s internal team was able to monitor progress 24 hours per day, 7 days per week via access to the Helen of Troy online data collection platform provided by SI.
Helen of Troy’s RCOI process revealed the following:
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• | A total of 131 Tier 1 suppliers were identified by Helen of Troy as potentially in-scope for conflict mineral reporting purposes and all were contacted as part of the RCOI process. The survey response rate among these suppliers was 93% or 122 responding suppliers. |
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• | Out of the 122 responding suppliers, 32% (39 suppliers) indicated conflict minerals were necessary to the functionality or production of the products they supply to Helen of Troy. |
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• | The 39 suppliers using conflict minerals provided names of 281 verified SORs. |
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• | Of the 281 verified SORs, 225 are currently certified, 2 are actively moving through the certification process, and 54 have unknown status. 237 of the 281 verified SORs had no indication of sourcing from the DRC/Covered Countries. |
The following table lists the verified SORs provided by Helen of Troy’s suppliers, along with the certification status of each SOR as of April 1, 2020.
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
1 | Gold | 8853 S.p.A. | RMAP |
2 | Gold | Abington Reldan Metals, LLC | Unknown |
3 | Gold | Advanced Chemical Company | RMAP |
4 | Gold | African Gold Refinery | Unknown |
5 | Gold | Aida Chemical Industries Co., Ltd. | RMAP |
6 | Gold | Al Etihad Gold Refinery DMCC | RMAP |
7 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | LBMA, RJC, RMAP |
8 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | LBMA, RMAP |
9 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | LBMA, RMAP |
10 | Gold | Argor-Heraeus S.A. | LBMA, RMAP |
11 | Gold | Asahi Pretec Corp. | LBMA, RMAP |
12 | Gold | Asahi Refining Canada Ltd. | LBMA, RMAP |
13 | Gold | Asahi Refining USA Inc. | LBMA, RMAP |
14 | Gold | Asaka Riken Co., Ltd. | RMAP |
15 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Unknown |
16 | Gold | AU Traders and Refiners | RJC, RMAP |
17 | Gold | Aurubis AG | LBMA, RMAP |
18 | Gold | Bangalore Refinery | RMAP |
19 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | LBMA, RMAP |
20 | Gold | Boliden AB | LBMA, RMAP |
21 | Gold | C. Hafner GmbH + Co. KG | LBMA, RJC, RMAP |
22 | Gold | Caridad | Unknown |
23 | Gold | CCR Refinery - Glencore Canada Corporation | LBMA, RMAP |
24 | Gold | Cendres + Metaux S.A. | RMAP |
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
25 | Gold | Chimet S.p.A. | LBMA, RMAP |
26 | Gold | Chugai Mining | RMAP |
27 | Gold | Daye Non-Ferrous Metals Mining Ltd. | Unknown |
28 | Gold | Degussa Sonne / Mond Goldhandel GmbH | Unknown |
29 | Gold | Dijllah Gold Refinery FZC | Unknown |
30 | Gold | DODUCO Contacts and Refining GmbH | RMAP |
31 | Gold | Dowa | RMAP |
32 | Gold | DS PRETECH Co., Ltd. | RMAP |
33 | Gold | DSC (Do Sung Corporation) | RMAP |
34 | Gold | Eco-System Recycling Co., Ltd. East Plant | RMAP |
35 | Gold | Emirates Gold DMCC | LBMA, RMAP |
36 | Gold | Fidelity Printers and Refiners Ltd. | Unknown |
37 | Gold | Fujairah Gold FZC | Unknown |
38 | Gold | GCC Gujrat Gold Centre Pvt. Ltd. | Unknown |
39 | Gold | Geib Refining Corporation | RMAP |
40 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | LBMA, RMAP |
41 | Gold | Great Wall Precious Metals Co., Ltd. of CBPM | Unknown |
42 | Gold | Guangdong Jinding Gold Limited | Unknown |
43 | Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | Unknown |
44 | Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | Unknown |
45 | Gold | Heimerle + Meule GmbH | LBMA, RMAP |
46 | Gold | Heraeus Metals Hong Kong Ltd. | LBMA, RJC, RMAP |
47 | Gold | Heraeus Precious Metals GmbH & Co. KG | LBMA, RMAP |
48 | Gold | Hunan Chenzhou Mining Co., Ltd. | Unknown |
49 | Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | Unknown |
50 | Gold | HwaSeong CJ CO., LTD. | Unknown |
51 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | LBMA, RMAP |
52 | Gold | International Precious Metal Refiners | Unknown |
53 | Gold | Ishifuku Metal Industry Co., Ltd. | LBMA, RMAP |
54 | Gold | Istanbul Gold Refinery | LBMA, RMAP |
55 | Gold | Italpreziosi | RJC, RMAP |
56 | Gold | Japan Mint | LBMA, RMAP |
57 | Gold | Jiangxi Copper Co., Ltd. | LBMA, RMAP |
58 | Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Unknown |
59 | Gold | JSC Uralelectromed | LBMA, RMAP |
60 | Gold | JX Nippon Mining & Metals Co., Ltd. | LBMA, RMAP |
61 | Gold | Kaloti Precious Metals | Unknown |
62 | Gold | Kazakhmys Smelting LLC | Unknown |
63 | Gold | Kazzinc | LBMA, RMAP |
64 | Gold | Kennecott Utah Copper LLC | LBMA, RMAP |
65 | Gold | KGHM Polska Miedz Spolka Akcyjna | RMAP |
66 | Gold | Kojima Chemicals Co., Ltd. | RMAP |
67 | Gold | Korea Zinc Co., Ltd. | RMAP |
68 | Gold | Kyrgyzaltyn JSC | LBMA, RMAP |
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
69 | Gold | Kyshtym Copper-Electrolytic Plant ZAO | Unknown |
70 | Gold | L'azurde Company For Jewelry | Unknown |
71 | Gold | Lingbao Gold Co., Ltd. | Unknown |
72 | Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Unknown |
73 | Gold | L'Orfebre S.A. | RMAP |
74 | Gold | LS-NIKKO Copper Inc. | LBMA, RMAP |
75 | Gold | LT Metal Ltd. | RMAP |
76 | Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | Unknown |
77 | Gold | Marsam Metals | RMAP |
78 | Gold | Materion | RMAP |
79 | Gold | Matsuda Sangyo Co., Ltd. | LBMA, RMAP |
80 | Gold | Metalor Technologies (Hong Kong) Ltd. | LBMA, RJC, RMAP |
81 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | LBMA, RJC, RMAP |
82 | Gold | Metalor Technologies (Suzhou) Ltd. | RJC, RMAP |
83 | Gold | Metalor Technologies S.A. | LBMA, RJC, RMAP |
84 | Gold | Metalor USA Refining Corporation | LBMA, RJC, RMAP |
85 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | LBMA, RMAP |
86 | Gold | Mitsubishi Materials Corporation | LBMA, RMAP |
87 | Gold | Mitsui Mining and Smelting Co., Ltd. | LBMA, RMAP |
88 | Gold | MMTC-PAMP India Pvt., Ltd. | LBMA, RMAP |
89 | Gold | Modeltech Sdn Bhd | Unknown |
90 | Gold | Morris and Watson | Unknown |
91 | Gold | Moscow Special Alloys Processing Plant | LBMA, RMAP |
92 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | LBMA, RMAP |
93 | Gold | Navoi Mining and Metallurgical Combinat | Unknown |
94 | Gold | NH Recytech Company | Unknown |
95 | Gold | Nihon Material Co., Ltd. | LBMA, RMAP |
96 | Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | RJC, RMAP |
97 | Gold | Ohura Precious Metal Industry Co., Ltd. | RMAP |
98 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | LBMA, RMAP |
99 | Gold | OJSC Novosibirsk Refinery | LBMA, RMAP |
100 | Gold | PAMP S.A. | LBMA, RMAP |
101 | Gold | Pease & Curren | Unknown |
102 | Gold | Penglai Penggang Gold Industry Co., Ltd. | Unknown |
103 | Gold | Planta Recuperadora de Metales SpA | RMAP |
104 | Gold | Prioksky Plant of Non-Ferrous Metals | LBMA, RMAP |
105 | Gold | PT Aneka Tambang (Persero) Tbk | LBMA, RMAP |
106 | Gold | PX Precinox S.A. | LBMA, RMAP |
107 | Gold | QG Refining, LLC | Unknown |
108 | Gold | Rand Refinery (Pty) Ltd. | LBMA, RMAP |
109 | Gold | Refinery of Seemine Gold Co., Ltd. | Unknown |
110 | Gold | REMONDIS PMR B.V. | RMAP |
111 | Gold | Royal Canadian Mint | LBMA, RMAP |
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
112 | Gold | SAAMP | RJC, RMAP |
113 | Gold | Sabin Metal Corp. | Unknown |
114 | Gold | Safimet S.p.A | RMAP |
115 | Gold | SAFINA A.S. | RMAP - Active |
116 | Gold | Sai Refinery | Unknown |
117 | Gold | Samduck Precious Metals | RMAP |
118 | Gold | SAMWON METALS Corp. | Unknown |
119 | Gold | SAXONIA Edelmetalle GmbH | RMAP |
120 | Gold | SEMPSA Joyeria Plateria S.A. | LBMA, RMAP |
121 | Gold | Shandong Humon Smelting Co., Ltd. | Unknown |
122 | Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Unknown |
123 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | LBMA, RMAP |
124 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | LBMA, RMAP |
125 | Gold | Singway Technology Co., Ltd. | RMAP |
126 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | LBMA, RMAP |
127 | Gold | Solar Applied Materials Technology Corp. | LBMA, RMAP |
128 | Gold | State Research Institute Center for Physical Sciences and Technology | Unknown |
129 | Gold | Sudan Gold Refinery | Unknown |
130 | Gold | Sumitomo Metal Mining Co., Ltd. | LBMA, RMAP |
131 | Gold | SungEel HiMetal Co., Ltd. | RMAP |
132 | Gold | T.C.A S.p.A | LBMA, RMAP |
133 | Gold | Tanaka Kikinzoku Kogyo K.K. | LBMA, RMAP |
134 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | LBMA, RMAP |
135 | Gold | Tokuriki Honten Co., Ltd. | LBMA, RMAP |
136 | Gold | Tongling Nonferrous Metals Group Co., Ltd. | Unknown |
137 | Gold | Tony Goetz NV | Unknown |
138 | Gold | TOO Tau-Ken-Altyn | RMAP |
139 | Gold | Torecom | RMAP |
140 | Gold | Umicore Brasil Ltda. | LBMA, RMAP |
141 | Gold | Umicore Precious Metals Thailand | RJC, RMAP |
142 | Gold | Umicore S.A. Business Unit Precious Metals Refining | LBMA, RMAP |
143 | Gold | United Precious Metal Refining, Inc. | RMAP |
144 | Gold | Valcambi S.A. | LBMA, RJC, RMAP |
145 | Gold | Western Australian Mint (T/a The Perth Mint) | LBMA, RMAP |
146 | Gold | WIELAND Edelmetalle GmbH | RMAP |
147 | Gold | Yamakin Co., Ltd. | RMAP |
148 | Gold | Yokohama Metal Co., Ltd. | RMAP |
149 | Gold | Yunnan Copper Industry Co., Ltd. | Unknown |
150 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | LBMA, RMAP |
151 | Tantalum | Asaka Riken Co., Ltd. | RMAP |
152 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | RMAP |
153 | Tantalum | D Block Metals, LLC | RMAP |
154 | Tantalum | Exotech Inc. | RMAP |
155 | Tantalum | F&X Electro-Materials Ltd. | RMAP |
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
156 | Tantalum | FIR Metals & Resource Ltd. | RMAP |
157 | Tantalum | Global Advanced Metals Aizu | RMAP |
158 | Tantalum | Global Advanced Metals Boyertown | RMAP |
159 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | RMAP |
160 | Tantalum | H.C. Starck Co., Ltd. | RMAP |
161 | Tantalum | H.C. Starck Hermsdorf GmbH | RMAP |
162 | Tantalum | H.C. Starck Inc. | RMAP |
163 | Tantalum | H.C. Starck Ltd. | RMAP |
164 | Tantalum | H.C. Starck Smelting GmbH & Co. KG | RMAP |
165 | Tantalum | H.C. Starck Tantalum and Niobium GmbH | RMAP |
166 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | RMAP |
167 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | RMAP |
168 | Tantalum | Jiangxi Tuohong New Raw Material | RMAP |
169 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | RMAP |
170 | Tantalum | Jiujiang Tanbre Co., Ltd. | RMAP |
171 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | RMAP |
172 | Tantalum | KEMET Blue Metals | RMAP |
173 | Tantalum | LSM Brasil S.A. | RMAP |
174 | Tantalum | Metallurgical Products India Pvt., Ltd. | RMAP |
175 | Tantalum | Mineracao Taboca S.A. | RMAP |
176 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | RMAP |
177 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | RMAP |
178 | Tantalum | NPM Silmet AS | RMAP |
179 | Tantalum | PRG Dooel | RMAP |
180 | Tantalum | QuantumClean | RMAP |
181 | Tantalum | Resind Industria e Comercio Ltda. | RMAP |
182 | Tantalum | Solikamsk Magnesium Works OAO | RMAP |
183 | Tantalum | Taki Chemical Co., Ltd. | RMAP |
184 | Tantalum | Telex Metals | RMAP |
185 | Tantalum | Ulba Metallurgical Plant JSC | RMAP |
186 | Tantalum | XinXing Haorong Electronic Material Co., Ltd. | RMAP |
187 | Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | RMAP |
188 | Tin | Alpha | RMAP |
189 | Tin | An Vinh Joint Stock Mineral Processing Company | Unknown |
190 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | RMAP |
191 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | RMAP |
192 | Tin | China Tin Group Co., Ltd. | RMAP |
193 | Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | Unknown |
194 | Tin | Dowa | RMAP |
195 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Unknown |
196 | Tin | EM Vinto | RMAP |
197 | Tin | Estanho de Rondonia S.A. | Unknown |
198 | Tin | Fenix Metals | RMAP |
199 | Tin | Gejiu Kai Meng Industry and Trade LLC | RMAP |
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
200 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | RMAP |
201 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | RMAP |
202 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | RMAP |
203 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | RMAP |
204 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | RMAP |
205 | Tin | HuiChang Hill Tin Industry Co., Ltd. | RMAP |
206 | Tin | Huichang Jinshunda Tin Co., Ltd. | RMAP |
207 | Tin | Jiangxi New Nanshan Technology Ltd. | RMAP |
208 | Tin | Magnu's Minerais Metais e Ligas Ltda. | RMAP |
209 | Tin | Malaysia Smelting Corporation (MSC) | RMAP |
210 | Tin | Melt Metais e Ligas S.A. | RMAP |
211 | Tin | Metallic Resources, Inc. | RMAP |
212 | Tin | Metallo Belgium N.V. | RMAP |
213 | Tin | Metallo Spain S.L.U. | RMAP |
214 | Tin | Mineracao Taboca S.A. | RMAP |
215 | Tin | Minsur | RMAP |
216 | Tin | Mitsubishi Materials Corporation | RMAP |
217 | Tin | Modeltech Sdn Bhd | Unknown |
218 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Unknown |
219 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | RMAP |
220 | Tin | O.M. Manufacturing Philippines, Inc. | RMAP |
221 | Tin | Operaciones Metalurgicas S.A. | RMAP |
222 | Tin | Pongpipat Company Limited | Unknown |
223 | Tin | PT Artha Cipta Langgeng | RMAP |
224 | Tin | PT ATD Makmur Mandiri Jaya | RMAP |
225 | Tin | PT Menara Cipta Mulia | RMAP |
226 | Tin | PT Mitra Stania Prima | RMAP |
227 | Tin | PT Refined Bangka Tin | RMAP |
228 | Tin | PT Timah Tbk Kundur | RMAP |
229 | Tin | PT Timah Tbk Mentok | RMAP |
230 | Tin | Resind Industria e Comercio Ltda. | RMAP |
231 | Tin | Rui Da Hung | RMAP |
232 | Tin | Soft Metais Ltda. | RMAP |
233 | Tin | Super Ligas | Unknown |
234 | Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | RMAP |
235 | Tin | Thaisarco | RMAP |
236 | Tin | Tin Technology & Refining | RMAP |
237 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Unknown |
238 | Tin | White Solder Metalurgia e Mineracao Ltda. | RMAP |
239 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | RMAP |
240 | Tin | Yunnan Tin Company Limited | RMAP |
241 | Tungsten | A.L.M.T. TUNGSTEN Corp. | RMAP |
242 | Tungsten | ACL Metais Eireli | RMAP |
243 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | RMAP |
244 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | RMAP |
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Number | Metal | Official Smelter Name | Conflict-Free Certifications |
245 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | RMAP |
246 | Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | RMAP |
247 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | RMAP |
248 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | RMAP |
249 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | RMAP |
250 | Tungsten | Global Tungsten & Powders Corp. | RMAP |
251 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | RMAP |
252 | Tungsten | H.C. Starck Smelting GmbH & Co. KG | RMAP |
253 | Tungsten | H.C. Starck Tungsten GmbH | RMAP |
254 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | RMAP |
255 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | RMAP |
256 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | RMAP |
257 | Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | RMAP |
258 | Tungsten | Hydrometallurg, JSC | RMAP |
259 | Tungsten | Japan New Metals Co., Ltd. | RMAP |
260 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | RMAP |
261 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | RMAP |
262 | Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Unknown |
263 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | RMAP |
264 | Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | RMAP - Active |
265 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | RMAP |
266 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | RMAP |
267 | Tungsten | Kennametal Fallon | RMAP |
268 | Tungsten | Kennametal Huntsville | RMAP |
269 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | RMAP |
270 | Tungsten | Masan Tungsten Chemical LLC (MTC) | RMAP |
271 | Tungsten | Moliren Ltd. | RMAP |
272 | Tungsten | Niagara Refining LLC | RMAP |
273 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | RMAP |
274 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | RMAP |
275 | Tungsten | Unecha Refractory Metals Plant | RMAP |
276 | Tungsten | Wolfram Bergbau und Hutten AG | RMAP |
277 | Tungsten | Woltech Korea Co., Ltd. | RMAP |
278 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | RMAP |
279 | Tungsten | Xiamen Tungsten Co., Ltd. | RMAP |
280 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | RMAP |
281 | Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | RMAP |
Certification Status:
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1. | Responsible Minerals Assurance Process (RMAP) |
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• | RMAP: The smelter has an active certification or is in the process of renewing their certification. |
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• | RMAP -Active: The smelter is actively moving through the certification process. |
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2. | Responsible Gold Certificate: London Bullion Market Association (LBMA) |
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• | LBMA: The smelter has obtained a Responsible Gold Certification. |
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3. | Chain of Custody Certificate: Responsible Jewelry Council (RJC) |
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• | RJC: The smelter has obtained a Chain-of-Custody Certification. |
Countries of origin for these SORs are believed to include:
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|
Country |
Angola |
Argentina |
Armenia |
Australia |
Austria |
Belarus |
Belgium |
Bermuda |
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 |
Hong Kong |
Hungary |
India |
Indonesia |
Ireland |
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Country |
Israel |
Italy |
Ivory Coast |
Japan |
Jersey |
Kazakhstan |
Kenya |
Korea, Republic of |
Kyrgyzstan |
Laos |
Luxembourg |
Madagascar |
Malaysia |
Mali |
Mexico |
Mongolia |
Morocco |
Mozambique |
Myanmar |
Namibia |
Netherlands |
New Zealand |
Niger |
Nigeria |
No known country of origin. |
Papua New Guinea |
Peru |
Philippines |
Poland |
Portugal |
Recycle/Scrap |
Russian Federation |
Rwanda |
Saudi Arabia |
Sierra Leone |
Singapore |
Slovakia |
South Africa |
South Sudan |
Spain |
Suriname |
Sweden |
Switzerland |
Taiwan |
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|
Country |
Tajikistan |
Tanzania |
Thailand |
Turkey |
Uganda |
United Arab Emirates |
United Kingdom |
United States |
Uzbekistan |
Viet Nam |
Zambia |
Zimbabwe |
Helen of Troy’s due diligence process was designed to conform to the Organization for Economic Cooperation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements1. It is important to note that the OECD Guidance was written for both upstream2 and downstream3 companies in the supply chain. As Helen of Troy is a downstream company in the supply chain, due diligence practices were tailored accordingly.
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• | Step 1- Establish strong company management systems |
Helen of Troy’s conflict minerals policy is publicly available at www.helenoftroy.com. The Company utilizes an internal team comprised of representatives from the finance, legal and supply chain departments to communicate and manage compliance initiatives. Team members work with the suppliers on a continual basis to maintain an open dialog and transparency in the procurement process. Findings are reported to senior management, as well as to the internal audit department. The Company’s internal team efforts are supplemented with a third-party service provider’s extensive knowledge and experience, as well as training seminars on conflict minerals.
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• | Step 2- Identify and assess risk in the supply chain |
The Company continues to refine its list of product categories and suppliers that may fall within the scope of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Expectations with regard to supplier performance, transparency and sourcing are clearly communicated through supplier training. Quality assessments with suppliers are being expanded to encompass compliance initiatives. Suppliers are being encouraged to implement conflict mineral policies with their vendors.
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• | Step 3- Design and implement a strategy to respond to identified risks |
Helen of Troy continues to make improvements on risk management. As RCOI are conducted and additional information becomes available regarding components and materials being used in the Company’s products, potential risks can be tracked and mitigated. The online platform maintained by SI allows Helen of Troy to access and analyze supplier responses as well as SOR information. Any suppliers found to be sourcing from SORs that support conflict in the DRC region will be required to explore alternative sources.
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• | Step 4- Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain |
As part of Helen of Troy’s due diligence, and in conjunction with SI, the Company relies upon the following internationally accepted audit standards to determine which SORs are considered DRC Conflict Free: RMAP, LBMA and RJC. If the SOR is not certified by these internationally-recognized schemes, attempts are made to contact the SOR to gain more information about their sourcing practices, including countries of origin and transfer, and whether there are any internal due diligence procedures in place or other processes to track the chain-of-custody on the source of the SOR’s mineral ores. Relevant information to review includes: whether the SOR has a documented, effective and communicated conflict free policy, an accounting system to support a mass balance of materials processed, and traceability documentation. Internet research is also performed to determine whether there are any outside sources of information regarding the SOR’s sourcing practices.
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• | Step 5- Report on supply chain due diligence |
Helen of Troy reports annually on supply chain due diligence through the Form SD and this CMR filed with the Securities and Exchange Commission. The Form SD is publicly available at www.helenoftroy.com.
6. Steps to Improve Due Diligence
Helen of Troy will endeavor to continuously improve upon its supply chain due diligence efforts via the following measures:
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• | Continue to assess the presence of 3TG in its supply chain |
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• | Clearly communicate expectations with regard to supplier performance, transparency and sourcing |
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• | Increase the response rate for the RCOI process |
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• | Continue to compare RCOI results to information collected via independent conflict free smelter validation programs |
7. Product Determination
Based on its RCOI process, Helen of Troy is unable to determine whether or not various components/materials, which contribute to products sold by its business segments, are DRC conflict free.
8. Independent Private Sector Audit
Based on Helen of Troy’s declaration, a private sector audit is not required.
