EX-1.01 2 a2022formsd_cmr.htm EX-1.01 Document

Exhibit 1.01


Conflict Minerals Report of Omnicell, Inc. for the reporting period from
January 1, 2022 to December 31, 2022


Introduction

This Conflict Minerals Report (the “Report”) of Omnicell, Inc. (“Omnicell” or the “Company”) has been prepared pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period from January 1, 2022 to December 31, 2022 (the “Reporting Period”).

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which the Company collectively refers to in this Report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“3TG”). The “Covered Countries,” for the purposes of the Rule and this Report, are the Democratic Republic of the Congo (“DRC”) and each adjoining country. Certain other terms in this Report are defined in the Rule, Form SD or SEC Release No. 34-67716 issued by the Securities and Exchange Commission (“SEC”) on August 22, 2012, and the reader is referred to those sources for such definitions.

Company and Product Overview

Omnicell is headquartered in the United States with a small number of operations offices located globally. The Company’s major products and related services are medication management solutions and adherence tools for healthcare systems and pharmacies. The Company’s product offerings are designed to help increase operational efficiency, reduce medication errors, improve patient safety and enhance patient engagement and adherence.

This Report relates to products: (i) for which Conflict Minerals are necessary to their functionality or production; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2022. These products, which are referred to in this Report collectively as the “Covered Products,” include the following: secure dispensing systems; storage, retrieval and packaging systems; supply management systems; pharmacy sealers; sterile compounding solutions; semi-automated filling equipment and pharmacy-automated systems for medication packaging.

As a “downstream” purchaser of products or components that contain Conflict Minerals, the Company is at the end of a very long supply chain. It manufactures or contracts to manufacture products and does not directly source Conflict Minerals from mines, smelters or refiners, nor does it specifically design Conflict Minerals into its products.

Reasonable Country-of-Origin Inquiry

The Company identified the following categories of suppliers that it reasonably believed represent the highest risk of providing products or components potentially containing Conflict Minerals: original equipment manufacturers, contract manufacturers, suppliers of cables, suppliers of printed circuit boards, and electromechanical and metals suppliers (including off-the-shelf suppliers). Based on these criteria, the Company reviewed its list of suppliers for Covered Products, the manufacture of which was completed in 2022, and determined that 57 suppliers may fall within scope. For those 57 suppliers, the Company conducted a good faith, reasonable country-of-origin inquiry (“RCOI”) regarding the Conflict Minerals that were necessary to the functionality or production of the Covered Products (the “necessary Conflict Minerals”). The RCOI was reasonably
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designed to determine whether any of the necessary Conflict Minerals originated in the Covered Countries and whether any of the necessary Conflict Minerals may have been from recycled or scrap sources. To that end, these suppliers were contacted and asked to complete the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). With the assistance of its third-party consultant, the Company reviewed and analyzed the quality of the responses and assessed the risk level of these suppliers. Of the 57 suppliers contacted, 89% (51 suppliers) responded to Omnicell’s request, either by providing a CMRT or a statement in lieu of a completed CMRT. Of those 51 suppliers, two suppliers returned a partially completed CMRT (missing smelter list or effective date); in this case, the Company is considering those suppliers to be “responsive.” The remaining six suppliers did not return a response or returned incomplete CMRTs. As such, Omnicell is considering them “non-responsive suppliers.” Of the six non-responsive suppliers, Omnicell believes that at least two of these “non-responsive suppliers” may fall within scope based on previous declarations and other communications.

Design of Due Diligence

The Company’s due diligence measures have been designed to conform, in all material respects, to the internationally recognized due diligence framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), consistent with the Company’s position in the minerals supply chain as a downstream purchaser. The scope of the Company’s due diligence remained on Conflict Minerals - namely tin, tantalum, tungsten, columbite-tantalite (coltan), cassiterite and wolframite and gold.

Description of Due Diligence Measures

The Company’s due diligence measures performed with respect to Covered Products for the Reporting Period included the following:

1.OECD Step 1 – Establish Strong Company Management Systems

Conflict Minerals policy. The Company’s Conflict Minerals policy was communicated to in-scope suppliers during the Reporting Period and is posted on its external website at:

https://s27.q4cdn.com/604413039/files/doc_downloads/governance/2022/08/OMCL-Conflict-Minerals-Policy-(FINAL-2022).pdf.

Conflict Minerals team. A cross-functional team comprised of senior and executive management personnel, in consultation with outside experts, is responsible for implementing various aspects of the Company’s Conflict Minerals program and reporting to the executive leadership team, as needed, to provide updates regarding the Company’s Conflict Minerals program.

System of controls and transparency. The Company maintains a Supplier Quality Manual (Revision 4, dated 2020) with a section (section 3.5) dedicated to Conflict Minerals, integrated within its quality management systems as a standard operating procedure, which it provides to suppliers. Pursuant to the Supplier Quality Manual, the Company may request its suppliers to complete a CMRT. The Company collects and maintains supplier due diligence records and survey responses in an electronic database, along with other information necessary to support its Conflict Minerals inquiry and reporting. The Company has also engaged the services of a third-party consultant to analyze the results of the CMRTs and to prepare the related risk assessment, which the Company subsequently reviews.

Strengthen engagement with suppliers. In addition to the initial outreach to in-scope suppliers directing such suppliers to the Company’s Conflict Minerals policy and requesting that they complete the CMRT, the Company communicates its risk analysis review findings to certain suppliers that the Company considers to have a weak conflict minerals program based on completed CMRTs and follows up with
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these suppliers regarding incomplete or inconsistent responses through periodic business reviews or other means. As the Company enters new business relationships, or as contracts renew, the Company has also included Conflict Minerals-related provisions in its contracts with direct suppliers regarding responsible sourcing and related reporting requirements.

Grievance mechanism. The Company’s publicly available Conflict Minerals policy directs suppliers and other stakeholders to report any questions or concerns about the policy by emailing the Company at conflictminerals@omnicell.com.

2.OECD Step 2 – Identify and Assess Risk in the Supply Chain

To identify risk in its supply chain, the Company relied on its suppliers to provide information on the presence, use, source and chain of custody of the Conflict Minerals contained in supplier products or components included in the Covered Products by requesting that in-scope suppliers complete the CMRT. With the assistance of its third-party consultant, the Company reviewed suppliers’ completed CMRTs. The Company continues to follow up through periodic business reviews or other means with certain suppliers considered to have a weak conflict minerals program based primarily on a review of plausibility, consistency and gaps in information provided in their completed CMRTs, as well as sourcing practices and policies, as well as with the two suppliers that did not provide fully completed CMRTs. Additional internal due diligence is in operation to further assess the suppliers’ conflict minerals program, sourcing practices, policies and procedures, regulatory compliance, and operational controls. The Company’s consultant compared the names of smelters and refiners listed by suppliers in completed CMRTs against lists published by the RMI and the U.S. Department of Commerce to verify that the identified facilities are known metal processors. The Company’s consultant also compared the identified smelters and facilities against lists published by the Responsible Minerals Assurance Process (“RMAP”), developed by the RMI, of smelters and refiners that have been certified as conflict-free (i.e., conformant with RMAP assessment protocols) or that are “active” in the RMAP process (i.e., they have agreed to participate in the RMAP but the audit process has yet to be completed).

3.OECD Step 3 – Design and Implement a Strategy to Respond to Risk

The Company has developed a strategy for addressing supply chain risks identified over the course of its due diligence, including where suppliers do not cooperate or ultimately, notwithstanding encouragement from the Company, do not source from smelters or refiners that have been certified as conflict-free by the RMAP. This risk-mitigation strategy includes, depending on the issues with respect to suppliers the Company considers to have a weak conflict minerals programs based on completed CMRTs, performing audits, cautioning the supplier, providing additional education and other corrective actions, giving the supplier an opportunity to address the risks, monitoring and tracking performance, continued incorporation of Conflict Minerals requirements into the Company’s contracts with direct suppliers, as well as its periodic business review and scoring process with in-scope suppliers and escalating issues to management as appropriate. If such a supplier is unable to source from smelters or refiners that have been certified as conflict-free, the Company would review the risk on a case-by-case basis and determine proper strategies, such as alternate sourcing, if reasonably available.

4.OECD Step 4 – Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

As a downstream purchaser, the Company relies on the RMAP to perform independent third-party audits of the smelters and refiners within its supply chain. The Company encourages its suppliers to implement responsible sourcing to use Conflict Minerals only from smelters or refiners that have been certified as conflict-free through the RMAP.

5.OECD Step 5 – Report on Supply Chain Due Diligence

The Company expects to report annually, to the extent required by the Rule, and has posted its Form SD containing this Report on its website at: https://ir.omnicell.com/financials/sec-filings/default.aspx.
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Results of Due Diligence Performed

The due diligence measures described above revealed the following:
As mentioned above, of the 57 suppliers contacted for the Reporting Period, 89% (51 suppliers) provided responses, 14 of which returned a CMRT declaring it sourced 3TG. As noted above, two suppliers returned partially completed CMRTs (missing smelter list or effective date), which the Company considers to be “responsive.”
The overall response rate has increased compared to the previous years, primarily as a result of increased and enhanced outreach by the Company, which the Company believes confirms that the Conflict Minerals program generally continues to be more widely accepted among its suppliers and manufacturers than in the initial years of the program.
Of the 51 suppliers that responded, 49 suppliers did so by providing a CMRT, 14 of which reported having 3TG in their products. Of those 14 suppliers, 10 were considered to have weak conflict minerals programs based primarily on a review of plausibility, consistency and gaps in information provided in their completed CMRTs, as well as sourcing practices and policies. According to the same criteria, 2 suppliers were categorized as medium risk. The Company intends to follow up with certain suppliers, including those who did not provide completed CMRTs, through periodic business reviews or other means.

During the Reporting Period, and on the basis of past performance, the Company provided two online training sessions for its in-scope suppliers, which were held in English and Chinese. The Company also conducted two on-site assessments of suppliers through an independent audit firm. The Company plans to further re-examine its policy regarding the timing of future supplier engagements throughout 2023.

Identified Smelters and Refiners

The Company has listed on Appendix 1 the smelters and refiners identified by its suppliers in completed CMRTs as a result of the Company’s RCOI and due diligence. Out of the 14 suppliers that provided CMRT smelter lists, six provided the smelters at the product or similar level (i.e., they provided information for the particular types of products and components they supplied to the Company) and eight provided smelters at the company level (i.e., they provided information regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components used in the Covered Products). As a result, some of the smelters and refiners reported to the Company and identified on Appendix 1 may not actually have been used to process the necessary Conflict Minerals in the Covered Products.

Identified Countries of Origin

The Company does not have sufficient information to reliably determine the countries of origin of all the necessary Conflict Minerals in the Covered Products given that certain suppliers provided inconsistent or incomplete responses or provided information at the company level. However, based on information provided by the Company’s in-scope suppliers in completed CMRTs, the Company believes that the countries of origin may include the countries listed on Appendix 2. As discussed above, because some suppliers provided information at the company level, there may be countries of origin identified in Appendix 2 that are not the countries of origin of the necessary Conflict Minerals included in the Covered Products. As a result, while certain Covered Countries are identified in Appendix 2, the Company is unable to reliably determine whether any of the necessary Conflict Minerals in the Covered Products originated in the Covered Countries or whether such Conflict Minerals were entirely from recycled or scrap sources or were from other conflict free sources.

Efforts to Determine Mine or Location of Origin

The Company’s efforts to determine the mines or locations of origin included the use of the due diligence measures described above.
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Future Due Diligence and Risk Mitigation Measures

As the Company further develops its Conflict Minerals program, the Company intends to take the following steps to further enhance its due diligence measures and to mitigate the risk that, with respect to any of the Covered Products, necessary Conflict Minerals were used, directly or indirectly, to finance or benefit armed groups in the Covered Countries:

Continue to communicate risk analysis review findings to certain suppliers which the Company considers as having a weak conflict minerals program based on completed CMRTs, through periodic business reviews and other means, in order to improve the accuracy and completeness of, and mitigate issues with, suppliers’ CMRT responses;
Continue to encourage its suppliers to implement responsible sourcing by using Conflict Minerals only from smelters or refiners that have been certified as conflict-free through the RMAP;
Continue to utilize a third-party consultant to review completed CMRTs from suppliers and prepare the related risk assessment;
Continue to incorporate Conflict Minerals requirements into the Company’s contracts with direct suppliers; and
Provide training in future years to certain suppliers the Company considers to have weak conflict minerals programs based on completed CMRTs during prior years and select several of these suppliers to undergo an on-site assessment, to be performed by the Company’s independent audit firm, of the CMRT information provided by these suppliers. The objective of the assessment would be to improve comprehension and performance for the following reporting period. The Company anticipates providing such training and conducting such assessments throughout 2023.

Inherent Limitations on Due Diligence Measures

The Company’s supply chain with respect to the Covered Products is complex, and its procurement and manufacturing process is significantly removed from the sourcing, mining, smelting and refining of Conflict Minerals. As a result, the Company does not have direct contractual relationships with smelters, refiners or mines, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and, therefore, has taken steps to identify the applicable smelters and refiners of necessary Conflict Minerals in the Company’s supply chain using the CMRT. However, tracing these minerals to their sources is a challenge that requires the Company to rely on its direct suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the necessary Conflict Minerals. The information provided by suppliers or third-party consultants or auditors may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited.

Cautionary Note on Forward-Looking Statements

Forward-looking statements in this Report are made pursuant to the safe harbor provisions of Section 21E of the Exchange Act, and other federal securities laws. Investors and others are cautioned that statements in this Report that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, future supplier audits and assessments and the timing thereof, future due diligence and risk mitigation efforts, strategy and future reporting, constitute forward-looking statements that involve risks and uncertainties. Words such as “expect,” “anticipate,” “target,” “goal,” “project,” ”intend,” “plan,” “believe,” “seek,” “estimate,” “evaluate,” “may,” “will,” “should,” “would,” “could,” “potential,” “forecast,” “guidance,” “outlook,” “predicts,” variations of these words, and similar expressions are intended to identify such forward-looking statements. Actual results could differ materially from the forward-looking statements. Forward-looking statements are subject to the occurrence of many events some of which are outside
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Omnicell’s control. Risks and uncertainties that could cause actual results to differ include, without limitation, the possibility of future regulatory changes and other developments relating to Conflict Minerals disclosures, changes in or developments related to Omnicell’s products or supply chain, changes to Omnicell’s supplier base, risks and uncertainties associated with the progress of industry developments related to supply chain diligence, disclosure and other practices, including supply chain transparency and smelter or refiner validation programs for Conflict Minerals, the possibility of inaccurate information, fraud and other irregularities in information provided by Omnicell’s suppliers, inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, as well as the other risks and uncertainties further described in the “Risk Factors” section of Omnicell’s most recent Annual Report on Form 10-K, as well as in Omnicell’s other reports filed with or furnished to the United States Securities and Exchange Commission, available at www.sec.gov. Forward-looking statements should be considered in light of these risks and uncertainties. Investors and others are cautioned not to place undue reliance on forward-looking statements.

The Company has provided information as of the date of this Report and undertakes no obligation to revise or update any forward-looking statements whether as a result of changed circumstances, new information, future events, or otherwise, except as required by law. Subsequent events, such as the inability or unwillingness of any of our suppliers, smelters or refiners to comply with Omnicell’s Conflict Minerals policy, may affect its future disclosures and determinations under the Rule. In addition, the Company’s due diligence and reporting obligations under the Rule may change in the future and its ability to implement certain processes or obtain information from its suppliers may differ materially from those anticipated or implied in this Report.

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Appendix 1
Smelters and Refiners by Mineral

Based on the information that was provided by the Company’s suppliers in completed CMRTs, the Company believes that, to the extent reasonably determinable by the Company, the facilities that may have been used to process the necessary Conflict Minerals contained in the Covered Products included the smelters and refiners identified below. However, as noted above, where the Company’s suppliers provided information on a division- or company-wide basis regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components supplied to the Company for use in the Covered Products, the smelters and refiners reported to the Company by those suppliers may not actually have been used to process the necessary Conflict Minerals in the Covered Products. The below smelter information refers to data available in the RMI smelter database in March 2023. Any changes to the RMI smelter database that took place after March 2023 are not covered.

Smelters and Refiners reported to have potentially been included in Omnicell’s supply chain as of December 31, 2022.

Smelter or Refiner IDRMAP Conformant*MineralNameLocation**
CID000004YesTungstenA.L.M.T. Corp.Japan
CID002708YesGoldAbington Reldan Metals, LLCUnited States Of America
CID000015YesGoldAdvanced Chemical CompanyUnited States Of America
CID000035YesGoldAgosi AGGermany
CID000019YesGoldAida Chemical Industries Co., Ltd.Japan
CID002560YesGoldAl Etihad Gold Refinery DMCCUnited Arab Emirates
CID003500ActiveGoldAlexy MetalsUnited States Of America
CID000041YesGoldAlmalyk Mining and Metallurgical Complex (AMMC)Uzbekistan
CID000292YesTinAlphaUnited States Of America
CID001076YesTantalumAMG BrasilBrazil
CID000058YesGoldAngloGold Ashanti Corrego do Sitio MineracaoBrazil
CID000077YesGoldArgor-Heraeus S.A.Switzerland
CID000082YesGoldAsahi Pretec Corp.Japan
CID000924YesGoldAsahi Refining Canada Ltd.Canada
CID000920YesGoldAsahi Refining USA Inc.United States Of America
CID000090YesGoldAsaka Riken Co., Ltd.Japan
CID002502YesTungstenAsia Tungsten Products Vietnam Ltd.Viet Nam
CID003461ActiveGoldAugmont Enterprises Private LimitedIndia
CID000113YesGoldAurubis AGGermany
CID002773YesTinAurubis BeerseBelgium
CID002774YesTinAurubis BerangoSpain
CID002863YesGoldBangalore RefineryIndia
CID000128YesGoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)Philippines
CID000157YesGoldBoliden ABSweden
CID000176YesGoldC. Hafner GmbH + Co. KGGermany
CID003421ActiveGoldC.I Metales Procesados Industriales SASColombia
CID000185YesGoldCCR Refinery - Glencore Canada CorporationCanada
CID000211YesTantalumChangsha South Tantalum Niobium Co., Ltd.China
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Smelter or Refiner IDRMAP Conformant*MineralNameLocation**
CID000228YesTinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.China
CID003190YesTinChifeng Dajingzi Tin Industry Co., Ltd.China
CID000233YesGoldChimet S.p.A.Italy
CID002641YesTungstenChina Molybdenum Tungsten Co., Ltd.China
CID001070YesTinChina Tin Group Co., Ltd.China
CID000258YesTungstenChongyi Zhangyuan Tungsten Co., Ltd.China
CID000264YesGoldChugai MiningJapan
CID003486YesTinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBrazil
CID003524YesTinCRM SynergiesSpain
CID003468YesTungstenCronimet Brasil LtdaBrazil
CID002570YesTinCV Ayi JayaIndonesia
CID002455YesTinCV Venus Inti PerkasaIndonesia
CID002504YesTantalumD Block Metals, LLCUnited States Of America
CID000402YesTinDowaJapan
CID000401YesGoldDowaJapan
CID003831YesTinDS MyanmarMyanmar
CID000359YesGoldDSC (Do Sung Corporation)Korea, Republic Of
CID000425YesGoldEco-System Recycling Co., Ltd. East PlantJapan
CID003424YesGoldEco-System Recycling Co., Ltd. North PlantJapan
CID003425YesGoldEco-System Recycling Co., Ltd. West PlantJapan
CID000438YesTinEM VintoBolivia (Plurinational State Of)
CID002561YesGoldEmirates Gold DMCCUnited Arab Emirates
CID000448YesTinEstanho de Rondonia S.A.Brazil
CID000460YesTantalumF&X Electro-Materials Ltd.China
CID003582YesTinFabrica Auricchio Industria e Comercio Ltda.Brazil
CID000468YesTinFenix MetalsPoland
CID002505YesTantalumFIR Metals & Resource Ltd.China
CID003401YesTungstenFujian Ganmin RareMetal Co., Ltd.China
CID003609YesTungstenFujian Xinlu Tungsten Co., Ltd.China
CID002645YesTungstenGanzhou Haichuang Tungsten Co., Ltd.China
CID000875YesTungstenGanzhou Huaxing Tungsten Products Co., Ltd.China
CID002315YesTungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
CID002494YesTungstenGanzhou Seadragon W & Mo Co., Ltd.China
CID002459YesGoldGeib Refining CorporationUnited States Of America
CID000538YesTinGejiu Non-Ferrous Metal Processing Co., Ltd.China
CID002852ActiveGoldGGC Gujrat Gold Centre Pvt. Ltd.India
CID002558YesTantalumGlobal Advanced Metals AizuJapan
CID002557YesTantalumGlobal Advanced Metals BoyertownUnited States Of America
CID000568YesTungstenGlobal Tungsten & Powders LLCUnited States Of America
CID003641YesGoldGold by Gold ColombiaColombia
CID002243YesGoldGold Refinery of Zijin Mining Group Co., Ltd.China
CID003116YesTinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.China
CID000218YesTungstenGuangdong Xianglu Tungsten Co., Ltd.China
CID002541YesTungstenH.C. Starck Tungsten GmbHGermany
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Smelter or Refiner IDRMAP Conformant*MineralNameLocation**
CID000694YesGoldHeimerle + Meule GmbHGermany
CID002492YesTantalumHengyang King Xing Lifeng New Materials Co., Ltd.China
CID000711YesGoldHeraeus Germany GmbH Co. KGGermany
CID000707YesGoldHeraeus Metals Hong Kong Ltd.China
CID003417YesTungstenHubei Green Tungsten Co., Ltd.China
CID002844YesTinHuiChang Hill Tin Industry Co., Ltd.China
CID000766YesTungstenHunan Chenzhou Mining Co., Ltd.China
CID000769YesTungstenHunan Jintai New Material Co., Ltd.China
CID002513YesTungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChina
CID000801YesGoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.China
CID000807YesGoldIshifuku Metal Industry Co., Ltd.Japan
CID000814YesGoldIstanbul Gold RefineryTurkey
CID002765YesGoldItalpreziosiItaly
CID000823YesGoldJapan MintJapan
CID000825YesTungstenJapan New Metals Co., Ltd.Japan
CID002551YesTungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China
CID000855YesGoldJiangxi Copper Co., Ltd.China
CID002512YesTantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.China
CID002321YesTungstenJiangxi Gan Bei Tungsten Co., Ltd.China
CID001231YesTinJiangxi New Nanshan Technology Ltd.China
CID002318YesTungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
CID002842YesTantalumJiangxi Tuohong New Raw MaterialChina
CID002317YesTungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
CID002316YesTungstenJiangxi Yaosheng Tungsten Co., Ltd.China
CID000914YesTantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
CID000917YesTantalumJiujiang Tanbre Co., Ltd.China
CID002506YesTantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.China
CID000937YesGoldJX Nippon Mining & Metals Co., Ltd.Japan
CID000957YesGoldKazzincKazakhstan
CID002539YesTantalumKEMET de MexicoMexico
CID000966YesTungstenKennametal FallonUnited States Of America
CID000105YesTungstenKennametal HuntsvilleUnited States Of America
CID000969YesGoldKennecott Utah Copper LLCUnited States Of America
CID003388YesTungstenKGETS Co., Ltd.Korea, Republic Of
CID002511YesGoldKGHM Polska Miedz Spolka AkcyjnaPoland
CID000981YesGoldKojima Chemicals Co., Ltd.Japan
CID002605YesGoldKorea Zinc Co., Ltd.Korea, Republic Of
CID002762YesGoldL'Orfebre S.A.Andorra
CID003407YesTungstenLianyou Metals Co., Ltd.Taiwan, Province Of China
CID001078YesGoldLS-NIKKO Copper Inc.Korea, Republic Of
CID000689YesGoldLT Metal Ltd.Korea, Republic Of
CID003387YesTinLuna Smelter, Ltd.Rwanda
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Smelter or Refiner IDRMAP Conformant*MineralNameLocation**
CID003379YesTinMa'anshan Weitai Tin Co., Ltd.China
CID002468YesTinMagnu's Minerais Metais e Ligas Ltda.Brazil
CID001105YesTinMalaysia Smelting Corporation (MSC)Malaysia
CID002319YesTungstenMalipo Haiyu Tungsten Co., Ltd.China
CID002543YesTungstenMasan High-Tech MaterialsViet Nam
CID001113YesGoldMaterionUnited States Of America
CID002548YesTantalumMaterion Newton Inc.United States Of America
CID001119YesGoldMatsuda Sangyo Co., Ltd.Japan
CID003575YesGoldMetal Concentrators SA (Pty) Ltd.South Africa
CID001142YesTinMetallic Resources, Inc.United States Of America
CID001163YesTantalumMetallurgical Products India Pvt., Ltd.India
CID001149YesGoldMetalor Technologies (Hong Kong) Ltd.China
CID001152YesGoldMetalor Technologies (Singapore) Pte., Ltd.Singapore
CID001147YesGoldMetalor Technologies (Suzhou) Ltd.China
CID001153YesGoldMetalor Technologies S.A.Switzerland
CID001157YesGoldMetalor USA Refining CorporationUnited States Of America
CID001161YesGoldMetalurgica Met-Mex Penoles S.A. De C.V.Mexico
CID001173YesTinMineracao Taboca S.A.Brazil
CID001175YesTantalumMineracao Taboca S.A.Brazil
CID001182YesTinMinsurPeru
CID001191YesTinMitsubishi Materials CorporationJapan
CID001188YesGoldMitsubishi Materials CorporationJapan
CID001193YesGoldMitsui Mining and Smelting Co., Ltd.Japan
CID001192YesTantalumMitsui Mining and Smelting Co., Ltd.Japan
CID001352YesGoldMKS PAMP SASwitzerland
CID002509YesGoldMMTC-PAMP India Pvt., Ltd.India
CID001220YesGoldNadir Metal Rafineri San. Ve Tic. A.S.Turkey
CID001236YesGoldNavoi Mining and Metallurgical CombinatUzbekistan
CID003189YesGoldNH Recytech CompanyKorea, Republic Of
CID002589YesTungstenNiagara Refining LLCUnited States Of America
CID001259YesGoldNihon Material Co., Ltd.Japan
CID001277YesTantalumNingxia Orient Tantalum Industry Co., Ltd.China
CID001200YesTantalumNPM Silmet ASEstonia
CID001314YesTinO.M. Manufacturing (Thailand) Co., Ltd.Thailand
CID002517YesTinO.M. Manufacturing Philippines, Inc.Philippines
CID002779YesGoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustria
CID001325YesGoldOhura Precious Metal Industry Co., Ltd.Japan
CID001337YesTinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)
CID002827YesTungstenPhilippine Chuangxin Industrial Co., Inc.Philippines
CID002919YesGoldPlanta Recuperadora de Metales SpAChile
CID001397YesGoldPT Aneka Tambang (Persero) TbkIndonesia
CID000309YesTinPT Aries Kencana SejahteraIndonesia
CID001399YesTinPT Artha Cipta LanggengIndonesia
CID002503YesTinPT ATD Makmur Mandiri JayaIndonesia
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Smelter or Refiner IDRMAP Conformant*MineralNameLocation**
CID001402YesTinPT Babel Inti PerkasaIndonesia
CID001406YesTinPT Babel Surya Alam LestariIndonesia
CID002776YesTinPT Bangka Prima TinIndonesia
CID003205YesTinPT Bangka SerumpunIndonesia
CID001421ActiveTinPT Belitung Industri SejahteraIndonesia
CID001428YesTinPT Bukit TimahIndonesia
CID002696YesTinPT Cipta Persada MuliaIndonesia
CID002835YesTinPT Menara Cipta MuliaIndonesia
CID001453YesTinPT Mitra Stania PrimaIndonesia
CID003449YesTinPT Mitra Sukses GlobalindoIndonesia
CID000313YesTinPT Premium Tin IndonesiaIndonesia
CID001458YesTinPT Prima Timah UtamaIndonesia
CID003868YesTinPT Putera Sarana Shakti (PT PSS)Indonesia
CID003381YesTinPT Rajawali Rimba PerkasaIndonesia
CID002593YesTinPT Rajehan AriqIndonesia
CID001460YesTinPT Refined Bangka TinIndonesia
CID001463YesTinPT Sariwiguna BinasentosaIndonesia
CID001468YesTinPT Stanindo Inti PerkasaIndonesia
CID002816YesTinPT Sukses Inti MakmurIndonesia
CID001486ActiveTinPT Timah NusantaraIndonesia
CID001477YesTinPT Timah Tbk KundurIndonesia
CID001482YesTinPT Timah Tbk MentokIndonesia
CID001493YesTinPT Tommy UtamaIndonesia
CID001498YesGoldPX Precinox S.A.Switzerland
CID002547YesTantalumQSIL Metals Hermsdorf GmbHGermany
CID001508YesTantalumQuantumCleanUnited States Of America
CID001512YesGoldRand Refinery (Pty) Ltd.South Africa
CID002582YesGoldREMONDIS PMR B.V.Netherlands
CID002706YesTinResind Industria e Comercio Ltda.Brazil
CID002707YesTantalumResind Industria e Comercio Ltda.Brazil
CID003583YesTantalumRFH Yancheng Jinye New Material Technology Co., Ltd.China
CID001534YesGoldRoyal Canadian MintCanada
CID001539YesTinRui Da HungTaiwan, Province Of China
CID002761YesGoldSAAMPFrance
CID002290YesGoldSAFINA A.S.Czechia
CID003529ActiveGoldSancus ZFS (L’Orfebre, SA)Colombia
CID001585YesGoldSEMPSA Joyeria Plateria S.A.Spain
CID001916YesGoldShandong Gold Smelting Co., Ltd.China
CID001622YesGoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.China
CID001736YesGoldSichuan Tianze Precious Metals Co., Ltd.China
CID001761YesGoldSolar Applied Materials Technology Corp.Taiwan, Province Of China
CID001798YesGoldSumitomo Metal Mining Co., Ltd.Japan
CID002918YesGoldSungEel HiMetal Co., Ltd.Korea, Republic Of
CID002756ActiveTinSuper LigasBrazil
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Smelter or Refiner IDRMAP Conformant*MineralNameLocation**
CID002580YesGoldT.C.A S.p.AItaly
CID001869YesTantalumTaki Chemical Co., Ltd.Japan
CID001875YesGoldTanaka Kikinzoku Kogyo K.K.Japan
CID002544YesTantalumTANIOBIS Co., Ltd.Thailand
CID002545YesTantalumTANIOBIS GmbHGermany
CID002549YesTantalumTANIOBIS Japan Co., Ltd.Japan
CID002550YesTantalumTANIOBIS Smelting GmbH & Co. KGGermany
CID002542YesTungstenTANIOBIS Smelting GmbH & Co. KGGermany
CID001891YesTantalumTelex MetalsUnited States Of America
CID002834YesTinThai Nguyen Mining and Metallurgy Co., Ltd.Viet Nam
CID001898YesTinThaisarcoThailand
CID002180YesTinTin Smelting Branch of Yunnan Tin Co., Ltd.China
CID003325YesTinTin Technology & RefiningUnited States Of America
CID001938YesGoldTokuriki Honten Co., Ltd.Japan
CID002615YesGoldTOO Tau-Ken-AltynKazakhstan
CID001955YesGoldTorecomKorea, Republic Of
CID001969YesTantalumUlba Metallurgical Plant JSCKazakhstan
CID002314YesGoldUmicore Precious Metals ThailandThailand
CID001980YesGoldUmicore S.A. Business Unit Precious Metals RefiningBelgium
CID001993YesGoldUnited Precious Metal Refining, Inc.United States Of America
CID002003YesGoldValcambi S.A.Switzerland
CID003615ActiveGoldWEEEREFININGFrance
CID002030YesGoldWestern Australian Mint (T/a The Perth Mint)Australia
CID002036YesTinWhite Solder Metalurgia e Mineracao Ltda.Brazil
CID002778YesGoldWIELAND Edelmetalle GmbHGermany
CID002044YesTungstenWolfram Bergbau und Hutten AGAustria
CID002320YesTungstenXiamen Tungsten (H.C.) Co., Ltd.China
CID002082YesTungstenXiamen Tungsten Co., Ltd.China
CID000616YesTantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChina
CID002830YesTungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.China
CID002508YesTantalumXinXing HaoRong Electronic Material Co., Ltd.China
CID002100YesGoldYamakin Co., Ltd.Japan
CID001522YesTantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
CID002129YesGoldYokohama Metal Co., Ltd.Japan
CID002158YesTinYunnan Chengfeng Non-ferrous Metals Co., Ltd.China
CID002224YesGoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChina
*Yes” means the smelter or refiner is conformant with RMAP assessment protocols as reported by the RMI. “Active” means the smelter or refiner is active in the RMAP process (i.e., it has agreed to participate in the RMAP but the audit process has not yet been completed). “No” means the smelter or refiner is a known metal processor based on information available from the RMI or the Department of Commerce but has not been certified as conflict-free through the RMAP and is not active in the RMAP process. “No (Unknown)” means the Company was unable to verify such facility as a known metal processor based on information available from the RMI or the U.S. Department of Commerce.
**     Country names according to ISO 3166-1
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Appendix 2
Potential Countries of Origin of Conflict Minerals

AngolaLuxembourg
AndorraMadagascar
ArgentinaMalaysia
ArmeniaMali
AustraliaMexico
AustriaMongolia
BelarusMorocco
BelgiumMozambique
BermudaMyanmar
Bolivia (Plurinational State of)Namibia
BrazilNetherlands
BurundiNew Zealand
CambodiaNiger
CanadaNigeria
Central African RepublicPapua New Guinea
ChilePeru
ChinaPhilippines
ColombiaPoland
CzechiaPortugal
Democratic Republic of the CongoRepublic of the Congo
DjiboutiRussian Federation
EcuadorRwanda
EgyptSaudi Arabia
EstoniaSierra Leone
EthiopiaSingapore
FinlandSlovakia
FranceSouth Africa
GermanySouth Sudan
GhanaSpain
GuineaSuriname
GuyanaSweden
Hong KongSwitzerland
HungaryTaiwan, Province of China
IndiaTajikistan
IndonesiaTanzania
IrelandThailand
IsraelTurkey
ItalyUganda
Ivory CoastUnited Arab Emirates
JapanUnited Kingdom
JerseyUnited States of America
KazakhstanUzbekistan
KenyaViet Nam
Korea, Republic ofZambia
KyrgyzstanZimbabwe
Laos
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