Document
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Graco Inc.
(Exact name of registrant as specified in its charter)
| | | | | | | | | | | | | | |
| | | | |
Minnesota | | 001-09249 | | 41-0285640 |
(State or other Jurisdiction of Incorporation or organization) | | (Commission File Number) | | (IRS Employer Identification No.) |
| | | | | | | | | | | | | | | | | | | | | | | | | | |
| | | | | | | | |
| | 88 – 11th Avenue Northeast Minneapolis, Minnesota | | | | 55413 | | |
| | (Address of principal executive offices) | | | | (Zip Code) | | |
| | |
|
Joseph James Humke, (612) 623-6000 |
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
¨ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the fiscal year ended____________.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Graco Inc. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period of January 1 to December 31, 2021.
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available at www.graco.com.
Item 1.02 Exhibit
As specified in Section 3, Item 3.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 - Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this report.
| | | | | | | | |
| | |
Exhibit No. | | Description |
| |
1.01 | | Conflict Minerals Report of Graco Inc. as required by Items 1.01 and 1.02 of this Form SD |
Signature
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| | | | | | | | |
| | | | GRACO INC.
| | |
| | | | | |
Date: | | May 27, 2022 | | By: | | /s/ Joseph James Humke | | | |
| | | | | | Joseph James Humke | | | |
| | | | | | Executive Vice President, General Counsel and Corporate Secretary | | | |
EXHIBIT INDEX
| | | | | | | | | | | | | | |
| | | | |
Exhibit | | Description | | Method of Filing |
| | |
1.01 | | Conflict Minerals Report of Graco Inc. as required by Items 1.01 and 1.02 of this Form SD | | Filed Electronically |
DocumentExhibit 1.01
GRACO INC.
Conflict Minerals Report
For the reporting period from January 1, 2021 to December 31, 2021
This is the Conflict Minerals Report (“Report”) of Graco Inc. (“Graco,” “we,” “our” or “us”) for the 2021 calendar year, pursuant to Rule 13p-1 of the Securities Exchange Act of 1934 (the “Rule”). Certain capitalized terms used but not defined herein have the meanings assigned to them in the Rule. This Report includes the activities of all subsidiaries of Graco that were required to be consolidated during the reporting period, other than any acquired companies that are not yet required by the Rule to be included in this Report.
The Rule requires certain SEC reporting companies that manufacture or contract to be manufactured products for which tantalum, tin, tungsten or gold (“3TG”) are necessary to the functionality or production of such products to disclose annually whether any of the 3TG in such products originated in the Democratic Republic of the Congo or one of its adjoining countries (collectively, the “Covered Countries”). If the company knows that the 3TG necessary to its products originated in the Covered Countries, or has reason to believe that the 3TG may have originated in the Covered Countries and did not or may not have come from scrap or recycled sources, the company must exercise due diligence on the source and chain of custody of the 3TG and prepare and file a Report describing its due diligence measures.
Graco Overview
Graco is a multi-national manufacturer of systems and equipment that move, measure, control, dispense and spray fluid and powder materials. Our systems and equipment are used in the manufacturing, processing, construction and maintenance industries. Our primary products include air, electric, gas and hydraulic pumps and sprayers; electronic and mechanical controls and sensors; and automatic and manual dispense valves, meters and spray guns. Our products that contain control boards, certain other electronic components, motors, engines, batteries, spray tips, and certain pumps and valves contain 3TG.
Company Management Systems
We have established management systems to support the execution of our Conflict Minerals program and to ensure it operates effectively and is sustainable into the future. Our management systems include the following:
Conflict Minerals Policy
We have adopted a policy affirming our commitment to conducting business fairly and ethically with respect for human rights and in compliance with all applicable laws and regulations, including the
Rule. Our policy also affirms our support for the responsible sourcing of 3TG through our global supply chain, and states that we are actively and diligently working with our global supply chain partners to determine the origin of any 3TG they may supply to us, and that we will continue to work with them towards the goal of providing greater supply chain transparency and responsible sourcing. Our policy is available on our website at http://www.graco.com/us/en/about-graco/conflict-minerals.html.
Internal Team
We have a cross-functional team with executive-level sponsorship and support that implemented and oversees our Conflict Minerals compliance program. The cross-functional team includes employees from functional groups such as procurement, finance, operations, legal and information systems. We report our Conflict Minerals findings to our team and designated members of senior management.
Control Systems
We have contributed to industry efforts to support the responsible sourcing of 3TG through our membership in the Responsible Minerals Initiative (RMI), which has helped develop standards, best practices and tools that benefit all companies working to end the link between 3TG and conflict in the Covered Countries. In prior years, we have also participated in the National Association of Manufacturers Conflict Minerals Working Group, the Manufacturers Alliance for Productivity and Innovation Conflict Minerals Forum and the Twin Cities Conflict Minerals Task Force. In addition, we retain a third party service provider to assist with collecting, evaluating and retaining supply chain information, identifying potential supply chain risks, and developing and implementing additional engagement steps with suppliers.
Supplier Engagement
We have a process in place to engage relevant first-tier suppliers to educate them about the Rule and request information from them regarding 3TG. We also have a process in place to try to improve the number and quality of supplier responses year over year. To help ensure suppliers understand the Rule and how to properly respond to requests for information from us regarding 3TG, we provide our suppliers access to on-line Conflict Minerals support materials, help desk support and other multilingual resources. We also respond to supplier inquiries during the information gathering process and take steps to address supplier issues that arise during that process.
Grievance Mechanism
We have an established grievance mechanism through which employees, suppliers, customers and other interested parties may communicate their concerns to us.
Records Management
We have a process in place to collect, analyze and retain Conflict Minerals information received from our suppliers. We will maintain records relating to Conflict Minerals supply chain due diligence in accordance with our records retention policy, which provides for retention of such records for five years.
Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. As a member of the RMI, we support the RMI’s efforts to carry out independent third-party audits of smelter and refiner due diligence activities and contribute to the improvement of smelter and refiner and upstream due diligence practices.
Report on Supply Chain Due Diligence
Graco has filed a Form SD and this Report with the Securities Exchange Commission. The filing is available on our website at https://www.graco.com/us/en/about-graco/conflict-minerals.html.
Reasonable Country of Origin Inquiry
Supply Chain
We do not directly source 3TG. Instead, we purchase components and raw materials from third party suppliers that are multiple layers removed from the smelters and refiners of the 3TG that are in the components and raw materials ultimately supplied to us. We evaluated our products and determined that certain products manufactured during calendar year 2021 were manufactured with components and raw materials that contain or likely contain 3TG that are necessary to the functionality or production of those products. We then identified the first-tier suppliers of those components and raw materials.
Request for Information
We use a third-party software solution to automate our reasonable country of origin inquiry (“RCOI”) process and improve the quality and efficiency of our Conflict Minerals compliance program. With this software solution, we surveyed all of our in-scope first-tier suppliers using the Conflict Minerals Reporting Template (CMRT) (version 6.1) developed by the RMI. We also provided these suppliers with
access to on-line Conflict Minerals support materials to help educate them on the Rule and to aid them in responding to the survey.
Survey Responses
All submitted CMRTs were reviewed and classified as valid or invalid. We tracked supplier responses and identified instances where suppliers submitted an invalid response (due to missing information or inconsistencies across responses) or did not provide us with a timely response, and followed up with those suppliers and requested that they submit a valid CMRT. Suppliers were provided with guidance on how to correct any validation errors in the form of feedback to their CMRT submissions, training courses and direct engagement help from a multilingual service team. As of May 2, 2022, there was a small percentage of invalid supplier CMRTs that were not corrected.
We compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters and refiners maintained by the RMI to determine the validity and the RMAP assessment status of each of the smelters and refiners identified by our suppliers. Our suppliers identified a total of 335 smelters and refiners that appear on the lists maintained by the RMI. Of these 335 smelters and refiners, 230 have been deemed conformant with the RMAP assessment protocols by an independent third party auditor according to the RMI list of conformant smelters and refiners. Based on information provided by the RMI, a further 19 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were completed on a company or supplier-defined level, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products.
Identification and Assessment of Risk
Risks are identified based on criteria established for supplier responses in the CMRT. Risks are addressed by contacting the supplier, gathering pertinent information, and performing an assessment of the supplier’s Conflict Minerals status. The primary risk identified relates to the nature of responses received. Many suppliers provided information at a company or supplier-defined level, which prevents us from determining whether the smelters or refiners listed by those suppliers actually processed the 3TG contained in the components and raw materials supplied to us. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they were unable to provide a complete list of all smelters and refiners in their supply chains.
Smelters and refiners that are not conformant with the RMAP assessment protocols or have not committed to undergo an RMAP assessment also pose a risk. When a CMRT is received, the smelters and refiners that are reported are examined. Each facility that meets the RMI definition of a smelter or refiner of 3TG is assigned a risk level based on: (i) geographic proximity to the Covered Countries; (ii) known mineral source country of origin; (iii) RMI Responsible Minerals Assurance Process (RMAP) audit status; (iv) credible evidence of unethical or conflict sourcing; and (v) peer assessments conducted by credible
third-party sources. When certain high-risk facilities are reported, risk mitigation activities are initiated, including sending an automated reply instructing the supplier to take risk mitigation actions, including submission of a product-specific CMRT to better identify the connection to components and raw materials supplied to us.
In addition, suppliers are evaluated on the strength of their Conflict Minerals programs based on whether: (i) they have a conflict minerals sourcing policy; (ii) they have implemented due diligence measures for responsible sourcing; (iii) they review information received from their suppliers against their own expectations; and (iv) their review process includes corrective action management. We evaluate and track the strength of their programs so we can make risk mitigation decisions as their programs progress.
Through our membership with the RMI, we encourage smelters and refiners to participate in the RMAP. Any smelters and refiners that were reported by our suppliers that were not part of the RMAP were also contacted directly to encourage them to participate in the RMAP.
Design of Due Diligence Measures
Our due diligence measures have been designed to be in conformity, in all material respects, with the applicable provisions of the internationally recognized framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, and the related supplements on 3TG.
Due Diligence Measures Performed
The due diligence measures we performed include defining roles and responsibilities for our cross-functional Conflict Minerals team and designated members of senior management; reporting our Conflict Minerals findings to our cross-functional Conflict Minerals team and designated members of senior management; and comparing the smelter and refiner information received from our suppliers against the RMI list of smelters and refiners that are conformant with the RMAP assessment protocols, the RMI list of smelters and refiners that have committed to undergo an RMAP audit, and the RMI reference list of known smelters and refiners. With respect to smelters and refiners that were on the RMI list of known smelters and refiners and certain other smelters and refiners that were not on the RMI list of known smelters and refiners, we reviewed certain other publicly available sources of information.
Due Diligence Results
A majority of suppliers surveyed responded to the survey. The majority of those who responded provided data at a company or supplier-defined level rather than at a product level, and reported that their products do not contain 3TG or, if they do, the 3TG in their products does not come from the Covered Countries. A number of suppliers reported that they do not know whether the 3TG in their products comes from the Covered Countries or from scrap or recycled sources. A small number of suppliers reported that
the 3TG in their products comes from or may come from the Covered Countries, and some of these suppliers further reported that some of the 3TG in their products comes from scrap or recycled sources.
Our suppliers identified over 500 entities in their supply chains as part of their smelter and refiner lists. However, not all of the entities identified by these suppliers appear to be actual smelters or refiners as the total number of entities identified exceeds the number of entities on the RMI list of known smelters and refiners. In addition, not all of the actual smelters and refiners identified by our suppliers may have processed the 3TG in the components and raw materials supplied to us. In some cases, our suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in information received from their suppliers or for other reasons.
Schedule 1 to this Report contains a list of legitimate smelters and refiners identified by our suppliers, and whose materials and components may or may not be in our products, including the RMAP assessment status of each smelter and refiner as of May 2, 2022. (Schedule 1 excludes any smelters and refiners identified by our suppliers that do not appear on the RMI list of known smelters and refiners.) 230 of the smelters and refiners identified by our suppliers have been deemed conformant with the RMAP assessment protocols by an independent third party auditor according to the RMI list of conformant smelters and refiners. 19 of the smelters and refiners identified by our suppliers have not yet been deemed conformant but have committed to undergo an RMAP audit according to the RMI list of smelters and refiners who have committed to undergo an RMAP audit. 69 of the smelters and refiners identified by our suppliers have not been deemed conformant and have not begun participating in an independent third party audit program. 17 of the smelters and refiners identified by our suppliers have failed an RMAP audit, refused to participate in the RMAP assessment process, or have failed to provide adequate access to their facilities to complete the RMAP assessment process. Schedule 2 to this Report includes an aggregate list of the countries of origin from which the smelters and refiners identified on Schedule 1 collectively source 3TG, based on information provided by the RMI.
Given that the majority of suppliers who responded to the survey provided their responses at a company or supplier-defined level rather than at a level specific to the materials and components they supplied to us, we were unable to determine which, if any, of the smelters and refiners listed in their responses were the actual source of the 3TG they supplied.
Determination
Given that a number of suppliers did not respond to our survey, the majority of responses we received were provided at a company or supplier-defined level not specific to the components and raw materials supplied to us, and that a number of suppliers do not know the origin of the 3TG in their products, we do not have sufficient information to determine the origin of the 3TG in our products subject to this Report, whether the 3TG came from scrap or recycled sources, the specific facilities used to process the 3TG, or the country of origin or the mine or location of origin of the 3TG.
Steps to be Taken to Mitigate Risk in 2022
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TG in our products finance or benefit armed groups in the Covered Countries:
•Continue to engage with our direct suppliers to increase the response rate to our survey and improve the content and quality of their responses; and
•Continue to engage with our direct suppliers to receive more information farther upstream regarding the source and chain of custody of the 3TG in the components and raw materials they supply to us.
Schedule 1
| | | | | | | | | | | | | | | | | | | | |
Metal | | Standard Smelter or Refiner Name | | Facility Location (Country) | | Smelter or Refiner Status* |
Gold | | 8853 S.p.A. | | Italy | | Conformant |
Gold | | Abington Reldan Metals, LLC | | United States | | Non Conformant |
Gold | | Advanced Chemical Company | | United States | | Conformant |
Gold | | African Gold Refinery | | Uganda | | Not Enrolled |
Gold | | Aida Chemical Industries Co., Ltd. | | Japan | | Conformant |
Gold | | Al Etihad Gold Refinery DMCC | | United Arab Emirates | | Conformant |
Gold | | Alexy Metals | | United States | | Active |
Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | Germany | | Conformant |
Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | Uzbekistan | | Conformant |
Gold | | AngloGold Ashanti Córrego do Sítio Mineração | | 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 | | Not Enrolled |
Gold | | AU Traders and Refiners | | South Africa | | Non Conformant |
Gold | | Augmont Enterprises Private Limited | | India | | Active |
Gold | | Aurubis AG | | Germany | | Conformant |
Gold | | Bangalore Refinery | | India | | Conformant |
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 | | C. I. Metales Procesados Industriales SAS | | Colombia | | Active |
Gold | | Caridad | | Mexico | | Not Enrolled |
Gold | | CCR Refinery - Glencore Canada Corporation | | Canada | | Conformant |
Gold | | Cendres + Métaux S.A. | | Switzerland | | Conformant |
Gold | | CGR Metalloys Pvt Ltd. | | India | | Not Enrolled |
Gold | | Chimet S.p.A. | | Italy | | Conformant |
Gold | | Chugai Mining | | Japan | | Conformant |
Gold | | Daye Non-Ferrous Metals Mining Ltd. | | China | | Not Enrolled |
Gold | | Degussa Sonne / Mond Goldhandel GmbH | | Germany | | Not Enrolled |
Gold | | Dijllah Gold Refinery FZC | | United Arab Emirates | | Not Enrolled |
Gold | | Dowa | | Japan | | Conformant |
Gold | | DSC (Do Sung Corporation) | | Republic of Korea | | 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 | | Emerald Jewel Industry India Limited (Unit 1) | | India | | Not Enrolled |
Gold | | Emerald Jewel Industry India Limited (Unit 2) | | India | | Not Enrolled |
Gold | | Emerald Jewel Industry India Limited (Unit 3) | | India | | Not Enrolled |
Gold | | Emerald Jewel Industry India Limited (Unit 4) | | India | | Not Enrolled |
Gold | | Emirates Gold DMCC | | United Arab Emirates | | Conformant |
Gold | | Fidelity Printers and Refiners Ltd. | | Zimbabwe | | Not Enrolled |
Gold | | Fujairah Gold FZC | | United Arab Emirates | | Not Enrolled |
Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | India | | Active |
Gold | | Geib Refining Corporation | | United States | | Conformant |
Gold | | Gold Coast Refinery | | Ghana | | Not Enrolled |
Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | China | | Conformant |
Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | China | | Not Enrolled |
Gold | | Guangdong Jinding Gold Limited | | China | | Not Enrolled |
| | | | | | | | | | | | | | | | | | | | |
Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | China | | Not Enrolled |
Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | China | | Not Enrolled |
Gold | | Heimerle + Meule GmbH | | Germany | | Conformant |
Gold | | Heraeus Metals Hong Kong Ltd. | | China | | Conformant |
Gold | | Heraeus Precious Metals GmbH & Co. KG | | Germany | | Conformant |
Gold | | Hunan Chenzhou Mining Co., Ltd. | | China | | Not Enrolled |
Gold | | Hunan Guiyang Yinxing Nonferrous Smelting Co., Ltd. | | China | | Not Enrolled |
Gold | | HwaSeong CJ Co., Ltd. | | Republic of Korea | | Not Enrolled |
Gold | | Industrial Refining Company | | Belgium | | Non Conformant |
Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | China | | Conformant |
Gold | | International Precious Metal Refiners | | United Arab Emirates | | Not Enrolled |
Gold | | Ishifuku Metal Industry Co., Ltd. | | Japan | | Conformant |
Gold | | Istanbul Gold Refinery | | Turkey | | Conformant |
Gold | | Italpreziosi | | Italy | | Conformant |
Gold | | JALAN & Company | | India | | Not Enrolled |
Gold | | Japan Mint | | Japan | | Conformant |
Gold | | Jiangxi Copper Co., Ltd. | | China | | Conformant |
Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | Russian Federation | | Not Enrolled |
Gold | | JSC Uralelectromed | | Russian Federation | | Non Conformant |
Gold | | JX Nippon Mining & Metals Co., Ltd. | | Japan | | Non Conformant |
Gold | | K.A. Rasmussen | | Norway | | Not Enrolled |
Gold | | Kaloti Precious Metals | | United Arab Emirates | | Not Enrolled |
Gold | | Kazakhmys Smelting LLC | | Kazakhstan | | Not Enrolled |
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. | | Republic of Korea | | Conformant |
Gold | | Kundan Care Products Ltd. | | India | | Not Enrolled |
Gold | | Kyrgyzaltyn JSC | | Kyrgyzstan | | Non Conformant |
Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | Russian Federation | | Not Enrolled |
Gold | | L’azurde Company For Jewelry | | Saudi Arabia | | Not Enrolled |
Gold | | Lingbao Gold Co., Ltd. | | China | | Not Enrolled |
Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | China | | Not Enrolled |
Gold | | L’Orfebre S.A. | | Andorra | | Conformant |
Gold | | LS-NIKKO Copper Inc. | | Republic of Korea | | Conformant |
Gold | | LT Metal Ltd. | | Republic of Korea | | Conformant |
Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | China | | Not Enrolled |
Gold | | Marsam Metals | | Brazil | | Conformant |
Gold | | Materion | | United States | | Conformant |
Gold | | Matsuda Sangyo Co., Ltd. | | Japan | | Conformant |
Gold | | MD Overseas | | India | | Not Enrolled |
Gold | | Metal Concentrators SA (Pty) Ltd. | | South Africa | | Conformant |
Gold | | Metallix Refining Inc. | | United States | | Not Enrolled |
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 | | Metalúrgica Met-Mex Peñoles 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 | | Non Conformant |
Gold | | Morris and Watson | | New Zealand | | Not Enrolled |
| | | | | | | | | | | | | | | | | | | | |
Gold | | Moscow Special Alloys Processing Plant | | Russian Federation | | Non Conformant |
Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | Turkey | | Conformant |
Gold | | Navoi Mining and Metallurgical Combinat | | Uzbekistan | | Conformant |
Gold | | NH Recytech Company | | Republic of Korea | | Non Conformant |
Gold | | Nihon Material Co., Ltd. | | Japan | | Conformant |
Gold | | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | | Austria | | Conformant |
Gold | | Ohura Precious Metal Industry Co., Ltd. | | Japan | | Conformant |
Gold | | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | | Russian Federation | | Non Conformant |
Gold | | OJSC Novosibirsk Refinery | | Russian Federation | | Non Conformant |
Gold | | PAMP S.A. | | Switzerland | | Conformant |
Gold | | Pease & Curren | | United States | | Not Enrolled |
Gold | | Penglai Penggang Gold Industry Co., Ltd. | | China | | Not Enrolled |
Gold | | Planta Recuperadora de Metales SpA | | Chile | | Conformant |
Gold | | Prioksky Plant of Non-Ferrous Metals | | Russian Federation | | Non Conformant |
Gold | | PT Aneka Tambang (Persero) Tbk | | Indonesia | | Conformant |
Gold | | PX Précinox S.A. | | Switzerland | | Conformant |
Gold | | QG Refining, LLC | | United States | | Not Enrolled |
Gold | | Rand Refinery (Pty) Ltd. | | South Africa | | Conformant |
Gold | | Refinery of Seemine Gold Co., Ltd. | | China | | Not Enrolled |
Gold | | REMONDIS PMR B.V. | | Netherlands | | Conformant |
Gold | | Royal Canadian Mint | | Canada | | Conformant |
Gold | | SAAMP | | France | | Conformant |
Gold | | Sabin Metal Corp. | | United States | | Not Enrolled |
Gold | | Safimet S.p.A | | Italy | | Conformant |
Gold | | SAFINA A.S. | | Czech Republic | | Conformant |
Gold | | Sai Refinery | | India | | Not Enrolled |
Gold | | Samduck Precious Metals | | Republic of Korea | | Conformant |
Gold | | Samwon Metals Corp. | | Republic of Korea | | Not Enrolled |
Gold | | Sancus ZFS (L’Orfebre, SA) | | Colombia | | Active |
Gold | | Sellem Industries Ltd. | | Mauritania | | Not Enrolled |
Gold | | SEMPSA Joyería Platería S.A. | | Spain | | Conformant |
Gold | | Shangdong Humon Smelting Co., Ltd. | | China | | Not Enrolled |
Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | China | | Not Enrolled |
Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | China | | Conformant |
Gold | | Shenzhen Zhonghenglong Real Industry Co., Ltd. | | China | | Not Enrolled |
Gold | | Shirpur Gold Refinery Ltd. | | India | | Not Enrolled |
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 | | Non Conformant |
Gold | | Solar Applied Materials Technology Corp. | | Taiwan | | Conformant |
Gold | | Sovereign Metals | | India | | Not Enrolled |
Gold | | State Research Institute Center for Physical Sciences and Technology | | Lithuania | | Not Enrolled |
Gold | | Sudan Gold Refinery | | Sudan | | Not Enrolled |
Gold | | Sumitomo Metal Mining Co., Ltd. | | Japan | | Conformant |
Gold | | SungEel HiMetal Co., Ltd. | | Republic of Korea | | Conformant |
Gold | | Super Dragon Technology Co., Ltd. | | Taiwan | | Not Enrolled |
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 | | Not Enrolled |
Gold | | TOO Tau-Ken-Altyn | | Kazakhstan | | Conformant |
Gold | | Torecom | | Republic of Korea | | 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 | | Value Trading | | Belgium | | Not Enrolled |
Gold | | Western Australian Mint trading as 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 | | Not Enrolled |
Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | China | | Conformant |
Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | China | | Conformant |
Tantalum | | D Block Metals, LLC | | United States | | Conformant |
Tantalum | | F&X Electro-Materials Ltd. | | China | | Conformant |
Tantalum | | FIR Metals & Resource Ltd. | | China | | Conformant |
Tantalum | | Global Advanced Metals Aizu | | Japan | | Conformant |
Tantalum | | Global Advanced Metals Boyertown | | United States | | Conformant |
Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | China | | Conformant |
Tantalum | | H.C. Starck Co., Ltd. | | Thailand | | Conformant |
Tantalum | | H.C. Starck Hermsdorf GmbH | | Germany | | Conformant |
Tantalum | | H.C. Starck Inc. | | United States | | Conformant |
Tantalum | | H.C. Starck Ltd. | | Japan | | Conformant |
Tantalum | | H.C. Starck Smelting GmbH & Co. KG | | Germany | | Conformant |
Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | Germany | | Conformant |
Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | China | | Conformant |
Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | China | | Conformant |
Tantalum | | Jiangxi Tuohong New Raw Material | | China | | Conformant |
Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | China | | Conformant |
Tantalum | | Jiujiang Tanbre Co., Ltd. | | China | | Conformant |
Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | China | | Conformant |
Tantalum | | KEMET Blue Metals | | Mexico | | Conformant |
Tantalum | | LSM Brasil S.A. | | Brazil | | Conformant |
Tantalum | | Metallurgical Products India Pvt., Ltd. | | India | | Conformant |
Tantalum | | Mineracao Taboca S.A. | | Brazil | | Conformant |
Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | Japan | | Conformant |
Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | China | | Conformant |
Tantalum | | NPM Silmet AS | | Estonia | | Conformant |
Tantalum | | QuantumClean | | United States | | Conformant |
Tantalum | | Resind Industria e Comercio Ltda. | | Brazil | | Conformant |
Tantalum | | Solikamsk Magnesium Works OAO | | Russian Federation | | Conformant |
Tantalum | | Taki Chemical Co., Ltd. | | Japan | | Conformant |
Tantalum | | Telex Metals | | United States | | Conformant |
Tantalum | | Ulba Metallurgical Plant JSC | | Kazakhstan | | Conformant |
Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | China | | Conformant |
Tantalum | | Yancheng Jinye New Material Technology Co., Ltd. | | China | | Conformant |
Tantalum | | Yangling Jincheng Tantalum and Niobium Co., Ltd. | | China | | Conformant |
Tin | | Alpha | | United States | | Conformant |
Tin | | An Vinh Joint Stock Mineral Processing Company | | Vietnam | | Not Enrolled |
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 | | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | | Brazil | | Active |
Tin | | CRM Synergies | | Spain | | Conformant |
Tin | | CV Venus Inti Perkasa | | Indonesia | | Active |
Tin | | Dongguan CiEXPO Environmental Engineering Co., Ltd. | | China | | Non Conformant |
| | | | | | | | | | | | | | | | | | | | |
Tin | | Dowa | | Japan | | Conformant |
Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | Vietnam | | Non Conformant |
Tin | | EM Vinto | | Bolivia | | Conformant |
Tin | | Estanho de Rondônia S.A. | | Brazil | | Conformant |
Tin | | Fabrica Auricchio Industria e Comercio Ltda. | | Brazil | | Conformant |
Tin | | Fenix Metals | | Poland | | Conformant |
Tin | | Gejiu City Fuxiang Industry & Trade Co., Ltd. | | China | | Not Enrolled |
Tin | | Gejiu Kai Meng Industry and Trade LLC | | China | | Non Conformant |
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 Limited Company | | 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 | | Not Enrolled |
Tin | | Metallic Resources, Inc. | | United States | | Conformant |
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 | | Non Conformant |
Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | Vietnam | | Not Enrolled |
Tin | | Novosibirsk Processing Plant Ltd. | | Russian Federation | | Conformant |
Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | Thailand | | Conformant |
Tin | | O.M. Manufacturing Philippines, Inc. | | Philippines | | Conformant |
Tin | | Operaciones Metalurgica S.A. | | Bolivia | | Conformant |
Tin | | Pongpipat Company Limited | | Myanmar | | Not Enrolled |
Tin | | Precious Minerals and Smelting Limited | | India | | Non 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 Cipta Persada Mulia | | Indonesia | | Conformant |
Tin | | PT Masbro Alam Stania | | Indonesia | | Active |
Tin | | PT Menara Cipta Mulia | | Indonesia | | Conformant |
Tin | | PT Mitra Stania Prima | | Indonesia | | Conformant |
Tin | | PT Mitra Sukses Globalindo | | Indonesia | | Active |
Tin | | PT Panca Mega Persada | | Indonesia | | Not Enrolled |
Tin | | PT Prima Timah Utama | | Indonesia | | Conformant |
Tin | | PT Rajawali Rimba Perkasa | | Indonesia | | Conformant |
Tin | | PT Refined Bangka Tin | | Indonesia | | Conformant |
Tin | | PT Sariwiguna Binasentosa | | Indonesia | | Conformant |
Tin | | PT Stanindo Inti Perkasa | | Indonesia | | Conformant |
Tin | | PT Sukses Inti Makmur | | Indonesia | | Active |
Tin | | PT Timah Nusantra | | Indonesia | | Active |
Tin | | PT Timah Tbk Kundur | | Indonesia | | Conformant |
Tin | | PT Timah Tbk Mentok | | Indonesia | | Conformant |
| | | | | | | | | | | | | | | | | | | | |
Tin | | PT Tinindo Inter Nusa | | Indonesia | | Conformant |
Tin | | PT Tirus Putra Mandiri | | Indonesia | | Not Enrolled |
Tin | | PT Tommy Utama | | Indonesia | | Not Enrolled |
Tin | | Resind Industria e Comercio Ltda. | | Brazil | | Conformant |
Tin | | Rui Da Hung | | Taiwan | | Conformant |
Tin | | Soft Metais Ltda. | | Brazil | | Conformant |
Tin | | Super Ligas | | Brazil | | Active |
Tin | | Thai Nguyen Mining and Metallurgy Co., Ltd. | | Vietnam | | Conformant |
Tin | | Thaisarco | | Thailand | | Conformant |
Tin | | Tin Technology & Refining | | United States | | Conformant |
Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | Vietnam | | Not Enrolled |
Tin | | VQB Mineral and Trading Group JSC | | Vietnam | | Not Enrolled |
Tin | | White Solder Metalurgia e Mineração 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 | | Non Conformant |
Tungsten | | A.L.M.T. Corp. | | Japan | | Conformant |
Tungsten | | ACL Metais Eireli | | Brazil | | Conformant |
Tungsten | | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | | Brazil | | Active |
Tungsten | | Artek LLC | | Russian Federation | | Not Enrolled |
Tungsten | | Asia Tungsten Products Vietnam Ltd. | | Vietnam | | Conformant |
Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | China | | Conformant |
Tungsten | | China Molybdenum Co., Ltd. | | China | | Conformant |
Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | CNMC (Guangxi) PGMA Co., Ltd. | | China | | Not Enrolled |
Tungsten | | Cronimet Brasil Ltda. | | Brazil | | Conformant |
Tungsten | | Fujian Ganmin RareMetal Co., Ltd. | | China | | Conformant |
Tungsten | | Fujian Xinlu Tungsten | | China | | Conformant |
Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | China | | Conformant |
Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | China | | Conformant |
Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | China | | Conformant |
Tungsten | | GEM Co. Ltd. | | China | | Conformant |
Tungsten | | Global Tungsten & Powders Corp. | | United States | | Conformant |
Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | H.C. Starck Smelting GmbH & Co.KG | | Germany | | Conformant |
Tungsten | | H.C. Starck Tungsten GmbH | | Germany | | Conformant |
Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | China | | Conformant |
Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | China | | Conformant |
Tungsten | | Hydrometallurg, JSC | | Russian Federation | | Conformant |
Tungsten | | Japan New Metals Co., Ltd. | | Japan | | Conformant |
Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | China | | Conformant |
Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | | China | | Not Enrolled |
Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | China | | Conformant |
Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | China | | Conformant |
Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | JSC “Kirovgrad Hard Alloys Plant” | | Russian Federation | | Conformant |
Tungsten | | Kennametal Fallon | | United States | | Conformant |
Tungsten | | Kennametal Huntsville | | United States | | Conformant |
Tungsten | | KGETS Co., Ltd. | | Republic of Korea | | Conformant |
Tungsten | | Lianyou Metals Co., Ltd. | | Taiwan | | Conformant |
Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | Masan Tungsten Chemical LLC | | Vietnam | | Conformant |
Tungsten | | Moliren Ltd. | | Russian Federation | | Conformant |
| | | | | | | | | | | | | | | | | | | | |
Tungsten | | Niagara Refining LLC | | United States | | Conformant |
Tungsten | | NPP Tyazhmetprom LLC | | Russian Federation | | Active |
Tungsten | | OOO “Technolom” 1 | | Russian Federation | | Active |
Tungsten | | OOO “Technolom” 2 | | Russian Federation | | Active |
Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | Philippines | | Conformant |
Tungsten | | Unecha Refractory metals plant | | Russian Federation | | Conformant |
Tungsten | | Wolfram Bergbau und Hütten AG | | Austria | | Conformant |
Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | China | | Conformant |
Tungsten | | Xiamen Tungsten Co., Ltd. | | China | | Conformant |
Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | China | | Conformant |
* “Conformant” means the smelter or refiner is included on the RMI list of smelters and refiners that have successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment; “Active” means the smelter or refiner is included on the RMI list of smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment (these smelters or refiners may be in the pre-assessment, assessment, or corrective-action phases of the assessment); “Not Enrolled” means the smelter or refiner is listed on the RMI reference list of smelters and refiners but is not Conformant and is not currently participating in an RMAP assessment; and “Non Conformant” means the smelter or refiner is listed on the RMI list of smelters and refiners and has failed an RMAP assessment, refuses to participate in the RMAP assessment process, or does not provide adequate access to facilities to complete the RMAP assessment. The compliance status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us.
Schedule 2
The following list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore it is not certain which of these countries of origin can be linked to our products.
Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Canada, Chile, China, Colombia, Costa Rica, Cote d’Ivoire, Cuba, Cyprus, Democratic Republic of the Congo, Dominican Republic, Ecuador, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Ivory Coast, Japan, Kazakhstan, Kenya, Krygyzstan, Laos, Liberia, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Namibia, New Zealand, Nicaragua, Niger, Nigeria, Oman, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Zambia, Zimbabwe