UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
STMicroelectronics N.V.
(Exact name of the registrant as specified in its charter)
| The Netherlands | 1-13546 | 26-0047957 |
|
(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| WTC Schiphol Airport | |
| Schiphol Boulevard 265 | |
| 1118 BH Schiphol | |
| The Netherlands | N/A |
| (Address of principal executive offices) | (Zip code) |
Steven Rose +41 22 929 29 29
(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:
| _√__ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021 |
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit
The Company has filed as an exhibit to this Form SD a Conflict Minerals Report. This Form SD and Conflict Minerals Report are available on our website at the following address: http://investors.st.com.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items
1.01 and 1.02 of this Form SD.
SIGNATURES
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.
STMicroelectronics N.V.
| (Registrant) |
| By: | /s/ Jean-Marc Chery | Date: May 30, 2022 | ||
| Name: | Jean-Marc Chery | |||
| Title: | President and Chief Executive Officer and Sole | |||
| Member of our Managing Board | ||||
Conflict Minerals Report of STMicroelectronics N.V.
in accordance with
Rule 13p-1 under the Securities Exchange Act of 1934
EU Regulation 2017/821
This Conflict Minerals Report (the “Report”) for the year ended December 31, 2021, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 and guidance in relation thereto promulgated by the Securities and Exchange Commission (the “SEC”) (collectively, the “Rule”) and EU Regulation 2017/821 laying down supply chain due diligence obligations for European Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas (the “Regulation”).
In this Report, references to “ST”, “we”, “us” and “Company” are to STMicroelectronics N.V. together with its consolidated subsidiaries, which includes its manufacturing facilities in and outside the European Union. Furthermore, the SEC defines “conflict minerals” as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. The Regulation is applicable to European Union importers of certain minerals or metals, whereby (i) the minerals refer to ores and concentrates containing tin, tantalum, tungsten or gold and (ii) the metals refer to metals containing or consisting of tin, tantalum, tungsten or gold, specifically where these minerals or metals potentially originate from, or are linked to, conflict-affected and high-risk areas (“CAHRAs”) as defined by the Organisation of Economic Co-Operation and Development (the "OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance").
The term “conflict minerals” throughout this Report refers to the minerals and metals as covered by the Rule and the Regulation, regardless of such metals’ and minerals’ country of origin or whether they are financing or benefiting armed conflict or contributing to violations of international law, including human rights abuses. Further definitions are included in Annex I hereto.
The content of any website referenced in this Report is included for general information only and is not incorporated by reference in this Report.
In accordance with the Rule and the Regulation, this Report is available on our website at the following address: https://investors.st.com/sec-filings.
| 1. | Company Overview |
Business and products
We are a global leader in the semiconductor market, serving a broad range of customers across different areas. Our products are used in a wide variety of applications, which address four end markets: automotive, industrial, personal electronics and communications equipment, computers and peripherals.
Our main categories of products1 are as follows:
1 We derive less than 0.10% of our total annual revenue from sales of promotional evaluation and development boards assembled by third party subcontractors, which represent prototypical system-level applications that include our integrated circuit products as well as components originating from third parties. These boards are useful to demonstrate the features and functionality of our semiconductor products and assist our customers in transitioning from initial prototype designs to final production releases. References herein to our “products” are to our integrated circuit products (excluding such boards) representing 99.9% or more of our total annual revenue.
| 1 |
| · | Automotive and Discrete Group (ADG), comprised of dedicated automotive integrated circuits (“ICs”), and discrete and power transistor products. |
| · | Analog, MEMS and Sensors Group (AMS), comprised of analog, smart power, low power RF, MEMS sensors and actuators, and optical sensing solutions. |
| · | Microcontrollers and Digital ICs Group (MDG), comprised of microcontrollers (general purpose and secure), memories (RF and EEPROM), and RF communications. |
A more detailed description of our product categories and the products relating to each category is contained in our Annual Report on Form 20-F and Dutch Annual Report, respectively, in relation to the 2021 calendar year which was filed with the SEC on February 24, 2022, and the AFM (Dutch Financial Market Authority) on March 24, 2022, respectively.
Manufacturing processes
The manufacture of semiconductor products requires, among other things, the mastery of the properties of conductivity, isolation and/or amplification. The manufacturing of an integrated circuit can be divided into two phases. The first, wafer fabrication, is the extremely sophisticated and intricate process of manufacturing the silicon chip. The second, assembly, is the highly precise and automated process of packaging the die. Those two phases are commonly known respectively as “Front-End” and “Back-End”.
The manufacturing process of semiconductor products requires various materials, gases and chemicals. We have identified tin, tantalum, tungsten and gold (collectively, “3TG”) as being among the materials necessary to the functionality or production of certain of our products manufactured during the 2021 calendar year.
Supply chain
We are not engaged in the mining and trade of minerals, nor in any refining or smelting activities. We purchase materials, commodities, chemicals and gases which potentially contain minerals and/or metals covered in the Rule and the Regulation as part of their composition. In general, we do not conduct business directly with smelters and refiners.
Because of our large size, the complexity of our products, and the depth, breadth, and constant evolution of our global supply chain, it is difficult and resource-intensive to identify actors upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives as described in section 2 below.
| 2. | Due Diligence Process |
I. Establish strong company management systems
Conflict minerals policy
ST began to address the conflict minerals issue as early as 2007 by requiring our tantalum suppliers to confirm they were not sourcing metals from conflict areas. We are a member of the Responsible Business Alliance (the “RBA”), commit to the RBA’s Code of Conduct and integrate its principles in our internal policies and participate in the Responsible Minerals Initiative (the “RMI”). We require all our suppliers and subcontractors to provide evidence that they are not sourcing 3TG through any channels that fund armed groups or security forces or contribute to widespread and systematic violations of international law, including, human rights abuses.
| 2 |
Our Policy Statement on Conflict Minerals and Responsible Minerals Sourcing (our “Policy Statement”) is regularly provided to our suppliers and is available at: www.st.com/conflict-free_minerals.
Our ‘Conflict Mineral Report’ is issued annually and published on our website: https://investors.st.com/sec-filings.
In our annual Sustainability Report we also report on our conflict minerals program and this report is available at: https://www.st.com/content/st_com/en/about/st_approach_to_sustainability/sustainability-reports.html.
Furthermore, the relevant Conflict Minerals Reporting Template (the “CMRT”) and the Extended Mineral Reporting Template (the “EMRT”) are provided on demand upon request of our customers through our online support portal https://community.st.com/s/onlinesupport.
The respective websites of the RBA and the RMI are accessible at http://www.responsiblebusiness.org/ and http://www.responsiblemineralsinitiative.org/.
Any grievance related to conflict minerals linked to ST can be reported through our Misconduct Reporting Hotline. Operated by an independent third-party provider, it is reachable 24/7 online or by phone (with a multilingual offering): https://secure.ethicspoint.eu/domain/media/en/gui/104021/index.html.
Furthermore, generic grievances can be reported through the RMI grievance mechanism: https://www.responsiblemineralsinitiative.org/rmap/grievance-mechanism/..
Design of due diligence
Our due diligence measures have been designed to conform, in all material respects, to the framework in the OECD Guidance and the related supplements for tin, tantalum, tungsten and gold, as well as related RBA recommendations. The OECD is an international organization that is endorsed by the United Nations and currently offers the only recognized framework available for such use.
Management system
In addition to implementing our Policy Statement as outlined above, evidencing our top management’s commitment to our conflict minerals program, we have implemented our conflict minerals management system in alignment with the OECD Guidance. We have established roles and duties within the Company’s relevant internal organizations involved in the program. The roles and duties established for several key internal organizations are outlined below.
Our Corporate Quality and Social Responsibility organizations are responsible for the following:
| · | proactively working with our customers to define the scope and form of our conflict minerals disclosures; |
| · | defining the strategy and annual objectives related to the implementation of the conflict minerals program within the Company and the coordination thereof with the appropriate internal organizations responsible for sourcing and purchasing materials and subcontracted services and products (including our Global Procurement Organization); |
| · | establishing the appropriate internal and external communication content on these programs through the relevant and necessary media and in accordance with our internal processes, including, without limitation, our Policy Statement and dedicated content in our annual Sustainability Report, both of which are made available on our website; and |
| · | reviewing and updating our conflict minerals management procedures on a regular basis. |
Our Global Procurement Organization helps to implement our conflict minerals program by supporting the communication of Company requirements to our suppliers and monitoring our suppliers’ engagement and progress in relation to our conflict minerals program. As part of the engagement with our suppliers they commit to respond to our requests with regard to, amongst others, their adherence to the requirements of our conflict minerals program.
| 3 |
Our Global Outsourcing Business Management group helps to implement our conflict minerals program by supporting the communication of Company requirements to Back-End subcontractors and monitoring our subcontractors’ engagement and progress in relation to our conflict minerals program.
Our Wafer Foundry group supports our conflict minerals program by communicating our requirements to wafer foundries and by monitoring our subcontractors’ engagement and progress in relation to our conflict minerals program.
In addition, our conflict minerals program is included as part of our sustainability and quality strategies and is highlighted as a key objective for each of our relevant internal organizations, in addition to the key internal groups discussed above, as applicable within the scope of their respective activities. A working group with representatives from the principal organizations involved, regularly reviews the progress of the implementation of our conflict minerals program. Based on our needs and as appropriate for the situation, such working group implements the appropriate risk mitigation measures.
Industry wide initiatives
As we are a participating member of the RBA, we employ due diligence methodologies defined by a joint working group comprised of RBA and the Global e-Sustainabiltiy Initiative (the “GeSI”) representatives. Tools available for participants in the RBA include a template known as the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The CMRT is used by many companies in their due diligence processes related to conflict minerals.
In addition, the RBA and the GeSI developed the RMI in 2010, which is a voluntary initiative in which an independent third-party audits smelter procurement and processing activities and determines if the smelter has provided sufficient documentation to demonstrate with reasonable confidence that the minerals it processed originated from conflict-free sources. In 2012, the RMI, the London Bullion Market Association (the “LBMA”) and the Responsible Jewellery Council (the “RJC”) announced their mutual cross-recognition of gold refiner audits. All three programs focus on independent third-party audits of refiners’ due diligence in conformity with the OECD Guidance, which recognizes refiners as a key “choke point” in the gold supply chain.
We, along with other leading participants in the electronics industry, rely on the RMI’s Responsible Minerals Assurance Process (the “RMAP”) or an equivalent industry-wide program for audits of smelters and/or refiners. Further details on this program are available on the RMI’s website at the address referenced above.
As a key element of our strategy, we only engage suppliers who declare to use minerals sourced from RMAP conformant smelters.
In previous years we had reported on additional initiatives undertaken directly towards certain smelters, which at that time did not yet participate in the RMAP conformant smelters program, to influence them to seek full RMAP conformant smelters validation. Currently as the market has reached a sufficient maturity as it regards RMAP conformant smelters and we require our suppliers and subcontractors to only source materials for us from RMAP conformant smelters we do not need to undertake such additional initiatives anymore.
| 4 |
II. Identify and assess risks in the supply chain
Risk definition
We have identified the following risks:
Main downstream risks
| · | Supplier not providing material composition |
| · | Supplier not conducting proper due diligence |
| · | Supplier declaring smelters list not linked to material sold (effects of multi-sourcing) |
| · | Use non-conformant Smelters |
Main upstream risks
| · | Serious abuses associated with the extraction, transport or trade of minerals: |
| - | Any form of torture, cruel, inhuman and degrading treatment |
| - | Any form of forced or compulsory labor |
| - | The worst forms of child labor |
| - | Other gross human rights violations and abuses, such as widespread sexual violence |
| - | War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide |
| · | Direct or indirect support to non-state armed groups |
| · | Direct or indirect support to public or private security forces |
| · | Bribery and fraudulent misrepresentation of the origin of minerals: |
| - | Money laundering |
| - | Non-payment of taxes, fees and royalties to governments |
Main additional risks
| · | Environment (pollution, water consumption abstraction, tailings) |
| · | Health & Safety (occupational health and safety, community health and safety) |
Risks related to red flag situations (situation where risks in supply chain are more likely to be found)
| · | Red flag locations of mineral origin and transit: |
| - | The minerals originate from or have been transported via a conflict-affected or high-risk area |
| - | The minerals are claimed to originate from a country that has limited known reserves, likely resources or expected production levels of the mineral in question (i.e. the declared volumes of mineral from that country are out of keeping with its known reserves or expected production levels) |
| - | The minerals are claimed to originate from a country in which minerals from conflict-affected and high-risk areas are known to transit |
| · | Supplier red flags: |
| - | The company’s suppliers or other known upstream companies have shareholder or other interests in companies that supply minerals from or operate in one of the above-mentioned red flag locations of mineral origin and transit |
| - | The company’s suppliers or other known upstream companies are known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months |
| 5 |
Risk identification processes and tools
We have identified the above risks using the processes and tools as described below.
| Risk | Risk identification |
| a) Main risk @ Downstream supply chain |
· Material Composition collection · Responsible Minerals Statement · Downstream Audit Program (“DAP”) |
| b) Main risk @ Upstream supply chain |
· CMRT · Smelters Audits (“RMAP”) |
| c) Additional risks |
· RMI & ST Grievance portal · Web watch |
| d) Red flag situations |
· Reasonable Country of Origin Inquiry (“RCOI”) list · Smelters Audit (“RMAP”) |
Risk identification methods
Below is a description of our risk identification methods:
| · | Material Composition collection |
We periodically ask our suppliers to provide the detailed material composition of the materials used in our manufacturing processes. That data allows us to identify the materials in scope of the RMI program.
If we do not receive this information from our suppliers, we check the material specification to find any useful information to determine the material composition.
In case the material specification does not disclose the presence of substances in scope of the RMI program, we check the material family to assess if the materials could potentially contain substances in scope of the RMI program.
| · | Responsible Minerals Statement |
During our annual survey, we deploy a questionnaire to our suppliers which allows us to:
| - | Identify substances & suppliers in scope of the RMI program; |
| - | Share our requirements; |
| - | Check supplier’s alignment with our requirements; and |
| - | Assess risks at supplier level. |
| · | Downstream Audit Program (“DAP”) |
We required our suppliers, in scope of the RMI program to pass the 3rd part audit DAP organized by the RMI, in order to validate their Responsible Minerals Sourcing due diligence practices.
| 6 |
| · | Conflict Minerals Reporting Template (“CMRT”) |
We require a CMRT to our suppliers in three cases:
| - | During our annual survey; |
| - | When a smelter’s conformance status changes; and |
| - | We require our suppliers to send us an updated CMRT in case their smelters list changes. |
In the “Responsible Minerals Statement”, we detail our requirements related to the CMRT.
| · | Smelters Audit |
As an RMI member, we benefit from third- party audits organized by the RMI, the LBMA and the RJC. During the Smelters Audit, OECD red flag identification and mitigation are assessed.
The audit results are aggregated in a list maintained by the RMI named the RMAP list.
We crosscheck our suppliers’ CMRT with the RMAP list in order to identify any non-conformant smelters.
Furthermore, we periodically receive notification from the RMI to highlight a smelter’s conformance change.
| · | RMI Grievance portal |
In our “Responsible Minerals Statement”, we encourage suppliers to initiate a grievance on the RMI portal if they become aware of a violation of the OECD Guidance Annex II or other critical risk. (https://mineralsgrievanceplatform.org/)
| · | ST Grievance portal |
Anyone can issue a grievance related to ST via our “Misconduct Reporting Hotline Platform”, which is operated by a third-party in order to guarantee an independent and objective process.
| · | Web Watch |
We use a service provider to screen the Web and the deep Web in order to track any publication related to our smelters. We receive daily notification of potential relevant publications.
| · | RCOI List |
We use the RCOI list to identify the countries of origin of the minerals and the related risk classification. The RCOI list allows us to identify Red Flags associated to CAHRAs (including the Democratic Republic of the Congo and adjoining countries).
CMRT inquiry responses 2021
We conducted an inquiry, using the CMRT, with all the suppliers and subcontractors which we identified within our conflict mineral supply chain. All such suppliers and subcontractors responded to our due diligence inquiry. The below table shows the supplier responses and completion rate since 2016 as of December 31 of each year:
| 2021 | 2020 | 2019 | 2018 | 2017 | 2016 | |
| Supplier Template Completion Rate | 100% | 100% | 100% | 100% | 100% | 100% |
| 137 | 124 | 124 | 128 | 126 | 118 |
| 7 |
We reviewed the responses received against criteria developed to determine which responses required further engagement with our suppliers. These criteria included untimely or incomplete responses as well as inconsistencies within the data reported in the CMRT.
We rely on the good faith efforts of our suppliers and subcontractors to provide us with reasonable representations of the processing facilities used to supply the necessary conflict minerals in our products. As a result of our inquiry via the CMRT, our suppliers and subcontractors reported to us a total of 204 smelters as sources of 3TG during the 2021 calendar year, 14 (see Table 2 below in section IV for details) of which we had discontinued as sources as of December 31, 2021, as reflected in the Table 2 in section IV below.
The table below indicates the CMRT inquiry responses as of December 31 of each of the relevant years, indicating per metal: (i) the number of smelters declared; (ii) the percentage of declared smelters which were RMAP conformant; (iii) the percentage of declared active smelters; and (iv) the percentage of smelters not identified or not listed. Information relating to RMAP conformant smelters is extracted from the RBA/RMI database. The information presented in the below table represents the state of affairs as of December 31 of each relevant year, but should not be interpreted as necessarily having applied consistently throughout the entire calendar year. Although we have received, and regularly continue to receive, updates to the RMAP conformance information presented in this table, we have presented it as of December 31 of each relevant year. Information on the smelters that we discontinued as sources during the calendar year, but before December 31, of each of the years 2017-2020 can be found in our conflict minerals report filed with the SEC as an exhibit to Form SD for that relevant year.
| YEAR | Metal | Number of smelters declared | Percentage of smelters RMAP conformant declared | Percentage of active smelters declared | Percentage of smelters not identified or not listed |
| 2021 | Gold | 63 | 100% | 0% | 0% |
| Tantalum | 33 | 100% | 0% | 0% | |
| Tin | 54 | 98.15% | 1.85% | 0% | |
| Tungsten | 39 | 100% | 0% | 0% | |
| 2020 | Gold | 107 | 100% | 0% | 0% |
| Tantalum | 37 | 100% | 0% | 0% | |
| Tin | 53 | 100% | 0% | 0% | |
| Tungsten | 42 | 100% | 0% | 0% | |
| 2019 | Gold | 102 | 100% | 0% | 0% |
| Tantalum | 39 | 100% | 0% | 0% | |
| Tin | 72 | 100% | 0% | 0% | |
| Tungsten | 40 | 100% | 0% | 0% | |
| 2018 | Gold | 99 | 100% | 0% | 0% |
| Tantalum | 39 | 100% | 0% | 0% | |
| Tin | 73 | 100% | 0% | 0% | |
| Tungsten | 40 | 100% | 0% | 0% | |
| 2017 | Gold | 86 | 100% | 0% | 0% |
| Tantalum | 17 | 100% | 0% | 0% | |
| Tin | 62 | 100% | 0% | 0% | |
| Tungsten | 32 | 100% | 0% | 0% |
| 8 |
The below table shows the status of all declared and identified smelters and refiners for the relevant years as per December 31 of each relevant year:
| 2021 | 2020 | 2019 | 2018 | 2017 | |
| Percentage of smelters certified RMAP conformant | 99.47% | 100% | 100% | 100% | 100% |
| (188/189) | (239/239) | (253/253) | (251/251) | (197/197) | |
| Currently participating, in communication or agreed to participate in audit process | 0.53% | N/A | N/A | N/A | N/A |
| (1/189) | |||||
| Outreach Required | N/A | N/A | N/A | N/A | N/A |
Analysis of our products in light of due diligence results
From the figures in the above table, we can conclude that 99.47% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2021, were validated by the RMAP as being conformant as of December 31, 2021. We have included in Table 1 in section IV below a list of these processing facilities as well as their identification number as used by the RMAP.
15 of the 204 smelters declared to us by our suppliers and subcontractors were RMAP conformant at some point during calendar year 2021 but no longer qualified as such as of December 31, 2021 and 14 were therefore removed from our authorized sources of 3TG as of such date. However, one non conformant Tin smelter remained in our supply chain as the process of replacing this smelter was still ongoing at December 31, 2021 and therefore, as of December 31, 2021, we declare 1 active Tin non conformant smelter, details of which are included in Table 3 in section IV below. We are not in a position to know whether a certain 3TG material which was used in the manufacture of a product during 2021 originated with one of such smelters before or after it lost its status as RMAP conformant. We have identified these smelters and the month during which we were notified of their removal from the RMAP conformance list in Table 2 in section IV below.
III. Design and implement a strategy to respond to identified risks
A key requirement to our supply chain, is to use only RMAP conformant smelters. By doing this we ensure that most of the risks identified are addressed. The following section details our mitigation strategy per identified risk.
Risk mitigation
We have a risk mitigation plan to address the risks identified. In this plan, mitigation actions are detailed per category of identified risks.
| 9 |
We mitigate risks identified “upstream” by only working with RMAP conformant smelters and relying on the smelter audits. In case a smelter becomes non-conformant we remove it from our supply chain.
We mitigate risks identified “downstream” by continuously assessing and training our suppliers to ensure the reliability of their due diligence.
On a quarterly basis a standard report is communicated to our Sustainability Council, consisting of representatives of the following organizations within ST: Corporate Social Responsibility, Internal Communication, External Communication, Quality, Product Groups, Manufacturing, Sales, Compliance & Business Ethics, Procurement, Investor Relations & Finance.
This report details (i) the conflict minerals-related risks identified during the quarter, (ii) the mitigation actions taken and (iii) the conformance status and a list of delinquent suppliers which do not meet our mandatory requirements despite several risk mitigation efforts attempted from our side. The Sustainability Council should indicate further action to be taken to treat delinquent suppliers, which may include disengaging with a delinquent supplier after failed attempts at risk mitigation, although the latter has not yet been the case.
IV. Independent third-party audit of smelters
99.47% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2021, were validated by the RMAP as being conformant as of December 31, 2021 based on independent third-party audits performed on these smelters. Included in the below table is a summary of the independent third-party audits performed on the processing facilities that were identified to us by our suppliers as potentially in our supply chain for 2021. The presence of a facility on this list does not mean that our products necessarily contained 3TGs processed by that facility. Location information for each processing facility is as reported by the RMAP as of December 31, 2021.
Lists of Processing Facilities
Table 1: Processing facilities reported in our supply chain in relation to calendar year 2021 which were validated by the RMAP conformant smelters program as of December 31, 2021:
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000015 | Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | RMI |
| CID000019 | Gold | Aida Chemical Industries Co., Ltd. | JAPAN | LBMA RG |
| CID000035 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | LBMA RG /RJC |
| CID000058 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | LBMA RG |
| CID000077 | Gold | Argor-Heraeus S.A. | SWITZERLAND | LBMA RG |
| CID000082 | Gold | Asahi Pretec Corp. | JAPAN | LBMA RG |
| CID000924 | Gold | Asahi Refining Canada Ltd. | CANADA | LBMA RG |
| CID000920 | Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | LBMA RG |
| CID000090 | Gold | Asaka Riken Co., Ltd. | JAPAN | LBMA RG |
| 10 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000113 | Gold | Aurubis AG | GERMANY | LBMA RG |
| CID000157 | Gold | Boliden AB | SWEDEN | LBMA RG |
| CID000176 | Gold | C. Hafner GmbH + Co. KG | GERMANY | LBMA RG /RJC |
| CID000185 | Gold | CCR Refinery - Glencore Canada Corporation | CANADA | LBMA RG |
| CID000233 | Gold | Chimet S.p.A. | ITALY | LBMA RG |
| CID000401 | Gold | Dowa | JAPAN | RMI |
| CID000425 | Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | LBMA RG |
| CID002561 | Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | LBMA RG |
| CID002459 | Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | RMI |
| CID002243 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | LBMA RG |
| CID000694 | Gold | Heimerle + Meule GmbH | GERMANY | LBMA RG |
| CID000711 | Gold | Heraeus Germany GmbH Co. KG | GERMANY | RMI |
| CID000707 | Gold | Heraeus Metals Hong Kong Ltd. | CHINA | LBMA RG /RJC |
| CID000801 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | LBMA RG |
| CID000807 | Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | LBMA RG |
| CID000814 | Gold | Istanbul Gold Refinery | TURKEY | LBMA RG |
| CID000855 | Gold | Jiangxi Copper Co., Ltd. | CHINA | LBMA RG |
| CID000937 | Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | LBMA RG |
| CID000969 | Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | LBMA RG |
| CID000981 | Gold | Kojima Chemicals Co., Ltd. | JAPAN | LBMA RG |
| CID002762 | Gold | L'Orfebre S.A. | ANDORRA | LBMA RG |
| CID001078 | Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | LBMA RG |
| CID001113 | Gold | Materion | UNITED STATES OF AMERICA | RMI |
| CID001119 | Gold | Matsuda Sangyo Co., Ltd. | JAPAN | LBMA RG |
| CID001149 | Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | LBMA RG /RJC |
| CID001152 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | LBMA RG |
| CID001147 | Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | LBMA RG |
| CID001153 | Gold | Metalor Technologies S.A. | SWITZERLAND | LBMA RG |
| CID001157 | Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | LBMA RG |
| CID001161 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | LBMA RG |
| CID001188 | Gold | Mitsubishi Materials Corporation | JAPAN | LBMA RG |
| CID001193 | Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | LBMA RG |
| 11 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID001220 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | LBMA RG |
| CID001259 | Gold | Nihon Material Co., Ltd. | JAPAN | LBMA RG |
| CID001325 | Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | RMI |
| CID001352 | Gold | PAMP S.A. | SWITZERLAND | LBMA RG |
| CID001498 | Gold | PX Precinox S.A. | SWITZERLAND | LBMA RG |
| CID001512 | Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | LBMA RG |
| CID001534 | Gold | Royal Canadian Mint | CANADA | LBMA RG |
| CID002777 | Gold | SAXONIA Edelmetalle GmbH | GERMANY | LBMA RG |
| CID001585 | Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | LBMA RG |
| CID001916 | Gold | Shandong Gold Smelting Co., Ltd. | CHINA | LBMA RG |
| CID001622 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | LBMA RG |
| CID001736 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | LBMA RG |
| CID001761 | Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | LBMA RG |
| CID001798 | Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | LBMA RG |
| CID001875 | Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | LBMA RG |
| CID001938 | Gold | Tokuriki Honten Co., Ltd. | JAPAN | LBMA RG |
| CID001980 | Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | LBMA RG |
| CID001993 | Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | LBMA RG |
| CID002003 | Gold | Valcambi S.A. | SWITZERLAND | LBMA RG /RJC |
| CID002030 | Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | LBMA RG |
| CID002778 | Gold | WIELAND Edelmetalle GmbH | GERMANY | LBMA RG |
| CID002224 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | LBMA RG |
| CID000092 | Tantalum | Asaka Riken Co., Ltd. | JAPAN | RMI |
| CID000211 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | LBMA RG |
| CID002504 | Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | LBMA RG |
| CID000456 | Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | LBMA RG |
| CID000460 | Tantalum | F&X Electro-Materials Ltd. | CHINA | LBMA RG |
| CID002505 | Tantalum | FIR Metals & Resource Ltd. | CHINA | LBMA RG |
| CID002558 | Tantalum | Global Advanced Metals Aizu | JAPAN | LBMA RG |
| CID002557 | Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | LBMA RG |
| CID002547 | Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | LBMA RG |
| CID002548 | Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | LBMA RG |
| CID002492 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | LBMA RG |
| CID002512 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | RMI |
| 12 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID002842 | Tantalum | Jiangxi Tuohong New Raw Material | CHINA | LBMA RG |
| CID000914 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | LBMA RG |
| CID000917 | Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | LBMA RG |
| CID002506 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | RMI |
| CID001076 | Tantalum | LSM Brasil S.A. | BRAZIL | RMI |
| CID001163 | Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | LBMA RG |
| CID001175 | Tantalum | Mineracao Taboca S.A. | BRAZIL | RMI |
| CID001192 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | RMI |
| CID001277 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | LBMA RG |
| CID001200 | Tantalum | NPM Silmet AS | ESTONIA | RMI |
| CID002707 | Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | RMI |
| CID001769 | Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | RMI |
| CID001869 | Tantalum | Taki Chemical Co., Ltd. | JAPAN | LBMA RG |
| CID002544 | Tantalum | TANIOBIS Co., Ltd. | THAILAND | LBMA RG |
| CID002545 | Tantalum | TANIOBIS GmbH | GERMANY | LBMA RG |
| CID002549 | Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | LBMA RG |
| CID002550 | Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | LBMA RG |
| CID001891 | Tantalum | Telex Metals | UNITED STATES OF AMERICA | RMI |
| CID001969 | Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | LBMA RG |
| CID000616 | Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | RMI |
| CID001522 | Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | LBMA RG |
| CID000292 | Tin | Alpha | UNITED STATES OF AMERICA | LBMA RG |
| CID000228 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | LBMA RG |
| CID003190 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | LBMA RG |
| CID001070 | Tin | China Tin Group Co., Ltd. | CHINA | LBMA RG |
| CID000402 | Tin | Dowa | JAPAN | LBMA RG |
| CID000438 | Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | LBMA RG |
| CID000468 | Tin | Fenix Metals | POLAND | LBMA RG |
| CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | LBMA RG |
| CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | LBMA RG |
| CID001908 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | LBMA RG |
| CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | LBMA RG |
| 13 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | LBMA RG |
| CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | LBMA RG |
| CID001231 | Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | LBMA RG |
| CID003387 | Tin | Luna Smelter, Ltd. | RWANDA | RMI |
| CID003379 | Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | LBMA RG |
| CID002468 | Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | LBMA RG |
| CID001105 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | LBMA RG |
| CID002500 | Tin | Melt Metais e Ligas S.A. | BRAZIL | LBMA RG |
| CID001142 | Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | LBMA RG |
| CID002773 | Tin | Metallo Belgium N.V. | BELGIUM | LBMA RG |
| CID002774 | Tin | Metallo Spain S.L.U. | SPAIN | LBMA RG |
| CID001173 | Tin | Mineracao Taboca S.A. | BRAZIL | LBMA RG |
| CID001182 | Tin | Minsur | PERU | LBMA RG |
| CID001191 | Tin | Mitsubishi Materials Corporation | JAPAN | LBMA RG |
| CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | LBMA RG |
| CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | LBMA RG |
| CID001337 | Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | LBMA RG |
| CID001399 | Tin | PT Artha Cipta Langgeng | INDONESIA | LBMA RG |
| CID002503 | Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | LBMA RG |
| CID001406 | Tin | PT Babel Surya Alam Lestari | INDONESIA | RMI |
| CID003205 | Tin | PT Bangka Serumpun | INDONESIA | RMI |
| CID002835 | Tin | PT Menara Cipta Mulia | INDONESIA | LBMA RG |
| CID001453 | Tin | PT Mitra Stania Prima | INDONESIA | LBMA RG |
| CID001458 | Tin | PT Prima Timah Utama | INDONESIA | LBMA RG |
| CID003381 | Tin | PT Rajawali Rimba Perkasa | INDONESIA | RMI |
| CID002593 | Tin | PT Rajehan Ariq | INDONESIA | LBMA RG |
| CID001460 | Tin | PT Refined Bangka Tin | INDONESIA | LBMA RG |
| CID001468 | Tin | PT Stanindo Inti Perkasa | INDONESIA | RMI |
| CID001477 | Tin | PT Timah Tbk Kundur | INDONESIA | LBMA RG |
| CID001482 | Tin | PT Timah Tbk Mentok | INDONESIA | LBMA RG |
| CID001490 | Tin | PT Tinindo Inter Nusa | INDONESIA | RMI |
| CID002706 | Tin | Resind Industria e Comercio Ltda. | BRAZIL | LBMA RG |
| CID001539 | Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | LBMA RG |
| CID000760 | Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | RMI |
| CID001402 | Tin | PT Babel Inti Perkasa | INDONESIA | RMI |
| CID001758 | Tin | Soft Metais Ltda. | BRAZIL | LBMA RG |
| 14 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID002834 | Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM | LBMA RG |
| CID001898 | Tin | Thaisarco | THAILAND | LBMA RG |
| CID003325 | Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | LBMA RG |
| CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | LBMA RG |
| CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | LBMA RG |
| CID003397 | Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | LBMA RG |
| CID000004 | Tungsten | A.L.M.T. Corp. | JAPAN | LBMA RG |
| CID002833 | Tungsten | ACL Metais Eireli | BRAZIL | RMI |
| CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | RMI |
| CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | RMI |
| CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | RMI |
| CID003401 | Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | RMI |
| CID002645 | Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | RMI |
| CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | RMI |
| CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | RMI |
| CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | RMI |
| CID000568 | Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | RMI |
| CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | RMI |
| CID002541 | Tungsten | H.C. Starck Tungsten GmbH | GERMANY | RMI |
| CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | RMI |
| CID000769 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | RMI |
| CID002649 | Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | RMI |
| CID000825 | Tungsten | Japan New Metals Co., Ltd. | JAPAN | RMI |
| CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | RMI |
| CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | RMI |
| CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | RMI |
| CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | RMI |
| CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | RMI |
| CID000966 | Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | RMI |
| 15 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000105 | Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | RMI |
| CID003388 | Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID003407 | Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | RMI |
| CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | RMI |
| CID002543 | Tungsten | Masan High-Tech Materials | VIETNAM | RMI |
| CID002845 | Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | RMI |
| CID002589 | Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | RMI |
| CID002827 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | RMI |
| CID002579 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | RMI |
| CID002542 | Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | RMI |
| CID002724 | Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | RMI |
| CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | RMI |
| CID002843 | Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | RMI |
| CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | RMI |
| CID002830 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | RMI |
Table 2: Processing facilities reported in our supply chain in relation to calendar year 2021 which were no longer qualified as RMAP conformant as of December 31, 2021, and from which we have discontinued the sourcing of materials as of such date:
| RMAP Smelter Identification Number | Metal | Smelter Name | Smelter Country | Month of communication date from RMI (all in 2021) | Cause (as of communication date from RMI) |
| CID000499 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | January | Ceased operations |
| CID002579 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | January | Ceased operations |
| CID000499 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | February | Ceased operations |
| CID001889 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | February | Ceased operations |
| CID003182 | Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | March | Ceased operations |
| CID002848 | Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | June | Ceased operations |
| CID000092 | Tantalum | Asaka Riken Co., Ltd. | JAPAN | July | Ceased operations |
| CID002849 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | July | Ceased operations |
| 16 |
| RMAP Smelter Identification Number | Metal | Smelter Name | Smelter Country | Month of communication date from RMI (all in 2021) | Cause (as of communication date from RMI) |
| CID003182 | Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | July | Ceased operations |
| CID003195 | Gold | TSK Pretech | KOREA, REPUBLIC OF | July | Not a Smelter |
| CID001889 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | July | Ceased operations |
| CID002847 | Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | August | Ceased operations |
| CID002850 | Gold | AU Traders and Refiners | SOUTH AFRICA | September | RJC requirement |
| CID001029 | Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | September | LBMA requirement |
Table 3: Processing facilities reported in our supply chain in relation to calendar year 2021 which were no longer qualified as RMAP conformant as of December 31, 2021, and from which we have not yet discontinued the sourcing of materials as of such date:
| RMAP Smelter Identification Number | Metal | Smelter Name | Smelter Country | Month of communication date from RMI (all in 2021) | Cause (as of communication date from RMI) |
| CID002180 | Tin | Yunnan Tin Company Limited | CHINA | May | Active smelter |
V. Reporting
We report on our responsible minerals program and performance through different channels, as highlighted in the below table:
| Availability | Policy statement | CMRT | CRT | Sustainability report | DFA (CMR) | Annual responsible mineral report | |
| Public | st.com | x | x | x | x | ||
| Public | Inspectie Leefomgeving en Transport – Inspection living environment and transportation | x | |||||
| Public | SEC | x | x | ||||
| On demand | x | x |
| 17 |
ANNEX I
DEFINITIONS
| Acronym | Definition |
| BEMT R&D | Back End Manufacturing & Technology R&D |
| CAHRA | Conflict-Affected and High-Risk Area |
| CMRT | Conflict Minerals Reporting Template |
| CSR | Corporate Social Responsibility ST Organization |
| DAP | Downstream Audit Program |
| GOBM | Global Outsourcing Business Management |
| GPO | Global Procurement ST Organization |
| LBMA | London Bullion Market Association |
| PQR | Product Quality & Reliability ST Organization |
| RJC | Responsible Jewellery Council |
| RMAP | Responsible Minerals Assurance Process |
| RMI | Responsible Minerals Initiative |
| RMS | Responsible Minerals Statement |
| WFO | Wafer Foundry Outsourcing ST Organization |
| Term | Definition |
|
“DAP” Downstream Audit Program |
The RMI Downstream Audit Program provides a mechanism for companies to obtain independent validation of responsible sourcing practices. The audit is based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. |
| Conflict Minerals Reporting Template | The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. The template also facilitates the identification of new smelters and refiners to potentially undergo an audit via the RMI’s Responsible Minerals Assurance Process (RMAP). |
| Downstream | The metal supply chain from the stage following the smelters and refiners to the final product. |
| London Bullion Market Association | The LBMA set standards from the purity, form and provenance of the bars to the way in which they are traded. |
| Reasonable Country of Origin Inquiry (RCOI) | The purpose of a RCOI is to determine the origin of the conflict mineral, so the determination of whether it came from a covered country can be made. |
| Responsible Jewellery Council | RJC is the world’s leading standard-setting organisation for the entire jewellery and watch industry. |
| Responsible Minerals Assurance Process | The RMAP uses an independent third-party assessment of smelter/refiner management systems and sourcing practices to validate conformance with RMAP standards. |
| Responsible Minerals operator | Person in charge to manage operationally the responsible minerals program. |
| Responsible Minerals Statement | Questionnaire deployed to our suppliers in order to check their alignment with requirements and evaluate some downstream risks. |
| RMAP standards | The RMAP standards are developed to meet the requirements of the OECD Due Diligence Guidance, the Regulation (EU) 2017/821 of the European Parliament and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. |
| 18 |
| Term | Definition |
| Smelter / Refiner | According to the EU regulation, smelter and refiner means any natural or legal person performing forms of extractive metallurgy involving processing steps with the aim to produce a metal from a mineral. |
| Upstream | The mineral supply chain from the extraction sites to the smelters and refiners, inclusive. |
| 19 |