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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

(State or other jurisdiction of

incorporation or organization)

(Commission

File Number)

 

 

 

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:

 

_√__Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023

 

____Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended_________.

 

   

 

 

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.

 

 

Date:    May 15, 2024   STMicroelectronics N.V.
     
  By:  /s/ Jean-Marc Chery
  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, 2023, 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/financial-information/sec-filings.

 

1.Company Overview

 

Business and products

 

We are a global semiconductor company that designs, develops, manufactures and markets a broad range of products used in a wide variety of applications for the four end-markets we address: automotive, industrial, personal electronics and communications equipment, computers and peripherals.

At December 31 2023, our reportable segments were[1] are as follows:

 

·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, MEMS sensors and actuators, and optical sensing solutions; and

 

1 We derive less than 0.075% 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 more than 99.9% of our total annual revenue.

  1 

 

 

·Microcontrollers and Digital ICs Group (MDG), comprised of general-purpose microcontrollers and microprocessors, connected security products (e.g. embedded secured elements and NFC readers), memories (e.g. serial and page EEPROM) and RF and Communications products.

 

Effective as of February 5, 2024, we re-organized our product groups and reportable

segments to further accelerate our time-to-market and speed of product development innovation and efficiency and we have moved from three product groups and three reportable segments

(ADG, AMS and MDG), to two product groups and four reportable segments, as follows:

·Analog, Power & Discrete, MEMS and Sensors, including two reportable segments (Analog Products, MEMS and Sensors and Power and Discrete Products); and
·Microcontrollers, Digital ICs and RF products, including two reportable segments (Microcontrollers, and Digital ICs and RF Products).

 

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 in relation to the 2023 calendar year which was filed with the SEC on February 22, 2024, and the AFM (Dutch Financial Market Authority) on March 21, 2024, 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 silicon chip. 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 2023 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 several 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/financial-information/sec-filings.

 

We also report on our conflict minerals program in our annual Sustainability Report which 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://ols.st.com/s/

 

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 Ethics 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 senior 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.

 

  3 

 

 

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.

 

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-Sustainability 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.

 

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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.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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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); and
-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; and
-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.

 

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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 related to the Downstream supply chain

·         Material Composition collection

·         Responsible Minerals Statement

·         Downstream Assessment Program (“DAP”)

b)    Main risk related to the 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 and suppliers in scope of the RMI program;
-Share our requirements;
-Check supplier’s alignment with our requirements; and
-Assess risks at supplier level.

 

·Downstream Assessment Program (“DAP”)

 

We are one of the first semi-conductor manufacturers to receive the DAP recognition for 3TG. In November 2021, we received the RMI’s DAP recognition, with a two-year validity, which validated our responsible minerals sourcing due diligence and practices.We were reassessed in November 2023 and revalidated beginning of 2024.

This international assessment organized by the RMI, offers independent third-party assurance for companies importing, amongst others, 3TG-containing products into the EU considering the Regulation. A further description of this assessment and the list of facilities that have completed it are accessible here: https://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/downstream -program/.

 

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Furthermore, we request our suppliers, in scope of the RMI program to pass the DAP to validate their Responsible Minerals Sourcing due diligence practices.

 

·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 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, as referenced in Section 2.II. above, 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 “Ethics Hotline”, as referenced in Section 2.II. above, which is operated by a third-party in order to guarantee an independent and objective process.

 

 

·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 2023

 

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 2017 as of December 31 of each year:

 

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CMRT inquiry responses 2023 2023 2022 2021 2020 2019 2018 2017

 

Supplier Template Completion Rate

 100% 100% 100% 100% 100% 100% 100%
141 154 137 124 124 128 126

 

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 230 smelters as sources of 3TG during the 2023 calendar year, 20 of which we had discontinued as sources as of December 31, 2023, 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 2017-2021 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
2023 Gold 86 100% 0% 0%
Tantalum 32 100% 0% 0%
Tin 60 100% 0% 0%
Tungsten 32 100% 0% 0%
2022 Gold 98 100% 0% 0%
Tantalum 34 100% 0% 0%
Tin 58 100% 0% 0%
Tungsten 39 100% 0% 0%
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%

 

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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:

 

   2023   2022 2021 2020 2019 2018 2017
Percentage of smelters certified RMAP conformant 100%   100% 99.47% 100% 100% 100% 100%
(210/210) (229/229) (188/189) (239/239) (253/253) (251/251) (197/197)
Currently participating, in communication or agreed to participate in audit process N/A  N/A 0.53% N/A N/A N/A N/A
   

 

(1/189)

        
Outreach Required N/A  N/A N/A N/A N/A N/A N/A
             

 

 

Analysis of our products considering due diligence results

 

From the figures in the above table, we can conclude that 100% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2023, were validated by the RMAP as being conformant as of December 31, 2023. 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.

 

20 of the 230 smelters declared to us by our suppliers and subcontractors were RMAP conformant at some point during calendar year 2023 but no longer qualified as such as of December 31, 2023 and 20 were therefore removed from our authorized sources of 3TG as of such date. We are not in a position to know whether a certain 3TG material which was used in the manufacture of a product during 2023 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.

 

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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.

 

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 and 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

 

100% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2023, were validated by the RMAP as being conformant 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 2023. 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, 2023.

 

Lists of Processing Facilities

 

Table 1: Processing facilities, listed by smelter identification number, reported in our supply chain in relation to calendar year 2023 which were validated by the RMAP conformant smelters program as of December 31, 2023:

 

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Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID000035 Gold Agosi AG GERMANY LBMA RG / RJC
CID000019 Gold Aida Chemical Industries Co., Ltd. JAPAN RMI (members / partners)
CID000041 Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN LBMA RG
CID000058 Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL LBMA RG
CID000077 Gold Argor-Heraeus S.A. SWITZERLAND LBMA RG / RJC
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 RMI (members / partners)
CID000113 Gold Aurubis AG GERMANY LBMA RG
CID000128 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES 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
CID000264 Gold Chugai Mining JAPAN RMI (members / partners)
CID000401 Gold Dowa JAPAN RMI (members / partners)
CID000359 Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF RMI (members / partners)
CID000425 Gold Eco-System Recycling Co., Ltd. East Plant JAPAN RMI (members / partners)
CID003424 Gold Eco-System Recycling Co., Ltd. North Plant JAPAN RMI (members / partners)
CID003425 Gold Eco-System Recycling Co., Ltd. West Plant JAPAN RMI (members / partners)
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 (members / partners)
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
CID002765 Gold Italpreziosi ITALY LBMA RG / RJC
CID000823 Gold Japan Mint JAPAN LBMA RG
CID000855 Gold Jiangxi Copper Co., Ltd. CHINA LBMA RG
CID000937 Gold JX Nippon Mining & Metals Co., Ltd. JAPAN LBMA RG
CID000957 Gold Kazzinc KAZAKHSTAN LBMA RG
CID000969 Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA LBMA RG
CID002511 Gold KGHM Polska Miedz Spolka Akcyjna POLAND LBMA RG
CID000981 Gold Kojima Chemicals Co., Ltd. JAPAN RMI (members / partners)
CID002605 Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF RMI (members / partners)

 

  12 

 

 

Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID002762 Gold L'Orfebre S.A. ANDORRA RMI (members / partners)
CID001078 Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF LBMA RG
CID000689 Gold LT Metal Ltd. KOREA, REPUBLIC OF RMI (members / partners)
CID001113 Gold Materion UNITED STATES OF AMERICA RMI (members / partners)
CID001119 Gold Matsuda Sangyo Co., Ltd. JAPAN LBMA RG
CID003575 Gold Metal Concentrators SA (Pty) Ltd. SOUTH AFRICA RJC
CID001149 Gold Metalor Technologies (Hong Kong) Ltd. CHINA LBMA RG / RJC
CID001152 Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE LBMA RG / RJC
CID001147 Gold Metalor Technologies (Suzhou) Ltd. CHINA LBMA RG / RJC
CID001153 Gold Metalor Technologies S.A. SWITZERLAND LBMA RG / RJC
CID001157 Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA LBMA RG / RJC
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
CID001352 Gold MKS PAMP SA SWITZERLAND LBMA RG
CID002509 Gold MMTC-PAMP India Pvt., Ltd. INDIA LBMA RG
CID001220 Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY LBMA RG
CID001236 Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN LBMA RG
CID003189 Gold NH Recytech Company KOREA, REPUBLIC OF RMI (members / partners)
CID001259 Gold Nihon Material Co., Ltd. JAPAN LBMA RG
CID002779 Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA RJC
CID001325 Gold Ohura Precious Metal Industry Co., Ltd. JAPAN RMI (members / partners)
CID002919 Gold Planta Recuperadora de Metales SpA CHILE RMI (members / partners)
CID001397 Gold PT Aneka Tambang (Persero) Tbk INDONESIA LBMA RG
CID001498 Gold PX Precinox S.A. SWITZERLAND LBMA RG
CID001512 Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA LBMA RG
CID002582 Gold REMONDIS PMR B.V. NETHERLANDS RMI (members / partners)
CID001534 Gold Royal Canadian Mint CANADA LBMA RG
CID002290 Gold SAFINA A.S. CZECHIA RMI (members / partners)
CID001585 Gold SEMPSA Joyeria Plateria S.A. SPAIN LBMA RG / RJC
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
CID002918 Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF RMI (members / partners)
CID002580 Gold T.C.A S.p.A ITALY LBMA RG
CID001875 Gold Tanaka Kikinzoku Kogyo K.K. JAPAN LBMA RG
CID001938 Gold Tokuriki Honten Co., Ltd. JAPAN LBMA RG
CID002615 Gold TOO Tau-Ken-Altyn KAZAKHSTAN LBMA RG

 

  13 

 

 

Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID001955 Gold Torecom KOREA, REPUBLIC OF RMI (members / partners)
CID001980 Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM LBMA RG
CID001993 Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA RMI (members / partners)
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 RJC
CID002100 Gold Yamakin Co., Ltd. JAPAN RMI (members / partners)
CID002129 Gold Yokohama Metal Co., Ltd. JAPAN RMI (members / partners)
CID002224 Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA LBMA RG
CID001076 Tantalum AMG Brasil BRAZIL RMI (members / partners)
CID002504 Tantalum D Block Metals, LLC UNITED STATES OF AMERICA RMI (members / partners)
CID000460 Tantalum F&X Electro-Materials Ltd. CHINA RMI (members / partners)
CID002505 Tantalum FIR Metals & Resource Ltd. CHINA RMI (members / partners)
CID002558 Tantalum Global Advanced Metals Aizu JAPAN RMI (members / partners)
CID002557 Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA RMI (members / partners)
CID002492 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA RMI (members / partners)
CID002512 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA RMI (members / partners)
CID002842 Tantalum Jiangxi Tuohong New Raw Material CHINA RMI (members / partners)
CID000914 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA RMI (members / partners)
CID000917 Tantalum Jiujiang Tanbre Co., Ltd. CHINA RMI (members / partners)
CID002506 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA RMI (members / partners)
CID002539 Tantalum KEMET de Mexico MEXICO RMI (members / partners)
CID002548 Tantalum Materion Newton Inc. UNITED STATES OF AMERICA RMI (members / partners)
CID001163 Tantalum Metallurgical Products India Pvt., Ltd. INDIA RMI (members / partners)
CID001175 Tantalum Mineracao Taboca S.A. BRAZIL RMI (members / partners)
CID001192 Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN RMI (members / partners)
CID001277 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA RMI (members / partners)
CID001200 Tantalum NPM Silmet AS ESTONIA RMI (members / partners)
CID001508 Tantalum QuantumClean UNITED STATES OF AMERICA RMI (members / partners)
CID002707 Tantalum Resind Industria e Comercio Ltda. BRAZIL RMI (members / partners)
CID003583 Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. CHINA RMI (members / partners)
CID001869 Tantalum Taki Chemical Co., Ltd. JAPAN RMI (members / partners)

 

  14 

 

 

Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID002544 Tantalum TANIOBIS Co., Ltd. THAILAND RMI (members / partners)
CID002545 Tantalum TANIOBIS GmbH GERMANY RMI (members / partners)
CID002549 Tantalum TANIOBIS Japan Co., Ltd. JAPAN RMI (members / partners)
CID002550 Tantalum TANIOBIS Smelting GmbH & Co. KG GERMANY RMI (members / partners)
CID001891 Tantalum Telex Metals UNITED STATES OF AMERICA RMI (members / partners)
CID001969 Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN RMI (members / partners)
CID000616 Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED CHINA RMI (members / partners)
CID002508 Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA RMI (members / partners)
CID001522 Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA RMI (members / partners)
CID000292 Tin Alpha UNITED STATES OF AMERICA RMI (members / partners)
CID002773 Tin Aurubis Beerse BELGIUM RMI (members / partners)
CID002774 Tin Aurubis Berango SPAIN RMI (members / partners)
CID000228 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA RMI (members / partners)
CID003190 Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA RMI (members / partners)
CID001070 Tin China Tin Group Co., Ltd. CHINA RMI (members / partners)
CID003486 Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda BRAZIL RMI (members / partners)
CID003524 Tin CRM Synergies SPAIN RMI (members / partners)
CID002570 Tin CV Ayi Jaya INDONESIA RMI (members / partners)
CID002455 Tin CV Venus Inti Perkasa INDONESIA RMI (members / partners)
CID000402 Tin Dowa JAPAN RMI (members / partners)
CID003831 Tin DS Myanmar MYANMAR RMI (members / partners)
CID000438 Tin EM Vinto BOLIVIA (PLURINATIONAL STATE OF) RMI (members / partners)
CID000448 Tin Estanho de Rondonia S.A. BRAZIL RMI (members / partners)
CID003582 Tin Fabrica Auricchio Industria e Comercio Ltda. BRAZIL RMI (members / partners)
CID000468 Tin Fenix Metals POLAND RMI (members / partners)
CID000538 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA RMI (members / partners)
CID003116 Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA RMI (members / partners)
CID002844 Tin HuiChang Hill Tin Industry Co., Ltd. CHINA RMI (members / partners)
CID001231 Tin Jiangxi New Nanshan Technology Ltd. CHINA RMI (members / partners)
CID003387 Tin Luna Smelter, Ltd. RWANDA RMI (members / partners)
CID002468 Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL RMI (members / partners)

 

  15 

 

 

Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID001105 Tin Malaysia Smelting Corporation (MSC) MALAYSIA RMI (members / partners)
CID001142 Tin Metallic Resources, Inc. UNITED STATES OF AMERICA RMI (members / partners)
CID001173 Tin Mineracao Taboca S.A. BRAZIL RMI (members / partners)
CID001182 Tin Minsur PERU RMI (members / partners)
CID001191 Tin Mitsubishi Materials Corporation JAPAN RMI (members / partners)
CID001314 Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND RMI (members / partners)
CID002517 Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES RMI (members / partners)
CID001337 Tin Operaciones Metalurgicas S.A. BOLIVIA (PLURINATIONAL STATE OF) RMI (members / partners)
CID000309 Tin PT Aries Kencana Sejahtera INDONESIA RMI (members / partners)
CID001399 Tin PT Artha Cipta Langgeng INDONESIA RMI (members / partners)
CID002503 Tin PT ATD Makmur Mandiri Jaya INDONESIA RMI (members / partners)
CID001402 Tin PT Babel Inti Perkasa INDONESIA RMI (members / partners)
CID001406 Tin PT Babel Surya Alam Lestari INDONESIA RMI (members / partners)
CID003205 Tin PT Bangka Serumpun INDONESIA RMI (members / partners)
CID001428 Tin PT Bukit Timah INDONESIA RMI (members / partners)
CID002696 Tin PT Cipta Persada Mulia INDONESIA RMI (members / partners)
CID002835 Tin PT Menara Cipta Mulia INDONESIA RMI (members / partners)
CID001453 Tin PT Mitra Stania Prima INDONESIA RMI (members / partners)
CID003449 Tin PT Mitra Sukses Globalindo INDONESIA RMI (members / partners)
CID001458 Tin PT Prima Timah Utama INDONESIA RMI (members / partners)
CID003868 Tin PT Putera Sarana Shakti (PT PSS) INDONESIA RMI (members / partners)
CID003381 Tin PT Rajawali Rimba Perkasa INDONESIA RMI (members / partners)
CID002593 Tin PT Rajehan Ariq INDONESIA RMI (members / partners)
CID001460 Tin PT Refined Bangka Tin INDONESIA RMI (members / partners)
CID001463 Tin PT Sariwiguna Binasentosa INDONESIA RMI (members / partners)
CID001468 Tin PT Stanindo Inti Perkasa INDONESIA RMI (members / partners)
CID002816 Tin PT Sukses Inti Makmur INDONESIA RMI (members / partners)
CID001486 Tin PT Timah Nusantara INDONESIA RMI (members / partners)
CID001477 Tin PT Timah Tbk Kundur INDONESIA RMI (members / partners)
CID001482 Tin PT Timah Tbk Mentok INDONESIA RMI (members / partners)
CID001493 Tin PT Tommy Utama INDONESIA RMI (members / partners)

 

  16 

 

 

Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID002706 Tin Resind Industria e Comercio Ltda. BRAZIL RMI (members / partners)
CID001539 Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA RMI (members / partners)
CID001898 Tin Thaisarco THAILAND RMI (members / partners)
CID002180 Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. CHINA RMI (members / partners)
CID003325 Tin Tin Technology & Refining UNITED STATES OF AMERICA RMI (members / partners)
CID002036 Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL RMI (members / partners)
CID002158 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA RMI (members / partners)
CID000004 Tungsten A.L.M.T. Corp. JAPAN RMI (members / partners)
CID002502 Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM RMI (members / partners)
CID002641 Tungsten China Molybdenum Tungsten Co., Ltd. CHINA RMI (members / partners)
CID000258 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA RMI (members / partners)
CID003468 Tungsten Cronimet Brasil Ltda BRAZIL RMI (members / partners)
CID003609 Tungsten Fujian Xinlu Tungsten Co., Ltd. CHINA RMI (members / partners)
CID002645 Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA RMI (members / partners)
CID002315 Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA RMI (members / partners)
CID002494 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA RMI (members / partners)
CID000568 Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA RMI (members / partners)
CID000218 Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA RMI (members / partners)
CID002541 Tungsten H.C. Starck Tungsten GmbH GERMANY RMI (members / partners)
CID003417 Tungsten Hubei Green Tungsten Co., Ltd. CHINA RMI (members / partners)
CID000766 Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA RMI (members / partners)
CID002513 Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch CHINA RMI (members / partners)
CID000825 Tungsten Japan New Metals Co., Ltd. JAPAN RMI (members / partners)
CID002551 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA RMI (members / partners)
CID002321 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA RMI (members / partners)
CID002318 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA RMI (members / partners)
CID002317 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA RMI (members / partners)
CID002316 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA RMI (members / partners)
CID000966 Tungsten Kennametal Fallon UNITED STATES OF AMERICA RMI (members / partners)
CID000105 Tungsten Kennametal Huntsville UNITED STATES OF AMERICA RMI (members / partners)
CID003407 Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA RMI (members / partners)

 

  17 

 

 

Smelter Identification Metal Smelter Name Smelter Country Auditor Name
CID002319 Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA RMI (members / partners)
CID002543 Tungsten Masan High-Tech Materials VIET NAM RMI (members / partners)
CID002589 Tungsten Niagara Refining LLC UNITED STATES OF AMERICA RMI (members / partners)
CID002827 Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES RMI (members / partners)
CID002542 Tungsten TANIOBIS Smelting GmbH & Co. KG GERMANY RMI (members / partners)
CID002044 Tungsten Wolfram Bergbau und Hutten AG AUSTRIA RMI (members / partners)
CID002320 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA RMI (members / partners)
CID002082 Tungsten Xiamen Tungsten Co., Ltd. CHINA RMI (members / partners)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  18 

 

 

Table 2: Processing facilities, listed by smelter identification number, reported in our supply chain in relation to calendar year 2023 which no longer qualified as RMAP conformant or eligible as of December 31, 2023, 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 Effective date reported by RMI (all in 2023) Reason for non-conformance or non-eligibility
CID002763 Gold 8853 S.p.A. ITALY January Non Conformant
CID002833 Tungsten ACL Metais Eireli BRAZIL January Non Conformant
CID000189 Gold Cendres + Metaux S.A. SWITZERLAND January Non Conformant
CID000555 Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA January Non Conformant
CID002845 Tungsten Moliren Ltd. RUSSIAN FEDERATION January RMI Due Diligence Review - Unable to Proceed
CID002973 Gold Safimet S.p.A ITALY January Non Conformant
CID002516 Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA January Non Conformant
CID001555 Gold Samduck Precious Metals KOREA, REPUBLIC OF February Non Conformant
CID002314 Gold Umicore Precious Metals Thailand THAILAND March Non Conformant
CID000769 Tungsten Hunan Jintai New Material Co., Ltd. CHINA April Non Conformant
CID000015 Gold Advanced Chemical Company UNITED STATES OF AMERICA May Non Conformant
CID003401 Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA July Ceased Operations
CID000875 Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA July Ceased Operations
CID002547 Tantalum QSIL Metals Hermsdorf GmbH GERMANY July Ceased Operations
CID002761 Gold SAAMP FRANCE July Non Conformant
CID002830 Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA July Ceased Operations
CID002561 Gold Emirates Gold DMCC UNITED ARAB EMIRATES July Non Conformant
CID002863 Gold Bangalore Refinery INDIA August Non Conformant
CID002560 Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES August Non Conformant
CID003379 Tin Ma'anshan Weitai Tin Co., Ltd. CHINA September Non Conformant

 

V. Reporting

 

We report on our responsible minerals program and performance through different channels, as highlighted in the below table:

 

  19 

 

 

Availability   Policy statement CMRT EMRT 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      

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  20 

 

 

ANNEX I

DEFINITIONS

 

Acronym Definition
CAHRA Conflict-Affected and High-Risk Area
CMRT Conflict Minerals Reporting Template
DAP Downstream Assessment Program
LBMA London Bullion Market Association
RJC Responsible Jewellery Council
RMAP Responsible Minerals Assurance Process
RMI Responsible Minerals Initiative
RCOI Reasonable Country of Origin Inquiry

 

Term Definition
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 Assessment Program The RMI Downstream Assessment Program provides a mechanism for companies to obtain independent validation of responsible sourcing practices. The assessment is based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
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 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 organization 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 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.
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.

 

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