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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 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, 2019

 

 

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 26, 2020
  Name: Jean-Marc Chery    
  Title: President and Chief Executive Officer and Sole    
    Member of our Managing Board    

 

 

 

 

 

   

Exhibit 1.01

 

Conflict Minerals Report of STMicroelectronics N.V.

in accordance with Rule 13p-1 under the Securities Exchange Act of 1934

 

This Conflict Minerals Report (the “Report”) for the year ended December 31, 2019 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”).

 

In this Report, references to “ST”, “we”, “us” and “Company” are to STMicroelectronics N.V. together with its consolidated subsidiaries. Furthermore, the SEC defines “conflict minerals” as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. We therefore ascribe the same meaning to the term “conflict minerals” throughout this Report, regardless of such minerals’ country of origin or whether they are financing or benefiting armed conflict. 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, this Report is available on our website at the following address: http://investors.st.com.

 

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 products[1] are as follows:

 

 

 

 

A more detailed discussion of our product categories and the products relating to each category is contained in our Annual Report on Form 20-F in relation to the 2019 calendar year which was filed with the SEC on February 26, 2020.

 

 

1 We derive less than 0.11% 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 99.89% or more of our total annual revenue.

 1  

 

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 2019 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 a conflict mineral 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.

 

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”), have adopted the RBA’s Code of Conduct and participate in the Responsible Minerals Initiative (the “RMI”), which is a program run jointly by the RBA and the Global e-Sustainability Initiative (the “GeSI”). We require all our suppliers and subcontractors to provide evidence that they are not sourcing 3TG through any channels that fund armed groups in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”).

 

Additional information on our Policy Statement on Conflict Minerals and Responsible Minerals Sourcing (our “Policy Statement”) is available at: www.st.com/conflict-free_minerals. In addition, the respective websites of the RBA, the RMI and the GeSI are available at http://www.responsiblebusiness.org/, http://www.responsiblemineralsinitiative.org/ and http://gesi.org/.

 

2.Due Diligence Process

 

Design of due diligence

 

Our due diligence measures have been designed to conform, in all material respects, to the framework in The Organisation for 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”) 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 the issue, 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;
 2  

 

·defining the strategy and annual objectives related to the implementation of the conflict minerals programs 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 according to 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.

 

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 suppliers’ 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 our conflict minerals program implementation. Based on need 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 GeSI representatives. Tools available for participants in the RBA include a template known as the Conflict Minerals Reporting Template (the “CMRT”). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free sourcing policy, engagement with its direct suppliers, and a listing of the smelters a company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in a company’s products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are also available. The CMRT is used by many companies in their due diligence processes related to conflict minerals.

 

In addition, the RBA and GeSI developed in 2010 the RMI, 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 Responsible Jewelry 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.

 

Methodology

 

The Company undertook due diligence on the source and chain of custody of its necessary conflict minerals. Our due diligence measures consisted of:

 

 3  

 

 

We conducted an inquiry, using the CMRT, with all of the suppliers and subcontractors which we identified within our supply chain. All such suppliers and subcontractors responded to our due diligence inquiry.

 

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.

 

CMRT inquiry responses

 

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 263 smelters as sources of 3TG during the 2019 calendar year, ten of which we had discontinued as sources as of December 31, 2019, as reflected in the table below. The table below indicates the percentage of reported smelters sourcing each metal which were RMAP conformant as of December 31, 2019. Information relating to RMAP conformant smelters is extracted from the RBA database. The information presented in the below table represents the state of affairs as of December 31, 2019, but should not be interpreted as necessarily having applied consistently throughout the entire 2019 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, 2019.

 

Metal Gold Tantalum Tin Tungsten
Total number of smelters declared during 2019 calendar year which remained as sources of 3TG as of December 31, 2019 102 39 72 40
Percentage of above smelters which were RMAP conformant as of December 31, 2019 100% 100% 100% 100%

 

Analysis of our products in light of 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, 2019 were validated by the RMAP as being conformant as of December 31, 2019. We have included in Table 1 on Appendix I to this Report a list of these processing facilities as well as their identification number as used by the RMAP.

 

Ten of the 263 smelters declared to us by our suppliers and subcontractors were RMAP conformant at some point during calendar year 2019 but no longer qualified as such as of December 31, 2019 and 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 2019 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 on Appendix I to this Report.

 

3.Further Risk Mitigation

 

Discussion is included below as to certain efforts we are making, and will continue to make, to further mitigate the risk that our necessary conflict minerals do not benefit armed groups, including steps we are taking to improve our due diligence.

 

Mitigating the effects of multi-sourcing

 

Certain of the challenges we encountered in our due diligence were a result of multi-sourcing. We conduct business with a large number of suppliers in obtaining the materials required for our products, in an effort to ensure continuity in our supply chain. Those suppliers, in turn, work with a large number of smelters and refiners to source materials (including conflict minerals) which ultimately are contained in our products. As a consequence, each of our material parts is linked to several suppliers and, consequently, to several smelters, each with a potentially differing status with the RMAP.

 

 4  

 

Our suppliers also service other semiconductor manufacturers and other electronics industry participants whose supply needs may or may not coincide with ours. Accordingly, the total number of smelters from which our suppliers source materials may exceed the number of such smelters whose conflict minerals are ultimately contained in our products.

 

Currently, the representations included within the responses to our CMRT inquiries which we receive from our suppliers and subcontractors cover all smelters providing materials to them, and do not necessarily correlate solely to the smelters whose minerals are contained only in our products (and not in those of other customers of such suppliers and subcontractors without also being contained in our products). This adds further complexity to linking the conflict minerals used in a particular product category to a specific source of origin, as the list of all potential smelters provided by our suppliers may be broader than the list of only those smelters from which our suppliers source conflict minerals for use in our product categories (and may include smelters sourcing conflict minerals for end use by other customers of such suppliers and not us).

 

A result of this complexity is that we are forced to include all smelters providing materials to our suppliers and subcontractors when performing our due diligence on the origin of the conflict minerals contained in our products, as our suppliers and subcontractors do not always provide us with a list that excludes the smelters whose conflict minerals are not contained in our products.

 

One method in which we expect to improve our due diligence is to continue to work with our suppliers and subcontractors with a view to obtaining certifications which are better tailored only to our end products, as opposed to blanket company-wide certifications from each supplier or subcontractor. For example, the CMRT contains a reporting category in which reporting parties can more specifically link a particular smelter to a particular product, which we will encourage our suppliers and subcontractors to complete. During the 2019 calendar year, we made progress with certain of our suppliers in obtaining more specific disclosures which are more closely aligned with our actual sourcing of materials. As a result of this effort, we may be able to eliminate in the future certain smelters from the list of potential smelters from which the conflict minerals contained in our products may originate. As referenced above, during 2019 we discontinued sourcing of materials from ten smelters in a continuing effort to depart from non-RMAP conformant smelters within our supply chain. Such ten smelters are identified in Table 2 of Appendix I to this Report.

 

Additional initiatives

 

We do not directly conduct business with most of the smelters from which the conflict minerals in our products originate. We have, however, conducted our own investigative research with respect to certain smelters, which is aimed at supplementing information available to us through the RMAP. We also have maintained direct contact with certain smelters which previously did not participate in the RMAP conformant smelters program, and we have succeeded in influencing them to seek full RMAP conformant smelters validation. We expect our continuing efforts to focus on increasing and/or maintaining our suppliers’ and subcontractors’ compliance with the RMAP conformant smelters program as it applies to the smelters and refiners from which such suppliers and subcontractors source conflict minerals which may ultimately be contained in our products.

 

A significant portion of our supply chain is not required to file reports with the SEC under Sections 13(a) or 14(d) of the Securities Exchange Act of 1934, and is therefore not concerned by reporting obligations pursuant to the Rule. Accordingly, the influence that we are able to exert on our supply chain is due in large part to market forces created as a result of a cumulative effort by us and other participants in the electronics industry to ensure compliance with the RMAP conformant smelters program by their lower tier providers. In general, we intend to continue to request that our suppliers and subcontractors not source materials for us from any smelters which have not been validated by the RMAP conformant smelters program (and to discontinue sourcing from any smelters which fail to maintain their RMAP conformant smelters validation status).

 

 5  

 

Cautionary Note Regarding Forward-Looking Statements

 

Some of the statements contained in this Report that are not historical facts are statements of future expectations and other forward-looking statements (within the meaning of Section 27A of the Securities Act of 1933 or Section 21E of the Securities Exchange Act of 1934, each as amended) that are based on management’s current views and assumptions, and are conditioned upon and also involve known and unknown risks and uncertainties that could cause actual results, performance or events to differ materially and adversely from those anticipated by such forward-looking statements. Certain forward-looking statements can be identified by the use of forward-looking terminology, such as “believes”, “expects”, “may”, “are expected to”, “should”, “would be”, “seeks” or “anticipates” or similar expressions or the negative thereof or other variations thereof or comparable terminology, or by discussions of strategy, plans or intentions. Should one or more of these risks or uncertainties materialize, or should underlying assumptions prove incorrect, actual results may vary materially from those described in this Report as anticipated, believed or expected. We do not intend, and do not assume any obligation, to update any information or forward-looking statements set forth in this Report to reflect subsequent events or circumstances.

 

 

 

 

 

 

 

 

 6  

 

Appendix I

 

Included in this Appendix I are processing facilities that were identified to us by our suppliers as potentially in our supply chain for 2019. As explained in this Report, the presence of a facility on the lists in this Appendix I does not mean that our products necessarily contained conflict minerals processed by that facility. Location information for each processing facility is as reported by the RMAP as of December 31, 2019.

 

Lists of Processing Facilities

 

 

Table 1: Processing facilities reported in our supply chain in relation to calendar year 2019 which were validated by the RMAP conformant smelters program as of December 31, 2019

 

Smelter Identification Metal Smelter Name Smelter Country
CID002763 Gold 8853 S.p.A. ITALY
CID000015 Gold Advanced Chemical Company UNITED STATES OF AMERICA
CID000019 Gold Aida Chemical Industries Co., Ltd. JAPAN
CID000035 Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY
CID000041 Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN
CID000058 Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL
CID000077 Gold Argor-Heraeus S.A. SWITZERLAND
CID000082 Gold Asahi Pretec Corp. JAPAN
CID000924 Gold Asahi Refining Canada Ltd. CANADA
CID000920 Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA
CID000090 Gold Asaka Riken Co., Ltd. JAPAN
CID002850 Gold AU Traders and Refiners SOUTH AFRICA
CID000113 Gold Aurubis AG GERMANY
CID002863 Gold Bangalore Refinery INDIA
CID000128 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES
CID000157 Gold Boliden AB SWEDEN
CID000176 Gold C. Hafner GmbH + Co. KG GERMANY
CID000185 Gold CCR Refinery - Glencore Canada Corporation CANADA
CID000189 Gold Cendres + Metaux S.A. SWITZERLAND
CID000233 Gold Chimet S.p.A. ITALY
CID000328 Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF
CID000362 Gold DODUCO Contacts and Refining GmbH GERMANY
CID000401 Gold Dowa JAPAN
CID003195 Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF
CID000359 Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF
CID000425 Gold Eco-System Recycling Co., Ltd. JAPAN
CID002561 Gold Emirates Gold DMCC UNITED ARAB EMIRATES
CID002459 Gold Geib Refining Corporation UNITED STATES OF AMERICA
CID002243 Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA
CID000689 Gold HeeSung Metal Ltd. KOREA, REPUBLIC OF
CID000694 Gold Heimerle + Meule GmbH GERMANY
CID000707 Gold Heraeus Metals Hong Kong Ltd. CHINA
CID000711 Gold Heraeus Precious Metals GmbH & Co. KG GERMANY
CID000801 Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA
CID000807 Gold Ishifuku Metal Industry Co., Ltd. JAPAN

 

 7  

 

CID000814 Gold Istanbul Gold Refinery TURKEY
CID002765 Gold Italpreziosi ITALY
CID000823 Gold Japan Mint JAPAN
CID000855 Gold Jiangxi Copper Co., Ltd. CHINA
CID000929 Gold JSC Uralelectromed RUSSIAN FEDERATION
CID000937 Gold JX Nippon Mining & Metals Co., Ltd. JAPAN
CID000957 Gold Kazzinc KAZAKHSTAN
CID000969 Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA
CID002511 Gold KGHM Polska Miedz Spolka Akcyjna POLAND
CID000981 Gold Kojima Chemicals Co., Ltd. JAPAN
CID002605 Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF
CID001029 Gold Kyrgyzaltyn JSC KYRGYZSTAN
CID002762 Gold L’Orfebre S.A. ANDORRA
CID001078 Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF
CID002606 Gold Marsam Metals BRAZIL
CID001113 Gold Materion UNITED STATES OF AMERICA
CID001119 Gold Matsuda Sangyo Co., Ltd. JAPAN
CID001149 Gold Metalor Technologies (Hong Kong) Ltd. CHINA
CID001152 Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE
CID001147 Gold Metalor Technologies (Suzhou) Ltd. CHINA
CID001153 Gold Metalor Technologies S.A. SWITZERLAND
CID001157 Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA
CID001161 Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO
CID001188 Gold Mitsubishi Materials Corporation JAPAN
CID001193 Gold Mitsui Mining and Smelting Co., Ltd. JAPAN
CID002509 Gold MMTC-PAMP India Pvt., Ltd. INDIA
CID001204 Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION
CID001220 Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY
CID001259 Gold Nihon Material Co., Ltd. JAPAN
CID002779 Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA
CID001325 Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
CID001326 Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) RUSSIAN FEDERATION
CID000493 Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION
CID001352 Gold PAMP S.A. SWITZERLAND
CID002919 Gold Planta Recuperadora de Metales SpA CHILE
CID001386 Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION
CID001397 Gold PT Aneka Tambang (Persero) Tbk INDONESIA
CID001498 Gold PX Precinox S.A. SWITZERLAND
CID001512 Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
CID002582 Gold REMONDIS PMR B.V. NETHERLANDS
CID001534 Gold Royal Canadian Mint CANADA
CID002761 Gold SAAMP FRANCE
CID002973 Gold Safimet S.p.A ITALY
CID002777 Gold SAXONIA Edelmetalle GmbH GERMANY
CID001585 Gold SEMPSA Joyeria Plateria S.A. SPAIN
CID001622 Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA
CID001736 Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA
CID002516 Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
CID001756 Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION
CID001761 Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA

 

 8  

 

CID001798 Gold Sumitomo Metal Mining Co., Ltd. JAPAN
CID002918 Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF
CID002580 Gold T.C.A S.p.A ITALY
CID001875 Gold Tanaka Kikinzoku Kogyo K.K. JAPAN
CID001916 Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA
CID001938 Gold Tokuriki Honten Co., Ltd. JAPAN
CID001955 Gold Torecom KOREA, REPUBLIC OF
CID001977 Gold Umicore Brasil Ltda. BRAZIL
CID002314 Gold Umicore Precious Metals Thailand THAILAND
CID001980 Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM
CID001993 Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA
CID002003 Gold Valcambi S.A. SWITZERLAND
CID002030 Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA
CID002778 Gold WIELAND Edelmetalle GmbH GERMANY
CID002100 Gold Yamakin Co., Ltd. JAPAN
CID002129 Gold Yokohama Metal Co., Ltd. JAPAN
CID002224 Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA
CID000092 Tantalum Asaka Riken Co., Ltd. JAPAN
CID000211 Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA
CID002504 Tantalum D Block Metals, LLC UNITED STATES OF AMERICA
CID000456 Tantalum Exotech Inc. UNITED STATES OF AMERICA
CID000460 Tantalum F&X Electro-Materials Ltd. CHINA
CID002505 Tantalum FIR Metals & Resource Ltd. CHINA
CID002558 Tantalum Global Advanced Metals Aizu JAPAN
CID002557 Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA
CID000291 Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. CHINA
CID000616 Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA
CID002544 Tantalum H.C. Starck Co., Ltd. THAILAND
CID002547 Tantalum H.C. Starck Hermsdorf GmbH GERMANY
CID002548 Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA
CID002549 Tantalum H.C. Starck Ltd. JAPAN
CID002550 Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY
CID002545 Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY
CID002492 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
CID002512 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA
CID002842 Tantalum Jiangxi Tuohong New Raw Material CHINA
CID003191 Tantalum Jiujiang Janny New Material Co., Ltd. CHINA
CID000914 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA
CID000917 Tantalum Jiujiang Tanbre Co., Ltd. CHINA
CID002506 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA
CID002539 Tantalum KEMET Blue Metals MEXICO
CID002568 Tantalum KEMET Blue Powder UNITED STATES OF AMERICA
CID001076 Tantalum LSM Brasil S.A. BRAZIL
CID001163 Tantalum Metallurgical Products India Pvt., Ltd. INDIA
CID001175 Tantalum Mineracao Taboca S.A. BRAZIL
CID001192 Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN
CID001277 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
CID002847 Tantalum Power Resources Ltd. NORTH MACEDONIA, REPUBLIC OF
CID001508 Tantalum QuantumClean UNITED STATES OF AMERICA
CID002707 Tantalum Resind Industria e Comercio Ltda. BRAZIL

 

 9  

 

CID001522 Tantalum RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA
CID001769 Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION
CID001869 Tantalum Taki Chemical Co., Ltd. JAPAN
CID001891 Tantalum Telex Metals UNITED STATES OF AMERICA
CID001969 Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN
CID002508 Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA
CID000292 Tin Alpha UNITED STATES OF AMERICA
CID000228 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
CID003190 Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA
CID001070 Tin China Tin Group Co., Ltd. CHINA
CID002570 Tin CV Ayi Jaya INDONESIA
CID002592 Tin CV Dua Sekawan INDONESIA
CID000306 Tin CV Gita Pesona INDONESIA
CID000315 Tin CV United Smelting INDONESIA
CID002455 Tin CV Venus Inti Perkasa INDONESIA
CID000402 Tin Dowa JAPAN
CID000438 Tin EM Vinto BOLIVIA (PLURINATIONAL STATE OF)
CID000468 Tin Fenix Metals POLAND
CID002848 Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
CID000942 Tin Gejiu Kai Meng Industry and Trade LLC CHINA
CID000538 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA
CID001908 Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA
CID000555 Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA
CID003116 Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA
CID002849 Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA
CID002844 Tin HuiChang Hill Tin Industry Co., Ltd. CHINA
CID000760 Tin Huichang Jinshunda Tin Co., Ltd. CHINA
CID001231 Tin Jiangxi New Nanshan Technology Ltd. CHINA
CID002468 Tin Magnu’s Minerais Metais e Ligas Ltda. BRAZIL
CID001105 Tin Malaysia Smelting Corporation (MSC) MALAYSIA
CID002500 Tin Melt Metais e Ligas S.A. BRAZIL
CID001142 Tin Metallic Resources, Inc. UNITED STATES OF AMERICA
CID002773 Tin Metallo Belgium N.V. BELGIUM
CID002774 Tin Metallo Spain S.L.U. SPAIN
CID001173 Tin Mineracao Taboca S.A. BRAZIL
CID001182 Tin Minsur PERU
CID001191 Tin Mitsubishi Materials Corporation JAPAN
CID001314 Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND
CID002517 Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES
CID001337 Tin Operaciones Metalurgicas S.A. BOLIVIA (PLURINATIONAL STATE OF)
CID000309 Tin PT Aries Kencana Sejahtera INDONESIA
CID001399 Tin PT Artha Cipta Langgeng INDONESIA
CID002503 Tin PT ATD Makmur Mandiri Jaya INDONESIA
CID001402 Tin PT Babel Inti Perkasa INDONESIA
CID002776 Tin PT Bangka Prima Tin INDONESIA
CID003205 Tin PT Bangka Serumpun INDONESIA
CID001419 Tin PT Bangka Tin Industry INDONESIA
CID001421 Tin PT Belitung Industri Sejahtera INDONESIA
CID001428 Tin PT Bukit Timah INDONESIA
CID001434 Tin PT DS Jaya Abadi INDONESIA

 

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CID002530 Tin PT Inti Stania Prima INDONESIA
CID001448 Tin PT Karimun Mining INDONESIA
CID002829 Tin PT Kijang Jaya Mandiri INDONESIA
CID002870 Tin PT Lautan Harmonis Sejahtera INDONESIA
CID002835 Tin PT Menara Cipta Mulia INDONESIA
CID001453 Tin PT Mitra Stania Prima INDONESIA
CID001457 Tin PT Panca Mega Persada INDONESIA
CID000313 Tin PT Premium Tin Indonesia INDONESIA
CID001458 Tin PT Prima Timah Utama INDONESIA
CID002593 Tin PT Rajehan Ariq INDONESIA
CID001460 Tin PT Refined Bangka Tin INDONESIA
CID001463 Tin PT Sariwiguna Binasentosa INDONESIA
CID001468 Tin PT Stanindo Inti Perkasa INDONESIA
CID002816 Tin PT Sukses Inti Makmur INDONESIA
CID001471 Tin PT Sumber Jaya Indah INDONESIA
CID001477 Tin PT Timah Tbk Kundur INDONESIA
CID001482 Tin PT Timah Tbk Mentok INDONESIA
CID001490 Tin PT Tinindo Inter Nusa INDONESIA
CID001493 Tin PT Tommy Utama INDONESIA
CID002706 Tin Resind Industria e Comercio Ltda. BRAZIL
CID001539 Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA
CID001758 Tin Soft Metais Ltda. BRAZIL
CID002834 Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIETNAM
CID001898 Tin Thaisarco THAILAND
CID003325 Tin Tin Technology & Refining UNITED STATES OF AMERICA
CID002036 Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL
CID002158 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
CID002180 Tin Yunnan Tin Company Limited CHINA
CID000004 Tungsten A.L.M.T. Corp. JAPAN
CID002833 Tungsten ACL Metais Eireli BRAZIL
CID002502 Tungsten Asia Tungsten Products Vietnam Ltd. VIETNAM
CID002513 Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA
CID000258 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA
CID000499 Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA
CID002645 Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA
CID000875 Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA
CID002315 Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
CID002494 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA
CID000568 Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA
CID000218 Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
CID002542 Tungsten H.C. Starck Smelting GmbH & Co. KG GERMANY
CID002541 Tungsten H.C. Starck Tungsten GmbH GERMANY
CID000766 Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA
CID002579 Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA
CID000769 Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA
CID002649 Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION
CID000825 Tungsten Japan New Metals Co., Ltd. JAPAN
CID002551 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA
CID002321 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA
CID002318 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA
CID002317 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA

 

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CID002316 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
CID000966 Tungsten Kennametal Fallon UNITED STATES OF AMERICA
CID000105 Tungsten Kennametal Huntsville UNITED STATES OF AMERICA
CID003388 Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF
CID002319 Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
CID002543 Tungsten Masan Tungsten Chemical LLC (MTC) VIETNAM
CID002845 Tungsten Moliren Ltd. RUSSIAN FEDERATION
CID002589 Tungsten Niagara Refining LLC UNITED STATES OF AMERICA
CID002827 Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
CID001889 Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIETNAM
CID002724 Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION
CID002044 Tungsten Wolfram Bergbau und Hutten AG AUSTRIA
CID002843 Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF
CID002320 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA
CID002082 Tungsten Xiamen Tungsten Co., Ltd. CHINA
CID002830 Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA
CID002095 Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA

 

 

 

 

 

 

 

 

 

 

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Table 2: Processing facilities reported in our supply chain in relation to calendar year 2019 which were no longer qualified as RMAP conformant as of December 31, 2019 and from which we had discontinued the sourcing of materials as of such date

 

 

Metal RMAP Smelter Identification Number Smelter Name Smelter Country Month of communication date from RMI (all in 2019) Cause (as of communication date from RMI)
Gold CID001555 Samduck Precious Metals KOREA, REPUBLIC OF April This facility was non-conformant to RMAP standards.
Gold CID002510 Republic Metals Corporation UNITED STATES OF AMERICA January This facility was no longer operating as a smelter or refiner.
Gold CID002560 Al Etihad Gold LLC UNITED ARAB EMIRATES August This facility was non-conformant to RMAP standards.
Tantalum CID001200 NPM Silmet AS ESTONIA September This facility was non-conformant to RMAP standards, but had indicated its intent to participate in the Extended Corrective Action Plan (ECAP) process.
Tin CID000244 Jiangxi Ketai Advanced Material Co., Ltd. CHINA January This facility was no longer operating as a smelter or refiner.
Tin CID001438 PT Eunindo Usaha Mandiri INDONESIA November This facility was no longer operating as a smelter or refiner.
Tin CID002858 Modeltech Sdn Bhd MALAYSIA June This facility was non-conformant to RMAP standards.
Tin CID002859 Gejiu Jinye Mineral Company CHINA July This facility was no longer operating as a smelter or refiner.
Tungsten CID002011 Vietnam Youngsun Tungsten Industry Co., Ltd. VIETNAM December This facility was no longer operating as a smelter or refiner.
Tungsten CID002815 South-East Nonferrous Metal Company Limited of Hengyang City CHINA July This facility was no longer operating as a smelter or refiner.

 

 

 

 

 

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