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, 2020 |
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 27, 2021 | ||
| 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, 2020 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 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. 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 Union importers of certain minerals or metals, whereby (i) the minerals refer to ores and concentrates containing tin, tantalum or tungsten and 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: 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 products1 are as follows:
1 We derive less than 0.13% 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 99.87% or more of our total annual revenue.
| 1 |
| · | Automotive and Discrete Group (ADG), comprised of dedicated automotive integrated circuits (“ICs”), and discrete and power transistor products. |
| · | Analog, MEMS and Sensors Group (AMS), comprised of analog, smart power, low power RF, MEMS sensors and actuators, and optical sensing solutions. |
| · | Microcontrollers and Digital ICs Group (MDG), comprised of microcontrollers (general purpose and secure), memories (RF and EEPROM), and RF communications. |
A more detailed description of our product categories and the products relating to each category is contained in our Annual Report on Form 20-F and Dutch Annual Report, respectively, in relation to the 2020 calendar year which was filed with the SEC on February 24, 2021, and the AFM (Dutch Financial Market Authority) on March 25, 2021, respectively.
Manufacturing processes
The manufacture of semiconductor products requires, among other things, the mastery of the properties of conductivity, isolation and/or amplification. The manufacturing of an integrated circuit can be divided into two phases. The first, wafer fabrication, is the extremely sophisticated and intricate process of manufacturing the silicon chip. The second, assembly, is the highly precise and automated process of packaging the die. Those two phases are commonly known respectively as “Front-End” and “Back-End”.
The manufacturing process of semiconductor products requires various materials, gases and chemicals. We have identified tin, tantalum, tungsten and gold (collectively, “3TG”) as being among the materials necessary to the functionality or production of certain of our products manufactured during the 2020 calendar year.
Supply chain
We are not engaged in the mining and trade of minerals, nor in any refining or smelting activities. We purchase materials, commodities, chemicals and gases which potentially contain minerals and/or metals covered in the Rule and the Regulation as part of their composition. In general, we do not conduct business directly with smelters and refiners.
Because of our large size, the complexity of our products, and the depth, breadth, and constant evolution of our global supply chain, it is difficult and resource-intensive to identify actors upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives as described in section 2 below.
| 2. | Due Diligence Process |
I. Establish strong company management systems
Conflict minerals policy
ST began to address the conflict minerals issue as early as 2007 by requiring our tantalum suppliers to confirm they were not sourcing metals from conflict areas. We are a member of the Responsible Business Alliance (the “RBA”), commit to the RBA’s Code of Conduct and integrate its principles in our internal policies and participate in the Responsible Minerals Initiative (the “RMI”). We require all our suppliers and subcontractors to provide evidence that they are not sourcing 3TG through any channels that fund armed groups or security forces or contribute to widespread and systematic violations of international law, including, human rights abuses.
| 2 |
Our Policy Statement on Conflict Minerals and Responsible Minerals Sourcing (our “Policy Statement”) is regularly provided to our suppliers and is available at: www.st.com/conflict-free_minerals.
Our ‘Conflict Mineral Report’ is issued annually and published on or website: https://investors.st.com/sec-filings.
In our annual Sustainability Report we also report on our conflict minerals program and this report is available at: https://www.st.com/content/st_com/en/about/st_approach_to_sustainability/sustainability-reports.html.
Furthermore, the relevant Conflict Minerals Reporting Template (the “CMRT”) and the Cobalt Reporting Template (the “CRT”) are provided on demand upon request of our customers through our online support portal https://community.st.com/s/onlinesupport.
The respective websites of the RBA and the RMI are accessible at http://www.responsiblebusiness.org/ and http://www.responsiblemineralsinitiative.org/.
Any grievance related to conflict minerals linked to ST can be reported through our Misconduct Reporting Hotline. Operated by an independent third-party provider, it is reachable 24/7 online or by phone (with a multilingual offering): https://secure.ethicspoint.eu/domain/media/en/gui/104021/index.html.
Furthermore, generic grievances can be reported through the RMI grievance mechanism: http://www.responsiblemineralsinitiative.org/rmap/grievance-mechanism/.
Design of due diligence
Our due diligence measures have been designed to conform, in all material respects, to the framework in the OECD Guidance and the related supplements for tin, tantalum, tungsten and gold, as well as related RBA recommendations. The OECD is an international organization that is endorsed by the United Nations and currently offers the only recognized framework available for such use.
Management system
In addition to implementing our Policy Statement as outlined above, evidencing our top management’s commitment to our conflict minerals program, we have implemented our conflict minerals management system in alignment with the OECD Guidance. We have established roles and duties within the Company’s relevant internal organizations involved in the program. The roles and duties established for several key internal organizations are outlined below.
Our Corporate Quality and Social Responsibility organizations are responsible for the following:
| · | proactively working with our customers to define the scope and form of our conflict minerals disclosures; |
| · | defining the strategy and annual objectives related to the implementation of the conflict minerals program within the Company and the coordination thereof with the appropriate internal organizations responsible for sourcing and purchasing materials and subcontracted services and products (including our Global Procurement Organization); |
| · | establishing the appropriate internal and external communication content on these programs through the relevant and necessary media and in accordance with our internal processes, including, without limitation, our Policy Statement and dedicated content in our annual Sustainability Report, both of which are made available on our website; and |
| · | reviewing and updating our conflict minerals management procedures on a regular basis. |
Our Global Procurement Organization helps to implement our conflict minerals program by supporting the communication of Company requirements to our suppliers and monitoring our suppliers’ engagement and progress in relation to our conflict minerals program. As part of the engagement with our suppliers they commit to respond to our requests with regard to, amongst others, their adherence to the requirements of our conflict minerals program.
| 3 |
Our Global Outsourcing Business Management group helps to implement our conflict minerals program by supporting the communication of Company requirements to Back-End subcontractors and monitoring our subcontractors’ engagement and progress in relation to our conflict minerals program.
Our Wafer Foundry group supports our conflict minerals program by communicating our requirements to wafer foundries and by monitoring our subcontractors’ engagement and progress in relation to our conflict minerals program.
In addition, our conflict minerals program is included as part of our sustainability and quality strategies and is highlighted as a key objective for each of our relevant internal organizations, in addition to the key internal groups discussed above, as applicable within the scope of their respective activities. A working group with representatives from the principal organizations involved, regularly reviews the progress of the implementation of our conflict minerals program. Based on our needs and as appropriate for the situation, such working group implements the appropriate risk mitigation measures.
Industry wide initiatives
As we are a participating member of the RBA, we employ due diligence methodologies defined by a joint working group comprised of RBA and the Global e-Sustainabiltiy Initiative (the “GeSI”) representatives. Tools available for participants in the RBA include a template known as the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The CMRT is used by many companies in their due diligence processes related to conflict minerals.
In addition, the RBA and the GeSI developed the RMI in 2010, which is a voluntary initiative in which an independent third-party audits smelter procurement and processing activities and determines if the smelter has provided sufficient documentation to demonstrate with reasonable confidence that the minerals it processed originated from conflict-free sources. In 2012, the RMI, the London Bullion Market Association (the “LBMA”) and the Responsible Jewellery Council (the “RJC”) announced their mutual cross-recognition of gold refiner audits. All three programs focus on independent third-party audits of refiners’ due diligence in conformity with the OECD Guidance, which recognizes refiners as a key “choke point” in the gold supply chain.
We, along with other leading participants in the electronics industry, rely on the RMI’s Responsible Minerals Assurance Process (the “RMAP”) or an equivalent industry-wide program for audits of smelters and/or refiners. Further details on this program are available on the RMI’s website at the address referenced above.
As a key element of our strategy, we only engage suppliers who declare to use minerals sourced from RMAP conformant smelters.
In previous years we had reported on additional initiatives undertaken directly towards certain smelters, which at that time did not yet participate in the RMAP conformant smelters program, to influence them to seek full RMAP conformant smelters validation. Currently as the market has reached a sufficient maturity as it regards RMAP conformant smelters and we require our suppliers and subcontractors to only source materials for us from RMAP conformant smelters we do not need to undertake such additional initiatives anymore.
| 4 |
II. Identify and assess risks in the supply chain
Risk definition
We have identified the following risks:
Main downstream risks
| · | Supplier not providing material composition |
| · | Supplier not conducting proper due diligence |
| · | Supplier declaring smelters list not linked to material sold (effects of multi-sourcing) |
| · | Use non-conformant Smelters |
Main upstream risks
| · | Serious abuses associated with the extraction, transport or trade of minerals: |
| - | Any form of torture, cruel, inhuman and degrading treatment |
| - | Any form of forced or compulsory labor |
| - | The worst forms of child labor |
| - | Other gross human rights violations and abuses, such as widespread sexual violence |
| - | War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide |
| · | Direct or indirect support to non-state armed groups |
| · | Direct or indirect support to public or private security forces |
| · | Bribery and fraudulent misrepresentation of the origin of minerals: |
| - | Money laundering |
| - | Non-payment of taxes, fees and royalties to governments |
Main additional risks
| · | Environment (pollution, water consumption abstraction, tailings) |
| · | Health & Safety (occupational health and safety, community health and safety) |
Risks related to red flag situations (situation where risks in supply chain are more likely to be found)
| · | Red flag locations of mineral origin and transit: |
| - | The minerals originate from or have been transported via a conflict-affected or high-risk area |
| - | The minerals are claimed to originate from a country that has limited known reserves, likely resources or expected production levels of the mineral in question (i.e. the declared volumes of mineral from that country are out of keeping with its known reserves or expected production levels) |
| - | The minerals are claimed to originate from a country in which minerals from conflict-affected and high-risk areas are known to transit |
| · | Supplier red flags: |
| - | The company’s suppliers or other known upstream companies have shareholder or other interests in companies that supply minerals from or operate in one of the above-mentioned red flag locations of mineral origin and transit |
| - | The company’s suppliers or other known upstream companies are known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months |
| 5 |
Risk identification processes and tools
We have identified the above risks using the processes and tools as described below.
| Risk | Risk identification |
| a) Main risk @ Downstream supply chain | · Material Composition collection · Responsible Minerals Statement · Downstream Audit Program (“DAP”) |
| b) Main risk @ Upstream supply chain | · CMRT · Smelters Audits (“RMAP”) |
| c) Additional risks | · RMI & ST Grievance portal · Web watch |
| d) Red flag situations | · Reasonable Country of Origin Inquiry (“RCOI”) list · Smelters Audit (“RMAP”) |
Risk identification methods
Below is a description of our risk identification methods:
| · | Material Composition collection |
We periodically ask our suppliers to provide the detailed material composition of the materials used in our manufacturing processes. That data allows us to identify the materials in scope of the RMI program.
If we do not receive this information from our suppliers, we check the material specification to find any useful information to determine the material composition.
In case the material specification does not disclose the presence of substances in scope of the RMI program, we check the material family to assess if the materials could potentially contain substances in scope of the RMI program.
| · | Responsible Minerals Statement |
During our annual survey, we deploy a questionnaire to our suppliers which allows us to:
| - | Identify substances & suppliers in scope of the RMI program; |
| - | Share our requirements; |
| - | Check supplier’s alignment with our requirements; and |
| - | Assess risks at supplier level. |
| · | Downstream Audit Program (“DAP”) |
Starting from our 2021 Responsible Minerals Statement deployment, we request our suppliers, in scope of the RMI program, to pass the RMI DAP in order to have a third-party assess the suppliers’ due diligence practices.
| 6 |
| · | Conflict Minerals Reporting Template (“CMRT”) |
We require a CMRT to our suppliers in three cases:
| - | During our annual survey; |
| - | When a smelter’s conformance status changes; and |
| - | We require our suppliers to send us an updated CMRT in case their smelters list changes. |
In the “Responsible Minerals Statement”, we detail our requirements related to the CMRT.
| · | Smelters Audit |
As an RMI member, we benefit from third- party audits organized by the RMI, the LBMA and the RJC. During the Smelters Audit, OECD red flag identification and mitigation are assessed.
The audit results are aggregated in a list maintained by the RMI named the RMAP list.
We crosscheck our suppliers’ CMRT with the RMAP list in order to identify any non-conformant smelters.
Furthermore, we periodically receive notification from the RMI to highlight a smelter’s conformance change.
| · | RMI Grievance portal |
In our “Responsible Minerals Statement”, we encourage suppliers to initiate a grievance on the RMI portal if they become aware of a violation of the OECD Guidance Annex II or other critical risk. (https://mineralsgrievanceplatform.org/)
| · | ST Grievance portal |
Anyone can issue a grievance related to ST via our “Misconduct Reporting Hotline Platform”, which is operated by a third-party in order to guarantee an independent and objective process.
| · | Web Watch |
We use a service provider to screen the Web and the deep Web in order to track any publication related to our smelters. We receive daily notification of potential relevant publications.
| · | RCOI List |
We use the RCOI list to identify the countries of origin of the minerals and the related risk classification. The RCOI list allows us to identify Red Flags associated to CAHRAs (including the Democratic Republic of the Congo and adjoining countries).
CMRT inquiry responses 2020
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.
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.
| 7 |
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 272 smelters as sources of 3TG during the 2020 calendar year, 33 (see Table 2 below in section IV for details) of which we had discontinued as sources as of December 31, 2020, as reflected in the Table 2 in section IV below. The table below indicates the percentage of reported smelters sourcing each metal which were RMAP conformant as of December 31, 2020. 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, 2020, but should not be interpreted as necessarily having applied consistently throughout the entire 2020 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, 2020.
| Metal | Tin | Tantalum | Tungsten | Gold |
| Total number of smelters declared during 2020 calendar year which remained as sources of 3TG as of December 31, 2020 | 53 | 37 | 42 | 107 |
| Percentage of above smelters which were RMAP conformant as of December 31, 2020 | 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, 2020 were validated by the RMAP as being conformant as of December 31, 2020. 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.
33 of the 272 smelters declared to us by our suppliers and subcontractors were RMAP conformant at some point during calendar year 2020 but no longer qualified as such as of December 31, 2020 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 2020 originated with one of such smelters before or after it lost its status as RMAP conformant. We have identified these smelters and the month during which we were notified of their removal from the RMAP conformance list in Table 2 in section IV below.
III. Design and implement a strategy to respond to identified risks
A key requirement to our supply chain, is to use only RMAP conformant smelters. By doing this we ensure that most of the risks identified are addressed. The following section details our mitigation strategy per identified risk.
Risk mitigation
We have a risk mitigation plan to address the risks identified. In this plan, mitigation actions are detailed per category of identified risks.
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.
| 8 |
We mitigate risks identified “downstream” by continuously assessing and training our suppliers to ensure the reliability of their due diligence.
On a quarterly basis a standard report is communicated to our Sustainability Council, consisting of representatives of the following organizations within ST: Corporate Social Responsibility, Internal Communication, External Communication, Quality, Product Groups, Manufacturing, Sales, Compliance & Business Ethics, Procurement, Investor Relations & Finance.
This report details (i) the conflict minerals-related risks identified during the quarter, (ii) the mitigation actions taken and (iii) the conformance status and a list of delinquent suppliers which do not meet our mandatory requirements despite several risk mitigation efforts attempted from our side. The Sustainability Council should indicate further action to be taken to treat delinquent suppliers, which may include disengaging with a delinquent supplier after failed attempts at risk mitigation, although the latter has not yet been the case.
IV. Independent third-party audit of smelters
100% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2020 were validated by the RMAP as being conformant as of December 31, 2020 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 2020. 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, 2020.
Lists of Processing Facilities
Table 1: Processing facilities reported in our supply chain in relation to calendar year 2020 which were validated by the RMAP conformant smelters program as of December 31, 2020:
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID002763 | Gold | 8853 S.p.A. | ITALY | RJC |
| CID000015 | Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | RMI |
| CID000019 | Gold | Aida Chemical Industries Co., Ltd. | JAPAN | RMI |
| CID002560 | Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | RMI |
| CID000035 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | LBMA RG / RJC |
| CID000041 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | LBMA |
| CID000058 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | LBMA |
| CID000077 | Gold | Argor-Heraeus S.A. | SWITZERLAND | LBMA RG / RJC |
| CID000082 | Gold | Asahi Pretec Corp. | JAPAN | LBMA |
| CID000924 | Gold | Asahi Refining Canada Ltd. | CANADA | LBMA |
| CID000920 | Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | LBMA |
| CID000090 | Gold | Asaka Riken Co., Ltd. | JAPAN | RMI |
| CID002850 | Gold | AU Traders and Refiners | SOUTH AFRICA | RJC |
| 9 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000113 | Gold | Aurubis AG | GERMANY | LBMA |
| CID002863 | Gold | Bangalore Refinery | INDIA | RMI |
| CID000128 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | LBMA |
| CID000157 | Gold | Boliden AB | SWEDEN | LBMA |
| CID000176 | Gold | C. Hafner GmbH + Co. KG | GERMANY | LBMA RG / RJC |
| CID000185 | Gold | CCR Refinery - Glencore Canada Corporation | CANADA | LBMA |
| CID000189 | Gold | Cendres + Metaux S.A. | SWITZERLAND | RJC |
| CID000233 | Gold | Chimet S.p.A. | ITALY | LBMA |
| CID000264 | Gold | Chugai Mining | JAPAN | RMI |
| CID000362 | Gold | DODUCO Contacts and Refining GmbH | GERMANY | RMI |
| CID000401 | Gold | Dowa | JAPAN | RMI |
| CID003195 | Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID000359 | Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | RMI |
| CID000425 | Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | RMI |
| CID003424 | Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | RMI |
| CID003425 | Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | RMI |
| CID002561 | Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | RMI |
| CID002459 | Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | RMI |
| CID002243 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | LBMA |
| CID000694 | Gold | Heimerle + Meule GmbH | GERMANY | LBMA |
| 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 |
| CID000807 | Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | LBMA |
| CID000814 | Gold | Istanbul Gold Refinery | TURKEY | LBMA |
| CID002765 | Gold | Italpreziosi | ITALY | LBMA RG / RJC |
| CID000823 | Gold | Japan Mint | JAPAN | LBMA |
| CID000855 | Gold | Jiangxi Copper Co., Ltd. | CHINA | LBMA |
| CID000929 | Gold | JSC Uralelectromed | RUSSIAN FEDERATION | LBMA |
| CID000937 | Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | LBMA |
| CID000957 | Gold | Kazzinc | KAZAKHSTAN | LBMA |
| CID000969 | Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | LBMA |
| CID002511 | Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | LBMA |
| 10 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000981 | Gold | Kojima Chemicals Co., Ltd. | JAPAN | RMI |
| CID002605 | Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID001029 | Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | LBMA |
| CID002762 | Gold | L’Orfebre S.A. | ANDORRA | RMI |
| CID001078 | Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | LBMA |
| CID000689 | Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | RMI |
| CID002606 | Gold | Marsam Metals | BRAZIL | RMI |
| CID001113 | Gold | Materion | UNITED STATES OF AMERICA | RMI |
| CID001119 | Gold | Matsuda Sangyo Co., Ltd. | JAPAN | LBMA |
| 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 |
| CID001188 | Gold | Mitsubishi Materials Corporation | JAPAN | LBMA |
| CID001193 | Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | LBMA |
| CID002509 | Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | LBMA |
| CID001204 | Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | LBMA |
| CID001220 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | LBMA |
| CID001236 | Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | LBMA |
| CID001259 | Gold | Nihon Material Co., Ltd. | JAPAN | LBMA |
| CID002779 | Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | RJC |
| CID001325 | Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | RMI |
| CID001326 | Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | LBMA |
| CID000493 | Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | LBMA |
| CID001352 | Gold | PAMP S.A. | SWITZERLAND | LBMA |
| CID002919 | Gold | Planta Recuperadora de Metales SpA | CHILE | RMI |
| CID001386 | Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | LBMA |
| CID001397 | Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | LBMA |
| 11 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID001498 | Gold | PX Precinox S.A. | SWITZERLAND | LBMA |
| CID001512 | Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | LBMA |
| CID002582 | Gold | REMONDIS PMR B.V. | NETHERLANDS | RMI |
| CID001534 | Gold | Royal Canadian Mint | CANADA | LBMA |
| CID002761 | Gold | SAAMP | FRANCE | RJC |
| CID002973 | Gold | Safimet S.p.A | ITALY | RJC |
| CID002290 | Gold | SAFINA A.S. | CZECHIA | RMI |
| CID001555 | Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | RMI |
| CID002777 | Gold | SAXONIA Edelmetalle GmbH | GERMANY | RMI |
| CID001585 | Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | LBMA RG / RJC |
| CID001622 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | LBMA |
| CID001736 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | LBMA |
| CID002516 | Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | RMI |
| CID001756 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | LBMA |
| CID001761 | Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | LBMA |
| CID001798 | Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | LBMA |
| CID002918 | Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID002580 | Gold | T.C.A S.p.A | ITALY | LBMA |
| CID001875 | Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | LBMA |
| CID001916 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | LBMA |
| CID001938 | Gold | Tokuriki Honten Co., Ltd. | JAPAN | LBMA |
| CID002615 | Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | LBMA |
| CID001955 | Gold | Torecom | KOREA, REPUBLIC OF | RMI |
| CID002314 | Gold | Umicore Precious Metals Thailand | THAILAND | RJC |
| CID001980 | Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | LBMA |
| CID001993 | Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | RMI |
| CID002003 | Gold | Valcambi S.A. | SWITZERLAND | LBMA RG / RJC |
| CID002030 | Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | LBMA |
| CID002778 | Gold | WIELAND Edelmetalle GmbH | GERMANY | RJC |
| CID002100 | Gold | Yamakin Co., Ltd. | JAPAN | RMI |
| CID002129 | Gold | Yokohama Metal Co., Ltd. | JAPAN | RMI |
| CID002224 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | LBMA |
| 12 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000092 | Tantalum | Asaka Riken Co., Ltd. | JAPAN | RMI |
| CID000211 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | RMI |
| CID002504 | Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | RMI |
| CID000456 | Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | RMI |
| CID000460 | Tantalum | F&X Electro-Materials Ltd. | CHINA | RMI |
| CID002505 | Tantalum | FIR Metals & Resource Ltd. | CHINA | RMI |
| CID002558 | Tantalum | Global Advanced Metals Aizu | JAPAN | RMI |
| CID002557 | Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | RMI |
| CID000616 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | RMI |
| CID002544 | Tantalum | H.C. Starck Co., Ltd. | THAILAND | RMI |
| CID002547 | Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | RMI |
| CID002548 | Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | RMI |
| CID002549 | Tantalum | H.C. Starck Ltd. | JAPAN | RMI |
| CID002550 | Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | RMI |
| CID002545 | Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | RMI |
| CID002492 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | RMI |
| CID002512 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | RMI |
| CID002842 | Tantalum | Jiangxi Tuohong New Raw Material | CHINA | RMI |
| CID000914 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | RMI |
| CID000917 | Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | RMI |
| CID002506 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | RMI |
| CID002539 | Tantalum | KEMET Blue Metals | MEXICO | RMI |
| CID001076 | Tantalum | LSM Brasil S.A. | BRAZIL | RMI |
| CID001163 | Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | RMI |
| CID001175 | Tantalum | Mineracao Taboca S.A. | BRAZIL | RMI |
| CID001192 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | RMI |
| CID001277 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | RMI |
| CID001200 | Tantalum | NPM Silmet AS | ESTONIA | RMI |
| CID002847 | Tantalum | PRG Dooel | NORTH MACEDONIA | RMI |
| CID001508 | Tantalum | QuantumClean | UNITED STATES OF AMERICA | RMI |
| CID002707 | Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | RMI |
| CID001769 | Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | RMI |
| CID001869 | Tantalum | Taki Chemical Co., Ltd. | JAPAN | RMI |
| CID001891 | Tantalum | Telex Metals | UNITED STATES OF AMERICA | RMI |
| CID001969 | Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | RMI |
| 13 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID002508 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | RMI |
| CID001522 | Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | RMI |
| CID000292 | Tin | Alpha | UNITED STATES OF AMERICA | RMI |
| CID000228 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | RMI |
| CID003190 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | RMI |
| CID001070 | Tin | China Tin Group Co., Ltd. | CHINA | RMI |
| CID000402 | Tin | Dowa | JAPAN | RMI |
| CID000438 | Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | RMI |
| CID000468 | Tin | Fenix Metals | POLAND | RMI |
| CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | RMI |
| CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | RMI |
| CID001908 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | RMI |
| CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | RMI |
| CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | RMI |
| CID002849 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | RMI |
| CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | RMI |
| CID000760 | Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | RMI |
| CID001231 | Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | RMI |
| CID003387 | Tin | Luna Smelter, Ltd. | RWANDA | RMI |
| CID003379 | Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | RMI |
| CID002468 | Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | RMI |
| CID001105 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | RMI |
| CID002500 | Tin | Melt Metais e Ligas S.A. | BRAZIL | RMI |
| CID001142 | Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | RMI |
| CID002773 | Tin | Metallo Belgium N.V. | BELGIUM | RMI |
| CID002774 | Tin | Metallo Spain S.L.U. | SPAIN | RMI |
| CID001173 | Tin | Mineracao Taboca S.A. | BRAZIL | RMI |
| CID001182 | Tin | Minsur | PERU | RMI |
| CID001191 | Tin | Mitsubishi Materials Corporation | JAPAN | RMI |
| CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | RMI |
| CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | RMI |
| CID001337 | Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | RMI |
| CID001399 | Tin | PT Artha Cipta Langgeng | INDONESIA | RMI |
| CID002503 | Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | RMI |
| 14 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID003205 | Tin | PT Bangka Serumpun | INDONESIA | RMI |
| CID001453 | Tin | PT Mitra Stania Prima | INDONESIA | RMI |
| CID001460 | Tin | PT Refined Bangka Tin | INDONESIA | RMI |
| CID001477 | Tin | PT Timah Tbk Kundur | INDONESIA | RMI |
| CID001482 | Tin | PT Timah Tbk Mentok | INDONESIA | RMI |
| CID002706 | Tin | Resind Industria e Comercio Ltda. | BRAZIL | RMI |
| CID001539 | Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | RMI |
| CID001406 | Tin | PT Babel Surya Alam Lestari | INDONESIA | RMI |
| CID002835 | Tin | PT Menara Cipta Mulia | INDONESIA | RMI |
| CID001458 | Tin | PT Prima Timah Utama | INDONESIA | RMI |
| CID003381 | Tin | PT Rajawali Rimba Perkasa | INDONESIA | RMI |
| CID002593 | Tin | PT Rajehan Ariq | INDONESIA | RMI |
| CID002848 | Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | RMI |
| CID001758 | Tin | Soft Metais Ltda. | BRAZIL | RMI |
| CID002834 | Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | RMI |
| CID001898 | Tin | Thaisarco | THAILAND | RMI |
| CID003325 | Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | RMI |
| CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | RMI |
| CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | RMI |
| CID002180 | Tin | Yunnan Tin Company Limited | CHINA | RMI |
| CID003397 | Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | RMI |
| CID000004 | Tungsten | A.L.M.T. Corp. | JAPAN | RMI |
| CID002833 | Tungsten | ACL Metais Eireli | BRAZIL | RMI |
| CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | RMI |
| CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | RMI |
| CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | RMI |
| CID003401 | Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | RMI |
| CID000499 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | RMI |
| CID002645 | Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | RMI |
| CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | RMI |
| CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | RMI |
| CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | RMI |
| CID000568 | Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | RMI |
| CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | RMI |
| CID002542 | Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | RMI |
| CID002541 | Tungsten | H.C. Starck Tungsten GmbH | GERMANY | RMI |
| 15 |
| Smelter Identification | Metal | Smelter Name | Smelter Country | Auditor |
| CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | RMI |
| CID002579 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | RMI |
| CID000769 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | RMI |
| CID003182 | Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | RMI |
| CID002649 | Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | RMI |
| CID000825 | Tungsten | Japan New Metals Co., Ltd. | JAPAN | RMI |
| CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | RMI |
| CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | RMI |
| CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | RMI |
| CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | RMI |
| CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | RMI |
| CID000966 | Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | RMI |
| CID000105 | Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | RMI |
| CID003388 | Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID003407 | Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | RMI |
| CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | RMI |
| CID002543 | Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | RMI |
| CID002845 | Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | RMI |
| CID002589 | Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | RMI |
| CID002827 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | RMI |
| CID001889 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | RMI |
| CID002724 | Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | RMI |
| CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | RMI |
| CID002843 | Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | RMI |
| CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | RMI |
| CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | RMI |
| CID002830 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | RMI |
| 16 |
Table 2: Processing facilities reported in our supply chain in relation to calendar year 2020 which were no longer qualified as RMAP conformant as of December 31, 2020 and from which we have discontinued the sourcing of materials as of such date:
| RMAP Smelter Identification Number | Metal | Smelter Name | Smelter Country | Month of communication date from RMI (all in 2020) | Cause (as of communication date from RMI) |
| CID000328 | Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | January | Ceased operations |
| CID000711 | Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | July | LBMA requirement |
| CID001977 | Gold | Umicore Brasil Ltda. | BRAZIL | July | LBMA requirement |
| CID003191 | Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | July | Ceased operations |
| CID002568 | Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | July | Ceased operations |
| CID002570 | Tin | CV Ayi Jaya | INDONESIA | July | Ceased operations |
| CID002592 | Tin | CV Dua Sekawan | INDONESIA | July | Ceased operations |
| CID000306 | Tin | CV Gita Pesona | INDONESIA | July | Ceased operations |
| CID000315 | Tin | CV United Smelting | INDONESIA | July | Ceased operations |
| CID002455 | Tin | CV Venus Inti Perkasa | INDONESIA | July | Ceased operations |
| CID000309 | Tin | PT Aries Kencana Sejahtera | INDONESIA | July | Ceased operations |
| CID001402 | Tin | PT Babel Inti Perkasa | INDONESIA | July | Ceased operations |
| CID002776 | Tin | PT Bangka Prima Tin | INDONESIA | July | Ceased operations |
| CID001419 | Tin | PT Bangka Tin Industry | INDONESIA | July | Ceased operations |
| CID001421 | Tin | PT Belitung Industri Sejahtera | INDONESIA | July | Ceased operations |
| CID001428 | Tin | PT Bukit Timah | INDONESIA | July | Ceased operations |
| CID001434 | Tin | PT DS Jaya Abadi | INDONESIA | July | Ceased operations |
| CID002530 | Tin | PT Inti Stania Prima | INDONESIA | July | Ceased operations |
| CID001448 | Tin | PT Karimun Mining | INDONESIA | July | Ceased operations |
| CID002829 | Tin | PT Kijang Jaya Mandiri | INDONESIA | July | Ceased operations |
| CID002870 | Tin | PT Lautan Harmonis Sejahtera | INDONESIA | July | Ceased operations |
| 17 |
| RMAP Smelter Identification Number | Metal | Smelter Name | Smelter Country | Month of communication date from RMI (all in 2020) | Cause (as of communication date from RMI) |
| CID001457 | Tin | PT Panca Mega Persada | INDONESIA | July | Ceased operations |
| CID000313 | Tin | PT Premium Tin Indonesia | INDONESIA | July | Ceased operations |
| CID001463 | Tin | PT Sariwiguna Binasentosa | INDONESIA | July | Ceased operations |
| CID001468 | Tin | PT Stanindo Inti Perkasa | INDONESIA | July | Ceased operations |
| CID002816 | Tin | PT Sukses Inti Makmur | INDONESIA | July | Ceased operations |
| CID001471 | Tin | PT Sumber Jaya Indah | INDONESIA | July | Ceased operations |
| CID001490 | Tin | PT Tinindo Inter Nusa | INDONESIA | July | Ceased operations |
| CID002478 | Tin | PT Tirus Putra Mandiri | INDONESIA | July | Ceased operations |
| CID001493 | Tin | PT Tommy Utama | INDONESIA | July | Ceased operations |
| CID002647 | Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | July | Ceased operations |
| CID003408 | Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION | July | Active smelter |
| CID002095 | Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | July | Ceased operations |
V. Reporting
We report on our responsible minerals program and performance through different channels, as highlighted in the below table:
| Availability | Policy statement | CMRT | CRT | Sustainability report | DFA (CMR) | Annual responsible mineral report | |
| Public | st.com | x | x | x | x | ||
| Public | Inspectie Leefomgeving en Transport – Inspection living environment and transportation | x | |||||
| Public | SEC | x | x | ||||
| On demand | x | x |
| 18 |
ANNEX I
DEFINITIONS
| Acronym | Definition |
| BEMT R&D | Back End Manufacturing & Technology R&D |
| CAHRA | Conflict-Affected and High-Risk Area |
| CMRT | Conflict Minerals Reporting Template |
| CSR | Corporate Social Responsibility ST Organization |
| DAP | Downstream Audit Program |
| GOBM | Global Outsourcing Business Management |
| GPO | Global Procurement ST Organization |
| LBMA | London Bullion Market Association |
| PQR | Product Quality & Reliability ST Organization |
| RJC | Responsible Jewellery Council |
| RMAP | Responsible Minerals Assurance Process |
| RMI | Responsible Minerals Initiative |
| RMS | Responsible Minerals Statement |
| WFO | Wafer Foundry Outsourcing ST Organization |
| Term | Definition |
|
“DAP” Downstream Audit Program |
The RMI Downstream Audit Program provides a mechanism for companies to obtain independent validation of responsible sourcing practices. The audit is based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. |
| Conflict Minerals Reporting Template | The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. The template also facilitates the identification of new smelters and refiners to potentially undergo an audit via the RMI’s Responsible Minerals Assurance Process (RMAP). |
| Downstream | The metal supply chain from the stage following the smelters and refiners to the final product. |
| London Bullion Market Association | The LBMA set standards from the purity, form and provenance of the bars to the way in which they are traded. |
| Reasonable Country of Origin Inquiry (RCOI) | The purpose of a RCOI is to determine the origin of the conflict mineral, so the determination of whether it came from a covered country can be made. |
| Responsible Jewellery Council | RJC is the world’s leading standard-setting organisation for the entire jewellery and watch industry. |
| Responsible Minerals Assurance Process | The RMAP uses an independent third-party assessment of smelter/refiner management systems and sourcing practices to validate conformance with RMAP standards. |
| Responsible Minerals operator | Person in charge to manage operationally the responsible minerals program. |
| Responsible Minerals Statement | Questionnaire deployed to our suppliers in order to check their alignment with requirements and evaluate some downstream risks. |
| RMAP standards | The RMAP standards are developed to meet the requirements of the OECD Due Diligence Guidance, the Regulation (EU) 2017/821 of the European Parliament and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. |
| 19 |
| 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. |
| 20 |