EX-1.01 2 ex_671400.htm EXHIBIT 1.01 ex_671400.htm

Exhibit 1.01

 

Conflict Minerals Report

 

Expro Group Holdings N.V. - For the reporting period from January 1 to December 31, 2023

 

Company Overview 

 

This report has been prepared by the management of Expro Group Holdings N.V. (herein referred to as the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated. 

 

With roots dating to 1938, the Company is a leading provider of energy services, offering cost- effective, innovative solutions and what the Company considers to be best-in-class safety and service quality. The Company’s extensive portfolio of capabilities spans well construction, well flow management, subsea well access, and well intervention and integrity solutions. The Company provides services in many of the world’s major offshore and onshore energy basins, with operations in approximately 60 countries. The Company’s broad portfolio of products and services provides solutions to enhance production and improve recovery across the well lifecycle, from exploration through abandonment.

 

Our broad portfolio of products and services includes:

 

 

●

Well Construction: Our well construction products and services support customers’ new wellbore drilling, wellbore completion and recompletion, wellbore plug and abandonment cementing and tubulars requirements. In particular, we offer advanced technology solutions in drilling and tubular running services.

 

 

●

Well flow management: We gather valuable well and reservoir data, with a particular focus on well-site safety and environmental impact. We provide global, comprehensive well flow management systems for the safe production, measurement and sampling of hydrocarbons from a well during the exploration and appraisal phase of a new field; the flowback and clean-up of a new well prior to production; and in-line testing of a well during its production life. We also provide early production facilities to accelerate production; production enhancement packages to enhance reservoir recovery rates through the realization of production that was previously locked within the reservoir; metering and other well surveillance technologies to monitor and measure flow and other characteristics of wells.

 

 

●

Well intervention and integrity: We provide well intervention solutions to acquire and interpret well data, maintain well bore integrity to improve production and well bore monitoring. In addition to our extensive fleet of mechanical and cased hole wireline units, CoilHose™, for wellbore lifting, cleaning and chemical treatments including fluid treatments in wellbore annuli.

 

 

Introduction

 

For the 2023 calendar year, Expro Group Holdings N.V. determined that tin, tungsten, tantalum, and/or gold (3TGs or “conflict minerals”) were necessary to the functionality or production of products that were manufactured or contracted to be manufactured. Therefore, Expro Group Holdings N.V. conducted a reasonable country of origin inquiry in good faith to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Democratic Republic of the Congo (DRC) or an adjoining country (collectively referred to as the “Covered Countries”).

 

 
 

 

Based on the country of origin data, Expro Group Holdings N.V. believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question to determine whether its products are “conflict-free or responsibly sourced.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of the Organization for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).

 

Expro Group Holdings N.V. is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, the Company has put into place a robust due diligence program to ensure its contributions to upholding human rights and responsible practices across the supply chain. 

 

Conflict Minerals Program & Policy

 

The Company has actively engaged with its customers and suppliers for several years with respect to the use of conflict minerals. Expro Group Holdings N.V. adopted a Conflict Minerals Policy articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals. The policy is available online and can be found here: https://investors.expro.com/governance/governance-documents. 

 

Description of Products

 

Only some of Expro International Group Limited’s products fall in scope of the Rule, as they contain (or may contain) one or more of the 3TGs. The following product line descriptions provide additional detail on in-scope products that contain, or may contain, 3TGs: 

 

Flow meters; subsea safety valves; oil, gas and core analysis laboratory equipment; downhole drilling tools, solids and pressure control equipment for drilling fluids systems, data acquisition equipment for drilling operations, surface and downhole completions tools, cementing equipment, wellhead and Landing String systems, production systems and manifolds and aftermarket parts, valves, actuators; chokes and aftermarket parts, oil and gas separation equipment; heaters, desalting units, gas conditioning units, and electronic controls equipment.

 

Reasonable Country of Origin Inquiry

 

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Expro Group Holdings N.V. retained Assent Inc. (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager.

 

To trace materials, and demonstrate transparency procured by the supply chain, Expro Group Holdings N.V. utilized the Conflict Minerals Reporting Template (CMRT) Version 6.31 or higher to conduct a survey of all in-scope suppliers. 

 

During the supplier survey, the Company contacted suppliers via the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The Assent Compliance Manager also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform. 

 

 
 

 

Via the Assent Compliance Manager and Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the Assent Compliance Manager for future reporting and transparency. Expro Group Holdings N.V. directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.

 

The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement. 

 

All submitted declaration forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors (see Appendix C for CMRT validation criteria). Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Expro Group Holdings N.V. tracks program gaps to account for future improvement opportunities. 

 

For RY 2023, there were 486 suppliers in scope of the conflict minerals program and 247 provided a completed CMRT. Expro International’s total response rate for this reporting year was 51%.

 

Through reasonable due diligence practices, Expro Group Holdings N.V. was able to take advantage of a broader set of country-of-origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Expro Group Holdings N.V. was able to determine all the possible countries minerals (such as 3TGs) used in its product originated from. As such, Expro Group Holdings N.V. can perform further due diligence on the source and chain of custody of the minerals in question.

 

Due Diligence

 

Design of Due Diligence

 

Expro Group Holdings N.V. designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities. 

 

Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot be fully owned by the Company. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps can be mitigated. This aligns with industry standards and market expectations for downstream companies’ due diligence.

 

 
 

 

Due Diligence Performed

 

1) Establish Strong Company Management Systems

 

Internal Compliance Team

 

Expro Group Holdings N.V. established a cross-functional Conflict Minerals Team led by Joerg Gruber – Chief Compliance Officer. The Conflict Minerals Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts. 

 

The Company also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company will undertake with suppliers and/or respective stakeholders in regard to conflict minerals. 

 

The Company leverages Assent’s Managed Services to work with dedicated program specialists who support Expro International’s conflict minerals program. The Company communicates regularly with the Assent team to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and CMRs, as well as Section 1502 of the Dodd-Frank Act.

 

Control Systems 

 

The Company expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Expro Group Holdings N.V. are “conflict free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from areas that have been identified to be in the presence of widespread human rights abuses and violations of law either directly or indirectly. The Company expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.

 

Expro Group Holdings N.V.’s Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviors and practices. This code of conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance.

 

The Supplier Code of Conduct is provided to all direct suppliers. If a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. The Supplier Code of Conduct is reviewed annually to ensure it continues to align with industry best practices.

 

Supplier Engagement

 

Expro Group Holdings N.V. has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, Expro Group Holdings N.V. has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. Expro International’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly fill a CMRT. Suppliers are provided guidance in their native language, if needed. 

 

The Company engages with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes supplier risk identification process that then leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative. 

 

 
 

 

Additionally, the Company’s Conflict Minerals Policy is included in supplier contracts, requiring new suppliers to read and accept the policy as a requirement of doing business with Expro International Group Limited. When entering into or renewing supplier contracts, a clause is added that requires suppliers to provide information about the source of 3TGs and smelters. 

 

The Company continues to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.

 

The Company believes that the combination of the Supplier Code of Conduct, Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.

 

Grievance Mechanisms

 

The Company established multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Expro Group Holdings N.V. policies, including conflict minerals. Suppliers and others outside of Expro Group Holdings N.V. may contact the Conflict Minerals Team, including to report grievances, via a dedicated email address that is published in the Conflict Minerals Policy and in other communications with suppliers. In addition, employees may anonymously report suspected violations using “Speak - Up”. Any violations are reported to the Corporate Compliance Committee.

 

Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/

 

Maintain Records 

 

The Company has adopted a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. The Company stores all of the information and findings from this process in a database that can be audited by internal or external parties.

 

2) Identifying & Assessing Risk in the Supply Chain

 

Supplier Risk Evaluation

 

Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company’s internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”

 

Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Expro Group Holdings N.V. is unable to determine if all of the specified smelters/refiners were used for 3TGs in the products supplied to the Company. 

 

 
 

 

Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple conflict minerals factors. 

 

Smelter/Refiners Risk Evaluation

 

Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s Smelter validation program compared listed facilities into the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2023 calendar year.

 

Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Expro Group Holdings N.V. does not have a direct relationship with smelters/refiners and does not perform direct audits of these entities within their pre-supply chain. Smelters that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict-free or responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or when they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to conflict minerals.

 

 

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

 

 

●

Geographic proximity to Conflict-Affected and High-Risk Areas.

 

 

●

Known mineral source country of origin.

 

 

●

RMAP audit status. 

 

 

●

Credible evidence of unethical or conflict sourcing.

 

 

●

Peer assessments conducted by credible third-party sources.

 

 

●

Sanctions risks

 

Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions. Examples include the submission of a product specific CMRT to better identify the connection to products that they supply to Expro International Group Limited. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. 

 

In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

 

 
 

 

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

 

3) Design & Implement A Strategy to Respond to Risks

 

Together with Assent, Expro Group Holdings N.V. developed processes to assess and respond to the risks identified in the supply chain. Expro Group Holdings N.V. has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.

Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, the Company will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Team and the Expro International’s Leadership Team to ensure transparency within the Company.

 

4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

Expro Group Holdings N.V. does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters/refiners (industry-recognized audit/assessment programs).

 

As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters/refiners that agree to participate in the program.

 

Assent directly engages smelters/refiners that are not currently enrolled in an industry-recognized audit/assessment program to encourage their participation and for those smelters/refiners already conformant to the corresponding program’s standards, Assent thanks them for their efforts on behalf of its compliance partners. Expro Group Holdings N.V. is a signatory of these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance. 

 

5) Report Annually on Supply Chain Due Diligence

 

Expro Group Holdings N.V. has published the Form SD for the year ended December 31, 2023. This report is available on the Investor Relations section of the Company’s website at https://investors.expro.com/financials/sec-filings. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. Expro Group Holdings N.V. has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission (SEC).

 

This year the Company has also considered impacts from the EU Conflict Minerals Regulation when disclosing details with regards to due diligence efforts. The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public reports.

 

Due Diligence Results

 

Supply Chain Outreach Results

 

Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten, and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refinery sources are identified. The following is the result of the outreach conducted by Expro Group Holdings N.V. for the 2023 reporting year.

 

 
 

 

Supply Chain Outreach Metrics

 

Number of in-scope suppliers

Response rate

486

50.82%

 

 

Upstream Data Transparency

 

Appendix A includes all smelters/refiners that suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2023 calendar year.

 

As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period.

 

Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners that actually processed the 3TGs contained in the Company’s products.

 

Although the potential for over-reporting is understood, Expro Group Holdings N.V. has taken measures to validate all smelter/refiner data against validated audit programs and databases intended to verify the material types and mine sources of origin.

 

Suppliers that identified smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections.

 

 

Status

Number of identified smelters/refiners

RMAP Conformant

224

RMAP Active

7

Not Enrolled

90

Non-Conformant

29

 

 
 

 

Country of Origin

 

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country-of-origin data obtained via Assent’s supply chain database (or other RCOI data, in the scenario Expro Group Holdings N.V. decides to use alternative data sources). As mentioned in the above section, it is understood that overreporting might occur which could result in Appendix B having more countries than those strictly relevant to the Company’s products.

 

Future Process Improvement

 

For RY 2024, Expro Group Holdings N.V. intends to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in the Company’s products could originate from Conflict-Affected and High-Risk Areas:

 

 

●

Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:

 

 

o

Using a comprehensive smelter and refinery library with detailed status and notes for each entity. 

 

 

o

Scanning for verifiable media sources on each smelter and refinery to flag risk issues.

 

 

o

Comparing the list of smelters/refiners against government watch and denied parties lists. 

 

 

●

Seeking to increase our supplier responses in reporting period 2024, while recognizing that responses will depend on supplier cooperation.

 

 

●

Engage with all high-risk suppliers to understand their risk level and the future implications of managing or reducing the risk level to an acceptable standard.

 

 

●

Engage with suppliers more closely and provide more information and training resources regarding responsible sourcing of 3TGs.

 

 

●

Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from their sub suppliers.

 

 

●

Continue to assess the presence of conflict minerals for non Expro engineered products in our relevant supply chain.

 

 

●

Continue to assess the presence of conflict minerals at design stage and identify on or engineered part numbering.

 

 

●

Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued. 

 

 

●

Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refinery information from the supply chain through feedback and detailed smelter analysis.

 

 

●

Seek where practicable alternative suppliers that responsibly source necessary conflict minerals.

 

 
 

 

Appendix A: Smelter List 

 

Includes: mineral, smelter/refinery name, location

 

 

 Metal

Smelter Name

Smelter Facility Location

 Smelter ID

 RMAP Audit Status

Gold

Advanced Chemical Company

United States of America

CID000015

Active

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

CID000041

Conformant

Gold

CCR Refinery - Glencore Canada Corporation

Canada

CID000185

Conformant

Gold

Heimerle + Meule GmbH

Germany

CID000694

Conformant

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

China

CID000801

Conformant

Gold

Istanbul Gold Refinery

Turkey

CID000814

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

China

CID001149

Conformant

Gold

Metalor Technologies S.A.

Switzerland

CID001153

Conformant

Gold

Mitsubishi Materials Corporation

Japan

CID001188

Conformant

Gold

Nihon Material Co., Ltd.

Japan

CID001259

Conformant

Gold

Rand Refinery (Pty) Ltd.

South Africa

CID001512

Conformant

Gold

Shandong Gold Smelting Co., Ltd.

China

CID001916

Conformant

Gold

Valcambi S.A.

Switzerland

CID002003

Conformant

Gold

Yokohama Metal Co., Ltd.

Japan

CID002129

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

India

CID002509

Conformant

Gold

SAAMP

France

CID002761

Non-Conformant

Gold

GGC Gujrat Gold Centre Pvt. Ltd.

India

CID002852

Non-Conformant

Gold

Safimet S.p.A

Italy

CID002973

Non-Conformant

Gold

Samduck Precious Metals

Korea, Republic of

CID001555

Non-Conformant

Gold

Umicore Precious Metals Thailand

Thailand

CID002314

Non-Conformant

Gold

Emirates Gold DMCC

United Arab Emirates

CID002561

Non-Conformant

Gold

Sabin Metal Corp.

United States of America

CID001546

Communication Suspended - Not Interested

 

 
 

 

Gold

Marsam Metals

Brazil

CID002606

Non-Conformant

Gold

Pease & Curren

United States of America

CID002872

Communication Suspended - Not Interested

Gold

QG Refining, LLC

United States of America

CID003324

Outreach Required

Gold

Prioksky Plant of Non-Ferrous Metals

Russian Federation

CID001386

RMI Due Diligence Review - Unable to Proceed

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Russian Federation

CID001756

RMI Due Diligence Review - Unable to Proceed

Tantalum

F&X Electro-Materials Ltd.

China

CID000460

Conformant

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

China

CID000616

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

China

CID000914

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

China

CID000917

Conformant

Tantalum

AMG Brasil

Brazil

CID001076

Conformant

Tantalum

Mineracao Taboca S.A.

Brazil

CID001175

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

Japan

CID001192

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

CID001277

Conformant

Tantalum

QuantumClean

United States of America

CID001508

Conformant

Tantalum

Telex Metals

United States of America

CID001891

Conformant

Tantalum

Ulba Metallurgical Plant JSC

Kazakhstan

CID001969

Conformant

Tantalum

D Block Metals, LLC

United States of America

CID002504

Conformant

Tantalum

KEMET de Mexico

Mexico

CID002539

Conformant

Tantalum

TANIOBIS Co., Ltd.

Thailand

CID002544

Conformant

Tantalum

TANIOBIS GmbH

Germany

CID002545

Conformant

Tantalum

Materion Newton Inc.

United States of America

CID002548

Conformant

Tantalum

TANIOBIS Japan Co., Ltd.

Japan

CID002549

Conformant

Tantalum

TANIOBIS Smelting GmbH & Co. KG

Germany

CID002550

Conformant

Tantalum

Global Advanced Metals Boyertown

United States of America

CID002557

Conformant

Tantalum

Global Advanced Metals Aizu

Japan

CID002558

Conformant

 

 
 

 

Tantalum

Solikamsk Magnesium Works OAO

Russian Federation

CID001769

RMI Due Diligence Review - Unable to Proceed

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

CID000228

Conformant

Tin

Alpha

United States of America

CID000292

Conformant

Tin

PT Aries Kencana Sejahtera

Indonesia

CID000309

Conformant

Tin

EM Vinto

Bolivia (Plurinational State of)

CID000438

Conformant

Tin

Fenix Metals

Poland

CID000468

Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

CID000538

Conformant

Tin

China Tin Group Co., Ltd.

China

CID001070

Conformant

Tin

Malaysia Smelting Corporation (MSC)

Malaysia

CID001105

Conformant

Tin

Metallic Resources, Inc.

United States of America

CID001142

Conformant

Tin

Minsur

Peru

CID001182

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

China

CID001231

Conformant

Tin

Operaciones Metalurgicas S.A.

Bolivia (Plurinational State of)

CID001337

Conformant

Tin

PT Artha Cipta Langgeng

Indonesia

CID001399

Conformant

Tin

PT Babel Inti Perkasa

Indonesia

CID001402

Conformant

Tin

PT Belitung Industri Sejahtera

Indonesia

CID001421

Conformant

Tin

PT Bukit Timah

Indonesia

CID001428

Conformant

Tin

PT Mitra Stania Prima

Indonesia

CID001453

Conformant

Tin

PT Prima Timah Utama

Indonesia

CID001458

Conformant

Tin

PT Refined Bangka Tin

Indonesia

CID001460

Conformant

Tin

PT Sariwiguna Binasentosa

Indonesia

CID001463

Conformant

Tin

PT Stanindo Inti Perkasa

Indonesia

CID001468

Conformant

Tin

PT Timah Tbk Kundur

Indonesia

CID001477

Conformant

Tin

PT Timah Tbk Mentok

Indonesia

CID001482

Conformant

Tin

PT Timah Nusantara

Indonesia

CID001486

Conformant

 

 
 

 

Tin

PT Tinindo Inter Nusa

Indonesia

CID001490

Conformant

Tin

Rui Da Hung

Taiwan, Province of China

CID001539

Conformant

Tin

Thaisarco

Thailand

CID001898

Conformant

Tin

White Solder Metalurgia e Mineracao Ltda.

Brazil

CID002036

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

CID002158

Conformant

Tin

Tin Smelting Branch of Yunnan Tin Co., Ltd.

China

CID002180

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

Brazil

CID002468

Conformant

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

CID002503

Conformant

Tin

CV Ayi Jaya

Indonesia

CID002570

Conformant

Tin

PT Rajehan Ariq

Indonesia

CID002593

Conformant

Tin

Super Ligas

Brazil

CID002756

Conformant

Tin

Aurubis Beerse

Belgium

CID002773

Conformant

Tin

Aurubis Berango

Spain

CID002774

Conformant

Tin

PT Sukses Inti Makmur

Indonesia

CID002816

Conformant

Tin

PT Menara Cipta Mulia

Indonesia

CID002835

Conformant

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

China

CID003116

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

China

CID003190

Conformant

Tin

PT Bangka Serumpun

Indonesia

CID003205

Conformant

Tin

Luna Smelter, Ltd.

Rwanda

CID003387

Conformant

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

China

CID003397

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

CID000555

Non-Conformant

Tin

PT Panca Mega Persada

Indonesia

CID001457

Outreach Required

Tin

Melt Metais e Ligas S.A.

Brazil

CID002500

Non-Conformant

Tin

VQB Mineral and Trading Group JSC

Viet Nam

CID002015

Outreach Required

Tungsten

A.L.M.T. Corp.

Japan

CID000004

Conformant

Tungsten

Kennametal Huntsville

United States of America

CID000105

Conformant

 

 
 

 

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

China

CID000218

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

China

CID000258

Conformant

Tungsten

Global Tungsten & Powders LLC

United States of America

CID000568

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

China

CID000766

Conformant

Tungsten

Japan New Metals Co., Ltd.

Japan

CID000825

Conformant

Tungsten

Kennametal Fallon

United States of America

CID000966

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

China

CID002082

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

China

CID002315

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

China

CID002317

Conformant

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

China

CID002318

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

China

CID002319

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

China

CID002320

Conformant

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

China

CID002321

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

China

CID002494

Conformant

Tungsten

Asia Tungsten Products Vietnam Ltd.

Viet Nam

CID002502

Conformant

Tungsten

Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch

China

CID002513

Conformant

Tungsten

H.C. Starck Tungsten GmbH

Germany

CID002541

Conformant

Tungsten

TANIOBIS Smelting GmbH & Co. KG

Germany

CID002542

Conformant

Tungsten

Masan High-Tech Materials

Viet Nam

CID002543

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

China

CID002551

Conformant

Tungsten

Niagara Refining LLC

United States of America

CID002589

Conformant

Tungsten

ACL Metais Eireli

Brazil

CID002833

Non-Conformant

Tungsten

Hydrometallurg, JSC

Russian Federation

CID002649

RMI Due Diligence Review - Unable to Proceed

Tungsten

Unecha Refractory metals plant

Russian Federation

CID002724

Non-Conformant

 

 
 

 

Appendix B: Countries of Origin

 

Includes: list of countries that declared smelters are known to source from.

 

 

Albania

Dominican Republic

Kenya

Portugal

Vietnam

Andorra

Ecuador

Korea

Russian Federation

Zambia

Angola

Egypt

Kyrgyzstan

Rwanda

  

Argentina

El Salvador

Liberia

Saudi Arabia

  

Armenia

Eritrea

Liechtenstein

Senegal

  

Australia

Estonia

Lithuania

Serbia

  

Austria

Ethiopia

Luxembourg

Sierra Leone

  

Azerbaijan

Fiji

Madagascar

Singapore

  

Belarus

Finland

Malaysia

Slovakia

  

Belgium

France

Mali

Solomon Islands

  

Benin

Georgia

Mauritania

South Africa

  

Bermuda

Germany

Mexico

South Sudan

  

Bolivia (Plurinational State of)

Ghana

Mongolia

Spain

  

Botswana

Guam

Morocco

Sudan

  

Brazil

Guatemala

Mozambique

Suriname

  

Bulgaria

Guinea

Myanmar

Sweden

  

Burkina Faso

Guyana

Namibia

Switzerland

  

Burundi

Honduras

Netherlands

Taiwan

  

Cambodia

Hong Kong

New Zealand

Tajikistan

  

Canada

Hungary

Nicaragua

Tanzania

  

Central African Republic

India

Niger

Thailand

  

Chile

Indonesia

Nigeria

Togo

  

China

Ireland

Norway

Turkey

  

Colombia

Israel

Oman

Uganda

  

Congo

Italy

Panama

United Arab Emirates

  

Cyprus

Ivory Coast

Papua New Guinea

United Kingdom

  

Democratic Republic of Congo

Japan

Peru

United States of America

  

Djibouti

Jersey

Philippines

Uruguay

  

Dominica

Kazakhstan

Poland

Uzbekistan

  

 

 
 

 

Appendix C: CMRT Declaration Rejection/Approval Criteria

 

Assent Sustainability Platform Logic Structure

 

The following tables map the Assent Sustainability Platform’s status outputs and CMRT logic structure when determining supplier conflict mineral statuses as displayed on the dashboard. Using this table, and referencing the CMRT questions listed above, users will be able to determine what answers were provided by their suppliers to earn their conflict minerals statuses. 

 

Dashboard Supplier Response Statuses

 

Supplier Status

Description

Not Submitted

A CMRT has not been submitted by the supplier

Complete

A CMRT has been submitted, and is valid and complete

Incomplete

A supplier with parts associated to them has submitted a partially completed Product-Level or User-Defined CMRT

Invalid Submission

A CMRT has been submitted and deemed invalid based on contradicting responses in the template

Out of Scope

The supplier is out of scope for conflict minerals and does not need to be contacted