SD 1 googexhibit101-2023.htm SD Document

Exhibit 1.01


Alphabet Inc.
Conflict Minerals Report
For The Year Ended December 31, 2023
                    
This Conflict Minerals Report for the year ended December 31, 2023 (this “CMR”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), which requires certain reporting and disclosure related to conflict minerals. Conflict minerals are currently defined as cassiterite, columbite-tantalite, wolframite, gold, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”)1 for the purpose of this assessment. These requirements apply to registrants whatever the geographic origin of their conflict minerals and whether or not their conflict minerals fund armed conflict. Please refer to the Rule, Form SD, and SEC Release No. 34-67716 for definitions to the terms used in this CMR, unless otherwise defined herein.
                
Statements in this CMR are based on our due diligence activities performed in good faith for the calendar year 2023 and are based on information available at the time of this filing, unless otherwise indicated. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter and/or refiner (collectively referred to as “smelter(s)”) data, errors or omissions by suppliers or smelters, ongoing certifications of smelters, continued guidance or amendments to the Rule, and other issues. Additionally, this CMR may contain forward-looking statements that reflect what we strive to achieve in the future as we continue to improve our responsible sourcing program. These forward-looking statements are based on current expectations and assumptions that are subject to risks and uncertainties.
                    
References to our websites and information available through these websites are not incorporated into this CMR.
                    
Throughout this CMR, we use “Alphabet,” “we,” “our,” “us” and similar terms to refer to Alphabet Inc. and its subsidiaries (collectively, “Alphabet”), unless otherwise indicated, and use “Google” to refer to Google LLC, a wholly owned subsidiary of Alphabet.    
            
1.Overview
                    
(A) Company
                    
Alphabet is a collection of businesses — the largest of which is Google — which we report as two segments: Google Services and Google Cloud; we also report all non-Google businesses collectively as Other Bets. Alphabet’s structure is about helping each of our businesses prosper through strong leaders and independence.

Our Google Services and Google Cloud segments together represented approximately 99% of our consolidated revenues in 2023. Our Google Services segment generates revenues primarily by delivering both performance advertising and brand advertising. In addition, Google Services increasingly generates revenues from products and services beyond advertising, including (i) consumer subscriptions, which primarily include revenues from YouTube services, such as YouTube TV, YouTube Music and Premium; (ii) platforms, which primarily include revenues from Google Play from the sales of apps and in-app purchases; and (iii) devices, which primarily include sales of the Pixel family of devices. Our Google Cloud segment generates revenues primarily from consumption-based fees and subscriptions for infrastructure, platform, collaboration tools and other cloud services. Our Other Bets are emerging businesses at various stages of development, ranging from those in the research and
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.



development phase to those that are in the beginning stages of commercialization, and our goal is for them to become thriving, successful businesses.

(B) In-Scope Products
                    
Products assessed for the scoping of the CMR included tangible products that enter the stream of commerce as defined by the Rule. The hardware products considered in scope for this CMR pertain to consumer-facing devices such as healthcare technology, home devices, phones, wearable devices, streaming devices, tablets, video cameras, and, more specifically, the components of the hardware, such as circuit boards, chips, capacitors, alloys, motor components, and wires.
            
(C) Supply Chain
                    
Our supply chain consists of a broad range of suppliers and several manufacturing models. Other companies manufacture the hardware components, such as those described in 1(B), on our behalf. Whether we are working with Original Equipment Manufacturers or more closely with the product design, we do not directly purchase raw materials and are several tiers away from the smelter and country of origin of the 3TG used in our products. In addition, many of the suppliers we work with are not directly subject to the Rule and its corresponding requirements. To influence activities through multiple tiers of the supply chain, we actively engage with a variety of industry members, including the Responsible Minerals Initiative (the “RMI”). Our engagement with RMI includes using tools such as the Conflict Minerals Reporting Template (the “CMRT”), Extended Minerals Reporting Template (the "EMRT") for select suppliers, and participating in numerous workgroups and activities that support the RMI’s efforts, including the Responsible Minerals Assurance Process (the “RMAP”).
                    
(D) Conflict Minerals Policy
                    
We believe it is essential to establish validated conflict-free sources of 3TG within the Democratic Republic of the Congo (the “DRC”) and adjoining countries (together, with the DRC, the “Covered Countries”), so that these minerals can be procured in a way that contributes to economic growth and development in the region. To aid in this effort, we have established a conflict minerals policy and an internal team to implement the policy. Our conflict minerals policy is accessible on our website at https://abc.xyz/investor/conflictminerals/.We expect our suppliers to assure the 3TG in our products are sourced from conformant conflict-free smelters, such as those audited through the RMI’s RMAP (http://www.responsiblemineralsinitiative.org), the London Bullion Market Association (LBMA) or the Responsible Jewellery Council (RJC), each of whom perform due diligence on the source and chain of custody of the 3TG used in our products and provide their due diligence measures to us upon request. The due diligence standards of the aforementioned organizations all meet the OECD Due Diligence Standard, which is discussed further below.

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2.Reasonable Country of Origin Inquiry
                    
To identify which of our suppliers to survey regarding the source of the 3TG used in our products, we inventoried our products to determine which products were either manufactured or contracted for manufacture by us between January 1, 2023 and December 31, 2023, and if they were intended to enter the stream of commerce. For all products in scope, we identified and compiled a list of our suppliers (our “in-scope suppliers”) from whom we requested information regarding their sourcing of 3TG.We requested that such identified in-scope suppliers provide us with information regarding their supply chain using the CMRT from the RMI. We also followed up with our own company-developed tools and templates to review CMRT completeness, ensure at least a base minimum of response across all respondents, and identify potential inconsistencies. The CMRT included questions about location or mine of origin of the 3TG in the products, and requested in-scope suppliers to make similar efforts to survey their supply chains and report the smelters and location or mine of origin of necessary 3TG. We reviewed and monitored responses from our in-scope suppliers and followed up if we identified information to be incomplete or inconsistent with the information we would expect from the supplier. Our follow-up actions included the following:

If an in-scope supplier did not respond, we initiated a supplier escalation process until a response was received.
If an in-scope supplier had inconsistent or incomplete information, we contacted the supplier and requested updated information, provided additional training resources, and reaffirmed our applicable supplier codes of conduct and conflict minerals policy expectations.
We worked with suppliers to improve their responses and commitment to conflict-free sourcing at both company and product levels and sourcing from RMAP conformant smelters.
We also encouraged suppliers to join industry collaborations to further support conflict-free sourcing.
                
We received a 100% response rate from our in-scope suppliers who provided data to us at either the company or product level. In-scope suppliers are continuously gathering information from their suppliers and we continue to work with them to ensure that suppliers are fully represented.
            
Some in-scope supplier responses indicated that some smelters used by them at various levels of our supply chain obtain 3TG from the Covered Countries. Some in-scope supplier responses also indicated sourcing 3TG from outside of the Covered Countries, from recycled or scrap sources, and/or from unknown origins. Based on the results of our supply chain survey and the nature of our supply chain as described in Section 1(C) above, we were unable to verify with certainty the source and chain of custody of all of the 3TG used by our suppliers and in our products. We completed due diligence on all smelters reported in our supply chain as described in Section 3 below.
                    
3.Due Diligence
                    
Our due diligence measures were designed to conform in all material respects to the five step framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, 2016 (“OECD Guidance”).
                    
Below is a description of our due diligence activities performed for the 2023 reporting year as they relate to the five-step framework set forth in the OECD Guidance.
                    
OECD Step 1 - Establish strong company management systems                
Our conflict minerals policy described in Section 1(D) is publicly available on our Investor Relations website.
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Our governance structure includes senior management from our in-scope supply chains, legal and finance organizations who are responsible for monitoring our due diligence activities. Oversight of the program consists of our CFO, Chief Compliance Officer, and vice presidents from supply chain and business operations, finance, and legal.
We include responsible sourcing and due diligence requirements in our applicable supplier codes of conduct and in supplier contract templates. Our suppliers are expected to source from conflict-free sources, and utilize the CMRT to disclose sourcing information about the 3TG in their products. We provide additional templates for follow-up, training and resources to our suppliers on our requirements.
Our product areas utilize a system that includes online platforms for storing and managing our conflict minerals due diligence activities, communications, and results.
We have a document retention policy for maintaining conflict minerals program documentation for a minimum of five years.
We have a grievance mechanism for reporting violations of our policies.
            
OECD Step 2 - Identify and assess risk in the supply chain                
We requested that our in-scope suppliers provide a CMRT to collect information about the smelters of 3TG used in our products.
We assessed the CMRTs received from our in-scope suppliers for completeness, and reasonableness based on OECD Guidance for Conflict and High Risk Areas (CAHRAs) globally, including the Covered Countries.
We validated each smelter disclosed by our in-scope suppliers by checking against the smelter data provided by the RMI.
We provided conflict minerals feedback as needed to in-scope suppliers that were audited by our internal Supplier Responsibility audit program.
For the seventh consecutive year, we utilized an independent third party to provide an assessment of 100% of the smelters disclosed by our in-scope suppliers, to track data, and to identify risks in smelters that have not yet undergone the RMAP. This prompted additional direct follow-up with smelters and suppliers.
We communicated with in-scope suppliers that reported smelters which were not yet identified as RMAP conformant. We worked with in-scope suppliers to improve the completeness and accuracy of their responses and fostered their ongoing commitment to conflict-free minerals at both company and product levels. We also encouraged all suppliers to join industry collaborations.
We developed a plan, for in-scope suppliers not sourcing exclusively from conformant smelters for products, to bring those smelters into conformance.
We worked with our in-scope suppliers and reviewed the CMRT responses they received from their suppliers. This process helped inform our direct suppliers on how to identify risks in the information they receive from their suppliers. As part of this process, we also encouraged suppliers to source from RMAP conformant smelters in the DRC and other CAHRAs.
                            
OECD Step 3 - Design and implement a strategy to respond to identified risks             
Program Governance:
We created a list of suppliers for in-scope product areas that are in conformance with our Supplier Code of Conduct, and we use this list to guide our supplier selections and continuing business with known conflict-free sourcing suppliers.
We provided updates to our Supplier Responsibility team, Supplier Responsibility Steering Committee, and Audit and Compliance Committee on our due diligence activities and CMR.

Supplier Due Diligence and Industry Engagement:
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We reviewed allegations and incidents in the supply chain and worked with suppliers and industry stakeholders to improve responsible sourcing outcomes. One way we do this is by encouraging suppliers to adopt responsible sourcing policies and practices instead of banning all minerals from the DRC and Covered Countries, which negatively impacts communities that depend on mining.
We also contributed to the RMI upstream due diligence fund and conducted due diligence on smelters in the DRC and Covered Countries through direct outreach as part of the RMI Smelter Engagement Team Working Group. We emphasized the importance of RMAP conformance when we engaged with smelters that were not yet conformant or active.

Economic and Energy Sustainability:
Diversifying economies, investing in sustainable development, and providing for alternative livelihoods are important components of any strategy to promote responsible mining. Thus, we contributed funding to the Public-Private Alliance for Responsible Minerals Trade (PPA), which signed a renewed 2023 Memorandum of Understanding that extended Google’s partnership for five more years. PPA also broadened its scope to focus on global transition minerals beyond 3TG within and outside of the Great Lakes Region of Africa in order to respond to global minerals demand.
As planned, we transitioned ownership of Congo Power projects to the PPA, and we helped formalize and centralize a partnership with the PPA and other donors to continue these energy sustainability efforts2. For example, this work provided two solar energy installations for the Good Shepherd International Foundation (also known as Bon Pasteur), which works directly with mining communities to address human rights abuses. The Foundation specifically focuses on breaking the cycle of abuse against children, women, and girls. The last step of installation was completed in early 2024.
Separate from Congo Power, we also began scoping a solar installation that will provide renewable energy to a Fair Cobalt Alliance partner organization. This is expected to be deployed in mid-2024 and is a continuation of our work on advancing energy resources and alternative livelihoods.

OECD Step 4 - Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain
We joined the RMI in 2013 (member ID: GOOG), and we continue to be a member.
We relied upon the RMI to validate that companies meet the criteria of a smelter, and then verify that they conform to the RMAP.
We worked with a third party to provide an assessment of smelters not participating in RMI to give Alphabet visibility on all smelters identified in supplier outreach.                     
We conducted supplier responsibility audits with independent third parties on a portion of our suppliers with a risk-based approach, which included reviewing their conflict minerals programs.
We continued activities to supplement the RMAP process and audits such as direct inquiries, communications, and development of industry tools to support audit programs and reporting mechanisms. This allowed us to better understand issues smelters face in the compliance process and how we can best align to support management systems used for compliance and in-region due diligence.
We continued our communication with civil society and NGOs with staff operating on the ground during the 2023 cycle. These communications helped us to better understand risks and opportunities, such as enhancing responsible supply chains.

OECD Step 5 - Report annually on supply chain due diligence
2 Congo Power is an effort we began in 2017 to provide energy resources, alternative opportunities for livelihoods, and increased economic stability to communities committed to responsible sourcing. The newly developed partnership group expects to initiate a slate of grants in the second half of 2024, which are intended to grow Congo Power’s scope and impact through updating grantee evaluation criteria and expanding current objectives. Current objectives primarily focus on developing renewable electricity, but they will expand to include additional social objectives, such as gender equity.
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We publish a CMR annually, and our reports are accessible on our Investor Relations website at https://abc.xyz/investor/conflictminerals/.
We published our 2023 Supplier Responsibility Report, which also included an update on our conflict minerals program and industry collaborations (https://sustainability.google/reports/).

4.Due Diligence Results
                    
Smelter Disclosure

Based on our due diligence of the information provided by our in-scope suppliers for the 2023 reporting period, we have reason to believe that a portion of the 3TG used in our products originated from the Covered Countries. In some instances, information provided by our in-scope suppliers was unverifiable or incomplete and, as such, we are not declaring any of our products to be “DRC Conflict Free” since we were unable to verify with certainty the
source and chain of custody of all of the necessary 3TG in our products. Based on the due diligence performed, our suppliers identified 302 unique smelters and we evaluated each of them based on third party audits and/or assessments; 224 are considered “conformant” and 5 are considered “active” on the RMI website. Based on our third party assessment and RCOI, we identified an additional 70 smelters as not sourcing from the Covered Countries (or have no reason to believe they are sourcing from the Covered Countries) bringing the total number of smelters identified as “conformant”, “active” or not sourcing from the DRC to 299 (99%). As for the 3 remaining smelters, the RMI statuses were updated to “Non Conformant” in Q4 2023 for 2 of them and early 2024 for the remaining 1. Our suppliers have communicated a need for further time to rectify the use of these non-conformant smelters, and we are currently engaging with them and supporting their efforts to do so.

The results of our due diligence on the 3TG used in our in-scope products are noted below:
2023 Smelters
Tin
Tungsten
Tantalum
Gold
Total
Total number of smelters
85
38
36
143
302
Number (%) of smelters listed as “conformant” by RMI
68 (80%)
32 (84%)
35 (97%)
89 (62%)
224 (74%)
Number (%) of smelters listed as “active” by RMI
2 (2%)
0 (0%)
1 (3%)
2 (1%)
5 (2%)
Number (%) of smelters confirmed by an independent third party to not be sourcing from the Covered Countries
15 (18%)
6 (16%)
0 (0%)
49 (34%)
70 (23%)
Number (%) of smelters that are conformant, active, or not sourced from the Covered Countries
85 (100%)
38 (100%)
36 (100%)
140 (98%)
299 (99%)

Efforts to Determine Mine or Location of Origin
                    
As part of our due diligence process described in Section 3 of this report, we worked to ensure that our efforts to identify mines and the countries of origin of the 3TG in our products have been reasonable and aligned with industry practices through our support of processes and tools developed by the RMI.

5.Continuous Improvement in Understanding Source of Material
                    
We recognize that efforts to reduce violence associated with conflict minerals are ongoing and are required to continually adapt to changing situations. We are committed to reviewing our compliance processes and actively engaging upstream directly in-region for opportunities to improve our processes.

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We include more detail on our policies and our results in our Supplier Responsibility Report, including work in other minerals and materials and in other regions that are not in scope of the Rules.

We will continue to review our compliance processes including, but not limited to, taking the following steps for the 2024 reporting year:
                    
We will continue to engage with in-scope suppliers to gain better visibility of the country of origin and chain of custody of the 3TG used in our in-scope products.
We will use and encourage our in-scope suppliers to use publicly available tools from the RMI.
We will continue to work with our in-scope suppliers and engage with our supply chain to increase the quality of the data provided to us.
We will continue to be a member of the RMI, and contribute to the various initiatives and working groups, as described above.
We will continue to encourage our in-scope suppliers to source from conflict-free smelters that are listed as conformant by the RMI.
As we enter into contracts with new suppliers and renew contracts with existing suppliers, we will continue to include requirements that our suppliers support our conflict minerals policy and due diligence efforts.
We will continue to explore additional opportunities to support livelihoods and health, improve conservation outcomes, improve stability, and support renewable energy projects to enhance conflict-free mining communities.    

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Appendix I: Smelter List
Metal
Smelter Name
Smelter Location Country
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Agosi AG
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S
TURKEY
Gold
Aurubis AG
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden Ronnskar
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
GoldCaridadMEXICO
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Dowa
JAPAN
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
GoldHeraeus Germany GmbH Co. KGGERMANY
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
HwaSeong CJ CO., LTD.KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
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Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
LS MnM Inc
KOREA, REPUBLIC OF
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEY
GoldNavoi Mining and Metallurgical CombinatUZBEKISTAN
GoldNihon Material Co., Ltd.JAPAN
GoldOhura Precious Metal Industry Co., Ltd.JAPAN
GoldMKS PAMP SASWITZERLAND
GoldPenglai Penggang Gold Industry Co., Ltd.CHINA
GoldPT Aneka Tambang (Persero) TbkINDONESIA
GoldPX Precinox S.A.SWITZERLAND
GoldRand Refinery (Pty) Ltd.SOUTH AFRICA
GoldRoyal Canadian MintCANADA
GoldSabin Metal Corp.UNITED STATES OF AMERICA
GoldSamduck Precious MetalsKOREA, REPUBLIC OF
GoldSamwon Metals Corp.KOREA, REPUBLIC OF
GoldSEMPSA Joyeria Plateria S.A.SPAIN
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINA
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINA
GoldSichuan Tianze Precious Metals Co., Ltd.CHINA
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINA
GoldSumitomo Metal Mining Co., Ltd.JAPAN
GoldSuper Dragon Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
GoldTanaka Kikinzoku Kogyo K.K.JAPAN
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINA
GoldShandong Gold Smelting Co., Ltd.CHINA
GoldTokuriki Honten Co., Ltd.JAPAN
GoldTongling Nonferrous Metals Group Co., Ltd.CHINA
GoldTorecomKOREA, REPUBLIC OF
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUM
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICA
9


GoldValcambi S.A.SWITZERLAND
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIA
GoldYamakin Co., Ltd.JAPAN
GoldYokohama Metal Co., Ltd.JAPAN
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINA
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINA
GoldMorris and WatsonNEW ZEALAND
GoldSAFINA A.S.CZECHIA
GoldGuangdong Jinding Gold LimitedCHINA
GoldUmicore Precious Metals ThailandTHAILAND
GoldMMTC-PAMP India Pvt., Ltd.INDIA
GoldKGHM Polska Miedz Spolka AkcyjnaPOLAND
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
GoldShandong Humon Smelting Co., Ltd.CHINA
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINA
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATES
GoldEmirates Gold DMCCUNITED ARAB EMIRATES
GoldT.C.A S.p.AITALY
GoldREMONDIS PMR B.V.NETHERLANDS
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OF
GoldTOO Tau-Ken-AltynKAZAKHSTAN
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICA
GoldSAAMPFRANCE
GoldL'Orfebre S.A.ANDORRA
Gold8853 S.p.A.ITALY
GoldItalpreziosiITALY
GoldWIELAND Edelmetalle GmbHGERMANY
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIA
GoldAU Traders and RefinersSOUTH AFRICA
GoldGGC Gujrat Gold Centre Pvt. Ltd.INDIA
GoldSai RefineryINDIA
GoldModeltech Sdn BhdMALAYSIA
GoldBangalore RefineryINDIA
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANY
GoldPease & CurrenUNITED STATES OF AMERICA
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OF
GoldPlanta Recuperadora de Metales SpACHILE
GoldSafimet S.p.AITALY
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIA
GoldNH Recytech CompanyKOREA, REPUBLIC OF
GoldQG Refining, LLCUNITED STATES OF AMERICA
GoldCGR Metalloys Pvt Ltd.INDIA
GoldSovereign MetalsINDIA
GoldEco-System Recycling Co., Ltd. North PlantJAPAN
10


GoldEco-System Recycling Co., Ltd. West PlantJAPAN
GoldAugmont Enterprises Private LimitedINDIA
GoldEmerald Jewel Industry India Limited (Unit 1)INDIA
GoldEmerald Jewel Industry India Limited (Unit 2)INDIA
GoldEmerald Jewel Industry India Limited (Unit 3)INDIA
GoldEmerald Jewel Industry India Limited (Unit 4)INDIA
GoldK.A. RasmussenNORWAY
GoldAlexy MetalsUNITED STATES OF AMERICA
GoldMD OverseasINDIA
GoldMetallix Refining Inc.UNITED STATES OF AMERICA
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICA
GoldWEEEREFININGFRANCE
GoldGold by Gold ColombiaCOLOMBIA
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINA
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.CHINA
TantalumF&X Electro-Materials Ltd.CHINA
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCHINA
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINA
TantalumJiujiang Tanbre Co., Ltd.CHINA
TantalumAMG BrasilBRAZIL
TantalumMetallurgical Products India Pvt., Ltd.INDIA
TantalumMineracao Taboca S.A.BRAZIL
TantalumMitsui Mining and Smelting Co., Ltd.JAPAN
TantalumNPM Silmet ASESTONIA
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINA
TantalumQuantumCleanUNITED STATES OF AMERICA
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINA
TantalumTaki Chemical Co., Ltd.JAPAN
TantalumTelex MetalsUNITED STATES OF AMERICA
TantalumUlba Metallurgical Plant JSCKAZAKHSTAN
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINA
TantalumD Block Metals, LLCUNITED STATES OF AMERICA
TantalumFIR Metals & Resource Ltd.CHINA
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINA
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINA
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINA
TantalumKEMET de MexicoMEXICO
TantalumTANIOBIS Co., Ltd.THAILAND
TantalumTANIOBIS GmbHGERMANY
TantalumQSIL Metals Hermsdorf GmbHGERMANY
TantalumMaterion Newton Inc.UNITED STATES OF AMERICA
TantalumTANIOBIS Japan Co., Ltd.JAPAN
TantalumTANIOBIS Smelting GmbH & Co. KGGERMANY
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICA
TantalumGlobal Advanced Metals AizuJAPAN
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TantalumResind Industria e Comercio Ltda.BRAZIL
TantalumJiangxi Tuohong New Raw MaterialCHINA
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.CHINA
TantalumPowerX Ltd.RWANDA
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINA
TinAlphaUNITED STATES OF AMERICA
TinPT Aries Kencana SejahteraINDONESIA
TinPT Premium Tin IndonesiaINDONESIA
TinDowaJAPAN
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)
TinEstanho de Rondonia S.A.BRAZIL
TinFenix MetalsPOLAND
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINA
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINA
TinGejiu Kai Meng Industry and Trade LLCCHINA
TinChina Tin Group Co., Ltd.CHINA
TinMalaysia Smelting Corporation (MSC)MALAYSIA
TinMetallic Resources, Inc.UNITED STATES OF AMERICA
TinMineracao Taboca S.A.BRAZIL
TinMinsurPERU
TinMitsubishi Materials CorporationJAPAN
TinJiangxi New Nanshan Technology Ltd.CHINA
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILAND
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)
TinPT Artha Cipta LanggengINDONESIA
TinPT Babel Inti PerkasaINDONESIA
TinPT Babel Surya Alam LestariINDONESIA
TinPT Bangka Tin IndustryINDONESIA
TinPT Belitung Industri SejahteraINDONESIA
TinPT Bukit TimahINDONESIA
TinPT Mitra Stania PrimaINDONESIA
TinPT Panca Mega PersadaINDONESIA
TinPT Prima Timah UtamaINDONESIA
TinPT Refined Bangka TinINDONESIA
TinPT Sariwiguna BinasentosaINDONESIA
TinPT Stanindo Inti PerkasaINDONESIA
TinPT Timah Tbk KundurINDONESIA
TinPT Timah Tbk MentokINDONESIA
TinPT Timah NusantaraINDONESIA
TinPT Tinindo Inter NusaINDONESIA
TinPT Tommy UtamaINDONESIA
TinRui Da HungTAIWAN, PROVINCE OF CHINA
TinSoft Metais Ltda.BRAZIL
TinThaisarcoTHAILAND
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TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINA
TinVQB Mineral and Trading Group JSCVIET NAM
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZIL
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINA
TinTin Smelting Branch of Yunnan Tin Co., Ltd.CHINA
TinCV Venus Inti PerkasaINDONESIA
TinMagnu's Minerais Metais e Ligas Ltda.BRAZIL
TinPT Tirus Putra MandiriINDONESIA
TinMelt Metais e Ligas S.A.BRAZIL
TinPT ATD Makmur Mandiri JayaINDONESIA
TinO.M. Manufacturing Philippines, Inc.PHILIPPINES
TinCV Ayi JayaINDONESIA
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAM
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAM
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAM
TinPT Rajehan AriqINDONESIA
TinPT Cipta Persada MuliaINDONESIA
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAM
TinResind Industria e Comercio Ltda.BRAZIL
TinSuper LigasBRAZIL
TinAurubis BeerseBELGIUM
TinAurubis BerangoSPAIN
TinPT Bangka Prima TinINDONESIA
TinPT Sukses Inti Makmur (SIM)INDONESIA
TinPT Menara Cipta MuliaINDONESIA
TinHuiChang Hill Tin Industry Co., Ltd.CHINA
TinModeltech Sdn BhdMALAYSIA
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINA
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINA
TinPT Bangka SerumpunINDONESIA
TinTin Technology & RefiningUNITED STATES OF AMERICA
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINA
TinMa'anshan Weitai Tin Co., Ltd.CHINA
TinPT Rajawali Rimba PerkasaINDONESIA
TinLuna Smelter, Ltd.RWANDA
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINA
TinPrecious Minerals and Smelting LimitedINDIA
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINA
TinPT Mitra Sukses GlobalindoINDONESIA
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZIL
TinCRM SynergiesSPAIN
TinFabrica Auricchio Industria e Comercio Ltda.BRAZIL
TinDS MyanmarMYANMAR
TinPT Putera Sarana Shakti (PT PSS)INDONESIA
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TinMining Minerals Resources SARLCONGO, DEMOCRATIC REPUBLIC OF THE
TungstenA.L.M.T. Corp.JAPAN
TungstenKennametal HuntsvilleUNITED STATES OF AMERICA
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINA
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINA
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINA
TungstenGlobal Tungsten & Powders LLCUNITED STATES OF AMERICA
TungstenHunan Chenzhou Mining Co., Ltd.CHINA
TungstenHunan Jintai New Material Co., Ltd.CHINA
TungstenJapan New Metals Co., Ltd.JAPAN
TungstenKennametal FallonUNITED STATES OF AMERICA
TungstenWolfram Bergbau und Hutten AGAUSTRIA
TungstenXiamen Tungsten Co., Ltd.CHINA
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINA
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINA
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINA
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINA
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINA
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINA
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINA
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINA
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINA
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAM
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchCHINA
TungstenH.C. Starck Tungsten GmbHGERMANY
TungstenTANIOBIS Smelting GmbH & Co. KGGERMANY
TungstenMasan High-Tech MaterialsVIET NAM
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINA
TungstenNiagara Refining LLCUNITED STATES OF AMERICA
TungstenChina Molybdenum Tungsten Co., Ltd.CHINA
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINES
TungstenACL Metais EireliBRAZIL
TungstenMoliren Ltd.RUSSIAN FEDERATION
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINA
TungstenHubei Green Tungsten Co., Ltd.CHINA
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZIL
TungstenCronimet Brasil LtdaBRAZIL
TungstenFujian Xinlu Tungsten Co., Ltd.CHINA
TungstenTungsten Vietnam Joint Stock Company
VIET NAM
The RMI does not provide a specific country of origin of the conflict minerals processed by conformant smelters. Due to business confidentiality reasons, the country of origin data is provided in an aggregated way based on country risk level. Thus, we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed conformant smelters. The list is the possible countries the material may have come from and references the plausible list of mineral mine production by country (RMI report published March 2020, Mineral Mine Production Country”). The list is based on
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the country of origin data provided by the RMI for RMAP LBMA, and RJC conformant smelters only. To supplement this list, Google conducts independent due diligence into all identified smelters. On a continuous basis, Google requests its suppliers to cease doing business with non-conformant smelters and notifies suppliers that non-conformant smelters are no longer approved to be in Google's supply chain.

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