0001206774-21-001526.txt : 20210528 0001206774-21-001526.hdr.sgml : 20210528 20210528090030 ACCESSION NUMBER: 0001206774-21-001526 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20201231 1.02 20201231 FILED AS OF DATE: 20210528 DATE AS OF CHANGE: 20210528 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CORNING INC /NY CENTRAL INDEX KEY: 0000024741 STANDARD INDUSTRIAL CLASSIFICATION: DRAWING AND INSULATING NONFERROUS WIRE [3357] IRS NUMBER: 160393470 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-03247 FILM NUMBER: 21976464 BUSINESS ADDRESS: STREET 1: ONE RIVERFRONT PLAZA CITY: CORNING STATE: NY ZIP: 14831 BUSINESS PHONE: 6079749000 MAIL ADDRESS: STREET 1: ONE RIVERFRONT PLAZA CITY: CORNING STATE: NY ZIP: 14831 FORMER COMPANY: FORMER CONFORMED NAME: CORNING GLASS WORKS DATE OF NAME CHANGE: 19890512 SD 1 corning3913291-sd.htm SPECIALIZED DISCLOSURE REPORT

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure report

CORNING INCORPORATED
(Exact Name of Registrant as Specified in Charter)

New York
(State or Other Jurisdiction
of incorporation)
1-3247
(Commission File No.)
16-0393470
(I.R.S. Employer
Identification Number)
 
One Riverfront Plaza, Corning New York
(Address of Principal Executive Offices)
14831
(Zip Code)
 
Daniel P. Christmas (607) 974-9000
 
(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

Item 1.01 Conflict Minerals Disclosure and Report

Corning Incorporated evaluated its current product lines and determined that certain products we manufacture or contract to manufacture contain tin, tantalum, tungsten and/or gold (3TG). The results of our reasonable country of origin inquiry and due diligence are contained in the Conflict Minerals Report filed herewith.

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available on the Investor Relations page of Corning’s website (see http://www.corning.com/investor_relations/index.aspx and click on “View All Filings”).

Item 1.02 Exhibit

As specified in Section 2, Item 2.01, Corning Incorporated is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report

Exhibit Number       Description
1.01 Conflict Minerals Report of Corning Incorporated.


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.

CORNING INCORPORATED

By:  /s/ Eric S. Musser           May 28, 2021
Eric S. Musser
President & Chief Operating Officer
(Date)


EX-1.01 2 corning3913291-ex101.htm CONFLICT MINERALS REPORT OF CORNING INCORPORATED

Exhibit 1.01

Corning Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2020

This Conflict Minerals Report (CMR) for the year ended December 31, 2020 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (3TG).

This report is available on the Investor Relations page of Corning’s website (see http://www.corning.com/investor_relations/index.aspx and click on “View All Filings”).

1. Company Overview
          

This report has been prepared by management of Corning Incorporated (herein referred to as “Corning,” 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 in accordance with US Generally Accepted Accounting Principles. It does not include the activities of subsidiaries or variable interest entities that are not required to be consolidated.

Corning is a world leader in the manufacture of specialty glass and ceramics. Drawing on nearly 170 years of materials science and process engineering knowledge, Corning creates and makes keystone components that enable high-technology systems for consumer electronics, mobile emissions control, telecommunications and life sciences. Corning operates in five reportable segments: Display Technologies, Optical Communications, Environmental Technologies, Specialty Materials and Life Sciences. Corning manufactures products at 122 plants in 15 countries.

2. Products Overview
          

Corning’s principal products, by segment, are as follows:

Corning’s Display Technologies segment manufactures glass substrates for flat panel displays, including liquid crystal displays (LCDs) and organic light-emitting diode (OLEDs) that are used primarily in televisions, notebook computers, desktop monitors, tablets and handheld devices.

Corning’s Optical Communications segment is classified into two main product groupings – carrier network and enterprise network. The carrier network product group consists primarily of products and solutions for optical-based communications infrastructure for services such as video, data and voice communications. The enterprise network product group consists primarily of optical-based communication networks sold to businesses, governments and individuals for their own use.

Corning’s Environmental Technologies segment manufactures ceramic substrates and filter products for emissions control in mobile applications around the world.

The Specialty Materials segment manufactures products that provide more than 150 material formulations for glass, glass ceramics and crystals, as well as precision metrology instruments and software to meet requirements for unique customer needs. Consequently, this segment operates in a wide variety of commercial and industrial markets that include materials optimized for mobile consumer electronics, semiconductor equipment optics and consumables, aerospace and defense optics, radiation shielding products, sunglasses, and telecommunications components.


Corning’s Life Sciences segment is a leading developer, manufacturer and global supplier of laboratory products, including consumables, such as plastic vessels, liquid handling plastics, specialty surfaces, cell culture media and serum, as well as general labware and equipment.

All other segments at Corning that do not meet the quantitative threshold for separate reporting have been grouped as “All Other.” This group is primarily comprised of the results of the pharmaceutical technologies business, auto glass, new product lines and development projects, as well as other businesses and certain corporate investments. The Company obtained a controlling interest in Hemlock Semiconductor Group (“HSG”) during the third quarter of 2020 and has consolidated results in “All Other” as of September 9, 2020.

3. Supply Chain Overview
          

Corning maintains complex and diverse supply chains across its reported segments, involving thousands of suppliers to the Company. We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three years or more and we cannot unilaterally impose new contract terms and flow-down requirements. Corning has incorporated a clause to relevant agreements that requires suppliers to provide information about the source of conflict minerals and smelters. Based upon these contractual requirements and our supplier relationships, we work annually with selected suppliers to ensure they provide us the 3TG sourcing information required.

Based upon technical knowledge regarding our products, as well as the results of the prior supplier surveys regarding conflict minerals, relevant personnel in each of our reported segments identified the suppliers to survey regarding whether the components or materials supplied to Corning by such suppliers contain 3TG. We relied upon these suppliers, approximately 163 in total, to provide us with information about whether the components or materials supplied to Corning contain 3TG; and if so, the source of such 3TG. Our direct suppliers are similarly reliant upon information provided by their suppliers, or in the case of distributors from whom we purchase components or materials, reliant upon the manufacturers of such items. Many of our larger suppliers are also SEC registrants and subject to the Rule.

4. Reasonable Country of Origin Inquiry (RCOI) and RCOI Conclusion
            
  4.1 Requests for Information
              
We surveyed those suppliers described above using version 6.01 of the conflict minerals reporting template developed by the Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Responsible Minerals Initiative (“RMI”) Reporting Template (or the “CMRT”). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on Responsible Business Alliance’s website. The CMRT is being used by many companies in their due diligence processes related to 3TG.
 
To determine whether any 3TG necessary to our products originated in the Covered Countries, we retained a third-party service provider, Assent Compliance (“Assent”) to assist us in surveying our supply chain. During our supplier survey, we contacted suppliers via the Assent Compliance Manager (“ACM”), a SaaS platform provided by Assent that enables its users to complete and track supplier communications as well as allows suppliers to upload completed CMRTs directly to the platform for assessment and management. The use of the CMRT allowed for some elimination of irrelevant suppliers. Specifically, question one of the CMRT asks suppliers whether any 3TGs are necessary to the functionality or production of their products. We also reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process (e.g., the removal of suppliers who provided only packaging to Corning).
 
Assent requested that all in-scope suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of the template. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Corning directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that such suppliers complete and submit the CMRT to Assent.



4.2 Survey Responses
                     

Where the CMRT responses included the names of entities listed by our suppliers as smelters or refiners, we consulted the RMI publicly-available information to determine whether such entities had been identified as certified Conflict-Free. In some cases, the CMRT responses did not provide smelter information; this was one of the items that we typically requested in follow-up communications with suppliers. Ultimately, some suppliers were unable to provide us with smelter information because they were engaged in their own efforts to obtain that information from their suppliers.

Through Assent’s platform automated data validation was performed 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 logical sequencing and required correlations between the CMRT questions (for example, if a supplier does not report having received information from 100% of its 3TG sources, it cannot logically offer definitive statements in response to certain other questions).

All submitted CMRTs are first accepted and then classified as valid or invalid so that their data is still retained. Suppliers are contacted in regard to invalid forms and are encouraged to resubmit a valid form. As of May 10, 2021, there were four (4) invalid supplier submissions in Corning’s supplier survey that could not be corrected.

Many of the responses we received provided data at a company or divisional level or, as described above, were unable to specify with certainty all of the smelters or refiners used for components supplied to Corning. In some instances, we engaged in follow-up communications with suppliers to request that they provide a CMRT response specific to the components or materials supplied to Corning; however, in many cases, the suppliers were unable to do so because they were unable to obtain detailed information from their own suppliers.

   
4.3 RCOI Conclusion
     

Based upon the results of our RCOI, we were able to determine that no 3TGs are contained in the products sold by Corning’s Environmental Technologies segment. In Corning’s Display Technologies segment, our RCOI determined that tin contained in the products sold by this segment is sourced from the Covered Countries, but only from RMI compliant smelters. For Corning’s Optical Communications, Specialty Materials, and Life Sciences segments, we were unable to conclusively determine whether the 3TG in the products for such segments originated in the Covered Countries because of the incomplete information received from our supply chain.

Based on RCOI responses we have received from certain suppliers, we believe that certain of the 3TG contained in the products for our Optical Communications, Specialty Materials, and/or Life Sciences segments may have originated in the Democratic Republic of the Congo or an adjoining country (the Covered Countries). Thus, we are required under the Rule to conduct due diligence on the source and chain of custody of those minerals as well as those in the supply chain for our Display Technologies segment and submit to the SEC a Conflict Minerals Report as an Exhibit to Form SD.

 

5.

Due Diligence Program

 

5.1

Design of Due Diligence

 

Our due diligence measures have been designed to conform, in all material respects, with the framework in 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, Second Edition, 2013 (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:


                   1. Establishing strong company management systems regarding conflict minerals;



                   2. Identifying and assessing risks in our supply chain;
3. Designing and implementing a strategy to respond to identified risks in our supply chain;
4. Utilizing independent third-party audits of supply chain diligence; and
5. Publicly reporting on our supply chain due diligence

 

We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, we do not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries directly. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

 
5.2 Establish Strong Company Management Systems
                     
                      5.2.1 Conflict Minerals Policy
          

We have adopted the following revised conflict minerals policy, effective March 2019:

Background on Conflict Minerals

Conflict minerals refer to the mineral precursors of the metals tantalum, tin, tungsten, and gold (3TG), which are found in small amounts in virtually all electronic products. Revenue from mining these minerals in the Democratic Republic of Congo (DRC) and nine neighboring countries has been linked to funding for groups engaged in extreme violence and human rights atrocities.

Pursuant to the Dodd–Frank Wall Street Reform and Consumer Protection Act, public companies in the US that make products for which 3TG metals (tantalum, tin, tungsten & gold) are necessary to the functionality or production of that product are required to assess their supply chains and report on the source of these materials. Corning Incorporated (“Corning”) is a public company, and therefore is committed to complying with this law.

Corning Incorporated’s Corporate Position on Conflict Minerals

At Corning, corporate social responsibility is a proactive commitment to preserving the trust of our stakeholders. The commitment contributes to sustainable economic and environmental development through all our business activities – how we operate, what we sell, how we give, and how we support our people, the communities in which we operate, and society at large. Any connection between the materials used in Corning products and armed violence or human rights abuses is unacceptable.

Corporate social responsibility is intrinsic to Corning’s heritage and it is integral to how we build value and trust in our company. It is also a demonstration of how we live our Values which represent the unchanging moral and ethical compass that guides everything we do. More information about Sustainability at Corning can be found here.

The 3TG supply chain is complex, typically including many stages between Corning and the smelters that purchase and process the ore into metals. The greatest risk of conflict minerals entering our supply chain is through these smelters’ ore purchasing practices. We require our suppliers to source 3TG for Corning products only from smelters that comply with the Responsible Minerals Initiative 's (RMI, formerly the Conflict Free Sourcing Initiative) Responsible Minerals Assurance Process (RMAP, formerly the Conflict-Free Smelter Program), which requires a third-party sourcing audit. To monitor 3TG suppliers’ performance, we assess their responses to the RMI’s Conflict Minerals Reporting Template, and request corrective action where needed, including the removal from our supply chain of smelters that pose a risk.




                     

More information about the Responsible Minerals Initiative can be found here. Our due diligence measures implemented as part of our conflict minerals program have been designed to conform, in all material respects, with the framework in 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.

Corning requires our suppliers to comply with our requests to provide complete and accurate Conflict Minerals Reporting Templates, and to perform further due diligence as required about the source of any conflict minerals in their products which are provided to us in order to ensure alignment throughout the supply chain. Failure to provide this information to Corning when requested may result in removal from active status as a Corning supplier.

Our conflict minerals policy is publicly available on our website at the following link:
http://www.corning.com/worldwide/en/sustainability/processes/supply-chain-social-responsibility/social/conflict-minerals-policy.html.

 
                      5.2.2 Internal Team
          

Corning has established a cross-functional Conflict Minerals Compliance Team for managing our conflict minerals program. Our Conflict Minerals Compliance Team includes a steering team sponsored by the Senior Vice President, Global Supply Chain as well as executive-level representatives from the company’s finance and legal functions. Reporting to the steering team is a core working team, which is led by our Global Supply Management organization. This core team, which includes subject matter experts from relevant functions such as finance, legal, and global supply management, is responsible for implementing our conflict minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on an annual basis. Corning also uses a third-party service provider, Assent, to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers regarding conflict minerals.

Corning leverages Assent’s Managed Services in order to work with dedicated program specialists who support Corning’s conflict minerals program. Corning communicates regularly with the Assent team in order 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 the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.

     
                      5.2.3 Control Systems
                                                                                                                                     

As we do not typically have a direct relationship with 3TG smelters and refiners, we have relied upon industry-wide initiatives to disclose upstream actors in the supply chain. Specifically, as part of our due diligence efforts we have utilized the smelter information provided by the Responsible Minerals Initiative.

In addition, with the assistance of personnel from Corning’s accounting, compliance and reporting function, we previously developed a detailed risk control matrix through which Corning’s conflict minerals program can be evaluated and monitored.

     
                      5.2.4 Supplier Engagement
          

With respect to the OECD requirement to strengthen engagement with suppliers, we have added a conflict minerals clause to our purchase order terms and conditions and relevant contract templates in order to communicate to suppliers our expectations and requirements regarding the sourcing of and disclosure of conflict minerals. We also include our Supplier Code of Conduct in our supplier contracts, which contains Corning’s expectations for suppliers with respect to humane labor conditions, health and safety, and environmental factors, among others. Further, Corning’s suppliers are required to flow down these expectations from Corning’s Supplier Code of Conduct to their own supply chains.




                     

A copy of our Supplier Code of Conduct is available at http://www.corning.com/worldwide/en/sustainability/articles/processes/supply-chain-management/supplier-code-of-conduct.html.

       
                      5.2.5 Grievance Mechanism
                
                     

Corning’s Supplier Code of Conduct, referenced in 5.2.4 above, instructs suppliers that questions or concerns may be submitted to Corning’s third-party telephone and web hotline service. This hotline is also described in Corning’s Code of Conduct, as referenced above. These phone or web services can be used to make an anonymous report and are available on a 24/7 basis. Corning maintains a robust internal compliance and ethics program under the oversight of a Vice President and Chief Compliance Officer to ensure that all such reports are properly investigated, reported and remediated as required.

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/.

       
                      5.2.6 Maintain Records
       

Corning has an existing document retention policy which governs the retention of documentation relevant to our due diligence efforts. We also implemented a document retention policy through Assent to retain conflict minerals related documents, including supplier responses to CMRTs. Assent stores all of the information and findings from this process in a database that can be audited by internal or external parties.

          
           5.3 Identify and Assess Risks in the Supply Chain
                                       
 

Because of our size, the complexity of our products, and the depth and breadth of our supply chain, it is difficult to identify actors upstream from our direct suppliers. One method for identifying risks in our supply chain is through automatic checks in the ACM system based on criteria established by Assent for supplier responses as outlined above. Another method Corning uses specifically for minerals supply chain risk management is an internal risk mapping of all mineral suppliers to Corning based on four criteria (supplier reputation, material risk, country risk, and sustainability compliance). More generally, Corning monitors risk across all of its suppliers using a third-party tool, riskmethods, and its standard set of 49 risk indicators.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters or refiners not being certified DRC-Conflict Free pose a significant risk to the supply chain. Certain of the responses provided by our suppliers via the CMRT included the names of facilities listed by the suppliers as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by RMI. As of May 10, 2021, of the 333 legitimate smelters and refiners identified by our suppliers, we have validated 237 smelters or refiners as Responsible Minerals Assurance Process (“RMAP”) conformant. Due to the provision of a mix of company-level, product-level and user defined CMRTs, we cannot definitively determine the connection of any smelters or refiners listed in them to our in-scope products.

Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent determines the level of risk that each smelter poses to the supply chain by identifying the following red flags:

   
Geographic proximity to the DRC and Covered Countries;
Responsible Minerals Assurance Process (RMAP) audit status;
Credible evidence of unethical or conflict sourcing;
Known mineral source country of origin; and
Peer Assessments conducted by credible third-party sources.


          

Based on these criteria the following facilities have been identified as being of highest concern to the supply chain:


Tony Goetz NV - CID002587
Kaloti Precious Metals - CID002563
African Gold Refinery Limited - CID003185
Fidelity Printers and Refiners Ltd. - CID002515
Sudan Gold Refinery - CID002567

As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers we surveyed, risk mitigation activities were initiated. Through our third-party vendor, Assent Compliance, submissions that included any of the above facilities immediately produced a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Corning, and escalating up to removal of these high-risk smelters from their supply chain.

As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

A. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?

When suppliers meet or exceed those criteria (Yes to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. At this time, eight (8) of our responsive suppliers have been identified as having a weak program.

 
5.4 Design and Implement a Strategy to Respond to Risks
                     

Corning has developed processes to assess and respond to the risks identified in the supply chain. Corning has a responsible minerals sourcing program through which its 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 Corning’s expectations.

As described in our conflict minerals policy, we intend to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to appropriately address the situation, which may include establishing an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. The result and timing will depend upon factors such as the criticality of the specific part and the availability of alternate suppliers.

In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, Corning will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Compliance Team and the leadership of Corning’s Global Supply Management function to ensure transparency within the company.




As of the date of this filing, we have found no instances where it was necessary to terminate a contract or find a replacement supplier due to 3TG sourced from the Covered Countries.

 
5.5

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

                     

Corning does not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities within our supply chain. However, we do rely on third-party audits of smelters and refiners conducted as part of the RMAP. The 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 and refiners that agree to participate in the program.

In early 2020, Corning became a member of the Responsible Minerals Initiative, enabling us to expand our industry collaborative efforts through RMI membership and to utilize RMI’s flagship Responsible Minerals Assurance Process (RMAP) through our supply chain as described above.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. Corning is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.

Through the company’s membership with the RMI, smelters or refiners have been encouraged to participate in the RMAP. Any smelters or refiners that were reported by suppliers who were not part of the RMAP were also contacted directly by Assent to encourage them to participate in the RMAP.

 
5.6 Report on Supply Chain Due Diligence
 

In addition to this report, see our website at http://www.corning.com/worldwide/en/about-us/suppliers.html for further information about Corning’s commercial relationships with and expectations of its suppliers.

              
5.6.1

Due Diligence Process

 

Corning conducted a survey of its relevant suppliers (as described above) using the template originally developed jointly by the Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Responsible Minerals Initiative Reporting Template (the “CMRT”). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on RMI’s website and via the website of Assent Compliance, our third-party provider.

 
5.6.2

Survey Responses

 

Corning surveyed approximately 163 suppliers based upon the likelihood that such suppliers supplied materials or components to Corning that contained one or more 3TG, and we received responses from 99% of the suppliers we surveyed. Corning’s response rate for 2020 was approximately 24% higher than the previous year. A total of six (6) suppliers indicated in their survey responses that they sourced 3TG from the Covered Countries, but those 3TG were “conflict free.” Nineteen (19) of the suppliers surveyed stated that the 3TG they sourced came from outside of the Covered Countries, and 22 suppliers reported as “undeterminable” in regard to sourcing 3TGs from the Covered Countries.

 
5.6.3

Efforts to Determine Country of Origin of Mine or 3TG

                                                                                                                                                       

We have determined that seeking information about 3TG smelters and refiners in our supply chain through the use of the CMRT with our relevant suppliers represents the most reasonable effort we are able to make to determine the mines or locations of origin of the 3TG in our supply chain.




5.6.4

Efforts to Identify Smelters or Refiners

                                

Because of the incomplete information provided to us by our suppliers in response to our surveys, or the receipt of company-level responses that do not provide information specific to materials or components supplied to Corning, in many cases the smelters and refiners we have identified to date cannot be tied to specific Corning products. However, in certain instances, our suppliers did provide CMRTs specific to the products supplied to Corning. We have reported all legitimate smelter or refiner information included in the CMRTs we received on Appendix A to this report, recognizing as stated above that not all such smelters or refiners can definitively be tied to Corning products. Of the 333 legitimate smelters identified on the CMRTs we received, as of May 10, 2021 237 were identified as RMAP Conformant and 23 were actively working toward a “conflict free” designation. As noted, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that processed the conflict minerals actually contained in our products.

 
5.6.5

Countries of Origin

 

Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI. As mentioned in the above section, many responses were provided at the company level, therefore, Appendix B may contain more countries than those that the conflict minerals used in our products are sourced from.

 
6.

Steps to be taken to mitigate risk

 

We have taken and/or intend to continue to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:

 
                      A.

Include a conflict minerals flow-down clause in relevant new or renewed supplier contracts.

 
B.

Include a step to our new supplier enrollment process to directly identify new suppliers who could potentially supply Corning with products or materials containing 3TG.

 
C.

Partner with a third-party company, Assent Compliance, which specializes in conducting conflict minerals compliance programs, to improve the accuracy and efficiency of our supplier survey and reporting process.

 
D.

Engage with suppliers to attempt to increase the response rate and improve the content of the supplier survey responses.

 
E.

Engage any of our suppliers found to be supplying us with 3TG from sources that support conflict in the DRC or any adjoining country to address the situation, which will include establishing an alternative source of 3TG that does not support such conflict, with timing depending on factors such as the criticality of the specific part and the availability of alternate suppliers.

 
F.

Maintain Corning’s membership in the Responsible Minerals Initiative, enabling us to expand our industry collaborative efforts through RMI membership and to utilize RMI’s flagship Responsible Minerals Assurance Process (RMAP) through our supply chain.



FORWARD-LOOKING STATEMENTS

The statements in this Form SD and related comments by management that are not historical facts or information and contain words such as “will,” “believe,” “anticipate,” “expect,” “intend,” “plan,” “seek,” “see,” “would,” and “target” and similar expressions are forward-looking statements. Such statements relate to future events that by their nature address matters that are, to different degrees, uncertain. These forward-looking statements relate to, among other things, the company’s future operating performance, the company's share of new and existing markets, the company's revenue and earnings growth rates, the company’s ability to innovate and commercialize new products, and the company’s implementation of cost-reduction initiatives and measures to improve pricing, including the optimization of the company’s manufacturing capacity.


Appendix A

RMI Smelter List1

Metal Standard Smelter Name Smelter Facility Location Smelter ID RMAP Status Conflict Free? Source from DRC?
Gold 8853 S.p.A. ITALY CID002763 Conformant Yes Unknown
Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA CID002708 Non Conformant Unknown Unknown
Gold Advanced Chemical Company UNITED STATES OF AMERICA CID000015 Conformant Yes No
Gold African Gold Refinery UGANDA CID003185 Outreach Required Unknown Unknown
Gold Aida Chemical Industries Co., Ltd. JAPAN CID000019 Conformant Yes No
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES CID002560 Conformant Yes Yes
Gold Alexy Metals UNITED STATES OF AMERICA CID003500 Active Unknown Unknown
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY CID000035 Conformant Yes Unknown
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN CID000041 Conformant Yes Unknown
Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL CID000058 Conformant Yes Unknown
Gold Argor-Heraeus S.A. SWITZERLAND CID000077 Conformant Yes Unknown
Gold Asahi Pretec Corp. JAPAN CID000082 Conformant Yes Unknown
Gold Asahi Refining Canada Ltd. CANADA CID000924 Conformant Yes Unknown
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA CID000920 Conformant Yes Unknown
Gold Asaka Riken Co., Ltd. JAPAN CID000090 Conformant Yes No
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY CID000103 Due Diligence Vetting Process Unknown Unknown
Gold AU Traders and Refiners SOUTH AFRICA CID002850 Conformant Yes Unknown
Gold Augmont Enterprises Private Limited INDIA CID003461 Active Unknown Unknown
Gold Aurubis AG GERMANY CID000113 Conformant Yes Unknown
Gold Bangalore Refinery INDIA CID002863 Conformant Yes No
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128 Conformant Yes Unknown
Gold Boliden AB SWEDEN CID000157 Conformant Yes Unknown
____________________

1 This Exhibit contains all legitimate smelter or refiner information we received on the CMRTs provided by our suppliers in response to our survey requests.  Because these CMRTs in some instances contained incomplete information, or were not specific to the products supplied to Corning, many of these smelters and refiners cannot be tied to specific Corning products.   



Metal Standard Smelter Name Smelter Facility Location Smelter ID RMAP Status Conflict Free? Source from DRC?
Gold C. Hafner GmbH + Co. KG GERMANY CID000176 Conformant Yes Unknown
Gold C.I Metales Procesados Industriales SAS COLOMBIA CID003421 Active Unknown Unknown
Gold Caridad MEXICO CID000180 Communication Suspended - Not Interested Unknown Unknown
Gold CCR Refinery - Glencore Canada Corporation CANADA CID000185 Conformant Yes Unknown
Gold Cendres + Metaux S.A. SWITZERLAND CID000189 Conformant Yes Unknown
Gold CGR Metalloys Pvt Ltd. INDIA CID003382 Outreach Required Unknown Unknown
Gold Chimet S.p.A. ITALY CID000233 Conformant Yes Unknown
Gold Chugai Mining JAPAN CID000264 Conformant Yes No
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA CID000343 In Communication Unknown Unknown
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY CID002867 Outreach Required Unknown Unknown
Gold Dijllah Gold Refinery FZC UNITED ARAB EMIRATES CID003348 In Communication Unknown Unknown
Gold DODUCO Contacts and Refining GmbH GERMANY CID000362 Conformant Yes No
Gold Dowa JAPAN CID000401 Conformant Yes No
Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF CID003195 Conformant Yes No
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF CID000359 Conformant Yes No
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN CID000425 Conformant Yes No
Gold Eco-System Recycling Co., Ltd. North Plant JAPAN CID003424 Conformant Yes No
Gold Eco-System Recycling Co., Ltd. West Plant JAPAN CID003425 Conformant Yes No
Gold Emerald Jewel Industry India Limited (Unit 1) INDIA CID003487 In Communication Unknown Unknown
Gold Emerald Jewel Industry India Limited (Unit 2) INDIA CID003488 In Communication Unknown Unknown
Gold Emerald Jewel Industry India Limited (Unit 3) INDIA CID003489 In Communication Unknown Unknown
Gold Emerald Jewel Industry India Limited (Unit 4) INDIA CID003490 In Communication Unknown Unknown
Gold Emirates Gold DMCC UNITED ARAB EMIRATES CID002561 Conformant Yes Yes
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE CID002515 RMI Due Diligence Review - Unable to Proceed Unknown Unknown
Gold Fujairah Gold FZC UNITED ARAB EMIRATES CID002584 Outreach Required Unknown Unknown
Gold GCC Gujrat Gold Centre Pvt. Ltd. INDIA CID002852 In Communication Unknown Unknown
Gold Geib Refining Corporation UNITED STATES OF AMERICA CID002459 Conformant Yes No



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Gold Gold Coast Refinery GHANA CID003186 Outreach Required Unknown Unknown
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA CID002243 Conformant Yes Unknown
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA CID001909 Outreach Required Unknown Unknown
Gold Guangdong Jinding Gold Limited CHINA CID002312 Outreach Required Unknown Unknown
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA CID000651 Outreach Required Unknown Unknown
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA CID000671 Outreach Required Unknown Unknown
Gold Heimerle + Meule GmbH GERMANY CID000694 Conformant Yes Unknown
Gold Heraeus Metals Hong Kong Ltd. CHINA CID000707 Conformant Yes Unknown
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY CID000711 Active Unknown Unknown
Gold Hunan Chenzhou Mining Co., Ltd. CHINA CID000767 Outreach Required Unknown Unknown
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. CHINA CID000773 Outreach Required Unknown Unknown
Gold HwaSeong CJ CO., LTD. KOREA, REPUBLIC OF CID000778 Communication Suspended - Not Interested Unknown Unknown
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA CID000801 Conformant Yes Unknown
Gold International Precious Metal Refiners UNITED ARAB EMIRATES CID002562 Active Unknown Unknown
Gold Ishifuku Metal Industry Co., Ltd. JAPAN CID000807 Conformant Yes Unknown
Gold Istanbul Gold Refinery TURKEY CID000814 Conformant Yes Unknown
Gold Italpreziosi ITALY CID002765 Conformant Yes Unknown
Gold JALAN & Company INDIA CID002893 Outreach Required Unknown Unknown
Gold Japan Mint JAPAN CID000823 Conformant Yes Unknown
Gold Jiangxi Copper Co., Ltd. CHINA CID000855 Conformant Yes Unknown
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION CID000927 RMI Due Diligence Review - Unable to Proceed Unknown Unknown
Gold JSC Uralelectromed RUSSIAN FEDERATION CID000929 Conformant Yes Unknown
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN CID000937 Conformant Yes Unknown
Gold K.A. Rasmussen NORWAY CID003497 Outreach Required Unknown Unknown
Gold Kaloti Precious Metals UNITED ARAB EMIRATES CID002563 RMI Due Diligence Review - Unable to Proceed Unknown Unknown



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Gold Kazakhmys Smelting LLC KAZAKHSTAN CID000956 In Communication Unknown Unknown
Gold Kazzinc KAZAKHSTAN CID000957 Conformant Yes Unknown
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA CID000969 Conformant Yes Unknown
Gold KGHM Polska Miedz Spolka Akcyjna POLAND CID002511 Conformant Yes Unknown
Gold Kojima Chemicals Co., Ltd. JAPAN CID000981 Conformant Yes No
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF CID002605 Conformant Yes No
Gold Kundan Care Products Ltd. INDIA CID003463 In Communication Unknown Unknown
Gold Kyrgyzaltyn JSC KYRGYZSTAN CID001029 Conformant Yes Unknown
Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION CID002865 Outreach Required Unknown Unknown
Gold L'azurde Company For Jewelry SAUDI ARABIA CID001032 RMI Due Diligence Review - Unable to Proceed Unknown Unknown
Gold Lingbao Gold Co., Ltd. CHINA CID001056 Outreach Required Unknown Unknown
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA CID001058 Outreach Required Unknown Unknown
Gold L'Orfebre S.A. ANDORRA CID002762 Conformant Yes Yes
Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF CID001078 Conformant Yes Unknown
Gold LT Metal Ltd. KOREA, REPUBLIC OF CID000689 Conformant Yes No
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA CID001093 Outreach Required Unknown Unknown
Gold Marsam Metals BRAZIL CID002606 Conformant Yes No
Gold Materion UNITED STATES OF AMERICA CID001113 Conformant Yes No
Gold Matsuda Sangyo Co., Ltd. JAPAN CID001119 Conformant Yes Unknown
Gold MD Overseas INDIA CID003548 In Communication Unknown Unknown
Gold Metal Concentrators SA (Pty) Ltd. SOUTH AFRICA CID003575 Conformant Yes Unknown
Gold Metallix Refining Inc. UNITED STATES OF AMERICA CID003557 Active Unknown Unknown
Gold Metalor Technologies (Hong Kong) Ltd. CHINA CID001149 Conformant Yes Unknown
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE CID001152 Conformant Yes Unknown
Gold Metalor Technologies (Suzhou) Ltd. CHINA CID001147 Conformant Yes Unknown
Gold Metalor Technologies S.A. SWITZERLAND CID001153 Conformant Yes Unknown
Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA CID001157 Conformant Yes Unknown
Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO CID001161 Conformant Yes Unknown
Gold Mitsubishi Materials Corporation JAPAN CID001188 Conformant Yes Unknown



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193 Conformant Yes Unknown
Gold MMTC-PAMP India Pvt., Ltd. INDIA CID002509 Conformant Yes Unknown
Gold Modeltech Sdn Bhd MALAYSIA CID002857 Non Conformant Unknown Unknown
Gold Morris and Watson NEW ZEALAND CID002282 Communication Suspended - Not Interested Unknown Unknown
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION CID001204 Conformant Yes Unknown
Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY CID001220 Conformant Yes Unknown
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN CID001236 Conformant Yes Unknown
Gold NH Recytech Company KOREA, REPUBLIC OF CID003189 Non Conformant Unknown Unknown
Gold Nihon Material Co., Ltd. JAPAN CID001259 Conformant Yes Unknown
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA CID002779 Conformant Yes Unknown
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN CID001325 Conformant Yes No
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION CID001326 Conformant Yes Unknown
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION CID000493 Conformant Yes Unknown
Gold PAMP S.A. SWITZERLAND CID001352 Conformant Yes Unknown
Gold Pease & Curren UNITED STATES OF AMERICA CID002872 Outreach Required Unknown Unknown
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA CID001362 Outreach Required Unknown Unknown
Gold Planta Recuperadora de Metales SpA CHILE CID002919 Conformant Yes No
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION CID001386 Conformant Yes Unknown
Gold PT Aneka Tambang (Persero) Tbk INDONESIA CID001397 Conformant Yes Unknown
Gold PX Precinox S.A. SWITZERLAND CID001498 Conformant Yes Unknown
Gold QG Refining, LLC UNITED STATES OF AMERICA CID003324 Outreach Required Unknown Unknown
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA CID001512 Conformant Yes Unknown
Gold Refinery of Seemine Gold Co., Ltd. CHINA CID000522 Outreach Required Unknown Unknown
Gold REMONDIS PMR B.V. NETHERLANDS CID002582 Conformant Yes No
Gold Royal Canadian Mint CANADA CID001534 Conformant Yes Unknown
Gold SAAMP FRANCE CID002761 Conformant Yes Unknown



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Gold Sabin Metal Corp. UNITED STATES OF  AMERICA  CID001546 Outreach Required  Unknown Unknown
Gold Safimet S.p.A ITALY CID002973 Conformant Yes Unknown
Gold SAFINA A.S. CZECH REPUBLIC CID002290 Conformant Yes No
Gold Sai Refinery INDIA CID002853 Outreach Required Unknown Unknown
Gold Samduck Precious Metals KOREA, REPUBLIC OF CID001555 Conformant Yes No
Gold Samwon Metals Corp. KOREA, REPUBLIC OF CID001562 Communication Suspended - Not Interested Unknown Unknown
Gold Sancus ZFS (L’Orfebre, SA) COLOMBIA CID003529 In Communication Unknown Unknown
Gold SAXONIA Edelmetalle GmbH GERMANY CID002777 Conformant Yes No
Gold Sellem Industries Ltd. MAURITANIA CID003540 Outreach Required Unknown Unknown
Gold SEMPSA Joyeria Plateria S.A. SPAIN CID001585 Conformant Yes Unknown
Gold Shandong Humon Smelting Co., Ltd. CHINA CID002525 Outreach Required Unknown Unknown
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA CID001619 Outreach Required Unknown Unknown
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA CID001622 Conformant Yes Unknown
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. CHINA CID002527 Outreach Required Unknown Unknown
Gold Shirpur Gold Refinery Ltd. INDIA CID002588 Outreach Required Unknown Unknown
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA CID001736 Conformant Yes Unknown
Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA CID002516 Conformant Yes No
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION CID001756 Conformant Yes Unknown
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA CID001761 Conformant Yes Unknown
Gold Sovereign Metals INDIA CID003383 Outreach Required Unknown Unknown
Gold State Research Institute Center for Physical Sciences and Technology LITHUANIA CID003153 Outreach Required Unknown Unknown
Gold Sudan Gold Refinery SUDAN CID002567 Outreach Required Unknown Unknown
Gold Sumitomo Metal Mining Co., Ltd. JAPAN CID001798 Conformant Yes Unknown
Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF CID002918 Conformant Yes No
Gold Super Dragon Technology Co., Ltd TAIWAN, PROVINCE OF CHINA CID001810 Outreach Required Unknown Unknown
Gold T.C.A S.p.A ITALY CID002580 Conformant Yes Unknown
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875 Conformant Yes Unknown



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA CID001916 Conformant Yes Unknown
Gold Tokuriki Honten Co., Ltd. JAPAN CID001938 Conformant Yes Unknown
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA CID001947 Outreach Required Unknown Unknown
Gold Tony Goetz NV BELGIUM CID002587 Non Conformant Unknown Unknown
Gold TOO Tau-Ken-Altyn KAZAKHSTAN CID002615 Conformant Yes Unknown
Gold Torecom KOREA, REPUBLIC OF CID001955 Conformant Yes No
Gold Umicore Precious Metals Thailand THAILAND CID002314 Conformant Yes Unknown
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM CID001980 Conformant Yes Unknown
Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA CID001993 Conformant Yes No
Gold Valcambi S.A. SWITZERLAND CID002003 Conformant Yes Unknown
Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA CID002030 Conformant Yes Unknown
Gold WIELAND Edelmetalle GmbH GERMANY CID002778 Conformant Yes Unknown
Gold Yamakin Co., Ltd. JAPAN CID002100 Conformant Yes No
Gold Yokohama Metal Co., Ltd. JAPAN CID002129 Conformant Yes No
Gold Yunnan Copper Industry Co., Ltd. CHINA CID000197 Outreach Required Unknown Unknown
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA CID002224 Conformant Yes Unknown
Tantalum Asaka Riken Co., Ltd. JAPAN CID000092 Conformant Yes No
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA CID000211 Conformant Yes No
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA CID002504 Conformant Yes No
Tantalum Exotech Inc. UNITED STATES OF AMERICA CID000456 Conformant Yes No
Tantalum F&X Electro-Materials Ltd. CHINA CID000460 Conformant Yes Yes
Tantalum FIR Metals & Resource Ltd. CHINA CID002505 Conformant Yes No
Tantalum Global Advanced Metals Aizu JAPAN CID002558 Conformant Yes No
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA CID002557 Conformant Yes Yes
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA CID000616 Conformant Yes Yes
Tantalum H.C. Starck Co., Ltd. THAILAND CID002544 Conformant Yes Yes
Tantalum H.C. Starck Hermsdorf GmbH GERMANY CID002547 Conformant Yes No
Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA CID002548 Conformant Yes No
Tantalum H.C. Starck Ltd. JAPAN CID002549 Conformant Yes No



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY CID002550 Conformant Yes Yes
Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY CID002545 Conformant Yes Yes
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA CID002492 Conformant Yes Yes
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA CID002512 Conformant Yes No
Tantalum Jiangxi Tuohong New Raw Material CHINA CID002842 Conformant Yes No
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914 Conformant Yes Yes
Tantalum Jiujiang Tanbre Co., Ltd. CHINA CID000917 Conformant Yes Yes
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA CID002506 Conformant Yes No
Tantalum KEMET Blue Metals MEXICO CID002539 Conformant Yes No
Tantalum LSM Brasil S.A. BRAZIL CID001076 Conformant Yes No
Tantalum Metallurgical Products India Pvt., Ltd. INDIA CID001163 Conformant Yes No
Tantalum Mineracao Taboca S.A. BRAZIL CID001175 Conformant Yes No
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN CID001192 Conformant Yes No
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277 Conformant Yes Yes
Tantalum NPM Silmet AS ESTONIA CID001200 Conformant Yes Yes
Tantalum PRG Dooel NORTH MACEDONIA, REPUBLIC OF CID002847 Conformant Yes No
Tantalum QuantumClean UNITED STATES OF AMERICA CID001508 Conformant Yes No
Tantalum Resind Industria e Comercio Ltda. BRAZIL CID002707 Conformant Yes No
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION CID001769 Conformant Yes No
Tantalum Taki Chemical Co., Ltd. JAPAN CID001869 Conformant Yes No
Tantalum Telex Metals UNITED STATES OF AMERICA CID001891 Conformant Yes No
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN CID001969 Conformant Yes Yes
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA CID002508 Conformant Yes Yes
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA CID001522 Conformant Yes Yes
Tin Alpha UNITED STATES OF AMERICA CID000292 Conformant Yes No
Tin An Vinh Joint Stock Mineral Processing Company VIET NAM CID002703 Outreach Required Unknown Unknown
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA CID000228 Conformant Yes No
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA CID003190 Conformant Yes No



Metal Standard Smelter Name Smelter Facility Location Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Tin China Tin Group Co., Ltd. CHINA CID001070 Conformant Yes No
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda BRAZIL CID003486 Active Unknown Unknown
Tin CRM Synergies SPAIN CID003524 Active Unknown Unknown
Tin CV Ayi Jaya INDONESIA CID002570 Active Unknown Unknown
Tin CV Venus Inti Perkasa INDONESIA CID002455 Active Unknown Unknown
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA CID003356 Non Conformant Unknown Unknown
Tin Dowa JAPAN CID000402 Conformant Yes No
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIET NAM CID002572 Non Conformant Unknown Unknown
Tin EM Vinto BOLIVIA (PLURINATIONAL STATE OF) CID000438 Conformant Yes No
Tin Estanho de Rondonia S.A. BRAZIL CID000448 Active Unknown Unknown
Tin Fenix Metals POLAND CID000468 Conformant Yes No
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. CHINA CID003410 Outreach Required Unknown Unknown
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA CID002848 Conformant Yes No
Tin Gejiu Kai Meng Industry and Trade LLC CHINA CID000942 Conformant Yes No
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA CID000538 Conformant Yes No
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA CID001908 Conformant Yes No
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA CID000555 Conformant Yes No
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA CID003116 Conformant Yes No
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA CID002844 Conformant Yes No
Tin Jiangxi New Nanshan Technology Ltd. CHINA CID001231 Conformant Yes No
Tin Luna Smelter, Ltd. RWANDA CID003387 Conformant Yes Yes
Tin Ma'anshan Weitai Tin Co., Ltd. CHINA CID003379 Conformant Yes No
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL CID002468 Conformant Yes No
Tin Malaysia Smelting Corporation (MSC) MALAYSIA CID001105 Conformant Yes Yes
Tin Melt Metais e Ligas S.A. BRAZIL CID002500 Conformant Yes No
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA CID001142 Conformant Yes No



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Tin Metallo Belgium N.V. BELGIUM CID002773 Conformant Yes No
Tin Metallo Spain S.L.U. SPAIN CID002774 Conformant Yes No
Tin Mineracao Taboca S.A. BRAZIL CID001173 Conformant Yes No
Tin Minsur PERU CID001182 Conformant Yes No
Tin Mitsubishi Materials Corporation JAPAN CID001191 Conformant Yes No
Tin Modeltech Sdn Bhd MALAYSIA CID002858 Non Conformant Unknown Unknown
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM CID002573 Outreach Required Unknown Unknown
Tin Novosibirsk Processing Plant Ltd. RUSSIAN FEDERATION CID001305 Active Unknown Unknown
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314 Conformant Yes No
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517 Conformant Yes No
Tin Operaciones Metalurgicas S.A. BOLIVIA (PLURINATIONAL STATE OF) CID001337 Conformant Yes No
Tin Pongpipat Company Limited MYANMAR CID003208 Outreach Required Unknown Unknown
Tin Precious Minerals and Smelting Limited INDIA CID003409 Non Conformant Unknown Unknown
Tin PT Aries Kencana Sejahtera INDONESIA CID000309 Active Unknown Unknown
Tin PT Artha Cipta Langgeng INDONESIA CID001399 Conformant Yes No
Tin PT ATD Makmur Mandiri Jaya INDONESIA CID002503 Conformant Yes No
Tin PT Babel Inti Perkasa INDONESIA CID001402 Conformant Yes No
Tin PT Babel Surya Alam Lestari INDONESIA CID001406 Conformant Yes No
Tin PT Bangka Serumpun INDONESIA CID003205 Conformant Yes No
Tin PT Bukit Timah INDONESIA CID001428 Active Unknown Unknown
Tin PT Cipta Persada Mulia INDONESIA CID002696 In Communication Unknown Unknown
Tin PT Lautan Harmonis Sejahtera INDONESIA CID002870 Active Unknown Unknown
Tin PT Menara Cipta Mulia INDONESIA CID002835 Conformant Yes No
Tin PT Mitra Stania Prima INDONESIA CID001453 Conformant Yes No
Tin PT Mitra Sukses Globalindo INDONESIA CID003449 In Communication Unknown Unknown
Tin PT Prima Timah Utama INDONESIA CID001458 Conformant Yes No
Tin PT Rajawali Rimba Perkasa INDONESIA CID003381 Conformant Yes No
Tin PT Rajehan Ariq INDONESIA CID002593 Conformant Yes No
Tin PT Refined Bangka Tin INDONESIA CID001460 Conformant Yes No
Tin PT Stanindo Inti Perkasa INDONESIA CID001468 Conformant Yes No



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Tin PT Sukses Inti Makmur INDONESIA CID002816 Active Unknown Unknown
Tin PT Timah Nusantara INDONESIA CID001486 Active Unknown Unknown
Tin PT Timah Tbk Kundur INDONESIA CID001477 Conformant Yes No
Tin PT Timah Tbk Mentok INDONESIA CID001482 Conformant Yes No
Tin PT Tinindo Inter Nusa INDONESIA CID001490 Conformant Yes Unknown
Tin Resind Industria e Comercio Ltda. BRAZIL CID002706 Conformant Yes No
Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA CID001539 Conformant Yes No
Tin Soft Metais Ltda. BRAZIL CID001758 Conformant Yes No
Tin Super Ligas BRAZIL CID002756 Active Unknown Unknown
Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIET NAM CID002834 Conformant Yes No
Tin Thaisarco THAILAND CID001898 Conformant Yes Yes
Tin Tin Technology & Refining UNITED STATES OF AMERICA CID003325 Conformant Yes No
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM CID002574 Outreach Required Unknown Unknown
Tin VQB Mineral and Trading Group JSC VIET NAM CID002015 Outreach Required Unknown Unknown
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL CID002036 Conformant Yes No
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA CID002158 Conformant Yes No
Tin Yunnan Tin Company Limited CHINA CID002180 Conformant Yes No
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA CID003397 Conformant Yes No
Tungsten A.L.M.T. Corp. JAPAN CID000004 Conformant Yes Unknown
Tungsten ACL Metais Eireli BRAZIL CID002833 Conformant Yes No
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. BRAZIL CID003427 Active Unknown Unknown
Tungsten Artek LLC RUSSIAN FEDERATION CID003553 Outreach Required Unknown Unknown
Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM CID002502 Conformant Yes Yes
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA CID002513 Conformant Yes Unknown
Tungsten China Molybdenum Co., Ltd. CHINA CID002641 Conformant Yes Unknown
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258 Conformant Yes Unknown
Tungsten CNMC (Guangxi) PGMA Co., Ltd. CHINA CID000281 Outreach Required Unknown Unknown
Tungsten Cronimet Brasil Ltda BRAZIL CID003468 Active Unknown Unknown
Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA CID003401 Conformant Yes No



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA CID002645 Conformant Yes No
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA CID000875 Conformant Yes Unknown
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315 Conformant Yes No
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494 Conformant Yes Unknown
Tungsten GEM Co., Ltd. CHINA CID003417 Active Unknown Unknown
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA CID000568 Conformant Yes Yes
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218 Conformant Yes Unknown
Tungsten H.C. Starck Smelting GmbH & Co. KG GERMANY CID002542 Conformant Yes Unknown
Tungsten H.C. Starck Tungsten GmbH GERMANY CID002541 Conformant Yes Unknown
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA CID000766 Conformant Yes No
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA CID000769 Conformant Yes Unknown
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION CID002649 Conformant Yes Unknown
Tungsten Japan New Metals Co., Ltd. JAPAN CID000825 Conformant Yes Unknown
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551 Conformant Yes Unknown
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA CID002321 Conformant Yes Unknown
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA CID002313 Communication Suspended - Not Interested Unknown Unknown
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002318 Conformant Yes Unknown
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA CID002317 Conformant Yes Unknown
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA CID002316 Conformant Yes Unknown
Tungsten JSC "Kirovgrad Hard Alloys Plant" RUSSIAN FEDERATION CID003408 Active Unknown Unknown
Tungsten Kennametal Fallon UNITED STATES OF AMERICA CID000966 Conformant Yes Unknown
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA CID000105 Conformant Yes Unknown
Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF CID003388 Conformant Yes No
Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA CID003407 Conformant Yes No
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA CID002319 Conformant Yes Unknown
Tungsten Masan Tungsten Chemical LLC (MTC) VIET NAM CID002543 Conformant Yes Yes
Tungsten Moliren Ltd. RUSSIAN FEDERATION CID002845 Conformant Yes Unknown



Metal Standard Smelter Name Smelter Facility
Location
Smelter ID RMAP Status Conflict
Free?
Source from
DRC?
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA CID002589 Conformant Yes Unknown
Tungsten NPP Tyazhmetprom LLC RUSSIAN FEDERATION CID003416 Active Unknown Unknown
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES CID002827 Conformant Yes No
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION CID002724 Conformant Yes No
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA CID002044 Conformant Yes Yes
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320 Conformant Yes Yes
Tungsten Xiamen Tungsten Co., Ltd. CHINA CID002082 Conformant Yes Unknown
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA CID002830 Conformant Yes Unknown


Appendix B

Country of Origin Information

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be specifically linked to our products.

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Congo, Democratic Republic of the, Djibouti, Dominican Republic, Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic of Korea, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe.