0001206774-22-001451.txt : 20220531 0001206774-22-001451.hdr.sgml : 20220531 20220531120804 ACCESSION NUMBER: 0001206774-22-001451 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20211231 1.02 20211231 FILED AS OF DATE: 20220531 DATE AS OF CHANGE: 20220531 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: 22981649 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 corning4066221-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       1-3247       16-0393470
(State or Other Jurisdiction (Commission File No.) (IRS Employer
of incorporation) Identification Number)
 
One Riverfront Plaza, Corning New York 14831
(Address of Principal Executive Offices) (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, 2021.
     
       

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 27, 2022
Eric S. Musser (Date)
President & Chief Operating Officer
 

EX-1.01 2 corning4066221-ex101.htm CONFLICT MINERALS REPORT OF CORNING INCORPORATED

Exhibit 1.01

Corning Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2021

This Conflict Minerals Report (CMR) for the year ended December 31, 2021 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 over 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 117 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 sera, 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 Hemlock Semiconductor Group, the pharmaceutical technologies business, auto glass, new product lines and development projects, as well as other businesses and certain corporate investments.

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 into relevant agreements that requires suppliers to provide information about the source of conflict minerals and the location of 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 126 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 6.10 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 the 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 6, 2022, there were three (3) 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, Optical Communications, Specialty Materials, and Life Sciences segments, our RCOI determined that certain of the 3TG contained in the products sold by these segments is sourced from the Covered Countries, but only from RMI compliant smelters. Thus, we are required under the Rule to conduct due diligence on the source and chain of custody of those minerals 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 responsible minerals policy, effective February 2022:

Corning Incorporated’s Corporate Position on Conflict Minerals

At Corning, corporate social responsibility is a proactive commitment to preserving the trust of our stakeholders. This 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. It is also a demonstration of how we live our Values which represent the unchanging moral and ethical compass that guides everything we do.

As part of our commitment to corporate social responsibility, Corning is committed to the responsible sourcing of minerals – sourcing done in an ethical and sustainable manner that safeguards the human rights of everyone in our global supply chain and preserves the environment. Any connection between the materials used in Corning products and armed violence or human rights abuses is unacceptable.

Corning requires our suppliers to comply with our requests to provide complete and accurate information about minerals supplied to Corning, and to perform further due diligence as required about the source of any 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.

We also require our suppliers to extend these expectations to their own suppliers. Suppliers are required to include provisions equivalent to Corning’s Supplier Code of Conduct, which include a commitment to responsible minerals sourcing and prohibition of forced labor, in their supply chain agreements and to flowdown the same requirements throughout their supply chains. See our Supplier Code of Conduct here: https://www.corning.com/worldwide/en/sustainability/processes/supply-chain-social-responsibility/supplier-responsibility/supplier-code-of-conduct.html.

Conflict Minerals

The term “conflict minerals” refers to the mineral precursors of the metals tantalum, tin, tungsten, and gold (also known as “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 are necessary to the functionality or production of those products are required to assess their supply chains and report on the source of these materials. Corning is a public company, and therefore is committed to complying with this law.

Corning’s Position on Conflict Minerals

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: https://www.responsiblemineralsinitiative.org/. 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’s Responsible Minerals Position

In 2020, in recognition of growing concerns about the risk of child labor and additional human rights violations beyond the scope of the 3TG minerals, Corning broadened its due diligence program to cover all minerals and affected areas in our supply chain. Our responsible minerals sourcing program – which covers all minerals, as well as suppliers and smelters/refiners previously or currently certified as “conflict free” and non-certified suppliers and smelters/refiners on their journey towards certification – is based on three key steps to identify and respond to risks in the minerals supply chain. As part of these efforts, we have become members of The Initiative for Responsible Mining Assurance (IRMA) and the Responsible Minerals Initiative, enabling us to expand our industry collaborative efforts through these memberships; to utilize RMI’s flagship Responsible Minerals Assurance Process (RMAP) through our supply chain; and to leverage resources, such as RMI’s eLearning Academy, to improve our ability to support and build the capacity of our suppliers and smelters/refiners in their risk assessment and due diligence efforts.

Our Responsible Minerals Policy is publicly available on our website at the following link: https://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 and Chief Supply Chain Officer 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 https://www.corning.com/worldwide/en/sustainability/processes/supply-chain-social-responsibility/supplier-responsibility/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 https://www.responsiblemineralsinitiative.org/rmap/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, risk methods, 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 6, 2022, of the 337 legitimate smelters and refiners identified by our suppliers, we have validated 231 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:

Industrial Refining Company – CID002587
Kyrgyzaltyn Joint Stock Company – CID001029
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 review 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, fourteen (14) 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 facility’s 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 in 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 suppliers’ products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on RMI’s website and via the website of Assent Compliance, our third-party provider.


5.6.2 Survey Responses

Corning surveyed approximately 126 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 2021 was the same as the previous year, which was also 99%. A total of sixteen (16) suppliers indicated in their survey responses that they sourced 3TG from the Covered Countries, but those 3TG were “conflict free.” 36 of the suppliers surveyed stated that the 3TG they sourced came from outside of the Covered Countries, and 21 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 337 legitimate smelters identified on the CMRTs we received, as of May 6, 2022, 231 were identified as RMAP Conformant and 18 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 in our 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 Quarterly Report on Form 10-Q, in reports subsequently filed by Corning with the Securities and Exchange Commission (“SEC”) on Forms 8-K, 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 Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Royal Canadian
Gold Mint Canada CID001534 Conformant No No
Jiangxi Copper Co.,
Gold Ltd. China CID000855 Conformant Yes Yes
Metalor
Technologies
Gold (Suzhou) Ltd. China CID001147 Conformant No No
Shandong Zhaojin
Gold & Silver
Gold Refinery Co., Ltd. China CID001622 Conformant No No
The Refinery of
Shandong Gold
Gold Mining Co., Ltd. China CID001916 Conformant No No
Guangdong Jinding Outreach
Gold Gold Limited China CID002312 Required No No
Advanced Chemical United States
Gold Company of America CID000015 Conformant No No
Aida Chemical
Gold Industries Co., Ltd. Japan CID000019 Conformant No No
Allgemeine Gold-
und
Silberscheideanstal
Gold t A.G. Germany CID000035 Conformant No No
Almalyk Mining and
Metallurgical
Gold Complex (AMMC) Uzbekistan CID000041 Conformant Yes Yes
AngloGold Ashanti
Corrego do Sitio
Gold Mineracao Brazil CID000058 Conformant No No
Gold Argor-Heraeus S.A. Switzerland CID000077 Conformant No No

____________________

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 Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Gold Asahi Pretec Corp. Japan CID000082 Conformant No Yes
Asaka Riken Co.,
Gold Ltd. Japan CID000090 Conformant Yes Yes
Gold Aurubis AG Germany CID000113 Conformant No No
Bangko Sentral ng
Pilipinas (Central
Bank of the
Gold Philippines) Philippines CID000128 Conformant No No
Gold Boliden AB Sweden CID000157 Conformant No No
C. Hafner GmbH +
Gold Co. KG Germany CID000176 Conformant No No
CCR Refinery -
Glencore Canada
Gold Corporation Canada CID000185 Conformant Yes Yes
Cendres + Metaux
Gold S.A. Switzerland CID000189 Conformant No No
Gold Chimet S.p.A. Italy CID000233 Conformant No No
Gold Chugai Mining Japan CID000264 Conformant No No
DSC (Do Sung Korea,
Gold Corporation) Republic Of CID000359 Conformant No No
Gold Dowa Japan CID000401 Conformant No Yes
Eco-System
Recycling Co., Ltd.
Gold East Plant Japan CID000425 Conformant No No
OJSC Novosibirsk Russian Non
Gold Refinery Federation CID000493 Conformant No No
Heimerle + Meule
Gold GmbH Germany CID000694 Conformant No No
Heraeus Metals
Gold Hong Kong Ltd. China CID000707 Conformant No No
Inner Mongolia
Qiankun Gold and
Silver Refinery
Gold Share Co., Ltd. China CID000801 Conformant No No
Ishifuku Metal
Gold Industry Co., Ltd. Japan CID000807 Conformant No No
Istanbul Gold
Gold Refinery Turkey CID000814 Conformant No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Gold Japan Mint Japan CID000823 Conformant No No
Asahi Refining USA United States
Gold Inc. of America CID000920 Conformant No No
Asahi Refining
Gold Canada Ltd. Canada CID000924 Conformant No No
Russian Non
Gold JSC Uralelectromed Federation CID000929 Conformant No No
JX Nippon Mining &
Gold Metals Co., Ltd. Japan CID000937 Conformant No No
Gold Kazzinc Kazakhstan CID000957 Conformant No No
Kennecott Utah United States
Gold Copper LLC of America CID000969 Conformant Yes Yes
Kojima Chemicals
Gold Co., Ltd. Japan CID000981 Conformant No Yes
LS-NIKKO Copper Korea,
Gold Inc. Republic Of CID001078 Conformant No No
United States
Gold Materion of America CID001113 Conformant No Yes
Matsuda Sangyo
Gold Co., Ltd. Japan CID001119 Conformant No Yes
Metalor
Technologies (Hong
Gold Kong) Ltd. China CID001149 Conformant No No
Metalor
Technologies
(Singapore) Pte.,
Gold Ltd. Singapore CID001152 Conformant No No
Metalor
Gold Technologies S.A. Switzerland CID001153 Conformant Yes Yes
Metalor USA
Refining United States
Gold Corporation of America CID001157 Conformant No No
Metalurgica Met-
Mex Penoles S.A.
Gold De C.V. Mexico CID001161 Conformant No No
Mitsubishi
Materials
Gold Corporation Japan CID001188 Conformant No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Mitsui Mining and
Gold Smelting Co., Ltd. Japan CID001193 Conformant No No
Moscow Special
Alloys Processing Russian Non
Gold Plant Federation CID001204 Conformant No No
Nadir Metal
Rafineri San. Ve Tic.
Gold A.S. Turkey CID001220 Conformant No No
Navoi Mining and
Metallurgical
Gold Combinat Uzbekistan CID001236 Conformant No No
Nihon Material Co.,
Gold Ltd. Japan CID001259 Conformant Yes Yes
Ohura Precious
Metal Industry Co.,
Gold Ltd. Japan CID001325 Conformant No Yes
OJSC "The Gulidov
Krasnoyarsk Non-
Ferrous Metals
Plant" (OJSC Russian Non
Gold Krastsvetmet) Federation CID001326 Conformant No No
Gold PAMP S.A. Switzerland CID001352 Conformant Yes No
Prioksky Plant of Russian Non
Gold Non-Ferrous Metals Federation CID001386 Conformant Yes Yes
PT Aneka Tambang
Gold (Persero) Tbk Indonesia CID001397 Conformant No No
Gold PX Precinox S.A. Switzerland CID001498 Conformant No No
Rand Refinery (Pty)
Gold Ltd. South Africa CID001512 Conformant Yes Yes
SEMPSA Joyeria
Gold Plateria S.A. Spain CID001585 Conformant No Yes
Sichuan Tianze
Precious Metals
Gold Co., Ltd. China CID001736 Conformant No No
SOE Shyolkovsky
Factory of
Secondary Precious Russian Non
Gold Metals Federation CID001756 Conformant No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Solar Applied Taiwan,
Materials Province Of
Gold Technology Corp. China CID001761 Conformant No Yes
Sumitomo Metal
Gold Mining Co., Ltd. Japan CID001798 Conformant No No
Tanaka Kikinzoku
Gold Kogyo K.K. Japan CID001875 Conformant No No
Tokuriki Honten
Gold Co., Ltd. Japan CID001938 Conformant No No
Korea,
Gold Torecom Republic Of CID001955 Conformant No No
Umicore S.A.
Business Unit
Precious Metals
Gold Refining Belgium CID001980 Conformant No No
United Precious United States
Gold Metal Refining, Inc. of America CID001993 Conformant No No
Gold Valcambi S.A. Switzerland CID002003 Conformant No No
Gold Yamakin Co., Ltd. Japan CID002100 Conformant No No
Yokohama Metal
Gold Co., Ltd. Japan CID002129 Conformant No No
Zhongyuan Gold
Smelter of Zhongjin
Gold Gold Corporation China CID002224 Conformant No No
Umicore Precious
Gold Metals Thailand Thailand CID002314 Conformant No No
Geib Refining United States
Gold Corporation of America CID002459 Conformant No No
MMTC-PAMP India
Gold Pvt., Ltd. India CID002509 Conformant Yes Yes
KGHM Polska
Miedz Spolka
Gold Akcyjna Poland CID002511 Conformant No Yes
Singway Taiwan,
Technology Co., Province of
Gold Ltd. China CID002516 Conformant No Yes
Al Etihad Gold United Arab
Gold Refinery DMCC Emirates CID002560 Conformant No Yes



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Emirates Gold United Arab
Gold DMCC Emirates CID002561 Conformant No No
Gold T.C.A S.p.A Italy CID002580 Conformant No No
Korea,
Gold Korea Zinc Co., Ltd. Republic of CID002605 Conformant No No
Ogussa
Osterreichische
Gold- und Silber-
Scheideanstalt
Gold GmbH Austria CID002779 Conformant No No
Western Australian
Mint (T/a The Perth
Gold Mint) Australia CID002030 Conformant No No
Outreach
Gold Caridad Mexico CID000180 Required No No
Daye Non-Ferrous In
Gold Metals Mining Ltd. China CID000343 Communication No No
Refinery of
Seemine Gold Co., Outreach
Gold Ltd. China CID000522 Required No No
Hangzhou
Fuchunjiang Outreach
Gold Smelting Co., Ltd. China CID000671 Required No No
Korea,
Gold LT Metal Ltd. Republic of CID000689 Conformant No No
Heraeus Precious
Metals GmbH & Co.
Gold KG Germany CID000711 Conformant No No
Hunan Chenzhou Outreach
Gold Mining Co., Ltd. China CID000767 Required No No
Hunan Guiyang
yinxing Nonferrous Outreach
Gold Smelting Co., Ltd. China CID000773 Required Yes No
Communication
HwaSeong CJ CO., Korea, Suspended -
Gold LTD. Republic of CID000778 Not Interested No No
Kazakhmys In
Gold Smelting LLC Kazakhstan CID000956 Communication No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Lingbao Gold Co., Outreach
Gold Ltd. China CID001056 Required No No
Lingbao Jinyuan
Tonghui Refinery Outreach
Gold Co., Ltd. China CID001058 Required No No
Luoyang Zijin Yinhui
Gold Refinery Co., Outreach
Gold Ltd. China CID001093 Required No No
Penglai Penggang
Gold Industry Co., Outreach
Gold Ltd. China CID001362 Required No No
Communication
United States Suspended -
Gold Sabin Metal Corp. of America CID001546 Not Interested No No
Samduck Precious Korea,
Gold Metals Republic of CID001555 Conformant Yes Yes
Communication
Samwon Metals Korea, Suspended -
Gold Corp. Republic of CID001562 Not Interested No No
Shandong
Tiancheng
Biological Gold Outreach
Gold Industrial Co., Ltd. China CID001619 Required No No
Great Wall Precious
Metals Co., Ltd. of Outreach
Gold CBPM China CID001909 Required No No
Tongling
Nonferrous Metals Outreach
Gold Group Co., Ltd. China CID001947 Required No No
Gold Refinery of
Zijin Mining Group
Gold Co., Ltd. China CID002243 Conformant No No
In
Gold Morris and Watson New Zealand CID002282 Communication No No
Gold SAFINA A.S. Czechia CID002290 Conformant No No
Shandong Humon Outreach
Gold Smelting Co., Ltd. China CID002525 Required Unknown Unknown



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
International
Precious Metal United Arab In
Gold Refiners Emirates CID002562 Communication Unknown Unknown
REMONDIS PMR
Gold B.V. Netherlands CID002582 Conformant No No
United Arab Outreach
Gold Fujairah Gold FZC Emirates CID002584 Required Unknown Unknown
Gold Marsam Metals Brazil CID002606 Conformant No Yes
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615 Conformant No No
Gold SAAMP France CID002761 Conformant No No
Gold L'Orfebre S.A. Andorra CID002762 Conformant No Yes
Gold 8853 S.p.A. Italy CID002763 Conformant Unknown Unknown
Gold Italpreziosi Italy CID002765 Conformant No No
WIELAND
Gold Edelmetalle GmbH Germany CID002778 Conformant No No
GCC Gujrat Gold
Gold Centre Pvt. Ltd. India CID002852 Active No Yes
Outreach
Gold Sai Refinery India CID002853 Required No No
Gold Bangalore Refinery India CID002863 Conformant No No
Kyshtym Copper-
Electrolytic Plant Russian Outreach
Gold ZAO Federation CID002865 Required No No
Degussa Sonne /
Mond Goldhandel Outreach
Gold GmbH Germany CID002867 Required No No
Communication
United States Suspended -
Gold Pease & Curren of America CID002872 Not Interested No No
SungEel HiMetal Korea,
Gold Co., Ltd. Republic of CID002918 Conformant No Yes
Planta
Recuperadora de
Gold Metales SpA Chile CID002919 Conformant Yes No
Gold Safimet S.p.A Italy CID002973 Conformant No No
State Research
Institute Center for
  Physical Sciences     Outreach    
Gold and Technology Lithuania CID003153 Required No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
United States Outreach
Gold QG Refining, LLC of America CID003324 Required Yes Yes
Dijllah Gold United Arab Outreach
Gold Refinery FZC Emirates CID003348 Required Unknown Unknown
CGR Metalloys Pvt Outreach
Gold Ltd. India CID003382 Required Unknown Unknown
Outreach
Gold Sovereign Metals India CID003383 Required Unknown Unknown
Eco-System
Recycling Co., Ltd.
Gold North Plant Japan CID003424 Conformant No No
Eco-System
Recycling Co., Ltd.
Gold West Plant Japan CID003425 Conformant No No
Metal
Concentrators SA
Gold (Pty) Ltd. South Africa CID003575 Conformant Unknown Unknown
Atasay Kuyumculuk
Sanayi Ve Ticaret Outreach
Gold A.S. Turkey CID000103 Required No No
Yunnan Copper Outreach
Gold Industry Co., Ltd. China CID000197 Required No No
Guoda Safina High-
Tech Environmental Outreach
Gold Refinery Co., Ltd. China CID000651 Required No No
RMI Due
Diligence
JSC Ekaterinburg Review -
Non-Ferrous Metal Russian Unable to
Gold Processing Plant Federation CID000927 Proceed No No
Non
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029 Conformant No No
RMI Due
Diligence
Review -
L'azurde Company Unable to
Gold For Jewelry Saudi Arabia CID001032 Proceed No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Super Dragon Taiwan,
Technology Co., Province of Outreach
Gold Ltd. China CID001810 Required Unknown Unknown
RMI Due
Diligence
Review -
Fidelity Printers and Unable to
Gold Refiners Ltd. Zimbabwe CID002515 Proceed No Yes
Shenzhen
Zhonghenglong
Real Industry Co., Outreach
Gold Ltd. China CID002527 Required No No
RMI Due
Diligence
Review -
Kaloti Precious United Arab Unable to
Gold Metals Emirates CID002563 Proceed No No
Sudan Gold Outreach
Gold Refinery Sudan CID002567 Required No No
Industrial Refining Non
Gold Company Belgium CID002587 Conformant No No
Shirpur Gold Outreach
Gold Refinery Ltd. India CID002588 Required Unknown Unknown
Abington Reldan United States Non
Gold Metals, LLC of America CID002708 Conformant No No
AU Traders and Non
Gold Refiners South Africa CID002850 Conformant No No
Non
Gold Modeltech Sdn Bhd Malaysia CID002857 Conformant No No
Outreach
Gold JALAN & Company India CID002893 Required Unknown Unknown
African Gold Outreach
Gold Refinery Uganda CID003185 Required Yes No
Outreach
Gold Gold Coast Refinery Ghana CID003186 Required Unknown Unknown
NH Recytech Korea,
Gold Company Republic of CID003189 Conformant No No
C.I Metales
Procesados
Gold Industriales SAS Colombia CID003421 Active Unknown Unknown



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status

Source
from
DRC?

Source
from
Conflict-
Affected
and
High-Risk
Areas?
Augmont
Enterprises Private
Gold Limited India CID003461 Active Unknown Unknown
Kundan Care In
Gold Products Ltd. India CID003463 Communication Unknown Unknown
Emerald Jewel
Industry India In
Gold Limited (Unit 1) India CID003487 Communication Unknown Unknown
Emerald Jewel
Industry India In
Gold Limited (Unit 2) India CID003488 Communication Unknown Unknown
Emerald Jewel
Industry India In
Gold Limited (Unit 3) India CID003489 Communication Unknown Unknown
Emerald Jewel
Industry India In
Gold Limited (Unit 4) India CID003490 Communication Unknown Unknown
Outreach
Gold K.A. Rasmussen Norway CID003497 Required Unknown Unknown
United States
Gold Alexy Metals of America CID003500 Active Unknown Unknown
Sancus ZFS
Gold (L’Orfebre, SA) Colombia CID003529 Active Unknown Unknown
Sellem Industries Communication
Suspended -
Gold Ltd. Mauritania CID003540 Not Interested Unknown Unknown
In
Gold MD Overseas India CID003548 Communication Unknown Unknown
Metallix Refining United States In
Gold Inc. of America CID003557 Communication Unknown Unknown
ABC Refinery Pty Outreach
Gold Ltd. Australia CID002920 Required Unknown Unknown
Gold WEEEREFINING France CID003615 Active Unknown Unknown
In
Gold Value Trading Belgium CID003617 Communication Unknown Unknown



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
F&X Electro-
Tantalum Materials Ltd. China CID000460 Conformant Yes Yes
Guangdong Zhiyuan
New Material Co.,
Tantalum Ltd. China CID000616 Conformant Yes Yes
Ningxia Orient
Tantalum Industry
Tantalum Co., Ltd. China CID001277 Conformant Yes Yes
Jiujiang Tanbre Co.,
Tantalum Ltd. China CID000917 Conformant Yes Yes
Changsha South
Tantalum Niobium
Tantalum Co., Ltd. China CID000211 Conformant Yes Yes
JiuJiang JinXin
Nonferrous Metals
Tantalum Co., Ltd. China CID000914 Conformant Yes Yes
Tantalum LSM Brasil S.A. Brazil CID001076 Conformant Yes Yes
Metallurgical
Products India Pvt.,
Tantalum Ltd. India CID001163 Conformant No Yes
Mineracao Taboca
Tantalum S.A. Brazil CID001175 Conformant No No
Mitsui Mining and
Tantalum Smelting Co., Ltd. Japan CID001192 Conformant No No
Tantalum NPM Silmet AS Estonia CID001200 Conformant Yes Yes
United States
Tantalum QuantumClean of America CID001508 Conformant Yes Yes
Yanling Jincheng
Tantalum &
Tantalum Niobium Co., Ltd. China CID001522 Conformant No No
Solikamsk
Magnesium Works Russian
Tantalum OAO Federation CID001769 Conformant Yes Yes
Taki Chemical Co.,
Tantalum Ltd. Japan CID001869 Conformant Yes Yes
United States
Tantalum Telex Metals of America CID001891 Conformant Yes Yes
Ulba Metallurgical
Tantalum Plant JSC Kazakhstan CID001969 Conformant Yes Yes



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Hengyang King Xing
Lifeng New
Tantalum Materials Co., Ltd. China CID002492 Conformant No Yes
United States
Tantalum D Block Metals, LLC of America CID002504 Conformant No No
FIR Metals &
Tantalum Resource Ltd. China CID002505 Conformant No Yes
Jiujiang Zhongao
Tantalum &
Tantalum Niobium Co., Ltd. China CID002506 Conformant Yes Yes
XinXing HaoRong
Electronic Material
Tantalum Co., Ltd. China CID002508 Conformant No No
Jiangxi Dinghai
Tantalum &
Tantalum Niobium Co., Ltd. China CID002512 Conformant No No
Tantalum KEMET Blue Metals Mexico CID002539 Conformant Yes Yes
Tantalum H.C. Starck Co., Ltd. Thailand CID002544 Conformant Yes Yes
H.C. Starck
Tantalum and
Tantalum Niobium GmbH Germany CID002545 Conformant Yes Yes
H.C. Starck
Tantalum Hermsdorf GmbH Germany CID002547 Conformant Yes Yes
United States
Tantalum H.C. Starck Inc. of America CID002548 Conformant Yes Yes
Tantalum H.C. Starck Ltd. Japan CID002549 Conformant Yes Yes
H.C. Starck
Smelting GmbH &
Tantalum Co. KG Germany CID002550 Conformant Yes Yes
Global Advanced United States
Tantalum Metals Boyertown of America CID002557 Conformant Yes Yes
Global Advanced
Tantalum Metals Aizu Japan CID002558 Conformant Yes Yes
Resind Industria e
Tantalum Comercio Ltda. Brazil CID002707 Conformant No No
Jiangxi Tuohong
Tantalum New Raw Material China CID002842 Conformant No No
Yancheng Jinye
Tantalum New Material
Technology Co.,
Ltd.
China CID003583 Conformant Unknown Unknown



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Tin Minsur Peru CID001182 Conformant Yes Yes
Yunnan Chengfeng
Non-ferrous Metals
Tin Co., Ltd. China CID002158 Conformant No Yes
Yunnan Tin
Tin Company Limited China CID002180 Conformant No Yes
United States
Tin Alpha of America CID000292 Conformant No Yes
Tin Dowa Japan CID000402 Conformant No No
Bolivia
(Plurinational
Tin EM Vinto State of) CID000438 Conformant Yes Yes
Tin Fenix Metals Poland CID000468 Conformant No No
Gejiu Non-Ferrous
Metal Processing
Tin Co., Ltd. China CID000538 Conformant No Yes
Gejiu Zili Mining
And Metallurgy Co.,
Tin Ltd. China CID000555 Conformant No No
Gejiu Kai Meng
Industry and Trade Non
Tin LLC China CID000942 Conformant No No
China Tin Group
Tin Co., Ltd. China CID001070 Conformant No No
Malaysia Smelting
Tin Corporation (MSC) Malaysia CID001105 Conformant Yes Yes
Metallic Resources, United States
Tin Inc. of America CID001142 Conformant No No
Mineracao Taboca
Tin S.A. Brazil CID001173 Conformant No No
Jiangxi New
Nanshan
Tin Technology Ltd. China CID001231 Conformant No Yes
O.M.
Manufacturing
Tin (Thailand) Co., Ltd. Thailand CID001314 Conformant No No



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
PT Artha Cipta
Tin Langgeng Indonesia CID001399 Conformant No Yes
PT Mitra Stania
Tin Prima Indonesia CID001453 Conformant No Yes
PT Refined Bangka
Tin Tin Indonesia CID001460 Conformant No Yes
Taiwan,
Province of
Tin Rui Da Hung China CID001539 Conformant No No
Tin Soft Metais Ltda. Brazil CID001758 Conformant Yes Yes
Tin Thaisarco Thailand CID001898 Conformant Yes Yes
Gejiu Yunxin
Nonferrous
Tin Electrolysis Co., Ltd. China CID001908 Conformant No No
White Solder
Metalurgia e
Tin Mineracao Ltda. Brazil CID002036 Conformant Yes Yes
Magnu's Minerais
Tin Metais e Ligas Ltda. Brazil CID002468 Conformant Yes Yes
Melt Metais e Ligas Outreach
Tin S.A. Brazil CID002500 Required No Yes
O.M.
Manufacturing
Tin Philippines, Inc. Philippines CID002517 Conformant No No
Resind Industria e
Tin Comercio Ltda. Brazil CID002706 Conformant Yes Yes
Bolivia
Operaciones (Plurinational
Tin Metalurgicas S.A. State of) CID001337 Conformant Yes Yes
PT Timah Tbk
Tin Mentok Indonesia CID001482 Conformant No Yes
Mitsubishi
Materials
Tin Corporation Japan CID001191 Conformant No No
PT Timah Tbk
Tin Kundur Indonesia CID001477 Conformant No Yes
PT ATD Makmur
Tin Mandiri Jaya Indonesia CID002503 Conformant No Yes



Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Metallo Belgium
Tin N.V. Belgium CID002773 Conformant Yes Yes
Guangdong Hanhe
Non-Ferrous Metal
Tin Co., Ltd. China CID003116 Conformant No No
Chifeng Dajingzi Tin
Tin Industry Co., Ltd. China CID003190 Conformant No No
PT Bangka
Tin Serumpun Indonesia CID003205 Conformant No Yes
Chenzhou Yunxiang
Mining and
Tin Metallurgy Co., Ltd. China CID000228 Conformant No No
Estanho de
Tin Rondonia S.A. Brazil CID000448 Conformant No No
PT Babel Inti
Tin Perkasa Indonesia CID001402 Conformant No Yes
PT Babel Surya
Tin Alam Lestari Indonesia CID001406 Conformant No No
PT Belitung Industri Outreach
Tin Sejahtera Indonesia CID001421 Required Unknown
Tin PT Bukit Timah Indonesia CID001428 Conformant No No
PT Panca Mega Outreach
Tin Persada Indonesia CID001457 Required Unknown
PT Prima Timah
Tin Utama Indonesia CID001458 Conformant No Yes
PT Sariwiguna
Tin Binasentosa Indonesia CID001463 Conformant Unknown Unknown
PT Stanindo Inti
Tin Perkasa Indonesia CID001468 Conformant No Yes
PT Timah
Tin Nusantara Indonesia CID001486 Active Yes Yes
PT Tinindo Inter
Tin Nusa Indonesia CID001490 Conformant No No
CV Venus Inti
Tin Perkasa Indonesia CID002455 Active No No
Tin Super Ligas Brazil CID002756 Active No No
Tin Metallo Spain S.L.U. Spain CID002774 Conformant Yes Yes
PT Sukses Inti
Tin Makmur Indonesia CID002816 Active Unknown Unknown


 
Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Tin Thai Nguyen Mining and Metallurgy Co., Ltd. Viet Nam CID002834 Conformant No No
Tin PT Menara Cipta Mulia Indonesia CID002835 Conformant No No
Tin Pongpipat Company Limited Myanmar CID003208 Outreach
Required
No Yes
Tin Tin Technology & Refining United States of America CID003325 Conformant No No
Tin Ma'anshan Weitai Tin Co., Ltd. China CID003379 Conformant No No
Tin PT Rajawali Rimba Perkasa Indonesia CID003381 Conformant Unknown Unknown
Tin Luna Smelter, Ltd. Rwanda CID003387 Conformant Unknown Unknown
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397 Non Conformant No No
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410 Outreach Required Unknown Unknown
Tin PT Mitra Sukses Globalindo Indonesia CID003449 Active Unknown Unknown
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486 Active Unknown Unknown
Tin CRM Synergies Spain CID003524 Conformant Unknown Unknown
Tin

Fabrica Auricchio Industria e Comercio Ltda.

Brazil CID003582 Conformant Unknown Unknown
Tin

PT Aries Kencana Sejahtera

Indonesia CID000309 Active No
Tin Novosibirsk Processing Plant Ltd. Russian Federation CID001305 Conformant No No
Tin VQB Mineral and Trading Group JSC Viet Nam CID002015 Outreach Required No No
             

 
Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Electro-Mechanical
Facility of the Cao
Bang Minerals &
Metallurgy Joint Non
Tin Stock Company Viet Nam CID002572 Conformant No No
Nghe Tinh Non-
Ferrous Metals
Joint Stock Outreach
Tin Company Viet Nam CID002573 Required No No
Tuyen Quang Non-
Ferrous Metals
Joint Stock Outreach
Tin Company Viet Nam CID002574 Required No No
PT Cipta Persada
Tin Mulia Indonesia CID002696 Conformant No No
An Vinh Joint Stock
Mineral Processing Outreach
Tin Company Viet Nam CID002703 Required No No
Non
Tin Modeltech Sdn Bhd Malaysia CID002858 Conformant No No
Dongguan CiEXPO
Environmental
Engineering Co., Non
Tin Ltd. China CID003356 Conformant Unknown Unknown
Precious Minerals
and Smelting Non
Tin Limited India CID003409 Conformant Unknown Unknown
In
Tin PT Tommy Utama Indonesia CID001493 Communication Unknown
PT Tirus Putra Outreach
Tin Mandiri Indonesia CID002478 Required Unknown
PT Masbro Alam
Tin Stania Indonesia CID003380 Active Unknown Unknown
H.C. Starck
Tungsten Tungsten GmbH Germany CID002541 Conformant Yes Yes
Tungsten A.L.M.T. Corp. Japan CID000004 Conformant Yes Yes
Kennametal United States
Tungsten Huntsville of America CID000105 Conformant No Yes
             

 
Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Chongyi Zhangyuan
Tungsten Tungsten Co., Ltd. China CID000258 Conformant Yes Yes
Global Tungsten & United States
Tungsten Powders Corp. of America CID000568 Conformant Yes Yes
Hunan Chenzhou
Tungsten Mining Co., Ltd. China CID000766 Conformant No Yes
United States
Tungsten Kennametal Fallon of America CID000966 Conformant No No
Wolfram Bergbau
Tungsten und Hutten AG Austria CID002044 Conformant Yes No
Xiamen Tungsten
Tungsten Co., Ltd. China CID002082 Conformant Yes Yes
Jiangxi Yaosheng
Tungsten Tungsten Co., Ltd. China CID002316 Conformant No No
Xiamen Tungsten
Tungsten (H.C.) Co., Ltd. China CID002320 Conformant Yes Yes
Jiangxi Gan Bei
Tungsten Tungsten Co., Ltd. China CID002321 Conformant No Yes
Ganzhou
Tungsten Seadragon W & Mo Co., Ltd. China CID002494 Conformant No Yes
H.C. Starck
Smelting GmbH &
Tungsten Co. KG Germany CID002542 Conformant Yes Yes
Masan Tungsten
Tungsten Chemical LLC (MTC) Viet Nam CID002543 Conformant No Yes
Jiangwu H.C. Starck
Tungsten Products
Tungsten Co., Ltd. China CID002551 Conformant No No
Hydrometallurg, Russian
Tungsten JSC Federation CID002649 Conformant Yes Yes
Guangdong Xianglu
Tungsten Tungsten Co., Ltd. China CID000218 Conformant No Yes
CNMC (Guangxi) Outreach
Tungsten PGMA Co., Ltd. China CID000281 Required Unknown Unknown
Hunan Chunchang
Nonferrous Metals
Tungsten Co., Ltd. China CID000769 Conformant No Yes
Japan New Metals
Tungsten Co., Ltd. Japan CID000825 Conformant No Yes
             

 
Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Ganzhou Huaxing
Tungsten Products
Tungsten Co., Ltd. China CID000875 Conformant Yes Yes
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313 Communication Suspended - Not Interested No No
Ganzhou Jiangwu
Ferrotungsten Co.,
Tungsten Ltd. China CID002315 Conformant Yes Yes
Jiangxi Xinsheng
Tungsten Industry
Tungsten Co., Ltd. China CID002317 Conformant Yes Yes
Jiangxi Tonggu
Non-ferrous
Metallurgical &
Tungsten Chemical Co., Ltd. China CID002318 Conformant No No
Malipo Haiyu
Tungsten Tungsten Co., Ltd. China CID002319 Conformant No Yes
Asia Tungsten
Products Vietnam
Tungsten Ltd. Viet Nam CID002502 Conformant Yes Yes
Chenzhou Diamond
Tungsten Products
Tungsten Co., Ltd. China CID002513 Conformant No Yes
Niagara Refining United States
Tungsten LLC of America CID002589 Conformant No Yes
China Molybdenum
Tungsten Co., Ltd. China CID002641 Conformant Unknown Unknown
Ganzhou Haichuang
Tungsten Tungsten Co., Ltd. China CID002645 Conformant No No
Unecha Refractory Russian
Tungsten metals plant Federation CID002724 Conformant No No
Philippine
Chuangxin
Tungsten Industrial Co., Inc. Philippines CID002827 Conformant No No
Xinfeng Huarui
Tungsten &
Molybdenum New
Tungsten Material Co., Ltd. China CID002830 Conformant No No
Tungsten ACL Metais Eireli Brazil CID002833 Conformant No No
             

 
Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and
High-Risk
Areas?
Russian
Tungsten Moliren Ltd. Federation CID002845 Conformant No No
Korea,
Tungsten KGETS Co., Ltd. Republic of CID003388 Conformant No No
Fujian Ganmin
Tungsten RareMetal Co., Ltd. China CID003401 Conformant Unknown Unknown
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province of China CID003407 Conformant No No
JSC "Kirovgrad Hard Russian
Tungsten Alloys Plant" Federation CID003408 Conformant Unknown Unknown
Cronimet Brasil
Tungsten Ltda Brazil CID003468 Conformant Unknown Unknown
NPP Tyazhmetprom Russian
Tungsten LLC Federation CID003416 Active Unknown Unknown
Tungsten GEM Co., Ltd. China CID003417 Conformant Unknown Unknown
Albasteel Industria
e Comercio de Ligas
Tungsten Para Fundicao Ltd. Brazil CID003427 Active Unknown Unknown
Russian Outreach
Tungsten Artek LLC Federation CID003553 Required Unknown Unknown
Fujian Xinlu
Tungsten Tungsten China CID003609 Conformant Unknown Unknown
OOO “Technolom” Russian
Tungsten 2 Federation CID003612 Active Unknown Unknown
OOO “Technolom” Russian
Tungsten 1 Federation CID003614 Active Unknown Unknown
Russian Outreach
Tungsten LLC Volstok Federation CID003643 Required Unknown 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.

Argentina, Armenia, Australia, Austria, Azerbaijan, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Canada, Chile, China, Colombia, Costa Rica, Cote d'Ivoire, Cuba, Cyprus, Democratic Republic of the Congo, Dominican Republic, Ecuador, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia Montenegro, Morocco, Mozambique, Myanmar, Namibia, New Zealand, Nicaragua, Niger, Nigeria, Oman, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Zambia, Zimbabwe.