EX-1.01 2 glw4203751-ex101.htm CONFLICT MINERALS REPORT OF CORNING INCORPORATED

 

Exhibit 1.01

 

Corning Incorporated
Conflict Minerals Report
For the Year Ended December 31, 2022

 

This Conflict Minerals Report (CMR) for the year ended December 31, 2022 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 77 plants in 14 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 106 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

 

4.1Requests for Information

 

We surveyed those suppliers described above using version 6.22 of the conflict minerals reporting template developed by the Responsible Business Alliance (“RBA”) and The Global e-Sustainability Initiative (“GeSI”), known as the Responsible Minerals Initiative (“RMI”) Conflict Minerals 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 and 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.

 

4.2Survey Responses

 

Where the CMRT responses included the names of entities listed by our suppliers as smelters or refiners, Assent 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 18, 2023, there were two (2) 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.

 

4.3RCOI Conclusion

 

Our RCOI determined that certain of the 3TG contained in the products sold by Corning may have originated in the Covered Countries. 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

 

5.1Design 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 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.

 

5.2Establish Strong Company Management Systems

 

5.2.1Conflict 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.

 

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. 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 material minerals suppliers and affected areas in our supply chain. Our responsible minerals sourcing program – which covers multiple types of 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 mineral 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
.

 

5.2.2Internal 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.

 

5.2.3Control 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.

 

5.2.4Supplier 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
.

 

5.2.5Grievance 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/.

 

5.2.6Maintain 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 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 material mineral suppliers to Corning. 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 18, 2023, of the 341 legitimate smelter and refiners identified by our suppliers, we have validated 221 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:

 

African Gold Refinery

Artek LLC

Fidelity Printers and Refiners Ltd.

Hydrometallurg JSC

Industrial Refining Company

JSC Kirovgrad Hard Alloys Plant

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

JSC Novosibirsk Refinery

JSC Uralelectromed

Kaloti Precious Metals

Kyshtym Copper-Electrolytic Plant ZAO

LLC Vostok

Moliren Ltd.

Moscow Special Alloys Processing Plant

Novosibirsk Tin Combine

NPP Tyazhmetprom LLC

OJSC The Gulidov Kransoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet)

OOO Technolom 1

OOO Technolom 2

Prioksky Plant of Non-Ferrous Metals

SOE Shyolkovsky Factory of Secondary Precious Metals

Solikamsk Magnesium Works OAO

Sudan Gold Refinery

Unecha Refractory Metals Plant

 

Notably, nineteen of the above facilities are in Russia. Effective in September 2022, RMI suspended new RMAP assessments in Russia, based on legal compliance requirements and risks associated with facilitating audits in Russia, as RMI explained in more detail at https://www.responsiblemineralsinitiative.org/news/notice-regarding-rmap-russia-based-auditees/. The suspension impacts inclusion of auditees in Russia on the public RMAP Conformant and Active lists. Thus, the inclusion of Russian facilities in the list above may not indicate concerns with their mineral sourcing practices.

 

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, eighteen (18) of our responsive suppliers have been identified as having a weak program.

 

5.4Design 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 which 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. 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.

 

5.5Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

Corning does not perform direct audits of 3TG smelters or refiners within our supply chain. Thus, we 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.

 

5.6Report 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.

 

5.6.1Due Diligence Process

 

Corning conducted a survey of its relevant suppliers (as described above) using the template originally developed jointly by the RBA and The Global e-Sustainability Initiative (“GeSI”), known as the Responsible Minerals Initiative Conflict Minerals 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.

 

5.6.2Survey Responses

 

Corning surveyed approximately 106 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 93.4% of the suppliers we surveyed. Corning’s response rate for 2022 was slightly lower than for the previous year, which was 99%. A total of nine (9) suppliers indicated in their survey responses that they sourced 3TG from the Covered Countries, but those 3TG were “conflict free.” 34 of the suppliers surveyed stated that the 3TG they sourced came from outside of the Covered Countries, and 18 suppliers reported as “undeterminable” in regard to sourcing 3TGs from the Covered Countries.

 

5.6.3Efforts 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.

 

5.6.4Efforts 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 341 legitimate smelters identified on the CMRTs we received, as of May 18, 2023, 222 were identified as RMAP Conformant and 8 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 may 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?
Tin Minsur Peru CID001182 Conformant No Yes
Gold Royal Canadian Mint Canada CID001534 Conformant No No
Gold Jiangxi Copper Co., Ltd. China CID000855 Conformant Yes Yes
Gold Metalor Technologies (Suzhou) Ltd. China CID001147   No No
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China CID001622 Conformant No Yes
Gold Shandong Gold Smelting Co., Ltd. China CID001916 Conformant Yes Yes
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China CID002158 Conformant No Yes
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China CID002180 Conformant No Yes
Gold Guangdong Jinding Gold Limited China CID002312 Outreach Required No No
Gold Advanced Chemical Company United States Of America CID000015 Conformant No Yes
Gold Aida Chemical Industries Co., Ltd. Japan CID000019 Conformant No Yes
Gold Agosi AG Germany CID000035 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 Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan CID000041 Conformant Yes Yes
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil CID000058 Conformant Yes No
Gold Argor-Heraeus S.A. Switzerland CID000077 Conformant No No
Gold Asahi Pretec Corp. Japan CID000082 Conformant No Yes
Gold Asaka Riken Co., Ltd. Japan CID000090 Conformant Yes Yes
Gold Aurubis AG Germany CID000113 Conformant No No
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines CID000128 Conformant No No
Gold Boliden AB Sweden CID000157 Conformant No No
Gold C. Hafner GmbH + Co. KG Germany CID000176 Conformant No No
Gold CCR Refinery - Glencore Canada Corporation Canada CID000185 Conformant Yes Yes
Gold Cendres + Metaux S.A. Switzerland CID000189 Non Conformant No No
Gold Chimet S.p.A. Italy CID000233 Conformant No No
Gold Chugai Mining Japan CID000264 Conformant No No
Tin Alpha United States Of America CID000292 Conformant No Yes
Gold DSC (Do Sung Corporation) Korea, Republic Of CID000359 Conformant No No
Gold Dowa Japan CID000401 Conformant No Yes
Tin Dowa Japan CID000402 Conformant No Yes
Gold Eco-System Recycling Co., Ltd. East Plant Japan CID000425 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?
Tin EM Vinto Bolivia (Plurinational State Of) CID000438 Conformant Yes Yes
Tin Fenix Metals Poland CID000468 Conformant No Yes
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China CID000538 Conformant No Yes
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China CID000555 Non Conformant Yes Yes
Gold Heimerle + Meule GmbH Germany CID000694 Conformant No No
Gold Heraeus Metals Hong Kong Ltd. China CID000707 Conformant No No
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China CID000801 Conformant No Yes
Gold Ishifuku Metal Industry Co., Ltd. Japan CID000807 Conformant No No
Gold Istanbul Gold Refinery Turkey CID000814 Conformant Yes Yes
Gold Japan Mint Japan CID000823 Conformant No No
Gold Asahi Refining USA Inc. United States Of America CID000920 Conformant Yes Yes
Gold Asahi Refining Canada Ltd. Canada CID000924 Conformant No Yes
Gold JX Nippon Mining & Metals Co., Ltd. Japan CID000937 Conformant Yes Yes
Tin Gejiu Kai Meng Industry and Trade LLC China CID000942 Non Conformant No Yes
Gold Kazzinc Kazakhstan CID000957 Conformant No Yes
Gold Kennecott Utah Copper LLC United States Of America CID000969 Conformant No Yes
Gold Kojima Chemicals Co., Ltd. Japan CID000981 Conformant No Yes
Tin China Tin Group Co., Ltd. China CID001070 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?
Gold LS-NIKKO Copper Inc. Korea, Republic Of CID001078 Conformant No No
Tin Malaysia Smelting Corporation (MSC) Malaysia CID001105 Conformant Yes Yes
Gold Materion United States Of America CID001113 Conformant No Yes
Gold Matsuda Sangyo Co., Ltd. Japan CID001119 Conformant No Yes
Tin Metallic Resources, Inc. United States Of America CID001142 Conformant No Yes
Gold Metalor Technologies (Hong Kong) Ltd. China CID001149 Conformant Yes Yes
Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore CID001152 Conformant No No
Gold Metalor Technologies S.A. Switzerland CID001153 Conformant Yes Yes
Gold Metalor USA Refining Corporation United States Of America CID001157 Conformant No Yes
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico CID001161 Conformant No Yes
Tin Mineracao Taboca S.A. Brazil CID001173 Conformant No No
Gold Mitsubishi Materials Corporation Japan CID001188 Conformant Yes Yes
Gold Mitsui Mining and Smelting Co., Ltd. Japan CID001193 Conformant No Yes
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey CID001220 Conformant No No
Tin Jiangxi New Nanshan Technology Ltd. China CID001231 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?
Gold Navoi Mining and Metallurgical Combinat Uzbekistan CID001236 Conformant No No
Gold Nihon Material Co., Ltd. Japan CID001259 Conformant Yes Yes
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand CID001314 Conformant No Yes
Gold Ohura Precious Metal Industry Co., Ltd. Japan CID001325 Conformant No Yes
Gold MKS PAMP SA Switzerland CID001352 Conformant Yes No
Gold PT Aneka Tambang (Persero) Tbk Indonesia CID001397 Conformant No No
Tin PT Artha Cipta Langgeng Indonesia CID001399 Conformant No Yes
Tin PT Mitra Stania Prima Indonesia CID001453 Conformant No Yes
Tin PT Refined Bangka Tin Indonesia CID001460 Conformant No Yes
Gold PX Precinox S.A. Switzerland CID001498 Conformant No No
Gold Rand Refinery (Pty) Ltd. South Africa CID001512 Conformant Yes Yes
Tin Rui Da Hung Taiwan, Province Of China CID001539 Conformant No Yes
Gold SEMPSA Joyeria Plateria S.A. Spain CID001585 Conformant No Yes
Gold Sichuan Tianze Precious Metals Co., Ltd. China CID001736 Conformant No No
Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China CID001761 Conformant No Yes
Gold Sumitomo Metal Mining Co., Ltd. Japan CID001798 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?
Gold Tanaka Kikinzoku Kogyo K.K. Japan CID001875 Conformant No No
Tin Thaisarco Thailand CID001898 Conformant Yes Yes
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China CID001908 Non Conformant No No
Gold Tokuriki Honten Co., Ltd. Japan CID001938 Conformant Yes Yes
Gold Torecom Korea, Republic Of CID001955 Conformant No No
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium CID001980 Conformant No Yes
Gold United Precious Metal Refining, Inc. United States Of America CID001993 Conformant No Yes
Gold Valcambi S.A. Switzerland CID002003 Conformant Yes Yes
Tin White Solder Metalurgia e Mineracao Ltda. Brazil CID002036 Conformant No Yes
Gold Yamakin Co., Ltd. Japan CID002100 Conformant No Yes
Gold Yokohama Metal Co., Ltd. Japan CID002129 Conformant Yes Yes
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China CID002224 Conformant Yes Yes
Gold Umicore Precious Metals Thailand Thailand CID002314 Non Conformant No Yes
Gold Geib Refining Corporation United States Of America CID002459 Conformant No Yes
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil CID002468 Conformant Yes Yes
Tin Melt Metais e Ligas S.A. Brazil CID002500 Non 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?
Gold MMTC-PAMP India Pvt., Ltd. India CID002509 Conformant Yes Yes
Gold KGHM Polska Miedz Spolka Akcyjna Poland CID002511 Conformant No Yes
Gold Singway Technology Co., Ltd. Taiwan, Province Of China CID002516 Non Conformant No Yes
Tin O.M. Manufacturing Philippines, Inc. Philippines CID002517 Conformant No Yes
Gold Al Etihad Gold Refinery DMCC United Arab Emirates CID002560 Conformant No Yes
Gold Emirates Gold DMCC United Arab Emirates CID002561 Conformant Yes Yes
Gold T.C.A S.p.A Italy CID002580 Conformant No Yes
Gold Korea Zinc Co., Ltd. Korea, Republic Of CID002605 Conformant No Yes
Tin Resind Industria e Comercio Ltda. Brazil CID002706 Conformant No Yes
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria CID002779 Conformant Yes Yes
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China CID000228 Conformant No Yes
Tin Chifeng Dajingzi Tin Industry Co., Ltd. China CID003190 Conformant No Yes
Tin PT Babel Surya Alam Lestari Indonesia CID001406 Conformant No Yes
Tin PT Timah Tbk Kundur Indonesia CID001477 Conformant No Yes
Tin PT Timah Tbk Mentok Indonesia CID001482 Conformant No Yes
Tin PT ATD Makmur 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?
Tin PT Rajawali Rimba Perkasa Indonesia CID003381 Conformant No Yes
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China CID001277 Conformant Yes Yes
Tantalum Ulba Metallurgical Plant JSC Kazakhstan CID001969 Conformant Yes Yes
Tungsten A.L.M.T. Corp. Japan CID000004 Conformant Yes Yes
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey CID000103 Outreach Required No No
Tungsten Kennametal Huntsville United States Of America CID000105 Conformant No Yes
Gold Caridad Mexico CID000180 Outreach Required No No
Gold Yunnan Copper Industry Co., Ltd. China CID000197 Outreach Required Yes Yes
Tantalum Changsha South Tantalum Niobium Co., Ltd. China CID000211 Conformant Yes Yes
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China CID000218 Conformant No Yes
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China CID000258 Conformant Yes Yes
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China CID000281 Outreach Required No No
Tin PT Aries Kencana Sejahtera Indonesia CID000309 Conformant No Yes
Gold Daye Non-Ferrous Metals Mining Ltd. China CID000343 In Communication No No
Tin Estanho de Rondonia S.A. Brazil CID000448 Conformant No No
Tantalum F&X Electro-Materials Ltd. China CID000460 Conformant Yes Yes
Gold JSC Novosibirsk Refinery Russian Federation CID000493 RMI Due Diligence Review - Unable to 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?
Gold Refinery of Seemine Gold Co., Ltd. China CID000522 Outreach Required No No
Tungsten Global Tungsten & Powders LLC United States Of America CID000568 Conformant Yes Yes
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED China CID000616 Conformant Yes Yes
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China CID000651 Outreach Required No No
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China CID000671 Outreach Required No No
Gold LT Metal Ltd. Korea, Republic Of CID000689 Conformant No No
Gold Heraeus Germany GmbH Co. KG Germany CID000711 Conformant No No
Tungsten Hunan Chenzhou Mining Co., Ltd. China CID000766 Conformant No Yes
Gold Hunan Chenzhou Mining Co., Ltd. China CID000767 Outreach Required No No
Tungsten Hunan Jintai New Material Co., Ltd. China CID000769 Conformant No Yes
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China CID000773 Outreach Required Yes No
Gold HwaSeong CJ CO., LTD. Korea, Republic Of CID000778 Communication Suspended - Not Interested No No
Tungsten Japan New Metals Co., Ltd. Japan CID000825 Conformant No Yes
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. China CID000875 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?
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. China CID000914 Conformant Yes Yes
Tantalum Jiujiang Tanbre Co., Ltd. China CID000917 Conformant Yes Yes
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation CID000927 RMI Due Diligence Review - Unable to Proceed No No
Gold JSC Uralelectromed Russian Federation CID000929 RMI Due Diligence Review - Unable to Proceed No No
Gold Kazakhmys Smelting LLC Kazakhstan CID000956 In Communication No No
Tungsten Kennametal Fallon United States Of America CID000966 Conformant Yes Yes
Gold Kyrgyzaltyn JSC Kyrgyzstan CID001029 Non Conformant No No
Gold L'azurde Company For Jewelry Saudi Arabia CID001032 RMI Due Diligence Review - Unable to Proceed No No
Gold Lingbao Gold Co., Ltd. China CID001056 Outreach Required No No
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China CID001058 Outreach Required No No
Tantalum AMG Brasil Brazil CID001076 Conformant Yes Yes
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China CID001093 Outreach Required No No
Tantalum Metallurgical Products India Pvt., Ltd. India CID001163 Conformant No Yes
Tantalum Mineracao Taboca S.A. Brazil CID001175 Conformant Yes Yes
Tin Mitsubishi Materials Corporation Japan CID001191 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?
Tantalum Mitsui Mining and Smelting Co., Ltd. Japan CID001192 Conformant Yes Yes
Tantalum NPM Silmet AS Estonia CID001200 Conformant No Yes
Gold Moscow Special Alloys Processing Plant Russian Federation CID001204 RMI Due Diligence Review - Unable to Proceed No No
Tin Novosibirsk Tin Combine Russian Federation CID001305 RMI Due Diligence Review - Unable to Proceed No No
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation CID001326 RMI Due Diligence Review - Unable to Proceed Yes Yes
Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State Of) CID001337 Conformant Yes Yes
Gold Penglai Penggang Gold Industry Co., Ltd. China CID001362 Outreach Required No No
Gold Prioksky Plant of Non-Ferrous Metals Russian Federation CID001386 RMI Due Diligence Review - Unable to Proceed Yes Yes
Tin PT Babel Inti Perkasa Indonesia CID001402 Conformant No Yes
Tin PT Belitung Industri Sejahtera Indonesia CID001421 Active No Yes
Tin PT Bukit Timah Indonesia CID001428 Conformant Yes Yes
Tin PT Panca Mega Persada Indonesia CID001457 In Communication No Yes
Tin PT Prima Timah Utama Indonesia CID001458 Conformant No Yes
Tin PT Sariwiguna Binasentosa Indonesia CID001463 Conformant No Yes
Tin PT Stanindo Inti Perkasa Indonesia CID001468 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?
Tin PT Timah Nusantara Indonesia CID001486 Active Yes Yes
Tin PT Tinindo Inter Nusa Indonesia CID001490 Non Conformant Yes Yes
Tin PT Tommy Utama Indonesia CID001493 Conformant No No
Tantalum QuantumClean United States Of America CID001508 Conformant Yes Yes
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China CID001522 Conformant No Yes
Gold Sabin Metal Corp. United States Of America CID001546 Communication Suspended - Not Interested No Yes
Gold Samduck Precious Metals Korea, Republic Of CID001555 Non Conformant Yes Yes
Gold Samwon Metals Corp. Korea, Republic Of CID001562 Communication Suspended - Not Interested No No
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China CID001619 Outreach Required No No
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation CID001756 RMI Due Diligence Review - Unable to Proceed No Yes
Tantalum Solikamsk Magnesium Works OAO Russian Federation CID001769 RMI Due Diligence Review - Unable to Proceed No Yes
Gold Super Dragon Technology Co., Ltd. Taiwan, Province Of China CID001810 Outreach Required No No
Tantalum Taki Chemical Co., Ltd. Japan CID001869 Conformant Yes Yes
Tantalum Telex Metals United States Of America CID001891 Conformant No Yes
Gold Great Wall Precious Metals Co., Ltd. of CBPM China CID001909 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?
Gold Tongling Nonferrous Metals Group Co., Ltd. China CID001947 Outreach Required No No
Tin VQB Mineral and Trading Group JSC Viet Nam CID002015 Outreach Required Yes Yes
Gold Western Australian Mint (T/a The Perth Mint) Australia CID002030 Conformant No No
Tungsten Wolfram Bergbau und Hutten AG Austria CID002044 Conformant Yes No
Tungsten Xiamen Tungsten Co., Ltd. China CID002082 Conformant Yes Yes
Gold Gold Refinery of Zijin Mining Group Co., Ltd. China CID002243 Conformant No No
Gold Morris and Watson New Zealand CID002282 In Communication No No
Gold SAFINA A.S. Czechia CID002290 Conformant No No
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China CID002313 Communication Suspended - Not Interested No No
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China CID002315 Conformant Yes Yes
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China CID002316 Conformant No No
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China CID002317 Conformant Yes Yes
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China CID002318 Conformant No Yes
Tungsten Malipo Haiyu Tungsten Co., Ltd. China CID002319 Conformant No Yes
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China CID002320 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?
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China CID002321 Conformant No Yes
Tin CV Venus Inti Perkasa Indonesia CID002455 Conformant Yes No
Tin PT Tirus Putra Mandiri Indonesia CID002478 In Communication No No
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China CID002492 Conformant No Yes
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China CID002494 Conformant No Yes
Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam CID002502 Conformant Yes Yes
Tantalum D Block Metals, LLC United States Of America CID002504 Conformant No Yes
Tantalum FIR Metals & Resource Ltd. China CID002505 Conformant No Yes
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China CID002506 Conformant Yes Yes
Tantalum XinXing HaoRong Electronic Material Co., Ltd. China CID002508 Conformant No Yes
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China CID002512 Conformant No No
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China CID002513 Conformant No Yes
Gold Shandong Humon Smelting Co., Ltd. China CID002525 Outreach Required No No
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China CID002527 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?
Tantalum KEMET de Mexico Mexico CID002539 Conformant Yes Yes
Tungsten H.C. Starck Tungsten GmbH Germany CID002541 Conformant No Yes
Tungsten TANIOBIS Smelting GmbH & Co. KG Germany CID002542 Conformant Yes Yes
Tungsten Masan High-Tech Materials Viet Nam CID002543 Conformant No Yes
Tantalum TANIOBIS Co., Ltd. Thailand CID002544 Conformant Yes Yes
Tantalum TANIOBIS GmbH Germany CID002545 Conformant Yes Yes
Tantalum Materion Newton Inc. United States Of America CID002548 Conformant Yes Yes
Tantalum TANIOBIS Japan Co., Ltd. Japan CID002549 Conformant Yes Yes
Tantalum TANIOBIS Smelting GmbH & Co. KG Germany CID002550 Conformant Yes Yes
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China CID002551 Conformant No No
Tantalum Global Advanced Metals Boyertown United States Of America CID002557 Conformant Yes Yes
Tantalum Global Advanced Metals Aizu Japan CID002558 Conformant Yes Yes
Gold International Precious Metal Refiners United Arab Emirates CID002562 In Communication No No
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam CID002572 Non Conformant No No
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam CID002573 Outreach Required Yes Yes

 

 

 

Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and High-
Risk
Areas?
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam CID002574 Outreach Required No No
Gold REMONDIS PMR B.V. Netherlands CID002582 Conformant No No
Gold Fujairah Gold FZC United Arab Emirates CID002584 Outreach Required No No
Gold Shirpur Gold Refinery Ltd. India CID002588 Outreach Required No No
Tungsten Niagara Refining LLC United States Of America CID002589 Conformant No Yes
Gold Marsam Metals Brazil CID002606 Non Conformant No Yes
Gold TOO Tau-Ken-Altyn Kazakhstan CID002615 Conformant No No
Tungsten China Molybdenum Tungsten Co., Ltd. China CID002641 Conformant No No
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. China CID002645 Conformant No No
Tungsten Hydrometallurg, JSC Russian Federation CID002649 RMI Due Diligence Review - Unable to Proceed Yes Yes
Tin PT Cipta Persada Mulia Indonesia CID002696 Conformant No No
Tin An Vinh Joint Stock Mineral Processing Company Viet Nam CID002703 Outreach Required No No
Tantalum Resind Industria e Comercio Ltda. Brazil CID002707 Conformant No Yes
Gold Abington Reldan Metals, LLC United States Of America CID002708 Conformant No Yes
Tungsten Unecha Refractory metals plant Russian Federation CID002724 Non 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?
Tin Super Ligas Brazil CID002756 Active No No
Gold SAAMP France CID002761 Conformant No No
Gold L'Orfebre S.A. Andorra CID002762 Conformant Yes Yes
Gold 8853 S.p.A. Italy CID002763 Non Conformant No No
Gold Italpreziosi Italy CID002765 Conformant No No
Tin Aurubis Beerse Belgium CID002773 Conformant Yes Yes
Tin Aurubis Berango Spain CID002774 Conformant Yes Yes
Gold WIELAND Edelmetalle GmbH Germany CID002778 Conformant No Yes
Tin PT Sukses Inti Makmur Indonesia CID002816 Conformant No Yes
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines CID002827 Conformant No No
Tungsten ACL Metais Eireli Brazil CID002833 Non Conformant No Yes
Tin PT Menara Cipta Mulia Indonesia CID002835 Conformant No Yes
Tantalum Jiangxi Tuohong New Raw Material China CID002842 Conformant No Yes
Tungsten Moliren Ltd. Russian Federation CID002845 RMI Due Diligence Review - Unable to Proceed No No
Gold AU Traders and Refiners South Africa CID002850 Non Conformant Yes Yes
Gold GGC Gujrat Gold Centre Pvt. Ltd. India CID002852 Active No Yes
Gold Sai Refinery India CID002853 Outreach Required No No
Gold Modeltech Sdn Bhd Malaysia CID002857 Non Conformant No No
Tin Modeltech Sdn Bhd Malaysia CID002858 Non Conformant No No
Gold Bangalore Refinery India CID002863 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?
Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation CID002865 RMI Due Diligence Review - Unable to Proceed No No
Gold Degussa Sonne / Mond Goldhandel GmbH Germany CID002867 Outreach Required No No
Gold Pease & Curren United States Of America CID002872 Communication Suspended - Not Interested No Yes
Gold JALAN & Company India CID002893 Outreach Required No No
Gold SungEel HiMetal Co., Ltd. Korea, Republic Of CID002918 Conformant No Yes
Gold Planta Recuperadora de Metales SpA Chile CID002919 Conformant Yes No
Gold Safimet S.p.A Italy CID002973 Non Conformant No Yes
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China CID003116 Conformant No Yes
Gold State Research Institute Center for Physical Sciences and Technology Lithuania CID003153 Outreach Required Yes Yes
Gold Gold Coast Refinery Ghana CID003186 Outreach Required No No
Gold NH Recytech Company Korea, Republic Of CID003189 Conformant No No
Tin PT Bangka Serumpun Indonesia CID003205 Conformant No Yes
Tin Pongpipat Company Limited Myanmar CID003208 Outreach Required No Yes
Gold QG Refining, LLC United States Of America CID003324 Outreach Required No Yes
Tin Tin Technology & Refining United States Of America CID003325 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?
Gold Dijllah Gold Refinery FZC United Arab Emirates CID003348 Outreach Required No No
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China CID003356 Non Conformant No No
Gold CGR Metalloys Pvt Ltd. India CID003382 Outreach Required No No
Gold Sovereign Metals India CID003383 Outreach Required Yes Yes
Tin Luna Smelter, Ltd. Rwanda CID003387 Conformant Yes Yes
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China CID003397 Non Conformant No Yes
Tungsten Fujian Ganmin RareMetal Co., Ltd. China CID003401 Conformant Yes Yes
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China CID003407 Conformant Yes Yes
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation CID003408 RMI Due Diligence Review - Unable to Proceed No No
Tin Precious Minerals and Smelting Limited India CID003409 Non Conformant No No
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China CID003410 Outreach Required No No
Tungsten NPP Tyazhmetprom LLC Russian Federation CID003416 RMI Due Diligence Review - Unable to Proceed No No
Tungsten Hubei Green Tungsten Co., Ltd. China CID003417 Conformant No No
Gold C.I Metales Procesados Industriales SAS Colombia CID003421 Active 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 Eco-System Recycling Co., Ltd. North Plant Japan CID003424 Conformant No No
Gold Eco-System Recycling Co., Ltd. West Plant Japan CID003425 Conformant No No
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil CID003427 Non Conformant Yes Yes
Tin PT Mitra Sukses Globalindo Indonesia CID003449 Conformant No No
Gold Augmont Enterprises Private Limited India CID003461 Active No No
Gold Kundan Care Products Ltd. India CID003463 In Communication No No
Tungsten Cronimet Brasil Ltda Brazil CID003468 Conformant No No
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil CID003486 Conformant Unknown Unknown
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 K.A. Rasmussen Norway CID003497 Outreach Required Yes No

 

 

 

Metal Smelter Name Smelter
Facility
Location
Smelter ID RMAP Audit
Status
Source
from
DRC?
Source
from
Conflict-
Affected
and High-
Risk
Areas?
Gold Alexy Metals United States Of America CID003500 Active No No
Tin CRM Synergies Spain CID003524 Conformant No No
Gold Sancus ZFS (L’Orfebre, SA) Colombia CID003529 Conformant Unknown Unknown
Gold Sellem Industries Ltd. Mauritania CID003540 Communication Suspended - Not Interested Unknown Unknown
Gold MD Overseas India CID003548 In Communication No No
Tungsten Artek LLC Russian Federation CID003553 RMI Due Diligence Review - Unable to Proceed No No
Gold Metallix Refining Inc. United States Of America CID003557 In Communication Unknown Unknown
Gold Metal Concentrators SA (Pty) Ltd. South Africa CID003575 Conformant No No
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil CID003582 Conformant Unknown Unknown
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China CID003583 Conformant Unknown Unknown
Tungsten Fujian Xinlu Tungsten Co., Ltd. China CID003609 Conformant Unknown Unknown
Tungsten OOO “Technolom” 2 Russian Federation CID003612 RMI Due Diligence Review - Unable to Proceed Unknown Unknown
Tungsten OOO “Technolom” 1 Russian Federation CID003614 RMI Due Diligence Review - Unable to Proceed Unknown Unknown
Gold WEEEREFINING France CID003615 Active Unknown Unknown
Tin CV Ayi Jaya Indonesia CID002570 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?
Tin PT Bangka Prima Tin Indonesia CID002776 Conformant Unknown Unknown
Tin PT Putera Sarana Shakti (PT PSS) Indonesia CID003868 Conformant Unknown Unknown
Tin PT Bangka Tin Industry Indonesia CID001419   Unknown Unknown
Gold Fidelity Printers and Refiners Ltd. Zimbabwe CID002515 RMI Due Diligence Review - Unable to Proceed Yes Yes
Gold Kaloti Precious Metals United Arab Emirates CID002563 RMI Due Diligence Review - Unable to Proceed No No
Gold Sudan Gold Refinery Sudan CID002567 Outreach Required Yes Yes
Gold Industrial Refining Company Belgium CID002587 Non Conformant No No
Gold Shenzhen CuiLu Gold Co., Ltd. China CID002750 Outreach Required Unknown Unknown
Gold Albino Mountinho Lda. Portugal CID002760 Outreach Required Unknown Unknown
Gold ABC Refinery Pty Ltd. Australia CID002920 Outreach Required Unknown Unknown
Gold African Gold Refinery Uganda CID003185 RMI Due Diligence Review - Unable to Proceed Yes No
Gold Gold by Gold Colombia Colombia CID003641 Conformant Unknown Unknown
Tungsten LLC Vostok Russian Federation CID003643 RMI Due Diligence Review - Unable to Proceed Unknown Unknown
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. China CID003662 Outreach Required Unknown Unknown
Gold Dongwu Gold Group China CID003663 Outreach 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?
Tin DS Myanmar Myanmar CID003831 Conformant Unknown Unknown
Tantalum 5D Production OU Estonia CID003926 Outreach Required Unknown Unknown
Tungsten HANNAE FOR T Co., Ltd. Korea, Republic Of CID003978 Outreach Required Unknown Unknown
Tin PT Premium Tin Indonesia Indonesia CID000313 Conformant 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.

 


Afghanistan, Ãland Islands, Albania, American Samoa, Andorra, Angola, Argentina, Armenia, Aruba, Australia, Austria, Azerbaijan, Bahamas, Barbados, Belarus, Belgium, Benin, Bermuda, Bolivia (Plurinational State of), Brazil, Bulgaria, Burkina Faso, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo, Czechia, Democratic Republic of Congo, Djibouti, Dominica, Dominican Republic, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, Finland, France, Georgia, Germany, Ghana, Guam, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jersey, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Liechtenstein, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Norway, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Samoa, Saudi Arabia, Senegal, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, South Sudan, Spain, Sudan, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, Zimbabwe.