EX-1.01 2 brhc10048434_ex1-01.htm EXHIBIT 1.01

Exhibit 1.01

Conflict Minerals Report 2022

Overview of Apple’s Commitment to Responsible Sourcing

At Apple, our respect for human rights begins with our commitment to treating everyone with dignity and respect. Apple’s Board of Directors adopted and oversees our human rights policy — Our Commitment to Human Rights (“Human Rights Policy”) — which governs how we treat everyone, including our customers, employees, business partners, and people at every level of our supply chain. In alignment with our Human Rights Policy as well as Apple’s Supplier Code of Conduct (“Supplier Code”), which includes Apple’s Supplier Responsibility Standard on the Responsible Sourcing of Materials (“Responsible Sourcing Standard”), we conduct human rights and environmental due diligence in our supply chain to identify and mitigate risks. We also work to identify and remedy potential adverse impacts, track and measure our progress, and report our findings.

We seek to one day use only recycled and renewable minerals and materials in our products and packaging, and are committed to achieving carbon neutrality for our entire footprint by 2030 — from our supply chain to the use of the products we make. Nearly 20 percent of all material used in Apple products in 2021 was recycled. Tin, tantalum, tungsten, and gold ("3TG”) are among 14 materials prioritized in our initial efforts to transition to recycled and renewable materials, based on an evaluation of the environmental, social, and supply impacts of 45 mined elements and raw materials. The results of this evaluation and the related methodology (“Material Impact Profiles”) are available on Apple’s website for others to access and use.1

As we make progress toward these ambitious goals, we continue to source 3TG and other minerals, such as cobalt and lithium, responsibly, while working to improve conditions in and around mining communities, including in the Democratic Republic of the Congo (“DRC”) and adjoining countries. Although Apple does not directly purchase, procure, or source primary minerals, we are committed to meeting and exceeding internationally-accepted due diligence standards for primary minerals and recycled materials in our supply chain. Our responsible minerals sourcing program includes requirements that apply to all levels of Apple’s supply chain. Conducting human rights and environmental due diligence in alignment with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (“OECD Due Diligence Guidance”) and the United Nations Guiding Principles on Business and Human Rights (“UN Guiding Principles”) is the foundation of Apple’s responsible sourcing programs for primary and recycled minerals and materials.

Our Supplier Code and Responsible Sourcing Standard requires suppliers, smelters, refiners, and recyclers in our supply chain to identify and assess a broad range of risks beyond conflict, including social, environmental, and human rights risks. Suppliers are also required to review reported incidents and public allegations linked to their smelters and refiners, and to participate in 3TG traceability and independent third-party audit programs to mitigate identified risks.


1 Available at apple.com/environment/pdf/Apple_Material_Impact_Profiles_April2019.pdf

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As of December 31, 2022 — for the eighth consecutive year — 100 percent of the identified smelters and refiners in our supply chain for all applicable Apple products manufactured during 2022 participated in or completed an independent third-party conflict minerals audit for 3TG. These audits encompassed the identified smelters and refiners that provide materials for the following Apple product categories: iPhone®, Mac®, iPad®, AirPods®, Apple TV®, Apple Watch®, Beats® products, HomePod®, HomePod mini®, iPod touch®, Apple Card®, and all Apple® accessories.

Since 2009, Apple has directed the removal of 198 3TG smelters and refiners from its supply chain (a total of 10 tantalum, 60 tin, 27 tungsten, and 101 gold smelters and refiners). In 2022, we removed 23 smelters and refiners from our supply chain, including those that were not willing to participate in or complete an independent third-party audit, or that did not otherwise meet our requirements for the responsible sourcing of minerals. Based on our due diligence efforts, including analyzing the information provided by third-party audit programs, upstream traceability programs, and our suppliers, we found no reasonable basis for concluding that any of the 238 smelters and refiners of 3TG determined to be in our supply chain as of December 31, 2022 directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.

As we work to strengthen industry-wide due diligence programs operating in areas where 3TG minerals are sourced, we engage with and support a broad range of multistakeholder and community initiatives. This includes support for human rights and environmental defenders as well as whistleblower initiatives that work to empower independent, local voices to raise issues and report incidents at the mining level. Input from stakeholders and rights-holders contributes to our robust due diligence program and drives industry-wide progress. As part of our widespread efforts to support education initiatives, we also aim to expand access to learning opportunities and skills development for people across our supply chain through a $50 million Supplier Employee Development Fund which was launched in 2022, in partnership with the International Labor Organization, the International Organization for Migration, and education experts around the world.

We believe that all stakeholders (including governments, civil society, and industry) should enhance their efforts to implement comprehensive due diligence programs, measure impact, and work together with, and support, local communities to improve conditions and drive economic and social development in mining areas, including in the African Great Lakes region.

The below chart summarizes the comprehensive set of tools we utilize to drive progress throughout our supply chain.2



2 More information on Apple’s Responsible Minerals Sourcing program is available at apple.com/supplier-responsibility
 
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OECD Step 1: Establish Strong Company Management Systems

In alignment with Step 1 of the OECD Due Diligence Guidance, Apple has robust internal policies and management systems overseeing its efforts for the responsible sourcing of minerals.

Apple conducts business ethically, honestly, and in compliance with applicable laws and regulations. This applies to every business decision in every area of the company worldwide.

Apple’s Supplier Code of Conduct and Responsible Sourcing of Materials Standard

Apple’s Supplier Code and Responsible Sourcing Standard applies to all levels of Apple’s supply chain, including traders, suppliers, sub-suppliers, mining companies, and operators of collection points for recycled minerals used in Apple products. The Supplier Code and Responsible Sourcing Standard is based on industry and internationally accepted principles, including the UN Guiding Principles, the International Labour Organization’s International Labour Standards, and the OECD Due Diligence Guidance.

The Supplier Code and Responsible Sourcing Standard outlines Apple’s requirements for its suppliers in the areas of labor and human rights, health and safety, the environment, ethics, and management systems. The Responsible Sourcing Standard specifically outlines Apple’s extensive requirements on the responsible sourcing of minerals and other materials, including expectations for suppliers concerning 3TG due diligence and related sourcing matters. The Supplier Code and Responsible Sourcing Standard is available in 17 languages and is evaluated and strengthened each year, raising the bar suppliers must meet.
 
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Relevant Apple Policies


Business Conduct Policy: provides a standard guide for what is required of everyone at Apple. Apple expects its suppliers, contractors, consultants, and other business partners to follow the Business Conduct Policy’s principles of honesty, respect, confidentiality, and compliance when providing goods or services to Apple or acting on its behalf.

Human Rights Policy: governs how Apple treats everyone, from customers and teams to business partners and people at every level of its supply chain.

Global Whistleblowing Policy: applies to all current and former employees, directors and officers, contractors and subcontractors of Apple and its subsidiaries, and sets out Apple’s approach to protecting and supporting individuals who report potential misconduct.

Relevant Apple Management Systems


Environment and Supply Chain Innovation (“ESCI”) team: within Apple’s Worldwide Operations group, ESCI has primary responsibility for upholding Apple’s values across the global supply chain. The ESCI team coordinates efforts related to Apple’s Supplier Code and Responsible Sourcing Standard and works across Apple’s business teams and functions, including product design, manufacturing operations, environmental initiatives, procurement, legal, finance, and retail. The ESCI team also regularly reports to, and consults with, Apple’s senior management to review progress and set ongoing strategies for our responsible sourcing of materials and human rights and environmental due diligence efforts.

Board Oversight


Board of Directors: oversees Apple’s CEO and other senior management in the competent and ethical operation of Apple on a day-to-day basis.

Audit and Finance Committee: consisting entirely of independent directors, the committee assists Apple’s Board of Directors in monitoring significant business risks, including operational and reputational risks.

Nominating and Corporate Governance Committee: consisting entirely of independent directors, the committee assists Apple’s Board of Directors in overseeing Apple’s strategies, policies, and practices relating to environmental and social matters.

Supplier Engagement

Apple requires its suppliers to adhere to the Supplier Code and the Responsible Sourcing Standard, including any subsequent amendments or updates. Suppliers are also required to apply Apple’s requirements upstream to their own suppliers throughout all levels of the supply chain. In this way, and through direct outreach by Apple to all 3TG smelters and refiners identified in its supply chain, Apple implements its requirement that smelters and refiners in its supply chain comply with Apple’s strict standards, including participation in independent third-party audit programs.

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We annually communicate our 3TG sourcing requirements to our direct suppliers. Additionally, throughout the year we engage with suppliers using tailored communication and guidance including:


Conducting annual 3TG due diligence training webinars with suppliers that have reported to Apple the use of 3TG in parts and products.

Providing suppliers access to our SupplierCare portal, which includes online training materials (in multiple languages) that focus on Apple’s due diligence expectations and requirements for 3TG reporting, among other topics.

We conduct third-party assessments of our suppliers who report to Apple the use of 3TG in their parts and products to confirm alignment with the OECD Due Diligence Guidance and our Supplier Code and Responsible Sourcing Standard. Additional information about these assessments is provided in Step 4 of this report. Suppliers can also reach out to Apple with questions about 3TG sourcing through the SupplierCare portal, or through a dedicated Apple email that allows suppliers to report concerns or grievances related to 3TG mining, processing, and trading. The concerns or grievances submitted are reviewed by Apple, and follow-up activities are conducted as appropriate. If we discover that our standards are not being met, we work collaboratively with suppliers to help them improve, in line with the OECD Due Diligence Guidance framework of progressive improvement, including terminating applicable business relationships if suppliers are unwilling or unable to meet our standards. We also support industry-wide grievance and allegations mechanisms at the smelter and refiner level and whistleblowing programs deeper in the supply chain at the mining level. These programs are discussed further in Step 2 of this report.

Industry and Stakeholder Engagement

We are committed to working in collaboration with stakeholders beyond our own supply chain. As part of this commitment, we regularly engage with a broad range of stakeholders and rights holders – including human rights, environmental, and minerals experts from civil society, non-governmental organizations (“NGOs”), industry, academia, and government – to review and gather feedback on Apple’s programs and discuss strategies for engaging industry and other stakeholders on innovative approaches to the responsible sourcing of recycled and primary sourced minerals in supply chains.

In 2022, we convened human rights, environmental, and minerals experts – including representatives from industry, NGOs, and civil society – to discuss strategies for engaging industry and other stakeholders on innovative approaches to advancing human rights and environmental rights across supply chains. We also continued to engage with and work to incorporate learnings from human rights and environmental defenders, including from the DRC, through our work with the Fund for Global Human Rights, a public foundation that works with human rights organizations globally.

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In 2022, we continued our active participation and leadership in multiple industry associations and multistakeholder initiatives, including serving on:


The Board of Directors of the Responsible Business Alliance (“RBA”)

The Steering Committee of the RBA’s Responsible Minerals Initiative ("RMI”)

The Governance Committee of the Public Private Alliance for Responsible Minerals Trade ("PPA”) — a multi-sector initiative supporting the ethical production, trade, and sourcing of minerals from the African Great Lakes region

The European Partnership for Responsible Minerals

Throughout 2022 we drove and actively contributed to a variety of activities with leading industry organizations and multistakeholder initiatives, including:


Supporting the continued development of industry-wide, responsible sourcing standards, including a responsible artisanal and small-scale mining (“ASM”) sourcing framework being co-developed by the RMI and other stakeholders.

Being featured at the annual OECD Forum on Responsible Mineral Supply Chains for discussing best practices for environmental due diligence.

Joining with other PPA member companies to provide funding to the Congo Power Project, which supports solar power initiatives for the Panzi Foundation’s healthcare facilities in DRC mining areas.

OECD Step 2: Identify and Assess Risks in the Supply Chain

Consistent with Step 2 of the OECD Due Diligence Guidance, we work at multiple levels in our supply chain to continuously identify and assess risks in our minerals supply chains. The 14 priority materials identified in our Material Impact Profiles were identified based in part on their salient environmental and human rights supply chain risks. We use this analysis to inform our process to map and conduct heightened due diligence on priority materials in Apple’s supply chain, including high-risk materials, such as gold. We also work with industry to promote effective and transparent systems that allow these and other materials to be sourced responsibly by others.

A foundational step in Apple’s 3TG risk assessment due diligence process is the requirement that all suppliers that utilize 3TG submit to Apple an industry-standard Conflict Minerals Reporting Template (“CMRT”). We collect and process data provided by suppliers through their completion of the CMRT to map our supply chain to the smelter and refiner level and, to the extent available, to the mining level. Our Responsible Sourcing Standard requires suppliers to inform Apple immediately if they identify certain high risks included in Annex II of the OECD Due Diligence Guidance, such as conflict or human rights risks associated with 3TG.

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Driving Impact Across Industries

In addition to conducting our own supply chain due diligence, we help strengthen and increase the transparency of independent third-party audit programs – in particular, audit programs by the RMI and the London Bullion Market Association (“LBMA”) – to help identify a broad range of social, environmental, human rights, and governance risks at the smelter, refiner, and mining levels.

We continue to innovate, develop, and scale tools to enhance risk identification and assessment beginning at the mining level, and emphasize the importance of cross-industry and multistakeholder collaboration in the use and refinement of these tools in order to drive greater collective impact throughout global supply chains. This includes a variety of tools aimed at enhancing risk identification and assessment, such as:


Risk Readiness Assessment (“RRA”): First funded and developed in 2016 by Apple the RRA has been a tool of the Responsible Minerals Initiative (RMI) and is a pre-requisite self-assessment for RMI Responsible Minerals Assurance Process (“RMAP”) auditees, since 2017. The RRA is widely adopted by industry via the RMI and available to all RMI member companies to assess risks in mineral supply chains. 428 RRAs were completed by RMI industry members and auditees as of December 31, 2022, compared with 366 completed as of 2021. The Copper Mark, an assurance framework for responsible copper production, also used the RRA to assess copper producers at 46 sites during 2022, an increase from 31 in 2021.

Minerals Grievance Platform: a cross-industry platform managed by RMI where allegations concerning minerals supply chains are investigated and addressed. Grievances can be anonymously submitted by NGOs, companies, or any member of the public.

Material Insights Platform: a resource for RMI member companies to identify and assess environmental, social, and governance issues in their materials supply chains, and encourage collective action in addressing risks and creating positive impacts for mining communities.

Blockchain traceability

Throughout 2022, we continued to use blockchain solutions for tracing 3TG and other minerals in the supply chain while aiming to protect data privacy. Apple believes that blockchain solutions are a tool to support — but not replace — supply chain due diligence. The interests of people working at the mining level and in surrounding communities should be taken into consideration when utilizing new technologies such as blockchain. As the use of new technologies increases, our goal is to ensure that data captured contributes to positive impacts along the supply chain.

Empowering Voices in Mining Communities

Apple believes that only addressing allegations that potentially affect its own supply chain will not lead to systemic progress. Accordingly, we have taken steps to work with a broad group of stakeholders to address public allegations together. This includes reviewing public allegations from civil society groups and analyzing investigative reports by international organizations — including NGOs and the United Nations Group of Experts on the DRC — related to risks outlined in Annex II of the OECD Due Diligence Guidance.

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Apple believes that empowering independent voices at the mining level is critical to identifying and assessing risks in the 3TG supply chain. In 2022, this included our work on the following initiatives:


Support for human rights and environmental defenders in the DRC: we continued our partnership with the Fund for Global Human Rights in support of human rights, labor, and environmental defenders in the DRC who work on a range of issues, including the economic and social rights of mining communities, inclusive economic growth, judicial advocacy, environmental justice, the rule of law, as well as health, safety, and fair compensation for mining communities.

Whistleblowing mechanisms at mining level: for the seventh consecutive year, Apple funded the International Tin Supply Chain Initiative’s (“ITSCI”) whistleblowing mechanism in the DRC, which enables people in and around mining communities in seven provinces of the DRC to place anonymous voice calls using a toll-free hotline to raise concerns related to mineral extraction, trade, handling, and exporting via local networks. In 2022, ITSCI and its partner organizations continued to increase awareness and utilization of the whistleblowing mechanism through radio campaigns in mining communities, distributing promotional material, and consulting with local civil society actors and other stakeholders.

Rights awareness trainings: Apple supported a sixth year of programming with international development NGO Pact to deliver rights awareness training to miners, youth, and community officials in ASM communities in the DRC. These training sessions were designed to raise awareness on a range of human rights issues and were based in part on curriculum developed by the United Nations Children’s Emergency Fund (“UNICEF”).

Vocational education: Apple also provided funding to the RBA Foundation in support of Pact’s sixth year of a vocational education program for youth living in mining communities in the Lualaba province of the DRC. In continued response to the COVID-19 pandemic, Pact coordinated with local communities and health officials to provide information and resources, including access to free face masks, soap, and educational materials on symptoms and prevention measures.

OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks

In alignment with Step 3 of the OECD Due Diligence Guidance, we implement our due diligence program and conduct supply chain analysis by leveraging information gained from independent research, engaging with civil society groups and rightsholders, analyzing independent third-party audits, and working directly with smelters and refiners to respond to risks identified in our supply chain.

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We closely monitor completion of independent third-party audits and corrective action plans by the smelters and refiners in our supply chain. In the instances where smelters or refiners delay implementation of corrective action plans developed by third-party audits, we leverage our downstream position, conducting applicable smelter or refiner outreach to reiterate the requirement for the smelter or refiner to complete and close the associated corrective action plan in order to remain in our supply chain.

If smelters or refiners are unable or unwilling to meet our standards, we take necessary actions, through our suppliers, to terminate the applicable business relationships. As of December 31, 2022, we found that all identified smelters and refiners in our supply chain participated in or completed an independent third-party audit that met Apple’s requirements for the responsible sourcing of minerals. Since 2009, Apple has directed removal of 198 3TG smelters or refiners from our supply chain, including more than 100 gold refiners.


Upstream Due Diligence

Each year, we analyze incident data provided by ITSCI and RCS Global Group’s Better Mining program (“Better Mining”), two upstream traceability and due diligence programs that monitor tin, tantalum, and tungsten mines in the DRC and across the African Great Lakes region. We work with these programs to help strengthen their incident review processes, and review and monitor incidents generated through their respective reporting systems, including reviewing mitigation actions and confirming incidents are closed in accordance with the programs’ standards and procedures.

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In 2022, we continued to review incidents and accompanying analysis reported by both ITSCI and Better Mining. As part of this process, we also reviewed reported incidents that could have directly or indirectly benefited or financed armed groups in the DRC or adjoining countries. In 2022, we found no reasonable basis for concluding that any of the reported incidents were connected to tin, tantalum, or tungsten included in Apple’s products. The challenges of tracking specific mineral quantities through the supply chain continue to impede the traceability of any specific mineral shipment through the entire product manufacturing process.

Innovating Responsible Gold Sourcing

Apple continues to address remaining challenges in the global gold supply chain through its due diligence program, which is aligned with the OECD Due Diligence Guidance Supplement on Gold and other sources. As part of our risk assessment and due diligence efforts, we designed and implemented systems that focus specifically on the gold supply chain. Apple accepts certification from the RMI’s RMAP and the LBMA’s Responsible Gold Program for gold refiners in our supply chain. We also prioritize gold in our efforts to transition to recycled and renewable materials in our products, and 100 percent of our recycled gold refiners are audited. In 2022, we reviewed gold refiners in our supply chain to identify potential risks and other sourcing challenges, and subsequently worked with suppliers to address such identified risks and challenges and to remove refiners as necessary.

Apple believes that innovative and data-driven solutions to sourcing help reduce risk and improve traceability, and is leading on responsible gold sourcing innovation. This includes pioneering industry-leading traceability mechanisms for recycled materials to build a supply chain of exclusively recycled gold. In 2022, we also expanded our use of certified recycled gold across all cameras for iPhone 14 family and in multiple printed circuit boards across Apple products, including the latest iPhone, iPad, Watch, MacBook Pro, Apple TV 4K and HomePod. We also worked with sustainability non-profit RESOLVE to fund the Regeneration project, which focuses on re-mining and processing waste material from legacy mines to restore natural environments and support rehabilitation and biodiversity. Regeneration is an expansion of the Salmon Gold project, which we continued to fund and scale with Tiffany & Co. and RESOLVE in 2022. The Salmon Gold project works with small-scale miners and Indigenous Peoples in remote regions of the Yukon, Alaska, and British Columbia to support a mining practice that helps restore rivers and streams so that salmon and other fish can thrive. Since RESOLVE first introduced the Salmon Gold project in 2017, the organization has connected local placer miners, environmentalists, and government agencies to mitigate the damage done by historic mining activities. The gold mined from this project is then traced from its origin to a refiner in Apple’s supply chain using blockchain technology.

Further building on innovative approaches to gold sourcing globally, in 2022, we supported the expansion of and continued to work with the Massachusetts Institute of Technology’s D-Lab Innovation Centers in Colombia. These Innovation Centers support training for local gold miners and community leaders to develop sustainable solutions to ASM challenges.

Apple believes that the lessons learned from these programs will help support further innovation across the supply chains of additional minerals.

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OECD Step 4: Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

Apple believes independent third-party audits remain foundational to robust due diligence systems. In particular, third-party audits play a significant role in providing assurance that smelters and refiners have appropriate due diligence systems in place, while helping to confirm that operations and sourcing practices are aligned with the OECD Due Diligence Guidance, and do not support conflict, including in the DRC or adjoining countries. Since 2015, we have continued to reach a 100 percent rate of participation in independent third-party audit programs by identified smelters and refiners in our supply chain.


In addition to smelter and refiner audit participation, in 2022 we continued to engage an independent audit firm to conduct specialized responsible sourcing audits of select suppliers in order to have a deeper review of their internal management systems and implementation of Apple's requirements related to 3TG and other minerals. These specialized audits continue to be part of Apple’s supplier engagement program which includes our Supplier Code assessments. At the end of an Apple-managed assessment or specialized audit, the supplier is given a list of areas to strengthen with regard to our Supplier Code and Responsible Sourcing Standard, and the supplier is required to correct any identified nonconformances in a timely manner. We provide support to help suppliers complete a corrective action plan to meet and exceed our requirements within the timeline identified as a result of the assessment or specialized audit. Timelines for corrective actions typically range between 30 and 90 days. If a supplier is unwilling or unable to meet Apple's requirements, we will terminate applicable business relationships.

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Supporting Data and Research Development

In addition to conducting independent assessments of our own supply chain, we continue to support a range of multistakeholder initiatives that contribute to broader learnings on the impact of due diligence programs, and opportunities for future innovations. In 2022, building on research Apple previously supported which assessed the human rights impacts of due diligence programs, these initiatives included:


Developing strategies for generating better data on due diligence: we contributed to the conceptualization, design, and presenter selection for a virtual “data for impact symposium” held for PPA members in June 2022.

Supporting new tools to connect ASM and downstream actors: we worked with IMPACT to support the continued development of a digital framework based on the United Nations Sustainable Development Goals which aims to harmonize how the impact of supply chain-related activities on socioeconomic and environmental wellbeing in ASM communities is measured.

Highlighting standards for remediation: in 2022, the International Organization for Migration continued to utilize the Remediation Guidelines for Victims of Exploitation in Extended Minerals Supply Chains, created previously in consultation with Apple.

Leveraging technology for supply chain transparency: via our partnership with the Working Capital Fund, we supported 11 companies that are developing scalable innovations in technological solutions for more transparent supply chains.

OECD Step 5: Report Annually on Supply Chain Due Diligence

Apple reports annually on its due diligence requirements through its Conflict Minerals Report filed with the U.S. Securities and Exchange Commission. Apple also publishes a list of all identified 3TG, cobalt, and lithium smelters and refiners in its supply chain, 100 percent of which participated in independent third-party audits as of December 31, 2022, and publishes its Supplier List based on direct spend for materials, manufacturing, and assembly of Apple products worldwide3. In addition, we publish the following4:


People and Environment in our Supply Chain Report

Environmental Progress Report

Product Environmental Reports

Material Impact Profiles

Statement on Efforts to Combat Human Slavery and Trafficking

Supplier List

Smelter and Refiner List


3 All referenced reports can be found at apple.com/supplier-responsibility
4 All referenced reports can be found via the following links:
apple.com/supplier-responsibility
apple.com/environment

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Determination

As of December 31, 2022, based on our due diligence efforts, including the information provided by our suppliers, Apple believes that the smelters and refiners listed in Annex I were used to process 3TG in our products at some point during 2022. Through our smelter and refiner identification and validation process, we have identified a total of 261 smelters and refiners that processed 3TG in our supply chain during 2022. Of these 261 smelters and refiners:


23 were removed including those that: previously participated in but subsequently stopped participating in an independent third-party audit program; were not willing to participate in or complete an independent third-party audit within given timelines; exceeded independent third-party audit corrective action plan timelines; or failed to meet Apple’s Supplier Code, Responsible Sourcing Standard, or 3TG mineral requirements.

238 remained in Apple’s 3TG supply chain as of December 31, 2022.

Based on the information provided by our suppliers, smelters, and refiners, as well as from third-party audit programs, Apple believes that the 3TG contained in our products originated from the countries listed in Annex II, as well as from recycled and scrap sources. Apple’s reasonable country of origin inquiry is based on third-party audit information and, to the extent the information has not been made available through audit programs, via the collection of additional information by Apple using other sources such as the United States of America Geological Survey. To the extent reasonably possible, we have documented the country of origin of identified smelters and refiners based on information received through the RMI’s RMAP, the LBMA, a survey of smelters and refiners, or third-party reviews of publicly available information. However, some country of origin information has not been audited by a third-party because, for example, applicable smelters and refiners ceased operations before completing an independent third-party audit. Therefore, Apple does not have sufficient information to conclusively determine the countries of origin of the 3TG in all of our products.

Of all 238 smelters and refiners of 3TG determined to be in our supply chain as of December 31, 2022, Apple found no reasonable basis for concluding that any such smelter or refiner sourced 3TG that directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.

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About This Report

This report has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 to December 31, 2022. Information contained on the websites referenced in this report is not part of, or incorporated by reference into, this filing. Information presented in this report is based on calendar years.

Apple believes it constitutes a “downstream” company in that Apple or its suppliers purchase cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold related materials after processing by smelters or refiners. In addition, Apple does not directly purchase or procure primary sourced minerals from mine sites.

This report relates to the process undertaken in accordance with OECD Due Diligence Guidance for Apple products that were manufactured, or contracted to be manufactured, during 2022 and that contain 3TG. These product categories are iPhone®, Mac®, iPad®, AirPods®, Apple TV®, Apple Watch®, Beats® products, HomePod®, HomePod mini®, iPod touch®, Apple Card®, and all Apple® accessories. Third-party products that Apple retails but that it does not manufacture or contract to manufacture are outside the scope of this report.

The smelters and refiners identified in this report include those producing inputs for service or spare parts contracted for manufacturing in 2022 for use in connection with the subsequent service of previously-sold products, including products serviced in subsequent years using those parts. This report does not include smelters of tin, tantalum, or tungsten or refiners of gold where such 3TG are included in end-of-life service parts for products that Apple no longer manufactures or contracts to manufacture.

This report’s use of the terms “smelters” and “refiners” refers to the facilities processing primary 3TG to retail purity. Apple suppliers have in some cases reported smelters and refiners that Apple believes are not operational or may have been misidentified as smelters and refiners. As a result, Apple continues to conduct independent research on smelters and refiners and to work with suppliers throughout its supply chain to revalidate, improve, and refine their reported information, taking into account supply chain fluctuations and other changes in status or scope and relationships over time. “Identified” smelters and refiners are those that (i) have been reported in a supplier’s CMRT, (ii) Apple believes are currently operational, were operational at some point during the applicable year, or, while inoperative, capable of re-engagement with minimal delay or effort, and (iii) otherwise meet the definition of a smelter or refiner, provided that Apple may determine to treat a third-party as an identified smelter or refiner notwithstanding a reclassification of such third-party or a change in its status. As part of its reasonable country of origin inquiry, Apple has determined that certain suppliers are utilizing at least some 3TG from secondary materials (i.e., scrap or recycled materials). Facilities that process only secondary materials (i.e., scrap or recycled materials) are excluded from the scope of this report.

Participating smelters and refiners are those that have agreed to participate in or have been found compliant with independent third-party conflict minerals audit programs confirming their 3TG sourcing practices. Such programs may also include audits of traceability requirements, conformity with the OECD Due Diligence Guidance, management systems, and/or risk assessments. Independent third-party 3TG audit programs include the RMI’s RMAP and the LBMA’s Responsible Gold Program. Throughout this report, the audits by these programs are included in references to “independent third-party audit” programs.

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ANNEX I: Smelter and Refiner List

List of identified smelters and refiners of 3TG reported in Apple’s supply chain as of December 31, 2022.

Conflict Mineral
Name of Smelter or Refiner
Location of
Smelter or Refiner
Tungsten
A.L.M.T. Corp. *
Japan
Tungsten
ACL Metais Eireli **
Brazil
Tungsten
Asia Tungsten Products Vietnam Ltd.
Vietnam
Tungsten
China Molybdenum Tungsten Co., Ltd.
China mainland
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China mainland
Tungsten
Cronimet Brasil Ltda
Brazil
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
China mainland
Tungsten
Fujian Xinlu Tungsten Co., Ltd.
China mainland
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
China mainland
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China mainland
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd. *
China mainland
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China mainland
Tungsten
Global Tungsten & Powders Corp. *
United States
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China mainland
Tungsten
H.C. Starck Tungsten GmbH *
Germany
Tungsten
Hubei Green Tungsten Co., Ltd.
China mainland
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China mainland
Tungsten
Hunan Jintai New Material Co., Ltd.
China mainland
Tungsten
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
China mainland
Tungsten
Japan New Metals Co., Ltd. *
Japan
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China mainland
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China mainland
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China mainland
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China mainland

Apple Inc. | 2022 Conflict Minerals Report | 15

Conflict Mineral Name of Smelter or Refiner Location of
Smelter or Refiner
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China mainland
Tungsten
Kennametal Fallon
United States
Tungsten
Kennametal Huntsville *
United States
Tungsten
KGETS Co., Ltd. *
South Korea
Tungsten
Lianyou Metals Co., Ltd. *
Taiwan
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China mainland
Tungsten
Masan High-Tech Materials *
Vietnam
Tungsten
Moliren Ltd. **, ***
Russia
Tungsten
Niagara Refining LLC
United States
Tungsten
Philippine Chuangxin Industrial Co., Inc. *
Philippines
Tungsten
TANIOBIS Smelting GmbH & Co. KG *
Germany
Tungsten
Wolfram Bergbau und Hütten AG
Austria
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China mainland
Tungsten
Xiamen Tungsten Co., Ltd. *
China mainland
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China mainland
Tin
Alpha *
United States
Tin
Aurubis Beerse
Belgium
Tin
Aurubis Berango *
Spain
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. *
China mainland
Tin
Chifeng Dajingzi Tin Industry Co., Ltd. *
China mainland
Tin
China Tin Group Co., Ltd. *
China mainland
Tin
CRM Synergies *
Spain
Tin
CV Ayi Jaya
Indonesia
Tin
CV Venus Inti Perkasa
Indonesia
Tin
Dowa *
Japan
Tin
EM Vinto
Bolivia
Tin
Estanho de Rondonia S.A.
Brazil
Tin
Fabrica Auricchio Industria e Comercio Ltda.
Brazil
Tin
Fenix Metals *
Poland
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China mainland
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd. **
China mainland
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. *
China mainland
Tin
HuiChang Hill Tin Industry Co., Ltd.
China mainland
Tin
Jiangxi New Nanshan Technology Ltd. *
China mainland
Tin
Luna Smelter, Ltd.
Rwanda
Tin
Ma'anshan Weitai Tin Co., Ltd. *
China mainland

Apple Inc. | 2022 Conflict Minerals Report | 16

Conflict Mineral Name of Smelter or Refiner
Location of
Smelter or Refiner
Tin
Magnu's Minerais Metais e Ligas Ltda. *
Brazil
Tin
Malaysia Smelting Corporation (MSC) *
Malaysia
Tin
Metallic Resources, Inc. *
United States
Tin
Mineração Taboca S.A.
Brazil
Tin
Minsur
Peru
Tin
Mitsubishi Materials Corporation *
Japan
Tin
O.M. Manufacturing (Thailand) Co., Ltd. *
Thailand
Tin
O.M. Manufacturing Philippines, Inc. *
Philippines
Tin
Operaciones Metalurgicas S.A.
Bolivia
Tin
PT Aries Kencana Sejahtera
Indonesia
Tin
PT Artha Cipta Langgeng
Indonesia
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Tin
PT Babel Inti Perkasa
Indonesia
Tin
PT Babel Surya Alam Lestari
Indonesia
Tin
PT Bangka Serumpun
Indonesia
Tin
PT Bukit Timah
Indonesia
Tin
PT Cipta Persada Mulia
Indonesia
Tin
PT Menara Cipta Mulia
Indonesia
Tin
PT Mitra Stania Prima
Indonesia
Tin
PT Mitra Sukses Globalindo
Indonesia
Tin
PT Prima Timah Utama
Indonesia
Tin
PT Putera Sarana Shakti (PT PSS)
Indonesia
Tin
PT Rajawali Rimba Perkasa
Indonesia
Tin
PT Rajehan Ariq
Indonesia
Tin
PT Refined Bangka Tin
Indonesia
Tin
PT Sariwiguna Binasentosa
Indonesia
Tin
PT Stanindo Inti Perkasa
Indonesia
Tin
PT Sukses Inti Makmur
Indonesia
Tin
PT Timah Nusantara
Indonesia
Tin
PT Timah Tbk Kundur
Indonesia
Tin
PT Timah Tbk Mentok
Indonesia
Tin
PT Tinindo Inter Nusa **
Indonesia
Tin
PT Tommy Utama
Indonesia
Tin
Resind Indústria e Comércio Ltda.
Brazil
Tin
Rui Da Hung *
Taiwan
Tin
Soft Metais Ltda. **
Brazil
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
Vietnam
Tin
Thaisarco *
Thailand
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
China mainland

Apple Inc. | 2022 Conflict Minerals Report | 17

Conflict Mineral Name of Smelter or Refiner
Location of
Smelter or Refiner
Tin
Tin Technology & Refining *
United States
Tin
White Solder Metalurgia e Mineração Ltda.
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China mainland
Tantalum
AMG Brasil
Brazil
Tantalum
Changsha South Tantalum Niobium Co., Ltd. *
China mainland
Tantalum
D Block Metals, LLC *
United States
Tantalum
F&X Electro-Materials Ltd.
China mainland
Tantalum
FIR Metals & Resource Ltd. *
China mainland
Tantalum
Global Advanced Metals Aizu *
Japan
Tantalum
Global Advanced Metals Boyertown *
United States
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.**
China mainland
Tantalum
H.C. Starck Hermsdorf GmbH *
Germany
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China mainland
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China mainland
Tantalum
Jiangxi Tuohong New Raw Material
China mainland
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China mainland
Tantalum
Jiujiang Tanbre Co., Ltd. *
China mainland
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China mainland
Tantalum
KEMET de Mexico *
Mexico
Tantalum
Materion Newton Inc. *
United States
Tantalum
Meta Materials **
North Macedonia
Tantalum
Metallurgical Products India Pvt., Ltd. *
India
Tantalum
Mineração Taboca S.A.
Brazil
Tantalum
Mitsui Mining and Smelting Co., Ltd. *
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China mainland
Tantalum
NPM Silmet AS *
Estonia
Tantalum
QuantumClean *
United States
Tantalum
Resind Indústria e Comércio Ltda.
Brazil
Tantalum
RFH Yancheng Jinye New Material Technology Co., Ltd.
China mainland
Tantalum
Taki Chemical Co., Ltd. *
Japan
Tantalum
TANIOBIS Co., Ltd.
Thailand
Tantalum
TANIOBIS GmbH *
Germany
Tantalum
TANIOBIS Japan Co., Ltd.
Japan
Tantalum
TANIOBIS Smelting GmbH & Co. KG *
Germany
Tantalum
Telex Metals *
United States

Apple Inc. | 2022 Conflict Minerals Report | 18

Conflict Mineral Name of Smelter or Refiner
Location of
Smelter or Refiner
Tantalum
Ulba Metallurgical Plant JSC *
Kazakhstan
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
China mainland
Tantalum
XinXing Haorong Electronic Material Co., Ltd.
China mainland
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
China mainland
Gold
8853 S.p.A. **, ***
Italy
Gold
Advanced Chemical Company *
United States
Gold
Agosi AG
Germany
Gold
Aida Chemical Industries Co., Ltd. *
Japan
Gold
Al Etihad Gold Refinery DMCC *
United Arab Emirates
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Brazil
Gold
Argor-Heraeus S.A.
Switzerland
Gold
Asahi Pretec Corp.
Japan
Gold
Asahi Refining Canada Ltd.
Canada
Gold
Asahi Refining USA Inc.
United States
Gold
Asaka Riken Co., Ltd. *
Japan
Gold
Aurubis AG
Germany
Gold
Bangalore Refinery *
India
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Boliden AB
Sweden
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Cendres + Metaux S.A. **, ***
Switzerland
Gold
Chimet S.p.A.
Italy
Gold
Chugai Mining *
Japan
Gold
DODUCO Contacts and Refining GmbH **
Germany
Gold
Dowa *
Japan
Gold
DSC (Do Sung Corporation) *
South Korea
Gold
Eco-System Recycling Co., Ltd. East Plant *
Japan
Gold
Eco-System Recycling Co., Ltd. North Plant *
Japan
Gold
Eco-System Recycling Co., Ltd. West Plant *
Japan
Gold
Emirates Gold DMCC *
United Arab Emirates
Gold
Geib Refining Corporation *
United States
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
China mainland
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
China mainland
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Germany GmbH Co. KG *
Germany

Apple Inc. | 2022 Conflict Minerals Report | 19

Conflict Mineral Name of Smelter or Refiner
Location of
Smelter or Refiner
Gold
Heraeus Metals Hong Kong Ltd.
China mainland
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China mainland
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Gold
Istanbul Gold Refinery
Turkey
Gold
Italpreziosi
Italy
Gold
Japan Mint
Japan
Gold
Jiangxi Copper Co., Ltd.
China mainland
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
Kazzinc
Kazakhstan
Gold
Kennecott Utah Copper LLC
United States
Gold
KGHM Polska Miedz Spólka Akcyjna
Poland
Gold
Kojima Chemicals Co., Ltd. *
Japan
Gold
Korea Zinc Co., Ltd. *
South Korea
Gold
L'Orfebre S.A. *
Andorra
Gold
LS-NIKKO Copper Inc.
South Korea
Gold
LT Metal Ltd. *
South Korea
Gold
Materion *
United States
Gold
Matsuda Sangyo Co., Ltd.
Japan
Gold
Metal Concentrators SA (Pty) Ltd. ***
South Africa
Gold
Metalor Technologies (Hong Kong) Ltd.
China mainland
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
Gold
Metalor Technologies (Suzhou) Ltd.
China mainland
Gold
Metalor Technologies S.A.
Switzerland
Gold
Metalor USA Refining Corporation
United States
Gold
Metalúrgica Met-Mex Peñoles S.A. de C.V.
Mexico
Gold
Mitsubishi Materials Corporation *
Japan
Gold
Mitsui Mining and Smelting Co., Ltd. *
Japan
Gold
MKS PAMP SA
Switzerland
Gold
MMTC-PAMP India Pvt., Ltd.
India
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Turkey
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Gold
NH Recytech Company *
South Korea
Gold
Nihon Material Co., Ltd.
Japan
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt
GmbH ***
Austria
Gold
Ohura Precious Metal Industry Co., Ltd. *
Japan
Gold
Planta Recuperadora de Metales SpA
Chile
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia

Apple Inc. | 2022 Conflict Minerals Report | 20

Conflict Mineral Name of Smelter or Refiner
Location of
Smelter or Refiner
Gold
PX Précinox S.A.
Switzerland
Gold
Rand Refinery (Pty) Ltd.
South Africa
Gold
Remondis PMR B.V. *
Netherlands
Gold
Royal Canadian Mint
Canada
Gold
SAAMP ***
France
Gold
Safimet S.p.A **, ***
Italy
Gold
SAFINA A.S. *
Czechia
Gold
Samduck Precious Metals *, **
South Korea
Gold
SEMPSA Joyería Platería S.A.
Spain
Gold
Shandong Gold Smelting Co., Ltd.
China mainland
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China mainland
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China mainland
Gold
Singway Technology Co., Ltd. **
Taiwan
Gold
Solar Applied Materials Technology Corp.
Taiwan
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Gold
SungEel HiMetal Co., Ltd. *
South Korea
Gold
T.C.A S.p.A
Italy
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Gold
Tokuriki Honten Co., Ltd.
Japan
Gold
TOO Tau-Ken-Altyn
Kazakhstan
Gold
Torecom *
South Korea
Gold
Umicore Precious Metals Thailand ***
Thailand
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
Gold
United Precious Metal Refining, Inc. *
United States
Gold
Valcambi S.A.
Switzerland
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
Gold
WIELAND Edelmetalle GmbH
Germany
Gold
Yamakin Co., Ltd. *
Japan
Gold
Yokohama Metal Co., Ltd. *
Japan
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China mainland

* The smelter/refiner is believed to process at least some 3TG from recycled or scrap sources.
** The smelter/refiner has changed its compliance or operational status since December 31, 2022.
*** The smelter/refiner continues to be in the process of removal as of the filing of this report and/or is no longer approved to be in Apple’s supply chain.

Apple Inc. | 2022 Conflict Minerals Report | 21

ANNEX II: Countries of Origin of 3TG

Argentina
Georgia
Panama
Australia
Germany
Papua New Guinea
Austria
Ghana
Peru
Azerbaijan
Guatemala
Philippines
Belgium
Guinea
Portugal
Benin
Guyana
Russia**
Bolivia
Honduras
Rwanda*
Botswana
Indonesia
Saudi Arabia
Brazil
Italy
Senegal
Burkina Faso
Japan
Serbia
Burundi*
Kazakhstan
Sierra Leone
Cambodia
Kenya
Slovakia
Canada
Kyrgyzstan
South Africa
Chile
Laos
South Korea
China
Liberia
Spain
Colombia
Malaysia
Sri Lanka
Congo, Democratic Republic of the*
Mali
Sudan
Côte d’Ivoire
Mauritania
Suriname
Czech Republic
Mexico
Sweden
Dominica
Mongolia
Taiwan
Dominican Republic
Morocco
Tanzania*
Ecuador
Mozambique
Thailand
Egypt
Myanmar (Burma)
Turkey
Eritrea
Namibia
United Kingdom
Eswatini
New Zealand
United States
Ethiopia
Nicaragua
Uzbekistan
Fiji
Niger
Venezuela
Finland
Nigeria
Vietnam
France
Norway
Zambia*
French Guiana
Oman
Zimbabwe

* The DRC or an adjoining country.
** Sourcing ceased during the calendar year in accordance with United States law.


Apple Inc. | 2022 Conflict Minerals Report | 22