EX-1.01 2 exhibit101.htm HASBRO, INC. CONFLICT MINERALS REPORT Document

Exhibit 1.01 – Conflict Minerals Report (CMR)

Conflict Minerals Report of Hasbro, Inc.

Section 1: Introduction
 
This is the Conflict Minerals Report of Hasbro, Inc. (herein referred to as "Hasbro," the Company," "we," "us," or "our ") for calendar year 2019 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1"). Certain terms in this report are defined in Rule 13p-1 and Form SD and the reader is invited to refer to those sources for complete definitions of these terms.

Hasbro marketed products based on owned, controlled and licensed intellectual properties within our brand architecture under the following four brand categories during 2019, each of which may include products containing 3TG: (1) Franchise Brands; (2) Partner Brands; (3) Hasbro Gaming; and (4) Emerging Brands. Examples of where 3TG can be found in our products are shown below.  In all cases, those metals are inaccessible to the consumer because they are located within internal components. As noted above, eOne’s products were not in scope for the 2019 conflict minerals report due to the fact that all of their products were licensed to third parties, eOne did not manufacture any products and had no contract manufacturers (as defined below).

Franchise Brands: Franchise Brands are Hasbro’s most significant owned or controlled properties which we believe have the ability to deliver significant revenues and growth over the long-term. Our seven Franchise Brands are BABY ALIVE, MAGIC: THE GATHERING, MONOPOLY, MY LITTLE PONY, NERF, PLAY-DOH and TRANSFORMERS. An example of 3TG used in Franchise Brands is the NERF Ultra One Motorized Blaster which contains tin in the solder and pins in the Printed Circuit Board Assembly. Gold is also found in the plating for the Printed Circuit Board Assembly.

Partner Brands: Partner Brands include those brands licensed by Hasbro from other parties for which Hasbro develops toy and game products. Significant Partner Brands include MARVEL, including SPIDER-MAN and THE AVENGERS, STAR WARS, DISNEY PRINCESS and DISNEY FROZEN, DISNEY’S DESCENDANTS, BEYBLADE, DREAMWORKS’ TROLLS and SESAME STREET. Partner brands MARVEL, STAR WARS, DISNEY’S DESCENDANTS, DISNEY PRINCESS and DISNEY FROZEN are all owned by The Walt Disney Company (“Disney”).

Hasbro Gaming: Hasbro continues to transform game play through our strong portfolio of Gaming Brands, digital integration, the mining of social media trends to garner consumer insights and capitalize on popular gaming themes, and the rapid introduction of innovative new gaming brands and play experiences. Hasbro gaming includes brands such as CONNECT 4, DUNGEONS & DRAGONS, JENGA, THE GAME OF LIFE, OPERATION, SCRABBLE, TRIVIAL PURSUIT and TWISTER. In addition, Hasbro’s games portfolio also includes new social games brands as well as many other well-known game brands. An example of 3TG used in Hasbro Gaming is the Botched Operation Board Game which includes Tin in the electronic wire.

Emerging Brands: Emerging Brands are those owned or controlled Hasbro brands which have not achieved Franchise Brand status, but many of which the Company believes have the potential to do so over time with investment and further development. Hasbro Emerging Brands include brands such as LITTLEST PET SHOP, EASY BAKE, FURBY, FURREAL FRIENDS, PLAYSKOOL, and most recently, the POWER RANGERS brand, which we purchased in 2018. The Emerging Brands portfolio also includes the LOST



KITTIES brand, as well as brands currently being developed by the Company and other brands not captured in the other three categories. Commencing in fiscal 2020, eOne brands, including PEPPA PIG, PJ MASKS and RICKY ZOOM, will be reported in our Emerging Brands category. An example of 3TG used in Emerging Brands is the PLAYSKOOL Play Favorites Lullaby Gloworm Toy which includes Tin in the solder and plating in the Printed Circuit Board Assembly. Gold is found in the electronic wire and Tungsten in the Integrated Circuit in the Printed Circuit Board Assembly.

Section 2: Due diligence framework

Hasbro designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (OECD, 2016) ("OECD Framework").

Section 3: Due diligence measures undertaken

Hasbro's due diligence efforts for 2019 included the following steps:

Establish company management systems:  

Continued to communicate our conflict minerals policy to all contract manufacturers, ensuring they were made aware that Hasbro’s policy does not preclude them from sourcing conflict free minerals from the DRC or the adjoining countries, but is intended to encourage responsible sourcing. To summarize our conflict minerals policy, Hasbro requires suppliers to fully respond to our information requests, provide a list of smelter or refiner (“Smelters”) names, source from conflict free Smelters as determined by a third-party audit program such as the Responsible Minerals Initiative (RMI), London Bullion Market Association, or any other recognized equivalent, and to initiate contact with non-audited Smelters to persuade such Smelters to undergo a Responsible Minerals Assurance Process (“RMAP”) audit of their due diligence practices.

Continued operating under our internal governance structure created in 2013, which is overseen by members of our senior management team and includes a cross functional conflict minerals steering committee and working group comprised of representatives from the Global Government and Regulatory Affairs, Corporate Social Responsibility, Global Sourcing, Legal, Finance and Internal Audit functions of Hasbro. The Senior Director, Global Ethical Sourcing oversees the program and its implementation.

Provided surveyed contract manufacturers with training presentations that included an overview of the conflict minerals rule under the Dodd-Frank Act, as well as trainings on how to complete the survey. The communication and training specified that contract manufacturers should not ban sourcing 3TG from the DRC region in order to maintain support of socio-economic regional development, so long as the contract manufacturers are utilizing only conformant Smelters. In addition, Hasbro directly reviewed a sample of contract manufacturer conflict minerals policies to ensure that they included the minimum policy requirements and did not ban minerals from the DRC region.




Continued to engage with contract manufacturers that Hasbro believed were most likely to supply products containing 3TG, informing them that Hasbro is subject to Section 1502 of the Dodd Frank Act and that their cooperation in responding to the survey is required.

Conducted supply chain surveys using a third-party platform based on the RMI Conflict Minerals Reporting Template (CMRT). Surveys were sent to the 32 contract manufacturers of products identified during our applicability assessment as potentially containing 3TG. 

Engaged as necessary with unaudited Smelters by sending a letter requiring that they undergo the RMI audit process in order to demonstrate compliance with the Hasbro Conflict Minerals policy.

Continued to maintain our grievance mechanism to enable the reporting of grievances via the Hasbro Conflict Minerals email box.

Continued to retain conflict minerals program documentation for 5 years.

Identify and assess risks in the supply chain
        
Contract manufacturers surveyed were asked to identify Smelters that process conflict minerals contained in our products, including country of origin of the 3TG, based on the RMI CMRT. Hasbro required vendors to provide information on Hasbro products only (“product-level declarations”).

Every survey was entered into our third-party technology platform and then reviewed by the technology platform, a third-party consultant and, where deemed necessary, Hasbro personnel.
        
Non-responsive contract manufacturers and survey responses that we believed to be incomplete or inconsistent were identified and resolved to achieve 100% complete/consistent responses.

Reasons for follow-up with contract manufacturers included, but were not limited to, that the contract manufacturer did not provide a complete or accurate Smelter list, did not receive complete 3TG sourcing information from all of its relevant suppliers, the response was not specific to Hasbro products only, or inconsistencies were identified in the answers contract manufacturers provided within the survey.

Smelters identified by contract manufacturers surveyed by Hasbro were compared against lists maintained by the technology platform provider, the current Smelter lists from the RMAP and our external consultant. This was done to confirm the validity of Smelters and the plausibility of the countries of origin.

Reviewed contract manufacturers policies and procedures directly, in addition to conducting Responsible Business Alliance (RBA) audits, in order to ensure they meet minimum requirements.

Conducted remote visits to a contract manufacturers and Smelters in order to learn more about effective implementation and challenges to responsible mineral use.




Design and implement a strategy to respond to identified risks

Executive members of the steering committee met three times during the 2019 conflict minerals due diligence period to review the results of the applicability assessment, survey review and associated risks.

Contract manufacturers that did not respond to Hasbro's initial survey request were sent escalation letters directing that they provide the information requested. In cases where additional follow-up was needed, emails were sent by the technology platform, by our third-party consultant and contact was made by Hasbro management.

Contract manufacturers that provided survey responses identifying Smelters not on the RMI’s active or compliant Smelter lists were sent corrective action letters, as necessary, noting that Hasbro requires them to source 3TG from RMAP-compliant Smelters. In the corrective action letters, Hasbro requested that contract manufacturers that source from non-RMAP-compliant Smelters verify if the Smelters are in the Hasbro supply chain. If the Smelter was not in the supply chain, they were required to update their response and remove the Smelter from their list. If the Smelter was is in the supply chain, contract manufacturers were instructed to contact the respective Smelters and require them to participate in a recognized conflict minerals audit program and provide documentation of this to Hasbro. If they were not able to obtain Smelter cooperation, the contract manufacturers were reminded of the Hasbro conflict minerals sourcing policy and requirement to remove the unaudited Smelter from their supply chain for Hasbro Products.

Carry out independent third-party audit of Smelter due diligence practices
Hasbro is a downstream consumer of 3TG and is many steps removed from Smelters that provide minerals and ores. Hasbro does not purchase raw minerals or ores and does not directly purchase 3TG. Therefore, Hasbro does not perform or direct audits of Smelters within the supply chain. Rather, as a member of the RMI we rely on and support the audits carried out by that organization. Those audits confirm that Smelters conform to the OECD Due Diligence Guidance for their own sourcing practices by reviewing the Smelter sourcing/conflict minerals policy and verifying implementation.

Report annually on supply chain due diligence

This report and the associated Form SD are available online at the following internet address http://csr.hasbro.com/has19-conflict-minerals-report.php.

Section 4: Determination
Based on the due diligence described above for 2019, Hasbro was able to determine that some of 3TG used by our contract manufacturers for Hasbro products did originate in the Covered Countries and/or from recycled or scrap sources.

As a downstream consumer of 3TG, Hasbro must rely on its contract manufacturers to gather information about Smelters in the supply chain. Hasbro received responses from 100% of the contract manufacturers it surveyed (the survey included all 32 contract manufacturers identified as potentially incorporating 3TG into products supplied to Hasbro). The relevant contract manufacturers declared a total of 161 unique Smelter



names as the source of 3TG in Hasbro products.  Of the 161 declared Smelters, 161 (100%) were designated as conflict free under the RMAP for 2019.  However, we are unable to link specific Smelters to our applicable products.

The results of our due diligence of the 3TG used in our in-scope products are noted below:
2019 SmeltersTinTungstenTantalumGoldTotal
Total number of Smelters71301941161
Number (%) of Smelters listed as conformant by RMI71(100%)30 (100%)19 (100%)41(100%)161 (100%)
Number (%) of Smelters not sourcing from Covered Countries (RMI)69 (97%)25 (83%)10 (52%)17 (41%)121 (75%)
Number (%) of Smelters that are conformant or not sourcing from the Covered Countries
71(100%)30 (100%)19 (100%)41 (100%)161 (100%)

Status of Identified Smelters
image1.jpg




Set forth in Annex 1 is a list of the unique Smelter names disclosed to us by contract manufacturers broken down by metal. Based on the information provided by Hasbro’s contract manufacturers, from the RMAP and other sources, Hasbro believes that the countries of origin of the 3TG contained in some of our products might include Covered Countries, as well as recycled and scrap sources, but we are not able to make that determination at this time for all products or sources. The aggregated list of Countries of Origin based on RMI Country of Origin list and the Smelters reported to us by our contract manufacturers is set forth in Annex 2.

The Hasbro sourcing model is designed to provide Hasbro flexibility to move production of products among contract manufacturers based on contract manufacturer capacities and product demand.  Consequently, there may be instances where the same Hasbro branded product is manufactured by multiple contract manufacturers, which increases the complexity in linking a product with specific Smelters.

Section 5: Independent audit

Hasbro has determined that for 2019 an independent private sector audit is not required.

Section 6: Continuous Improvement efforts to mitigate risk

Hasbro took the following steps to improve our program overall, the number and quality of responses in the 2019 compliance period and to mitigate risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:

Hasbro’s Senior Vice President, Global Government Affairs & Corporate Social Responsibility issued a response request letter to all contract manufacturers for the 2019 reporting year survey.

Achieved a 100% response rate from all applicable contract manufacturers and resolved 100% of inconsistent responses from contract manufacturers.

Continued to use contract terms and conditions for new contracts requiring contract manufacturers to respond to inquiries regarding 3TG in a timely manner, such as through incorporation of conflict minerals requirements into Hasbro’s Vendor Manual, which is incorporated into Hasbro’s Master Agreements with contract manufacturers.

Rather than relying on contract manufacturers to provide country of origin information, we undertook our own efforts to identify countries of origin using our third-party technology provider. Our external consultant conducted a further plausibility review to ensure that the identified countries have known 3TG ore mining operations or proven mineral reserves.

Continued to work with contract manufacturers to help them understand the importance of this initiative to Hasbro and to encourage their participation in the conflict minerals survey through trainings for relevant contract manufacturers. Since most of our contract manufacturers are based in the People’s Republic of China, Hasbro conducted in-person training sessions with our Chinese contract manufacturers, as well as virtual trainings for other countries. We believe this resulted in improvements in identifying Smelters applicable to Hasbro.



In the next compliance period, Hasbro intends to take the following steps to further improve the number and quality of contract manufacturer responses and continue to mitigate the risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:

Continue to use contract terms and conditions for new contracts requiring contract manufacturers to respond to inquiries regarding conflict minerals in a timely manner.

Continue engaging with contract manufacturers, with the objective of maintaining a 100% response rate from all applicable contract manufacturers and obtaining complete lists.

Continue to work with contract manufacturers to identify to the extent possible the source of 3TG used in Hasbro's products.

Continue to build capabilities with active and new contract manufacturers by helping them understand the importance of this initiative to Hasbro and to encourage their participation through contract manufacturer trainings.

Continue to require that any 3TG included in our products be sourced from Smelters that are identified as conflict free through the RMAP or an audit program with which RMAP has a mutual recognition agreement.

Continue working with our contract manufacturers to better understand how individual sources of 3TG may apply to our individual product categories.

As a result of becoming a full RBA member in October 2016, Hasbro will continue to utilize an annual RBA Validated Audit Process (VAP) or Customer Managed Audit (CMA) audit for 100% of our contract manufacturers, which includes verifying that a manufacturer has a documented, effective and communicated conflict minerals policy and management program.

Continue to emphasize that Hasbro’s policy does not preclude contract manufacturers from sourcing conflict free minerals from the DRC and adjoining countries and communicate this policy provision to contract manufacturers.

Certain statements in this Conflict Minerals Report contain "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements include expectations concerning the Company's future actions to engage contract manufacturers, to identify to the extent possible the source of 3TG in its products and to take other actions regarding its product sourcing. The Company's actual actions or results may differ materially from those expected or anticipated in the forward-looking statements due to both known and unknown risks and uncertainties including, but not limited to, decisions to make changes in the Company’s continual improvement efforts and delays or difficulties in engaging contract manufacturers and identifying the source of 3TG contained in the Company’s products.







ANNEX 1
 
 Identified Smelters
(of the 161 identified Smelters, all 161 were RMAP conformant for 2019)*
MetalOfficial Smelter NameRMI Smelter IDSmelter Country
Gold8853 S.p.A.CID002763Italy
GoldAida Chemical Industries Co., Ltd.CID000019Japan
GoldArgor-Heraeus S.A.CID000077Switzerland
GoldAsahi Refining Canada Ltd.CID000924Canada
GoldAsahi Refining USA Inc.CID000920United States
GoldAU Traders and RefinersCID002850South Africa
GoldCendres + Metaux S.A.CID000189Switzerland
GoldDS PRETECH Co., Ltd.CID003195Korea, Republic of
GoldGeib Refining CorporationCID002459United States
GoldGold Refinery of Zijin Mining Group Co., Ltd.CID002243China
GoldHeraeus Metals Hong Kong Ltd.CID000707China
GoldHeraeus Precious Metals GmbH & Co. KGCID000711Germany
GoldItalpreziosiCID002765Italy
GoldJiangxi Copper Co., Ltd.CID000855China
GoldJX Nippon Mining & Metals Co., Ltd.CID000937Japan
GoldKennecott Utah Copper LLCCID000969United States
GoldKojima Chemicals Co., Ltd.CID000981Japan
GoldLT Metal Ltd.CID000689Korea, Republic of
GoldMarsam MetalsCID002606Brazil
GoldMaterionCID001113United States
GoldMatsuda Sangyo Co., Ltd.CID001119Japan
GoldMetalor Technologies (Hong Kong) Ltd.CID001149China
GoldMetalor Technologies (Singapore) Pte., Ltd.CID001152Singapore
GoldMetalor Technologies S.A.CID001153Switzerland
GoldMetalor USA Refining CorporationCID001157United States
GoldMetalurgica Met-Mex Penoles S.A. De C.V.CID001161Mexico
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHCID002779Austria
GoldPAMP S.A.CID001352Switzerland
GoldRand Refinery (Pty) Ltd.CID001512South Africa
GoldSAAMPCID002761France
GoldSafimet S.p.ACID002973Italy
GoldSEMPSA Joyeria Plateria S.A.CID001585Spain



GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CID001622China
GoldSingway Technology Co., Ltd.CID002516Taiwan
GoldTanaka Kikinzoku Kogyo K.K.CID001875Japan
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CID001916China
GoldUmicore Brasil Ltda.CID001977Brazil
GoldUnited Precious Metal Refining, Inc.CID001993United States
GoldValcambi S.A.CID002003Switzerland
GoldWestern Australian Mint (T/a The Perth Mint)CID002030Australia
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCID002224China
TantalumChangsha South Tantalum Niobium Co., Ltd.CID000211China
TantalumD Block Metals, LLCCID002504United States
TantalumExotech Inc.CID000456United States
TantalumF&X Electro-Materials Ltd.CID000460China
TantalumFIR Metals & Resource Ltd.CID002505China
TantalumGlobal Advanced Metals AizuCID002558Japan
TantalumGlobal Advanced Metals BoyertownCID002557United States
TantalumH.C. Starck Co., Ltd.CID002544Thailand
TantalumH.C. Starck Hermsdorf GmbHCID002547Germany
TantalumH.C. Starck Inc.CID002548United States
TantalumH.C. Starck Ltd.CID002549Japan
TantalumH.C. Starck Smelting GmbH & Co. KGCID002550Germany
TantalumH.C. Starck Tantalum and Niobium GmbHCID002545Germany
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CID002492China
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CID000914China
TantalumJiujiang Tanbre Co., Ltd.CID000917China
TantalumNingxia Orient Tantalum Industry Co., Ltd.CID001277China
TantalumTaki Chemical Co., Ltd.CID001869Japan
TantalumUlba Metallurgical Plant JSCCID001969Kazakhstan
TinAlphaCID000292United States
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CID000228China
TinChifeng Dajingzi Tin Industry Co., Ltd.CID003190China
TinChina Tin Group Co., Ltd.CID001070China
TinDowaCID000402Japan
TinEM VintoCID000438Bolivia
TinFenix MetalsCID000468Poland
TinGejiu Kai Meng Industry and Trade LLCCID000942China



TinGejiu Non-Ferrous Metal Processing Co., Ltd.CID000538China
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CID001908China
TinGejiu Zili Mining And Metallurgy Co., Ltd.CID000555China
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CID003116China
TinGuanyang Guida Nonferrous Metal Smelting PlantCID002849China
TinHuiChang Hill Tin Industry Co., Ltd.CID002844China
TinHuichang Jinshunda Tin Co., Ltd.CID000760China
TinJiangxi New Nanshan Technology Ltd.CID001231China
TinMagnu's Minerais Metais e Ligas Ltda.CID002468Brazil
TinMalaysia Smelting Corporation (MSC)CID001105Malaysia
TinMelt Metais e Ligas S.A.CID002500Brazil
TinMetallic Resources, Inc.CID001142United States
TinMetallo Belgium N.V.CID002773Belgium
TinMetallo Spain S.L.U.CID002774Spain
TinMineracao Taboca S.A.CID001173Brazil
TinMinsurCID001182Peru
TinMitsubishi Materials CorporationCID001191Japan
TinO.M. Manufacturing (Thailand) Co., Ltd.CID001314Thailand
TinO.M. Manufacturing Philippines, Inc.CID002517Philippines
TinOperaciones Metalurgicas S.A.CID001337Bolivia
TinPT Artha Cipta LanggengCID001399Indonesia
TinPT ATD Makmur Mandiri JayaCID002503Indonesia
TinPT Menara Cipta MuliaCID002835Indonesia
TinPT Mitra Stania PrimaCID001453Indonesia
TinPT Refined Bangka TinCID001460Indonesia
TinPT Timah Tbk KundurCID001477Indonesia
TinPT Timah Tbk MentokCID001482Indonesia
TinResind Industria e Comercio Ltda.CID002706Brazil
TinRui Da HungCID001539Taiwan
TinSoft Metais Ltda.CID001758Brazil
TinThaisarcoCID001898Thailand
TinWhite Solder Metalurgia e Mineracao Ltda.CID002036Brazil
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CID002158China
TinYunnan Tin Company LimitedCID002180China
TinCV Ayi JayaCID002570Indonesia
TinCV Dua SekawanCID002592Indonesia
TinCV Gita PesonaCID000306Indonesia
TinCV United SmeltingCID000315Indonesia
TinCV Venus Inti PerkasaCID002455Indonesia
TinGejiu Fengming Metallurgy Chemical PlantCID002848Indonesia
TinPT Aries Kencana SejahteraCID000309Indonesia
TinPT Babel Inti PerkasaCID001402Indonesia
TinPT Babel Surya Alam LestariCID001406Indonesia



TinPT Bangka Prima TinCID002776Indonesia
TinPT Bangka SerumpunCID003205Indonesia
TinPT Bangka Tin IndustryCID001419Indonesia
TinPT Belitung Industri SejahteraCID001421Indonesia
TinPT Bukit TimahCID001428Indonesia
TinPT DS Jaya AbadiCID001434Indonesia
TinPT Inti Stania PrimaCID002530Indonesia
TinPT Karimun MiningCID001448Indonesia
TinPT Kijang Jaya MandiriCID002829Indonesia
TinPT Lautan Harmonis SejahteraCID002870Indonesia
TinPT Panca Mega PersadaCID001457Indonesia
TinPT Premium Tin IndonesiaCID000313Indonesia
TinPT Prima Timah UtamaCID001458Indonesia
TinPT Rajehan AriqCID002593Indonesia
TinPT Sariwiguna BinasentosaCID001463Indonesia
TinPT Stanindo Inti PerkasaCID001468Indonesia
TinPT Sukses Inti MakmurCID002816Indonesia
TinPT Sumber Jaya IndahCID001471Indonesia
TinPT Tinindo Inter NusaCID001490Indonesia
TinPT Tommy UtamaCID001493Indonesia
TungstenA.L.M.T. TUNGSTEN Corp.CID000004Japan
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CID002513China
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CID000258China
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CID000875China
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CID002315China
TungstenGanzhou Seadragon W & Mo Co., Ltd.CID002494China
TungstenGlobal Tungsten & Powders Corp.CID000568United States
TungstenGuangdong Xianglu Tungsten Co., Ltd.CID000218China
TungstenH.C. Starck Smelting GmbH & Co. KGCID002542Germany
TungstenH.C. Starck Tungsten GmbHCID002541Germany
TungstenHunan Chenzhou Mining Co., Ltd.CID000766China
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CID000769China
TungstenHydrometallurg, JSCCID002649Russian Federation
TungstenJapan New Metals Co., Ltd.CID000825Japan
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CID002551China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CID002321China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CID002318China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CID002317China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CID002316China
TungstenKennametal FallonCID000966United States
TungstenKennametal HuntsvilleCID000105United States
TungstenKGETS CO., LTD.CID003388Korea, Republic of
TungstenMalipo Haiyu Tungsten Co., Ltd.CID002319China
TungstenMasan Tungsten Chemical LLC (MTC)CID002543Vietnam
TungstenNiagara Refining LLCCID002589United States



TungstenTejing (Vietnam) Tungsten Co., Ltd.CID001889Vietnam
TungstenWolfram Bergbau und Hutten AGCID002044Austria
TungstenXiamen Tungsten (H.C.) Co., Ltd.CID002320China
TungstenXiamen Tungsten Co., Ltd.CID002082China
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CID002095China
* Legitimate Smelter facility names, locations and conformance status reported by RMI as of April 20, 2020.




ANNEX 2

Countries of Origin of 3TG
Country of Origin
Argentina - GGuyana – GRussian Federation – 3TG
Australia - 3TGHonduras – GRwanda – 3TG
Austria - Ta, WIndia – TaSaudi Arabia -G
Azerbaijan - GIndonesia – G, SN, WSenegal - G
Benin - GIran – GSerbia - G
Bolivia - 3TGIvory Coast – GSierra Leone - Ta
Botswana - GJapan – GSlovakia - G
Brazil - 3TGKazakhstan – GSolomon Islands - G
Burkina Faso - GKenya – GSomaliland - Ta
Burundi - 3TLaos -G, Sn, WSouth Africa - G
Canada - GLiberia – GSpain – G, Ta, W
Chile - GMadagascar – TaSuriname - G
China – 3TGMalaysia – 3TGSweden - G
Colombia -3TGMali – GTaiwan – Sn, W
Congo, Democratic Republic of the – 3TGMauritania – GTajikistan - G
Cuba - GMexico – GTanzania - G
Cyprus - GMongolia – G, Sn, WThailand – 3T
Dominican Republic - GMorocco – GTogo - G
Ecuador - GMyanmar (Burma) – Sn, WTurkey - G
Egypt - GNamibia -G, TaUganda – G, Sn, W
Eritrea - GNew Zealand -GUnited Kingdom – G, Sn, W
Ethiopia - G, TaNicaragua – GUruguay - G
Fiji - GNiger – GUSA – G, W
Finland - GNigeria – 3TUzbekistan - W
France - TaPapua New Guinea - GVenezuela - Sn
Georgia - GPeru – G, Sn, WVietnam – Sn, W
Ghana - GPhilippines – GZambia - G
Guatemala - GPortugal – Sn, WZimbabwe – G, Ta
Guinea – 3TGPuerto Rico – G 
Key:3TG = Tantalum, Tin, Tungsten and Gold; 3T= Tantalum, Tin and Tungsten
G = Gold; Ta= Tantalum; Sn= Tin; W=Tungsten