EX-1.01 2 exhibit101to2022formsdsw.htm EX-1.01 Document


EXHIBIT 1.01
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CONFLICT MINERALS REPORT OF HP INC.
PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
HP Inc. (“HP”) presents this Conflict Minerals Report for the reporting period of January 1, 2021 to December 31, 2021 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission.
HP is a leading global provider of personal computing and other access devices, imaging and printing products, and related technologies, solutions and services. HP sells to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. Unless otherwise specified or unless the context otherwise requires, references to “HP,” “we,” “us” or “our” refer to HP Inc. and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD.
Overview of our Conflict Minerals Program
As part of our long-standing commitment to sustainability, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HP’s Supply Chain Social and Environmental Responsibility Policy. In 2011, we added to this policy a section on conflict minerals. We engage in ongoing supplier outreach and communications regarding the substance of our conflict minerals policy, our expectations of suppliers with respect to conflict minerals, and our objective of responsible mineral sourcing. The policy is available on our website (which is not incorporated by reference herein) at http://h20195.www2.hp.com/v2/GetDocument.aspx?docname=c04797682.
HP has been recognized as an industry leader in the conflict minerals domain since 2008. HP collaboratively works with other businesses, nongovernmental organizations, government agencies, and our extensive network of direct suppliers to advance the use of responsibly sourced minerals, including from the Democratic Republic of the Congo (“DRC”) and adjoining countries (collectively, the “Covered Countries”). Our work began in 2008, when we helped establish the working group that was the precursor to the Responsible Minerals Initiative (“RMI”), and we have been instrumental since then in developing and advancing the RMI programs and tools such as the Responsible Minerals Assurance Process (“RMAP”) and the Conflict Minerals Reporting Template (the “Template”). We contributed to the development of the Organisation for Economic Co-operation and Development (“OECD”) due diligence guidance and were a founding member of the Public Private Alliance for Responsible Mineral Trade as well as the Responsible Sourcing Network Multi-Stakeholder Group. We are a member of the European Partnership for Responsible Minerals. We were one of the first three companies to fund the Initial Audit Fund to offset part of the smelter audit cost. We also supported the initial piloting of the iTSCi traceability scheme for tin, and were a member of the Sustainable Trade Initiative (IDH) Indonesian Tin Working Group. We have visited DRC mines and have participated in critical in-region conflict free sourcing projects including Solutions for Hope, Kemet Partnership for Social and Economic Stability, and the former Conflict Free Tin Initiative. For each year since 2014, we have been able to report that all tantalum smelters reported to be in our supply chain were compliant with RMAP. For more information on our Responsible Minerals Program, we refer you to our annual Sustainable Impact Report, available on our website (which is not incorporated by reference herein) - https://h20195.www2.hp.com/v2/GetDocument.aspx?docname=c06040843.
HP Products
Conflict minerals in the form of gold and the mineral derivatives tin, tantalum and tungsten (collectively, “3TG”) are necessary to the functionality or production (“necessary conflict minerals”) of certain products. The products that we manufactured or contracted to manufacture during 2021 were:



Personal Systems Products. Consumer and commercial desktop and notebook personal computers, workstations, thin clients, commercial mobility devices, retail point-of-sale systems, displays and peripherals.
Printing Products. Consumer and commercial printer hardware (including 3D printing hardware) and supplies as well as scanning and imaging devices.
Design of Our Due Diligence Measures
We designed our due diligence measures to conform with applicable portions of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition, OECD 2016) and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures took into account our individual facts and circumstances, our downstream position in the minerals supply chain, the OECD recommendations for downstream actors that have no direct relationships to smelters or refiners1 and the use of independent assessment programs to provide information about smelters or refiners.
Consistent with the OECD Guidance, the design of our due diligence has the following features:
1.Establishment of strong internal company management systems, including a conflict minerals policy; a Conflict Minerals Program team with senior management support; a Supply Chain Transparency System; engagement with 3TG Direct Suppliers2 to communicate and reinforce HP expectations with respect to necessary conflict minerals; and a company level grievance mechanism that is available internally and externally to report concerns, including those related to conflict minerals.
2.Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Conflict Minerals Program team in systematically surveying, collecting, and analyzing information relating to 3TG facilities’3 use of necessary conflict minerals in the supply chain for our products.
3.Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on the due diligence practices of 3TG facilities, formulation of a risk management plan, and reporting to senior management.
4.Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership in the RMI, the industry initiative that conducts audits and assessments of facilities’ due diligence activities.
5.Annual reporting through this Conflict Minerals Report, supplemented with additional information about our Responsible Minerals Program in our annual Sustainable Impact Report, available on our website (which is not incorporated by reference herein) - http://h20195.www2.hp.com/v2/GetDocument.aspx?docname=c06040843.
Description of Due Diligence Measures Performed
We undertook due diligence on the source and chain of custody of necessary conflict minerals from the relevant 3TG facilities (having excluded as a result of our reasonable country of origin inquiry, or “RCOI”, those 3TG facilities that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries) and reviewed the results with senior supply chain management, including our Chief Supply Chain Officer.



1 The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HP; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
2 3TG Direct Suppliers are HP’s direct suppliers of materials, parts, components or products containing necessary conflict minerals.
3 3TG facilities are those entities reported by our 3TG Direct Suppliers that are also identified by RMI to be smelters, refiners, recyclers or scrap processors of conflict minerals.




As part of our due diligence measures:
we compared the relevant 3TG facilities to the facilities that are listed by RMI as either compliant or in process4 with RMAP, which assesses facilities’ systems and processes for traceability of ore and demonstration of conflict-free sourcing;
we engaged facilities when sourcing was unknown (directly or through a third party) to provide conflict minerals education, collect information on necessary conflict minerals such as country of origin, or encourage participation in RMAP;

if any 3TG Direct Supplier reported to us a facility for which we had information that triggered one of our potential risk indicators, we then requested the supplier investigate whether or not that facility contributed 3TG to HP products, and if the supplier reported that it did, we asked that the supplier remove the facility from our supply chain;
if we obtained information that indicated there was a potential risk associated with a particular facility, we sought information from industry sources, news and media, stakeholders, and other relevant sources to support our decisions and actions;
we reviewed upstream incident review reporting produced by RMI that focuses on moderate and major mine-level incidents to determine whether there were incidents associated with facilities’ sourcing that might be linked, directly or indirectly, to supporting armed groups;
we supported the RMAP (member ID: HPQQ) through membership and participation in the RMI; and
we asked 3TG Direct Suppliers to encourage the facilities in their supply chain to participate in the RMAP.
Results
We set forth below the results of our due diligence as well as our overall progress toward DRC conflict free products. First, we summarize the outcome of due diligence focused on the relevant 3TG facilities (i.e., the facilities that we did not reasonably believe were exclusively sourcing conflict minerals from recycled or scrap sources or from outside the Covered Countries). We then provide a year-over-year view of all of the supplier-reported 3TG facilities and the status of due diligence. We then provide a snapshot of our overall progress toward DRC conflict free products resulting from our RCOI and due diligence efforts, including a chart that highlights our progress by each 3TG metal as well as our total progress toward DRC conflict free products. In 2021, 98% of all 3TG facilities reported to us are compliant, in process to become compliant, and/or are reasonably believed to provide only conflict minerals from recycled or scrap sources or to source conflict minerals from outside the Covered Countries. Finally, as a measure of progress toward responsible minerals sourcing from Conflict Affected and High-Risk Areas (“CAHRAs”) worldwide, we provide a summary of RMAP participation rates by each 3TG metal and in total.
Due Diligence Results for Relevant 3TG Facilities
We began our inquiry by focusing on the 267 supplier-reported 3TG facilities. After conducting a RCOI on these 3TG facilities, we reasonably believe that 62 of these 3TG facilities provided conflict minerals exclusively from recycled or scrap sources, and 106 sourced conflict minerals exclusively from outside the Covered Countries. Attachment A to this Conflict Minerals Report includes the countries from which the 267 3TG facilities may have sourced necessary conflict minerals.
The remaining 99 3TG facilities underwent further due diligence on the source and chain of custody of conflict minerals as detailed in Chart 1 and below.

4 Throughout this Conflict Minerals Report, “compliant” refers to facilities that are listed by RMI, as of March 31, 2022 (the “2022 Cut-Off Date”), as conformant to RMAP assessment protocols (including certification or accreditation by similar independent assessment programs cross-recognized by RMAP such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme), and “in process” refers to facilities that are listed by RMI (as of the 2022 Cut-Off Date) as in the process of becoming conformant to RMAP.



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Based on further due diligence on the 99 relevant 3TG facilities, as of March 31, 2022 (the “2022 Cut-Off Date”):
93 facilities were listed by RMI as compliant or in process to become compliant with the RMAP assessment protocols.
The remaining 6 facilities are not participating, and we have limited information about their sourcing and operations. Further, we have not been able to determine if these facilities are processing necessary conflict minerals contained in our products.
HP’s 3TG Direct Suppliers have reported to us more than 76% of the facilities in the world (as recognized by RMI). We are not certain that all of these facilities are contributing to the production of HP products. Any over-reporting of facilities is a function of being several supply chain actors removed from the facilities and sub-tier suppliers refusing to provide customer-specific Templates to our suppliers. Conflict minerals due diligence continues to be difficult and partially inconclusive.
    Status of all Supplier-Reported 3TG Facilities
We also analyze our data set for information on the status of supplier-reported 3TG facilities and evaluate our overall progress by calculating how many of these facilities are listed as participating in or successfully completing an independent assessment program. Our suppliers reported a total of 267 3TG facilities in 2021, of which 252 are



compliant with, or in process to become compliant with, an independent assessment program. Of the remaining 3TG facilities that are not participating, we have reason to believe that 9 facilities are exclusively sourcing conflict minerals from recycled or scrap sources or from outside the Covered Countries, leaving only the 6 3TG facilities with unknown status discussed above.
Attachment B to this Conflict Minerals Report sets forth the name and status of the 267 supplier-reported 3TG facilities. Chart 2 illustrates a year-over-year comparison of all supplier-reported 3TG facilities.
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Overall Progress toward DRC Conflict Free
Based on the RCOI we performed with respect to the 267 3TG facilities our suppliers reported to us and the additional due diligence on relevant 3TG facilities, 98% are RMAP compliant, in process to become compliant, and/or we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries. 2% (6 facilities) have sourcing that is unknown and are not participating in an independent assessment program.
Chart 3, below, further expands on our results by providing for each metal the number and percentage (as of the 2022 Cut-off Date) of all supplier-reported 3TG facilities that were either RMAP compliant or in process to become compliant, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries. All of the tantalum smelters reported to be in our supply chain are again compliant with the RMAP assessment protocols.




Chart 3: Overall Progress toward DRC Conflict Free by Metal
Total
Progress toward DRC
Conflict Free5
Percentage
Tantalum Facilities3636100%
Tin Facilities686494%
Tungsten Facilities4646100%
Gold Facilities11711598%
Total26726198%

Participation in RMAP
RMI’s RMAP standards are developed to meet the requirements of the OECD Guidance, the Regulation (EU) 2017/821 of the European Parliament, and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. 3TG facilities conformant to RMAP standards have undergone independent third-party assessment of systems and processes for traceability of ore and demonstration of conflict-free sourcing, regardless of country of mineral origin, including from CAHRAs worldwide. Chart 4, below, gives the RMAP participation rates (as of the 2022 Cut-off Date) for supplier-reported 3TG facilities.
Chart 4: Participation in RMAP
 TotalRMAP Conformant (Compliant)RMAP Active (In process)Percentage RMAP Participating
Tantalum Facilities
36
36
0
100%
Tin Facilities
68
54
9
93%
Tungsten Facilities
46
42
4
100%
Gold Facilities
117
101
6
91%
Total
267
233
19
94%

Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity
As a downstream actor, we rely upon independent assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for downstream actors, our efforts to facilitate upstream mine or location of origin determinations were focused on supporting independent assessment programs such as the RMAP.
To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by independent assessment programs, we:
surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the Template (which included questions about the mine or location of origin) and required those suppliers to make similar efforts to survey their supply chains using the Template;
reviewed the information we obtained on 3TG facilities, and any mine or location of origin information if it was provided; and
assessed any information on countries of origin available through our membership in the RMI for 3TG facilities (as part of the RMAP assessment protocols, the independent auditor makes an examination of the countries of origin as well as the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to RMI members).
5 This column includes the number of 3TG facilities that (as of the 2022 Cut-Off Date) were either RMAP compliant, in process to become compliant, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries.



Steps to Further Mitigate Risk and Improve Due Diligence in 2022
We plan to continue the following steps to further mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group:
engage with 3TG Direct Suppliers to update information provided to us, including visits to supplier
sites;
repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the RMAP; and
support the development of the RMI’s RMAP, including outreach efforts to encourage participation in the process.




Attachment A
Countries of Origin
Based on information available from the RMI as of the 2022 Cut-Off Date and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals from supplier-reported 3TG facilities may include the following countries.

Covered Countries
Outside Covered Countries
BurundiArgentinaIndiaSingapore
Democratic Republic of the CongoArmeniaIndonesiaSlovakia
RwandaAustraliaIvory CoastSolomon Islands
South SudanAustriaJapanSouth Africa
TanzaniaAzerbaijanKazakhstanSouth Korea
UgandaBelgiumKenyaSpain
BeninKyrgyzstanSudan
BoliviaLaosSuriname
BotswanaLiberiaSwaziland
BrazilMadagascarSweden
BulgariaMalaysiaTaiwan
Burkina FasoMaliTajikistan
BurundiMauritaniaTanzania
CanadaMexicoThailand
ChileMongoliaTurkey
ChinaMontenegroUganda
ColombiaMoroccoUnited Kingdom
Costa RicaMozambiqueUnited States of America
Cote d'IvoireMyanmarUruguay
CyprusNamibiaUzbekistan
Dominican RepublicNew ZealandVenezuela
EcuadorNicaraguaVietnam
EgyptNigerZimbabwe
EritreaNigeria
EthiopiaOman
FijiPapua New Guinea
FinlandPeru
FrancePhilippines
French GuianaPoland
GeorgiaPortugal
GermanyRussian Federation
GhanaRwanda
GuatemalaSaudi Arabia
GuineaSenegal
GuyanaSerbia
HondurasSierra Leone





Attachment B
3TG Facility List
This 3TG Facility List sets forth the name, location and status of all of the 267 3TG facilities our suppliers reported to us. It is the result of our review of data from several sources, including information reported to us by 3TG Direct Suppliers, obtained through supplemental engagement with certain 3TG facilities, and obtained from the RMI. In many cases, facility information was provided to us for the entire supply chain of 3TG Direct Suppliers, and did not identify with specificity those 3TG facilities believed to contribute necessary conflict minerals to an HP product.

Metal
Facility Name6
Facility Location7
Status8
Gold8853 S.p.A.ITALYCompliant
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACompliant
GoldAgosi AGGERMANYCompliant
GoldAida Chemical Industries Co., Ltd.JAPANCompliant
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCompliant
GoldAlexy MetalsUNITED STATES OF AMERICAIn process
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCompliant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCompliant
GoldArgor-Heraeus S.A.SWITZERLANDCompliant
GoldAsahi Pretec Corp.JAPANCompliant
GoldAsahi Refining Canada Ltd.CANADACompliant
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICACompliant
GoldAsaka Riken Co., Ltd.JAPANCompliant
GoldAU Traders and RefinersSOUTH AFRICANot participating
GoldAugmont Enterprises Private LimitedINDIAIn process
GoldAurubis AGGERMANYCompliant
GoldBangalore RefineryINDIACompliant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCompliant
GoldBoliden ABSWEDENCompliant
GoldC. Hafner GmbH + Co. KGGERMANYCompliant
GoldC.I Metales Procesados Industriales SASCOLOMBIAIn process
GoldCCR Refinery - Glencore Canada CorporationCANADACompliant
GoldCendres + Metaux S.A.SWITZERLANDCompliant
GoldChimet S.p.A.ITALYCompliant
GoldChugai MiningJAPANCompliant
GoldDaye Non-Ferrous Metals Mining Ltd.CHINANot participating
GoldDODUCO Contacts and Refining GmbHGERMANYCompliant
GoldDowaJAPANCompliant
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCompliant
GoldEco-System Recycling Co., Ltd. East PlantJAPANCompliant
GoldEco-System Recycling Co., Ltd. North PlantJAPANCompliant
GoldEco-System Recycling Co., Ltd. West PlantJAPANCompliant
GoldEmirates Gold DMCCUNITED ARAB EMIRATESCompliant
GoldGeib Refining CorporationUNITED STATES OF AMERICACompliant
GoldGGC Gujrat Gold Centre Pvt. Ltd.INDIAIn process
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACompliant
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINANot participating



Metal
Facility Name6
Facility Location7
Status8
GoldHeimerle + Meule GmbHGERMANYCompliant
GoldHeraeus Germany GmbH Co. KGGERMANYCompliant
GoldHeraeus Metals Hong Kong Ltd.CHINACompliant
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACompliant
GoldIshifuku Metal Industry Co., Ltd.JAPANCompliant
GoldIstanbul Gold RefineryTURKEYCompliant
GoldItalpreziosiITALYCompliant
GoldJapan MintJAPANCompliant
GoldJiangxi Copper Co., Ltd.CHINACompliant
GoldJSC Novosibirsk RefineryRUSSIAN FEDERATIONNot participating
GoldJSC UralelectromedRUSSIAN FEDERATIONNot participating
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCompliant
GoldKazzincKAZAKHSTANCompliant
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACompliant
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCompliant
GoldKojima Chemicals Co., Ltd.JAPANCompliant
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCompliant
GoldKyrgyzaltyn JSCKYRGYZSTANNot participating
GoldL’Orfebre S.A.ANDORRACompliant
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFCompliant
GoldLT Metal Ltd.KOREA, REPUBLIC OFCompliant
GoldMarsam MetalsBRAZILCompliant
GoldMaterionUNITED STATES OF AMERICACompliant
GoldMatsuda Sangyo Co., Ltd.JAPANCompliant
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICACompliant
GoldMetalor Technologies (Hong Kong) Ltd.CHINACompliant
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECompliant
GoldMetalor Technologies (Suzhou) Ltd.CHINACompliant
GoldMetalor Technologies S.A.SWITZERLANDCompliant
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACompliant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCompliant
GoldMitsubishi Materials CorporationJAPANCompliant
GoldMitsui Mining and Smelting Co., Ltd.JAPANCompliant
GoldMMTC-PAMP India Pvt., Ltd.INDIACompliant
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONNot participating
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCompliant
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCompliant
GoldNH Recytech CompanyKOREA, REPUBLIC OFCompliant
GoldNihon Material Co., Ltd.JAPANCompliant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACompliant
GoldOhura Precious Metal Industry Co., Ltd.JAPANCompliant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONNot participating
GoldPAMP S.A.SWITZERLANDCompliant
GoldPlanta Recuperadora de Metales SpACHILECompliant
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONNot participating



Metal
Facility Name6
Facility Location7
Status8
GoldPT Aneka Tambang (Persero) TbkINDONESIACompliant
GoldPX Precinox S.A.SWITZERLANDCompliant
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACompliant
GoldREMONDIS PMR B.V.NETHERLANDSCompliant
GoldRoyal Canadian MintCANADACompliant
GoldSAAMPFRANCECompliant
GoldSafimet S.p.AITALYCompliant
GoldSAFINA A.S.CZECHIACompliant
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCompliant
GoldSancus ZFS (L’Orfebre, SA)COLOMBIAIn process
GoldSAXONIA Edelmetalle GmbHGERMANYCompliant
GoldSEMPSA Joyeria Plateria S.A.SPAINCompliant
GoldShandong Gold Smelting Co., Ltd.CHINACompliant
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACompliant
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACompliant
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACompliant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONNot participating
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACompliant
GoldSumitomo Metal Mining Co., Ltd.JAPANCompliant
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCompliant
GoldT.C.A S.p.AITALYCompliant
GoldTanaka Kikinzoku Kogyo K.K.JAPANCompliant
GoldTokuriki Honten Co., Ltd.JAPANCompliant
GoldTOO Tau-Ken-AltynKAZAKHSTANCompliant
GoldTorecomKOREA, REPUBLIC OFCompliant
GoldUmicore Precious Metals ThailandTHAILANDCompliant
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCompliant
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACompliant
GoldValcambi S.A.SWITZERLANDCompliant
GoldWEEEREFININGFRANCEIn process
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACompliant
GoldWIELAND Edelmetalle GmbHGERMANYCompliant
GoldYamakin Co., Ltd.JAPANCompliant
GoldYokohama Metal Co., Ltd.JAPANCompliant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACompliant
TantalumAMG BrasilBRAZILCompliant
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACompliant
TantalumD Block Metals, LLCUNITED STATES OF AMERICACompliant
TantalumExotech Inc.UNITED STATES OF AMERICACompliant
TantalumF&X Electro-Materials Ltd.CHINACompliant
TantalumFIR Metals & Resource Ltd.CHINACompliant
TantalumGlobal Advanced Metals AizuJAPANCompliant
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACompliant
TantalumH.C. Starck Hermsdorf GmbHGERMANYCompliant
TantalumH.C. Starck Inc.UNITED STATES OF AMERICACompliant



Metal
Facility Name6
Facility Location7
Status8
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACompliant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACompliant
TantalumJiangxi Tuohong New Raw MaterialCHINACompliant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACompliant
TantalumJiujiang Tanbre Co., Ltd.CHINACompliant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACompliant
TantalumKEMET de MexicoMEXICOCompliant
TantalumMetallurgical Products India Pvt., Ltd.INDIACompliant
TantalumMineracao Taboca S.A.BRAZILCompliant
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCompliant
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACompliant
TantalumNPM Silmet ASESTONIACompliant
TantalumQuantumCleanUNITED STATES OF AMERICACompliant
TantalumResind Industria e Comercio Ltda.BRAZILCompliant
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.CHINACompliant
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCompliant
TantalumTaki Chemical Co., Ltd.JAPANCompliant
TantalumTANIOBIS Co., Ltd.THAILANDCompliant
TantalumTANIOBIS GmbHGERMANYCompliant
TantalumTANIOBIS Japan Co., Ltd.JAPANCompliant
TantalumTANIOBIS Smelting GmbH & Co. KGGERMANYCompliant
TantalumTelex MetalsUNITED STATES OF AMERICACompliant
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCompliant
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCHINACompliant
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACompliant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACompliant
TinAlphaUNITED STATES OF AMERICACompliant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACompliant
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACompliant
TinChina Tin Group Co., Ltd.CHINACompliant
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILIn process
TinCRM SynergiesSPAINCompliant
TinCV Venus Inti PerkasaINDONESIAIn process
TinDowaJAPANCompliant
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)Compliant
TinEstanho de Rondonia S.A.BRAZILCompliant
TinFabrica Auricchio Industria e Comercio Ltda.BRAZILCompliant
TinFenix MetalsPOLANDCompliant
TinGejiu Kai Meng Industry and Trade LLCCHINANot participating
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACompliant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACompliant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACompliant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACompliant



Metal
Facility Name6
Facility Location7
Status8
TinHuiChang Hill Tin Industry Co., Ltd.CHINACompliant
TinJiangxi New Nanshan Technology Ltd.CHINACompliant
TinLuna Smelter, Ltd.RWANDACompliant
TinMa'anshan Weitai Tin Co., Ltd.CHINACompliant
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCompliant
TinMalaysia Smelting Corporation (MSC)MALAYSIACompliant
TinMelt Metais e Ligas S.A.BRAZILCompliant
TinMetallic Resources, Inc.UNITED STATES OF AMERICACompliant
TinMetallo Belgium N.V.BELGIUMCompliant
TinMetallo Spain S.L.U.SPAINCompliant
TinMineracao Taboca S.A.BRAZILCompliant
TinMinsurPERUCompliant
TinMitsubishi Materials CorporationJAPANCompliant
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONIn process
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCompliant
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCompliant
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)Compliant
TinPT Aries Kencana SejahteraINDONESIAIn process
TinPT Artha Cipta LanggengINDONESIACompliant
TinPT ATD Makmur Mandiri JayaINDONESIACompliant
TinPT Babel Inti PerkasaINDONESIACompliant
TinPT Babel Surya Alam LestariINDONESIACompliant
TinPT Bangka SerumpunINDONESIACompliant
TinPT Belitung Industri SejahteraINDONESIANot participating
TinPT Bukit TimahINDONESIAIn process
TinPT Menara Cipta MuliaINDONESIACompliant
TinPT Mitra Stania PrimaINDONESIACompliant
TinPT Mitra Sukses GlobalindoINDONESIAIn process
TinPT Panca Mega PersadaINDONESIANot participating
TinPT Prima Timah UtamaINDONESIACompliant
TinPT Rajawali Rimba PerkasaINDONESIACompliant
TinPT Refined Bangka TinINDONESIACompliant
TinPT Sariwiguna BinasentosaINDONESIACompliant
TinPT Stanindo Inti PerkasaINDONESIACompliant
TinPT Sukses Inti MakmurINDONESIAIn process
TinPT Timah NusantaraINDONESIAIn process
TinPT Timah Tbk KundurINDONESIACompliant
TinPT Timah Tbk MentokINDONESIACompliant
TinPT Tinindo Inter NusaINDONESIACompliant
TinResind Industria e Comercio Ltda.BRAZILCompliant
TinRui Da HungTAIWAN, PROVINCE OF CHINACompliant
TinSoft Metais Ltda.BRAZILCompliant
TinSuper LigasBRAZILIn process
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCompliant
TinThaisarcoTHAILANDCompliant
TinTin Smelting Branch of Yunnan Tin Co., Ltd.CHINACompliant
TinTin Technology & RefiningUNITED STATES OF AMERICACompliant



Metal
Facility Name6
Facility Location7
Status8
TinVQB Mineral and Trading Group JSCVIET NAMNot participating
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCompliant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACompliant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINANot participating
TungstenA.L.M.T. Corp.JAPANCompliant
TungstenACL Metais EireliBRAZILCompliant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILIn process
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCompliant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACompliant
TungstenChina Molybdenum Tungsten Co., Ltd.CHINACompliant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACompliant
TungstenCronimet Brasil LtdaBRAZILCompliant
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACompliant
TungstenFujian Xinlu Tungsten Co., Ltd.CHINACompliant
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACompliant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACompliant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACompliant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACompliant
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACompliant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACompliant
TungstenH.C. Starck Tungsten GmbHGERMANYCompliant
TungstenHubei Green Tungsten Co., Ltd.CHINACompliant
TungstenHunan Chenzhou Mining Co., Ltd.CHINACompliant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACompliant
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCompliant
TungstenJapan New Metals Co., Ltd.JAPANCompliant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACompliant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACompliant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACompliant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACompliant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACompliant
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCompliant
TungstenKennametal FallonUNITED STATES OF AMERICACompliant
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACompliant
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFCompliant
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACompliant
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACompliant
TungstenMasan High-Tech MaterialsVIET NAMCompliant
TungstenMoliren Ltd.RUSSIAN FEDERATIONCompliant
TungstenNiagara Refining LLCUNITED STATES OF AMERICACompliant
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONIn process
TungstenOOO “Technolom” 1RUSSIAN FEDERATIONIn process
TungstenOOO “Technolom” 2RUSSIAN FEDERATIONIn process
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCompliant
TungstenTANIOBIS Smelting GmbH & Co. KGGERMANYCompliant
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCompliant



Metal
Facility Name6
Facility Location7
Status8
TungstenWolfram Bergbau und Hutten AGAUSTRIACompliant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACompliant
TungstenXiamen Tungsten Co., Ltd.CHINACompliant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACompliant

6 Entities that have been reported to us by our 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by RMI (as of the 2022 Cut-Off Date) to be smelters, refiners, recyclers or scrap processors of conflict minerals (“3TG facilities”). The facility names are listed as they appear on the RMI Smelter Database. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler or scrap processor) that is providing different types of minerals or metals.
7 The facility locations are listed as they appear for each of the 3TG facilities in the RMI Smelter Database.
8 Compliant refers to 3TG facilities that are listed by RMI (as of the 2022 Cut-Off Date) as (a) conformant with RMAP protocols or (b) certified or accredited by a similar independent assessment program cross-recognized by RMAP such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme. In Process refers to 3TG facilities that are listed by RMI (as of the 2022 Cut-Off Date) as currently in the process of becoming RMAP conformant. Not participating refers to 3TG facilities that are not engaged in an independent assessment program, including the RMAP.