DocumentCardinal Health, Inc.
Conflict Minerals Report
For the 2021 Reporting Period
Introduction
As used in this report, "Cardinal Health," "we," "our," "us" and similar pronouns refer to Cardinal Health, Inc. and its consolidated subsidiaries at the end of 2021, unless the context indicates otherwise. "Conflict minerals" (or “3TG”) are defined as columbite-tantalite (coltan), cassiterite, gold, and wolframite and the derivatives tantalum, tin, and tungsten.
Cardinal Health is a global, integrated healthcare services and products company providing customized solutions for hospitals, healthcare systems, pharmacies, ambulatory surgery centers, clinical laboratories, and physician offices. We provide medical products and pharmaceuticals and cost-effective solutions that enhance supply chain efficiency.
We manage our business in two segments: Pharmaceutical and Medical. Our Pharmaceutical segment distributes branded and generic pharmaceutical, specialty pharmaceutical, and over-the-counter healthcare and consumer products in the United States. This segment also: provides services to pharmaceutical manufacturers and healthcare providers for specialty pharmaceutical products; operates nuclear pharmacies and radiopharmaceutical manufacturing facilities; through the Outcomes service offering, connects pharmacists, payers, and pharmaceutical companies and delivers health solutions for personalized medication therapy management, digital patient engagement, and telepharmacy; provides pharmacy management services to hospitals and operates a limited number of pharmacies, including in community health centers; and repackages generic pharmaceuticals and over-the-counter healthcare products.
Our Medical segment manufactures, sources, and distributes Cardinal Health branded medical, surgical, and laboratory products, which are sold in the United States, Canada, Europe, Asia, and other markets. In addition to distributing Cardinal Health branded products, this segment also distributes a broad range of medical, surgical, and laboratory products known as national brand products and provides supply chain services and solutions to hospitals, ambulatory surgery centers, clinical laboratories, and other healthcare providers in the United States and Canada. This segment also distributes medical products to patients' homes in the United States through our Cardinal Health at-Home Solutions division.
Our Pharmaceutical segment, which generated approximately 90% of our consolidated revenue for our fiscal year ended June 30, 2021, does not have any in-scope products under the 3TG Rule (as defined below). Accordingly, most of our business activities do not come within the scope of the 3TG Rule.
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the "3TG Rule"), this Conflict Minerals Report describes, for the period from January 1, 2021 to December 31, 2021 (the "2021 Reporting Period"), our reasonable country of origin inquiry ("RCOI") and the measures we have taken to exercise due diligence on the source and chain of custody of the 3TG contained in, and necessary to the functionality or production of, the products that we manufactured or contracted to manufacture during the 2021 Reporting Period. This report does not address products of businesses that we divested during 2021.
In-Scope Products and Our Supply Chain
We assessed all product lines manufactured or contracted to be manufactured by us in the 2021 Reporting Period to determine whether they potentially contained necessary 3TG. Through the assessment process, our product teams determined that certain product lines manufactured or contracted to be manufactured by our Medical segment (collectively, the "Products"), including RFID enabled inventory management cabinets and wands, negative pressure wound therapy devices, and enteral feeding, electrode, and thermometry product lines, contained necessary 3TG for the 2021 Reporting Period.
Our supply chains are complex and fragmented. As a “downstream” company, we are many tiers removed in the minerals supply chain from smelters and refiners (collectively, "SORs") that process the 3TG found in the Products, with many intervening third parties between the original sources of 3TG and us.
Reasonable Country of Origin Inquiry
As required by the 3TG Rule, we conducted a good faith RCOI regarding the 3TG in materials, components, and finished goods supplied to us that relate to the Products. The RCOI was designed to determine whether any of the 3TG originated in the Democratic Republic of the Congo or its adjoining countries (collectively, the “Covered Countries”) and was not from recycled or scrap sources. Selected elements of our RCOI process are described below.
•With the assistance of a third-party vendor with expertise in supply chain traceability (the "Vendor") and a Software as a Service ("SaaS") platform for tracking, we engaged 30 potentially in-scope suppliers to collect information regarding the presence and source of 3TG in the Products. These suppliers were asked to create a profile on the Vendor's SaaS platform and complete an online questionnaire based on the Responsible Minerals Initiative's ("RMI's") Conflict Minerals Reporting Template (“CMRT”) and a product list of sales to us for the 2021 Reporting Period. The CMRT is an internationally recognized standardized reporting form developed by the RMI that requests, among other things, information regarding the SORs that processed the 3TG in the supplier’s products, the country of origin of that 3TG, and the supplier’s compliance program. Any suppliers that provided information at the company level are encouraged to re-submit at the product level to attempt to get more detail on the 3TG in specific products.
•The SaaS platform generated automated reminders for unresponsive suppliers. When suppliers were unresponsive to the reminders generated from the SaaS platform, the Vendor and our employees followed up with personalized emails and offering assistance and further information about the requirements of the 3TG Rule and our compliance expectations.
•The Vendor identified and followed up on incomplete or contradictory answers submitted by suppliers and encouraged them to re-submit with corrected information.
•Where suppliers identified SORs in their responses, the Vendor verified whether the listed entities matched known SORs and SORs that conform to the RMI's Responsible Minerals Assurance Process (the “RMAP”) assessment protocols. The RMAP uses an independent third-party assessment of SOR management systems and sourcing practices to validate conformance with RMAP standards. Our suppliers identified a total of 337 known SORs, of which 234 were listed by the RMI as of May 9, 2022 as being “conformant” and 17 were listed as being “active” in the conformance assessment process. Approximately a quarter of the responses we received were prepared at a company level, meaning that they covered all the supplier’s products and not just those that the supplier sold to us. The remainder were submitted based on a product list provided by the supplier, although the listed products were not in all cases limited to the products supplied to us and the identified SORs were not necessarily limited to the products supplied to us. Based on this reporting, we were not able to determine with certainty whether the identified SORs processed the 3TG contained in the Products. In addition, given the complexity of the supply chain, suppliers may not have identified all the SORs in their supply chains.
Based on our RCOI, we have reason to believe that at least some of the 3TG contained in the Products may have originated in the Covered Countries and may not be from recycled or scrap sources. Accordingly, we exercised due diligence on the source and chain of custody of the 3TG.
Due Diligence
The due diligence measures described below were designed to conform, in all material respects, with the applicable portions of the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplements for tin, tantalum and tungsten and gold (Third Edition) (the "OECD Guidance"). The OECD Guidance identifies five steps for due diligence that should be implemented and provides specific guidance with respect to each step. We developed our due diligence measures utilizing the OECD-aligned RMI model to address each of these five steps and to help ensure that the 3TG in the Products is responsibly sourced. These measures considered the OECD Guidance’s recommendations for companies in the downstream segments of the supply chain, which typically are several tiers removed from, and have no direct relationships with, SORs. The following discussion addresses each of the five steps in turn.
1. Establish Company Management Systems
We have implemented a 3TG compliance program (the “Program”) with the following attributes:
Policy Statement
We have adopted a Conflict Minerals Policy (the "Policy") that sets forth the expectation that our suppliers source materials from suppliers that also source responsibly, including from conflict-free mines in the Covered Countries. The Policy is available on our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html. Information contained on our website is not incorporated by reference into this report or the Form SD.
The Policy states that we expect suppliers to be aware of the requirements of the 3TG Rule and other 3TG legislation and to respond in a timely manner to our requests for information. As stated in the Policy, we do not embargo sourcing from the Covered Countries and encourage our suppliers to continue to source responsibly from those countries.
Program Management
The Risk Management, Procurement Operations group within our Medical segment oversees the Program. This group, which manages supplier due diligence with respect to environmental and social issues, reports to our senior leadership.
Control Systems and Supply Chain Transparency
As discussed above, the Vendor facilitates supplier engagement and assists us in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Program. With the assistance of the Vendor, we contacted and solicited information from suppliers concerning the usage and source of 3TG, using the RMI-aligned approach and questions based on RMI's CMRT.
To further strengthen the Program, we are a member of the RMI, a cross-industry organization that provides resources, tools, and information to help companies source conflict-free minerals, including a list of conformant SORs, and manages the RMAP.
Our Vendor Code of Conduct requires suppliers to comply with the Policy, including working with their suppliers to identify the source and chain of custody of any 3TG contained in their products. Under the Vendor Code of Conduct, suppliers must agree to cooperate with us in connection with any inquiries or due diligence that we choose to perform with respect to such 3TG. The Vendor Code of Conduct is available on our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.
The Vendor and SaaS provider maintain records of product and supply chain information collected through the due diligence activities carried out under the Program. Documentation is retained for at least five years in an electronic database.
Supplier Engagement
In support of our Policy, we have incorporated 3TG compliance provisions into the standard terms of our Medical segment's supplier agreement template. As discussed above, we also address 3TG compliance in the Policy and the Vendor Code of Conduct. Both documents are distributed to suppliers and publicly available on our website.
Grievance Mechanism
We have a dedicated email address for reporting questions or concerns relating to our Policy or Program to a Cardinal Health representative. The email address is conflict_minerals@cardinalhealth.com. In addition, we have a business conduct line that provides a mechanism for anyone to anonymously report conduct they know or suspect is in violation of Cardinal Health guidelines or policies, including any concerns related to the 3TG supply chain. The contact information for this mechanism is found in our Standards of Business Conduct, which is available on our website at https://www.cardinalhealth.com/en/about-us/who-we-are/ethics-and-compliance.html.
2. Risk Identification and Assessment in the Supply Chain
Risks are identified by the Vendor's software partner based on “red flag” criteria established for supplier responses, including the submission of responses to questions based on RMI's CMRT where there were incomplete or contradictory answers. These risks are addressed in the first instance by the Vendor's staff, who contact the supplier, gather pertinent data, and perform an assessment of the supplier’s 3TG sourcing risk. The results of the Vendor’s outreach campaign and review of supplier responses, including the Vendor’s risk assessment, are communicated to our senior leadership.
Possible sourcing risks are identified by assessing the due diligence practices of SORs listed in our suppliers' responses. The Vendor determines whether each SOR identified in a supplier response is conformant by reviewing the identified SORs against the lists of conformant SORs published by the RMI. SORs classified as actively pursuing conformant status under the RMAP also are identified.
Additionally, through the Vendor, we evaluate the strength of our suppliers' 3TG due diligence and supply chain control programs, further assisting us in identifying supply chain risk. The criteria used to evaluate the program strength of our suppliers includes reviewing whether the supplier has a 3TG policy, whether it has implemented due diligence measures for conflict-free sourcing, whether it verifies due diligence information from its suppliers, and whether its verification process includes corrective action management.
3. Risk Response Strategy
Together with the Vendor, we have developed processes to assess and respond to risks in 3TG sourcing.
The Vendor and our employees made escalating contacts with unresponsive suppliers, emphasizing the importance of their response and their required cooperation for compliance with the 3TG Rule. When a SOR determined to be of higher risk is identified by a supplier in its response, as an RMI member, we report this to RMI and request that RMI contact the SOR to encourage participation in the RMAP and gather information regarding the SOR's sourcing practices. We believe this approach exerts the most leverage over SORs.
In addition, under our Vendor Code of Conduct, if we determine or believe at any time that a supplier has failed to comply with the standards set forth in the Vendor Code of Conduct, including those with respect to 3TG, we have the right to cease the purchase of the supplier's products without liability or obligation.
We address identified risks on a case-by-case basis. This flexible approach enables us to tailor the response to the risks identified.
4. Audits of Due Diligence Practices of SORs
We do not have a direct relationship with SORs and do not perform or direct SOR audits. Instead, as a member of the RMI, we rely on internationally recognized assessment programs, such as the RMAP, that facilitate and confirm independent third-party audits of SORs’ supply chain due diligence practices. As noted above, when an SOR determined to be of higher risk is identified by a supplier in its response, we report this to RMI and request that RMI contact the SOR to encourage participation in the RMAP and gather information regarding the SOR's sourcing practices.
5. Annual Public Reporting on Supply Chain Due Diligence
We report annually on our supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the U.S. Securities and Exchange Commission. We have published our Conflict Minerals Report for the 2021 Reporting Period on our website at https://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.
Due Diligence Results
Survey Results
For the 2021 Reporting Period, we received responses from 80% of all surveyed suppliers. Responses were reviewed and validated as discussed earlier in this report.
Smelters and Refiners
Notwithstanding our due diligence, we did not conclusively determine the country of origin of, or facilities used to process, the necessary 3TG in the Products for the 2021 Reporting Period. Thus, SOR information we received from our suppliers may not be relevant to the Products and may identify SORs that are not actually in our supply chain. In addition, a majority of suppliers indicated that they received incomplete information from their suppliers and, therefore, could not provide a comprehensive list of all SORs in their supply chains.
Annex A contains a list of the SORs reported by the suppliers. A total of 337 SORs were identified. As of May 9, 2022, 234 of these SORs, or 69%, were listed as conformant and 17, or 5%, were listed as active by the RMI. Annex B provides an aggregated list of identified potential countries of origin of the 3TG processed by the conformant SORs.
Cardinal Health's efforts to determine the mine or location of origin of the necessary 3TG in the Products with the greatest possible specificity consisted of the implementation of the Program and other due diligence measures described above in this Conflict Minerals Report.
Additional Risk Mitigation Steps
Since the filing of our Conflict Minerals Report last year, we have continued to utilize our vendors' expertise in supplier surveys and supply chain traceability, which considers improvements in broader industry practice. In addition, we renewed our membership in RMI to support programs like the RMAP that facilitate and validate independent third-party audits of SORs’ supply chain due diligence practices.
Forward-Looking Statements
This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties, such as whether industry organizations and initiatives remain effective as a source of external support to us in the 3TG compliance process. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms and include statements reflecting future results or guidance and statements of outlook. These matters are subject to risks and uncertainties that could cause actual results to differ materially from those projected, anticipated, or implied. Forward-looking statements are not guarantees of future performance. We assume no obligation to revise or update any forward-looking statements for any reason, except as required by law. Subsequent events may affect our future determinations under the 3TG Rule.
ANNEX A
Identified SORs
The following is a list of SORs reported in suppliers' responses. SORs that are listed as conformant by the RMI as of May 9, 2022, or that are listed by the RMI as having committed to undergo an RMAP assessment, are indicated as noted by an asterisk below.
As discussed in our Conflict Minerals Report, we cannot determine with certainty whether any of the SORs listed in this Annex A processed the 3TG in the Products. As a result, the presence of a SOR on the list does not mean that the Products necessarily contained 3TG processed by that SOR. In addition, because the suppliers may not have identified all of the SORs in their supply chains, the Products may contain 3TG processed by other SORs not listed below.
| | | | | | | | |
Mineral | SOR Name | SOR Location |
Gold | 8853 S.p.A.* | ITALY |
Gold | Abington Reldan Metals, LLC* | UNITED STATES |
Gold | Advanced Chemical Company* | UNITED STATES |
Gold | African Gold Refinery | UGANDA |
Gold | Aida Chemical Industries Co., Ltd.* | JAPAN |
Gold | Al Etihad Gold Refinery DMCC* | UNITED ARAB EMIRATES |
Gold | Alexy Metals* | UNITED STATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | GERMANY |
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 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | Augmont Enterprises Private Limited* | INDIA |
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 | C.I Metales Procesados Industriales SAS* | COLOMBIA |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation* | CANADA |
Gold | Cendres + Métaux S.A.* | SWITZERLAND |
Gold | CGR Metalloys Pvt Ltd. | INDIA |
Gold | Chimet S.p.A.* | ITALY |
Gold | Chugai Mining* | JAPAN |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Degussa Sonne | GERMANY |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
Gold | DODUCO Contacts and Refining GmbH* | GERMANY |
Gold | Dowa* | JAPAN |
Gold | DSC (Do Sung Corporation)* | REPUBLIC OF 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 | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
Gold | Emirates Gold DMCC* | UNITED ARAB EMIRATES |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
Gold | GCC Gujrat Gold Centre Pvt. Ltd.* | INDIA |
Gold | Geib Refining Corporation* | UNITED STATES |
Gold | Gold Coast Refinery | GHANA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | CHINA |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH* | GERMANY |
Gold | Heraeus Germany GmbH Co. KG* | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd.* | CHINA |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
Gold | HwaSeong CJ CO., LTD. | REPUBLIC OF KOREA |
Gold | Industrial Refining Company | BELGIUM |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | CHINA |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
Gold | Ishifuku Metal Industry Co., Ltd.* | JAPAN |
Gold | Istanbul Gold Refinery* | TURKEY |
Gold | Italpreziosi* | ITALY |
Gold | JALAN & Company | INDIA |
Gold | Japan Mint* | JAPAN |
Gold | Jiangxi Copper Co., Ltd.* | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIA |
Gold | JSC Novosibirsk Refinery | RUSSIA |
Gold | JSC Uralelectromed | RUSSIA |
Gold | JX Nippon Mining & Metals Co., Ltd.* | JAPAN |
Gold | K.A. Rasmussen | NORWAY |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc* | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC* | UNITED STATES |
Gold | KGHM Polska Miedz Spolka Akcyjna* | POLAND |
Gold | Kojima Chemicals Co., Ltd.* | JAPAN |
Gold | Korea Zinc Co., Ltd.* | REPUBLIC OF KOREA |
Gold | Kundan Care Products Ltd. | INDIA |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| | | | | | | | |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIA |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | L'Orfebre S.A.* | ANDORRA |
Gold | LS-NIKKO Copper Inc.* | REPUBLIC OF KOREA |
Gold | LT Metal Ltd.* | REPUBLIC OF KOREA |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Marsam Metals* | BRAZIL |
Gold | Materion* | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd.* | JAPAN |
Gold | MD Overseas | INDIA |
Gold | Metal Concentrators SA (Pty) Ltd.* | SOUTH AFRICA |
Gold | Metallix Refining Inc. | UNITED STATES |
Gold | Metalor Technologies (Hong Kong) Ltd.* | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE |
Gold | Metalor Technologies (Suzhou) Ltd.* | CHINA |
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 | MMTC-PAMP India Pvt., Ltd.* | INDIA |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | Moscow Special Alloys Processing Plant | RUSSIA |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş.* | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat* | UZBEKISTAN |
Gold | NH Recytech Company* | REPUBLIC OF KOREA |
Gold | Nihon Material Co., Ltd.* | JAPAN |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH* | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd.* | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIA |
Gold | PAMP S.A.* | SWITZERLAND |
Gold | Pease & Curren | UNITED STATES |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Planta Recuperadora de Metales SpA* | CHILE |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIA |
Gold | PT Aneka Tambang (Persero) Tbk* | INDONESIA |
Gold | PX Précinox S.A.* | SWITZERLAND |
Gold | QG Refining, LLC | UNITED STATES |
Gold | Rand Refinery (Pty) Ltd.* | SOUTH AFRICA |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
Gold | REMONDIS PMR B.V.* | NETHERLANDS |
Gold | Royal Canadian Mint* | CANADA |
Gold | SAAMP* | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES |
| | | | | | | | |
Gold | Safimet S.p.A* | ITALY |
Gold | SAFINA A.S.* | CZECH REPUBLIC |
Gold | Sai Refinery | INDIA |
Gold | Samduck Precious Metals* | REPUBLIC OF KOREA |
Gold | Samwon Metals Corp. | REPUBLIC OF KOREA |
Gold | Sancus ZFS (L’Orfebre, SA)* | COLOMBIA |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | Sellem Industries Ltd. | MAURITANIA |
Gold | SEMPSA Joyería Platería S.A.* | SPAIN |
Gold | Shandong Gold Smelting Co., Ltd.* | CHINA |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | CHINA |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
Gold | Shirpur Gold Refinery Ltd. | INDIA |
Gold | Sichuan Tianze Precious Metals Co., Ltd.* | CHINA |
Gold | Singway Technology Co., Ltd.* | TAIWAN |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIA |
Gold | Solar Applied Materials Technology Corp.* | TAIWAN |
Gold | Sovereign Metals | INDIA |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
Gold | Sudan Gold Refinery | SUDAN |
Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
Gold | SungEel HiMetal Co., Ltd.* | REPUBLIC OF KOREA |
Gold | Super Dragon Technology Co., Ltd. | TAIWAN |
Gold | T.C.A S.p.A* | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K.* | JAPAN |
Gold | Tokuriki Honten Co., Ltd.* | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | TOO Tau-Ken-Altyn* | KAZAKHSTAN |
Gold | Torecom* | REPUBLIC OF 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 | Value Trading | BELGIUM |
Gold | WEEEREFINING* | FRANCE |
Gold | Western Australian Mint (Trading as The Perth Mint)* | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH* | GERMANY |
Gold | Yamakin Co., Ltd.* | JAPAN |
Gold | Yokohama Metal Co., Ltd.* | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
Tantalum | AMG Brasil* | BRAZIL |
Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CHINA |
Tantalum | D Block Metals, LLC* | UNITED STATES |
Tantalum | Exotech Inc. | UNITED STATES |
| | | | | | | | |
Tantalum | F&X Electro-Materials Ltd.* | CHINA |
Tantalum | FIR Metals & Resource Ltd.* | CHINA |
Tantalum | Global Advanced Metals Aizu* | JAPAN |
Tantalum | Global Advanced Metals Boyertown* | UNITED STATES |
Tantalum | H.C. Starck Hermsdorf GmbH* | GERMANY |
Tantalum | H.C. Starck Inc.* | UNITED STATES |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | CHINA |
Tantalum | Jiangxi Tuohong New Raw Material* | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd.* | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | CHINA |
Tantalum | KEMET de Mexico* | MEXICO |
Tantalum | Metallurgical Products India Pvt., Ltd.* | INDIA |
Tantalum | Mineracao Taboca S.A.* | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA |
Tantalum | NPM Silmet AS* | ESTONIA |
Tantalum | QuantumClean* | UNITED STATES |
Tantalum | Resind Industria e Comercio Ltda.* | BRAZIL |
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd.* | CHINA |
Tantalum | Solikamsk Magnesium Works OAO* | RUSSIA |
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 |
Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED.* | CHINA |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | CHINA |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd.* | CHINA |
Tin | Alpha* | UNITED STATES |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd.* | CHINA |
Tin | China Tin Group Co., Ltd.* | CHINA |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda* | BRAZIL |
Tin | CRM Synergies* | SPAIN |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Venus Inti Perkasa* | INDONESIA |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
Tin | Dowa* | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
Tin | EM Vinto* | BOLIVIA |
Tin | Estanho de Rondônia S.A.* | BRAZIL |
Tin | Fabrica Auricchio Industria e Comercio Ltda.* | BRAZIL |
| | | | | | | | |
Tin | Fenix Metals* | POLAND |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | CHINA |
Tin | Gejiu Zili Mining and Metallurgy Co., Ltd.* | CHINA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd.* | CHINA |
Tin | Jiangxi New Nanshan Technology Ltd.* | CHINA |
Tin | Luna Smelter, Ltd.* | RWANDA |
Tin | Ma'anshan Weitai Tin Co., Ltd.* | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda.* | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | Metallic Resources, Inc.* | UNITED STATES |
Tin | Metallo Belgium N.V.* | BELGIUM |
Tin | Metallo Spain S.L.U.* | SPAIN |
Tin | Mineracao Taboca S.A.* | BRAZIL |
Tin | Minsur* | PERU |
Tin | Mitsubishi Materials Corporation* | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | Novosibirsk Processing Plant Ltd.* | RUSSIA |
Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc.* | PHILIPPINES |
Tin | Operaciones Metalurgicas S.A.* | BOLIVIA |
Tin | Pongpipat Company Limited | MYANMAR |
Tin | Precious Minerals and Smelting Limited | INDIA |
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 Lautan Harmonis Sejahtera | INDONESIA |
Tin | PT Masbro Alam Stania | 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 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 | Resind Industria e Comercio Ltda.* | BRAZIL |
Tin | Rui Da Hung* | TAIWAN |
Tin | Soft Metais Ltda.* | BRAZIL |
Tin | Super Ligas* | BRAZIL |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd.* | VIETNAM |
Tin | Thaisarco* | THAILAND |
Tin | Tin Technology & Refining* | UNITED STATES |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | VQB Mineral and Trading Group JSC | VIETNAM |
Tin | White Solder Metalurgia e Mineração Ltda.* | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CHINA |
Tin | Yunnan Tin Company Limited* | CHINA |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | A.L.M.T. Corp.* | JAPAN |
Tungsten | ACL Metais Eireli* | BRAZIL |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.* | BRAZIL |
Tungsten | Artek LLC | RUSSIA |
Tungsten | Asia Tungsten Products Vietnam Ltd.* | VIETNAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | CHINA |
Tungsten | China Molybdenum Tungsten Co., Ltd.* | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | CHINA |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tungsten | Cronimet Brasil Ltda* | BRAZIL |
Tungsten | Fujian Ganmin RareMetal Co., Ltd.* | CHINA |
Tungsten | Fujian Xinlu Tungsten* | CHINA |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd.* | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | CHINA |
Tungsten | Global Tungsten & Powders Corp.* | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | CHINA |
Tungsten | H.C. Starck Tungsten GmbH* | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd.* | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.* | CHINA |
Tungsten | Hydrometallurg, JSC* | RUSSIA |
Tungsten | Japan New Metals Co., Ltd.* | JAPAN |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA |
Tungsten | Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd.* | CHINA |
| | | | | | | | |
Tungsten | JSC "Kirovgrad Hard Alloys Plant"* | RUSSIA |
Tungsten | Kennametal Fallon* | UNITED STATES |
Tungsten | Kennametal Huntsville* | UNITED STATES |
Tungsten | KGETS Co., Ltd.* | REPUBLIC OF KOREA |
Tungsten | Lianyou Metals Co., Ltd.* | TAIWAN |
Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
Tungsten | Masan High-Tech Materials* | VIETNAM |
Tungsten | Moliren Ltd.* | RUSSIA |
Tungsten | Niagara Refining LLC* | UNITED STATES |
Tungsten | NPP Tyazhmetprom LLC* | RUSSIA |
Tungsten | OOO "Technolom" 1* | RUSSIA |
Tungsten | OOO "Technolom" 2* | RUSSIA |
Tungsten | Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES |
Tungsten | TANIOBIS Smelting GmbH & Co. KG* | GERMANY |
Tungsten | Unecha Refractory metals plant* | RUSSIA |
Tungsten | Wolfram Bergbau und Hütten AG* | AUSTRIA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | CHINA |
ANNEX B
Countries of Origin
Below is an aggregated list of countries of origin from which the conformant SORs listed in Annex A are believed to have potentially sourced 3TG (which also may include other countries). The countries of origin listed below were furnished by the Vendor based on supplier submissions. Some of the identified SORs also may have sourced in whole or in part from recycled or scrap sources.
| | | | | |
Angola | Liberia |
Argentina | Luxembourg |
Australia | Madagascar |
Austria | Malaysia |
Belarus | Mali |
Belgium | Mexico |
Bolivia | Mongolia |
Brazil | Mozambique |
Burundi | Myanmar |
Cambodia | Namibia |
Canada | Netherlands |
Central African Republic | Niger |
Chile | Nigeria |
China | Papua New Guinea |
Colombia | Peru |
Czech Republic | Philippines |
Djibouti | Poland |
Democratic Republic of the Congo | Portugal |
Ecuador | Republic of Korea |
Egypt | Russia |
Estonia | Rwanda |
Ethiopia | Sierra Leone |
France | Singapore |
Germany | Slovakia |
Ghana | Slovenia |
Guinea | South Africa |
Guyana | Spain |
Hungary | Sudan |
India | Suriname |
Indonesia | Switzerland |
Ireland | Tanzania |
Israel | Thailand |
Italy | Uganda |
Ivory Coast | United Kingdom |
Japan | United States of America |
Kazakhstan | Uzbekistan |
Kenya | Vietnam |
Kyrgyzstan | Zambia |
Laos | Zimbabwe |