UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
MOVADO GROUP, INC. | |
(Exact name of registrant as specified in its charter) | |
New York | 1-16497 |
(State or other jurisdiction of incorporation) |
(Commission File Number) |
650 From Road, Suite 375, Paramus, NJ | 07652-3556 |
(Address of principal executive offices) | (Zip Code) |
Mitchell C. Sussis (201) 267-8000 | |
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended December 31, 2021.
Section 1 – Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available at www.movadogroup.com.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01. Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 – Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 — Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
MOVADO GROUP, INC. | ||||
Date: May 31, 2022 | By: | /s/ Mitchell C. Sussis | ||
Name: | Mitchell C. Sussis | |||
Title: | Senior Vice President and General Counsel | |||
EXHIBIT 1.01
Movado Group, Inc.
Conflict Minerals Report
For The Calendar Year Ended December 31, 2021
This Conflict Minerals Report (“Report”) is submitted by Movado Group, Inc. (together with all of its subsidiaries hereinafter referred to as the “Company” or “we”) for the calendar year ended December 31, 2021 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to what are referred to as “conflict minerals” under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants who manufacture or contract to manufacture products containing conflict minerals which are necessary to the functionality or production of their products. Specifically, the Rule requires such companies to report on their use and sourcing of tantalum, tin, tungsten and gold (collectively “3TG”).
Under the Rule, the Company must submit a Form SD and undertake an inquiry (a “reasonable country of origin inquiry” or “RCOI”) to determine whether there is any reason to believe that the 3TG used in its products may have originated from sources within the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (the “Covered Countries”) or whether such minerals came from recycled and scrap sources. If, following the RCOI, there is any reason to believe that any of the 3TG in its production and supply chains may have originated in the Covered Countries, or if the Company is unable to determine the country of origin of the 3TG, then it must exercise due diligence on the 3TG’s source and chain of custody. This Report, which is posted on the Company’s website at www.movadogroup.com, describes those due diligence measures. This Report has not been subject to an independent private sector audit.
1. Company Overview
The Company and its Products
The Company designs, develops, sources and sells watches globally under a number of prominent, owned and licensed brands. It also designs, develops, sources and sells jewelry and other accessories under certain of its brands. We conducted an analysis of all our products and determined that most contain tin and many contain gold. To a limited extent, some contain tungsten and tantalum. Tin is present in soldering paste, which is used principally in watch movements, and is also used in various component parts containing bronze, galvanic blue plating, black PVD plating and ionic plated silver. Certain of our watches contain parts made of gold and many use gold plated component parts, including primarily cases and bracelets. Some of our watches use tungsten, which is present in tungsten carbide, principally in hard metal cases and bracelets and in some black PVD plating. Some of our watch movement capacitors (devices used to store electric charges) contain tantalum.
Supply chain
The Company uses independent manufacturers and assemblers to produce all of its finished products while maintaining quality control through its supply chain organizations in Switzerland, Mainland China and Hong Kong. A majority of the Swiss watch movements used in the manufacture of the Company’s proprietary watch brands are purchased from two movement suppliers. The Company obtains other watch components for all of its brands, including movements for its licensed watch brands, as well as cases, hands, crystals, dials, bracelets and straps, and finished jewelry and other accessories from various other suppliers. The Company purchases some of the gold used in certain component parts in its watches directly from UBS in Switzerland, which it makes available to some of its suppliers and, otherwise, its suppliers obtain gold used in parts and for plating from their own suppliers.
The Company’s standard form of agreement for use with its component parts and finished goods suppliers obligates the suppliers to provide the Company with all information requested related to the source of any 3TG used in the production of the products they supply and to use their best efforts to obtain such information from all of their subcontractors and sub-suppliers. However, because of the Company’s position as a downstream purchaser of finished products and component parts, we are several tiers removed from the smelters and the refineries where the 3TG is processed. Consequently, we have little, if any, visibility beyond our direct suppliers to entities in the upstream supply chain. Therefore, in addition to contractually obligating our direct suppliers to furnish and to use their best efforts to obtain all requested information pertaining to 3TG use, we have communicated to all of our direct suppliers what our reporting obligations are in this area and the need for full and accurate information, with the goal of ultimately achieving complete transparency throughout our entire supply chain. We also communicate to our suppliers a Vendor Code of Conduct, including a supplementary Supply Chain Policy based on the Organisation for Economic Co-operation and Development (“OECD”) Model Supply Chain Policy for a Responsible Global Supply Chain and a supplementary Supply Chain Policy Regarding Gold. The Vendor Code of Conduct, together with the supplementary supply chain and gold policies, is available on our website at www.movadogroup.com under “Corporate Responsibility”.
2. Reasonable Country of Origin Inquiry
In conducting our RCOI, we contacted direct suppliers (56 in total) from whom we obtained assembled watches, jewelry, other accessories and any component parts in calendar year 2021 and whose parts or processes we determined reasonably could be expected to result in 3TG being contained in our finished products. We sent each of them the conflict mineral reporting template (CMRT) created by the Conflict-Free Sourcing Initiative (now known as the Responsible Minerals Initiative or RMI) and received completed CMRTs from all but three of them. Of the remaining three suppliers, two submitted documentation in another form, and one did not submit a response at all. We then assessed the reasonableness and reliability of the responses, including analyzing such responses for completeness and internal consistency. Where necessary, we sent follow-up requests for additional information and clarification to suppliers whose responses were incomplete or internally inconsistent. We also requested from all suppliers the identity of every smelter and gold refinery used to process the 3TG in the products supplied by them, or confirmation that all such 3TG were from scrap or recycled material, and whenever necessary requested that they contact their upstream suppliers for this information. From this process, we were able to discover refineries and smelters (listed in the table under section 3.2 below) used by 31 (79%) of the 39 suppliers who indicated that we purchase from them any product containing 3TG. However, some of those 31 suppliers were not able to identify all of the smelters and refineries from which 3TG was sourced for use in our products. 165 of the 375 (44%) refineries and smelters that were identified by those 31 suppliers either are RMI-conformant, which indicates compliance with a Responsible Minerals Assurance Process (“RMAP”) audit by RMI or participation in one of RMI’s cross-recognized certification programs such as the Responsible Jewelry Program Chain-of-Custody Certification, or are RMI-active, which indicates that they have committed to undergo an RMAP assessment, have completed the relevant documents, and have scheduled the on-site assessment. The 31 suppliers who identified refineries and smelters also identified the location by country (listed in the table under section 3.2 below) of those smelters and refineries. Beyond this, however, none of our suppliers who responded were able to definitively identify the country of origin of its 3TG. Additionally, as noted above, one supplier did not respond to our inquiries. Accordingly, the information we have gathered is insufficient to support a determination that there is no reason to believe that any 3TG contained in our products may have originated in any of the Covered Countries. For that reason, we are required under the Rule to submit this Report as an Exhibit to our Form SD.
3. Due Diligence Process
Our due diligence measures have been designed to conform, in all material respects, with the framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten.
3.1 Management Systems
As discussed above, the Company has adopted a Supply Chain policy and a separate Supply Chain policy regarding gold as supplements to its Vendor Code of Conduct.
With the support of the Company’s senior management, we have established a cross-functional team charged with developing and implementing the Company’s conflict minerals program and overseeing compliance with its supply chain policies. That team comprises executive-level representatives and subject matter experts in the United States, Switzerland and Asia from various departments, including Global Value Chain, Purchasing and Production, Operations, Quality Assurance, Internal Audit, Legal and Finance. Senior management is briefed about the results of our due diligence efforts on a periodic basis.
The Company does not have a direct relationship with any 3TG smelters or refiners. Therefore, the focus of our efforts has been to engage our direct suppliers in a process designed to bring transparency to our supply chain by obtaining information from them and having them and their suppliers obtain information from their respective upstream suppliers as to the facilities used to process the 3TG contained in our products. It is an ongoing process as we continue to both inform and educate our suppliers about our policies and aggregate and analyze the information we obtain. All such information is retained in electronic format on a password protected shared access drive on the Company’s computer network. Our ultimate goal is for all of our suppliers to be able to furnish us with complete, accurate and reliable information as to all of the upstream actors in our supply chain and we encourage them to participate in and to deal exclusively with other suppliers who participate in industry-wide audit and certification programs such as the RMAP. Our controls in this endeavor include our Vendor Code of Conduct and our related supply chain policies as well as contract provisions.
In addition to the foregoing, our Swiss- and Asia-based supply chain personnel have identified responsible individuals at all of our key suppliers and continue to dialogue with them concerning our informational needs and suggest ways for them to comply with our policies.
Due to the Company’s downstream position in the supply chain, we have limited information or visibility as to the smelters and refineries processing our 3TG or the mines where those minerals originate and, therefore, are not likely to have knowledge of conflict financing. However, the Company does have established grievance procedures whereby employees and suppliers can report suspected violations of our policies.
3.2 Identification and assessment of risk in the supply chain
The Company identifies and assesses risk in our supply chain by identifying the 3TG present in our products; identifying the suppliers of those products; and obtaining and assessing all relevant information that is reasonably available from those suppliers and indirectly from their upstream suppliers as to the origin of such 3TG and the identity of the smelters and refineries processing them. This process includes, where we have obtained the identity of a particular smelter or refinery, checking the name of such smelter or refinery against the RMI’s lists of smelters and refineries that have been certified as processing only conflict-free minerals.
As noted above, we were able to identify refineries and smelters used by 31 of the 39 suppliers who reported that we purchased from them any product containing 3TG. These refineries and smelters are listed below.
Refinery or Smelter Name | 3TG Material |
8853 S.p.A.* | Gold |
A.L.M.T. Corp.* | Tungsten |
Abington Reldan Metals, LLC** | Gold |
ACL Metais Eireli* | Tungsten |
Advanced Chemical Company* | Gold |
Aida Chemical Industries Co., Ltd.* | Gold |
Al Etihad Gold Refinery DMCC* | Gold |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.** | Tungsten |
Allgemeine Gold-und Silberscheideanstalt A.G. | Gold |
Almalyk Mining and Metallurgical Complex (AMMC)* | Gold |
Alpha* | Tin |
An Thai Minerals Co., Ltd. | Tin |
An Vinh Joint Stock Mineral Processing Company | Tin |
AngloGold Ashanti Corrego do Sitio Mineracao* | Gold |
Arco Alloys | Tin |
Argor-Heraeus S.A.* | Gold |
ARY Aurum Plus | Gold |
Asahi Pretec Corp.* | Gold |
Asahi Refining Canada Ltd.* | Gold |
Asahi Refining USA Inc.* | Gold |
Asaka Riken Co., Ltd.* | Gold |
Asia Tungsten Products Vietnam Ltd.* | Tungsten |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Gold |
AU Traders and Refiners | Gold |
Aurubis AG* | Gold |
Bangalore Refinery Pvt Ltd* | Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | Gold |
Boliden AB* | Gold |
C. Hafner GmbH + Co. KG* | Gold |
Caridad | Gold |
CCR Refinery - Glencore Canada Corporation* | Gold |
Cendres + Mtaux SA* | Gold |
CGR Metalloys Pvt Ltd. | Gold |
Chimet S.p.A.* | Gold |
Chofu Works | Tin |
Chongyi Zhangyuan Tungsten Co., Ltd. | Gold, Tungsten |
Chugai Mining* | Gold |
CNMC (Guangxi) PGMA Co., Ltd. | Tungsten, Tin |
Cooperativa Metalurgica de Rondônia Ltda. | Tin |
Refinery or Smelter Name | 3TG Material |
CP Metals Inc. | Tungsten |
CV Ayi Jaya | Tin |
CV Dua Sekawan | Tin |
CV Gita Pesona | Tin |
CV Serumpun Sebalai | Tin |
CV United Smelting | Tin |
CV Venus Inti Perkasa** | Tin |
DAIDO STEEL | Tungsten |
Daye Non-Ferrous Metals Mining Ltd. | Gold |
Degussa Sonne / Mond Goldhandel GmbH | Gold |
Dijilah Gold Refinery FZC | Gold |
DODUCO Contacts and Refining GmbH* | Gold |
Dongguan CiEXPO Environmental Engineering Co., Ltd. | Tin |
Dongguan City Xida Soldering Tin Products Co. | Tin |
Dowa* | Gold, Tin |
DS Pretech Co., Ltd. | Gold |
DSC (Do Sung Corporation)* | Gold |
Eco-System Recycling Co., Ltd. East Plant* | Gold |
Eco-System Recycling Co., Ltd. North Plant* | Gold |
Eco-System Recycling Co., Ltd. West Plant* | Gold |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Tin |
Elemetal Refining LLC | Gold |
EM Vinto* | Tin |
Emirates Gold DMCC* | Gold |
Estanho de Rondonia S.A.* | Tin |
Fenix Metals* | Tin |
Fujairah Gold FZC | Gold |
Fuji Metal Mining Corp. | Tin |
Fujian Jinxin Tungsten Co., Ltd. | Tungsten |
Ganzhou Beseem Ferrotungsten Co., Ltd. | Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. | Tungsten |
GCC Gujrat Gold Centre Pvt. Ltd. | Gold |
Geib Refining Corporation* | Gold |
Gejiu City Fuxiang Industry and Trade Co., Ltd. | Tin |
Gejiu Fengming Metallurgy Chemical Plant | Tin |
Gejiu Jinye Mineral Company | Tin |
Gejiu Kai Meng Industry and Trade LLC | Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd.* | Tin |
Gejiu Yunxi Group Corp. | Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd.* | Tin |
Gold Refinery of Zijin Mining Group Co., Ltd.* | Gold |
Great Wall Precious Metals Col, Ltd. of CBPM | Gold |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | Tin |
Guangdong Hua Jian Trade Co., Ltd. | Gold |
Guangdong Jinding Gold Limited | Gold |
Guangdong Xianglu Tungsten Co., Ltd.* | Tungsten |
GUANGXI HUA TIN GOLD MINUTE FEE, LTD. | Tin |
Guangxi Nonferrous Metals Group | Tin |
Guangxi Zhongshan Jin Yi Smelting Co., Ltd. | Tin |
Guoda Safina High-Tech Environmental Refinery | Gold |
Hang Seng Technology | Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. | Gold |
Refinery or Smelter Name | 3TG Material |
Heimerle + Meule GmbH* | Gold |
Henan Yuguang Gold & Lead Co., Ltd. | Gold |
Heraeus Germany GmbH Co. KG* | Gold |
Heraeus Metals Hong Kong Ltd.* | Gold |
Hetai Gold Mineral Guangdong Co., Ltd. | Gold |
Hezhou Jinwei Tin Co., Ltd. | Tin |
Hongqiao Metals (Kunshan) Co., Ltd. | Tin |
Hop Hing electroplating factory Zhejiang | Gold |
HuiChang Hill Tin Industry Co., Ltd.* | Tin |
Huichang Jinshunda Tin Co., Ltd. | Tin |
Hulterworth Smelter | Tin |
Hunan Chenzhou Mining Co., Ltd. | Gold |
Hunan Chenzhou Mining Group Co., Ltd.* | Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd.* | Tungsten |
Hunan Guiyang Yinxing Nonferrous Smelting Co., Ltd. | Gold |
Hunan Litian Tungsten Industry Co., Ltd. | Tungsten |
Hung Cheong Metal Manufacturing Limited | Gold |
HwaSeong CJ CO., LTD. | Gold |
Hydrometallurg, JSC* | Tungsten |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | Gold |
International Precious Metal Refiners | Gold |
Ishifuku Metal Industry Co., Ltd.* | Gold |
Istanbul Gold Refinery* | Gold |
Italpreziosi* | Gold |
Japan Mint* | Gold |
Jiang Jia Wang Technology Co. | Tin |
Jiangxi Copper Co., Ltd.* | Gold |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. | Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd.* | Tungsten |
Jiangxi Ketai Advanced Material Co., Ltd. | Tin |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Tungsten |
Jiangxi Nanshan | Tin |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd.* | Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. | Tin |
Jin Jinyin Refining Co., Ltd. | Gold |
Jinlong Copper Co., Ltd. | Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold |
JSC Uralelectromed | Gold |
Ju Tai Industrial Co., Ltd. | Tin |
JX Nippon Mining & Metals Co., Ltd.* | Gold |
Kaloti Precious Metals | Gold |
Kazakhmys Smelting LLC | Gold |
Kazzinc* | Gold |
Kennametal Fallon* | Tungsten |
Kennametal Huntsville* | Tungsten |
Kennecott Utah Copper LLC* | Gold |
KGETS Co., Ltd.* | Tungsten |
KGHM Polska Miedz Spolka Akcyjna* | Gold |
Kojima Chemicals Co., Ltd.* | Gold |
Korea Zinc Co., Ltd.* | Gold |
Kosak Seiren | Gold |
Refinery or Smelter Name | 3TG Material |
Kyrgyzaltyn JSC | Gold |
Kyshtym Copper-Electrolytic Plant ZAO | Gold |
L'azurde Company For Jewelry | Gold |
LIAN JING | Tin |
Lianyou Metals Co., Ltd.* | Tungsten |
Lingbao Gold Co., Ltd. | Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Gold |
L'Orfebre S.A.* | Gold |
LS-NIKKO Copper Inc.* | Gold |
LT Metal Ltd.* | Gold |
Luna Smelter, Ltd.* | Tin |
M/s ECO Tropical Resources | Tin |
Ma An Shan Shu Guang Smelter Corp. | Tin |
Ma'anshan Weitai Tin Co., Ltd.* | Tin |
Magnu's Minerais Metais e Ligas Ltda.* | Tin |
Malaysia Smelting Corporation (MSC)* | Tin |
Malipo Haiyu Tungsten Co., Ltd.* | Tungsten |
Marsam Metals* | Gold |
Materials Eco-Refining Co., Ltd. | Tin |
Materion* | Gold |
Matsuda Sangyo Co., Ltd.* | Gold |
Mehra Ferro-Alloys Pvt. Ltd. | Tungsten |
Melt Metais e Ligas S.A. | Tin |
Metahub Industries Sdn. Bhd. | Tin |
Metallic Resources, Inc.* | Tin |
Metallo Belgium N.V.* | Tin |
Metallo Chimique | Tin |
Metallo Spain S.L.U.* | Tin |
Metalor Switzerland* | Gold |
Metalor Technologies (Hong Kong) Ltd.* | Gold |
Metalor Technologies (Singapore) Pte., Ltd.* | Gold |
Metalor Technologies (Suzhou) Ltd.* | Gold |
Metalor USA Refining Corporation* | Gold |
Metalurgica Met-Mex Peoples, S.A. de C.V* | Gold |
Minchali Metal Industry Co., Ltd. | Tin |
Mineracao Taboca S.A.* | Tin |
Ming Li Jia smelt Metal Factory | Tin |
Minsur* | Tin |
Mitsubishi Materials Corporation* | Gold, Tin |
Mitsui Kinzoku Co., Ltd. | Gold |
MMTC-PAMP India Pvt., Ltd.* | Gold |
Modeltech Sdn Bhd | Gold, Tin |
Moliren Ltd.* | Tungsten |
Morris and Watson | Gold |
Morris and Watson Gold Coast | Gold |
Moscow Special Alloys Processing Plant | Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş.* | Gold |
Navoi Mining and Metallurgical Combinat* | Gold |
Nghe Tinh Non-Ferrous Metals Joint Stock Company | Tin |
NH Recytech Company* | Gold |
Niagara Refining LLC* | Tungsten |
Nihon Material Co., Ltd.* | Gold |
Nihon Material Corporation | Gold |
Nihon Superior Co., Ltd. | Gold |
Nyrstar Metals | Gold |
Refinery or Smelter Name | 3TG Material |
O.M. Manufacturing (Thailand) Co., Ltd.* | Tin |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Gold |
Ohura Precious Metal Industry Co., Ltd.* | Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold |
OJSC Novosibirsk Refinery | Gold |
Old City Metals Processing Co., Ltd. | Tin |
PAMP S.A.* | Gold |
Pan Light Corporation | Tin |
Pease & Curren | Gold |
Penglai Penggang Gold Industry Co., Ltd. | Gold |
Philippine Chuangxin Industrial Co., Inc.* | Tungsten |
Planta Recuperadora de Metales SpA* | Gold |
Pongpipat Company Limited | Tin |
Precious Metals Sales Corp. | Gold |
Prioksky Plant of Non-Ferrous Metals | Gold |
PT Aneka Tambang (Persero) Tbk* | Gold |
PT Aries Kencana Sejahtera** | Tin |
PT Artha Cipta Langgeng* | Tin |
PT ATD Makmur Mandiri Jaya* | Tin |
PT Babel Surya Alam Lestari* | Tin |
PT Bangka Prima Tin | Tin |
PT Bangka Serumpun* | Tin |
PT Bangka Tin Industry | Tin |
PT Belitung Industri Sejahtera | Tin |
PT Bukit Timah* | Tin |
PT Cipta Persada Mulia* | Tin |
PT DS Jaya Abadi | Tin |
PT Eunindo Usaha Mandiri | Tin |
PT Inti Stania Prima | Tin |
PT Justindo | Tin |
PT Karimun Mining | Tin |
PT Kijang Jaya Mandiri | Tin |
PT Lautan Harmonis Sejahtera | Tin |
PT Mitra Stania Prima* | Tin |
PT NATARI | Tin |
PT Panca Mega Persada | Tin |
PT Prima Timah Utama* | Tin |
PT Rajawali Rimba Perkasa* | Tin |
PT Rajehan Ariq* | Tin |
PT Refined Bangka Tin* | Tin |
PT Sariwiguna Binasentosa* | Tin |
PT Stanindo Inti Perkasa* | Tin |
PT Sukses Inti Makmur** | Tin |
PT Sumber Jaya Indah | Tin |
PT Timah Tbk Kundur* | Tin |
PT Timah Tbk Mentok* | Tin |
PT Tinindo Inter Nusa* | Tin |
PT Tirus Putra Mandiri | Tin |
PT Tommy Utama | Tin |
PT Wahana Perkit Jaya | Tin |
PX Precinox S.A.* | Gold |
QG Refining, LLC | Gold |
Rand Refinery (Pty) Ltd.* | Gold |
Realized the Enterprise Co., Ltd. | Gold |
Refinery or Smelter Name | 3TG Material |
Refinery of Seemine Gold Co., Ltd. | Gold |
Remondis Argentia B.V. | Gold |
Republic Metals Corporation | Gold |
Resind Industria e Comercio Ltda.* | Tin |
Royal Canadian Mint* | Gold |
Rui Da Hung* | Tin |
SAAMP* | Gold |
Safimet S.p.A* | Gold |
Safina A.S.* | Gold |
Sai Refinery | Gold |
Samduck Precious Metals* | Gold |
Samwon Metals Corp. | Gold |
SAXONIA Edelmetalle GmbH | Gold |
Schone Edelmetaal B.V. | Gold |
SEMPSA Joyeria Plateria S.A.* | Gold |
Shan Dong Huangjin | Gold |
Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co., Ltd. | Gold, Tin |
Shandon Jin Jinyin Refining Limited | Gold |
Shandong Hengbang Smelter Co., Ltd. | Gold |
Shandong Humon Smelting Co., Ltd. | Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Gold |
Shandong Yanggu Xiangguang Co., Ltd. | Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | Gold |
Shenzhen Heng Zhong Industry Co., Ltd. | Gold |
Shenzhen Hong Chang Metal Manufacturing Factory | Tin |
Shenzhen Zhonghenglong Real Industry Co., Ltd. | Gold |
Sichuan Tianze Precious Metals Co., Ltd.* | Gold |
Sigma Tin Alloy Co., Ltd. | Tin |
Singway Technology Co., Ltd.* | Gold |
Sino-Platinum Metals Co., Ltd. | Gold |
So Accurate Group, Inc. | Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals | Gold |
Soft Metais Ltda.* | Tin |
Solar Applied Materials Technology Corp.* | Gold |
Solar Chemical Applied Materials Technology (KUN SHAN) | Gold |
Solder Court Ltd. | Tin |
South-East Nonferrous Metal Company Limited of Hengyang City | Tungsten |
Sovereign Metals | Gold |
Spectro Alloys Corp. | Tin |
State Research Institute Center for Physical Sciences and Technology | Gold |
Sudan Gold Refinery | Gold |
Sumitomo Kinzoku Kozan K.K. | Gold |
SungEel HiMetal Co., Ltd.* | Gold |
Suntain Co., Ltd. | Gold |
Super Dragon Technology Co., Ltd. | Gold |
Super Ligas** | Tin |
Suzhou Nuonengda Chemical Co., Ltd. | Tin |
SuZhou ShenChuang recycling Ltd. | Gold |
T.C.A S.p.A* | Gold |
Taicang City Nancang Metal Material Co., Ltd. | Tin |
Taiwan high-tech Co., Ltd. | Tin |
TAIWAN TOTAI CO., LTD. | Gold |
Taiwan's lofty Enterprises Ltd. | Tin |
Tanaka Kikinzoku International* | Gold |
TAP | Tin |
Refinery or Smelter Name | 3TG Material |
Tejing (Vietnam) Tungsten Co., Ltd. | Tungsten |
The Refinery of Shandong Gold Mining Co., Ltd.* | Gold |
Three green surface technology limited company | Tin |
Tianshui Ling Bo Technology Co., Ltd. | Tin |
TIN PLATING GEJIU | Tin |
Tokuriki Honten Co., Ltd.* | Gold |
TONG LONG | Tin |
Tongling Nonferrous Metals Group Co., Ltd. | Gold |
Tony Goetz NV | Gold |
TOO Tau-Ken-Altyn* | Gold |
Top-Team Technology (Shenzhen) Ltd. | Tin |
Torecom* | Gold |
Tsai Brother industries | Gold |
Tungsten Diversified Industries LLC | Tungsten |
Tuyen Quang Non-Ferrous Metals Joint Stock Company | Tin |
Umicore Brasil Ltda. | Gold |
Umicore Precious Metals Thailand* | Gold |
Umicore S.A. Business Unit Precious Metals Refining* | Gold |
Unecha Refractory metals plant* | Tungsten |
United Precious Metal Refining, Inc.* | Gold |
Universal Precious Metals Refining Zambia | Gold |
Valcambi S.A.* | Gold |
Viagra Di precious metals (Zhaoyuan) Co., Ltd. | Gold |
Vietnam Youngsun Tungsten Industry Co., Ltd. | Tungsten |
VQB Mineral and Trading Group JSC | Tin |
Wang Ting | Gold |
Welley | Tin |
Western Australian Mint (T/a The Perth Mint)* | Gold |
WIELAND Edelmetalle GmbH* | Gold |
Wolfram Bergbau und Hutten AG* | Tungsten |
Woltech Korea Co., Ltd.* | Tungsten |
Wujiang City Luxe Tin Factory | Tin |
Wuzhong Group | Gold |
Xiamen Honglu Tungsten Molybdenum Co., Ltd. | Tin |
Xiamen Tungsten (H.C.) Co., Ltd.* | Tungsten |
Xiamen Tungsten Co., Ltd.* | Tungsten |
Xianghualing Tin Industry Co., Ltd. | Tin |
Xin Furukawa Metal ( Wuxi ) Co., Ltd. | Tin |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Tungsten |
XURI | Tin |
Yamakin Co., Ltd.* | Gold |
Yamato Denki Ind. Co., Ltd. | Gold |
Yifeng Tin | Tin |
Yiquan Manufacturing | Tin |
Yokohama Metal Co., Ltd.* | Gold |
Yuecheng Tin Co., Ltd. | Tin |
Yunnan Chengo Electric Smelting Plant | Tin |
Yunnan Copper Industry Co., Ltd. | Gold |
Yunnan Copper Zinc Industry Co., Ltd. | Tin |
Yunnan Geiju Smelting Corp. | Tin |
Yunnan Gold Mining Group Co., Ltd. (YGMG) | Gold |
Yunnan Industrial Co., Ltd. | Tin |
Yunnan Malipo Baiyi Kuangye Co. | Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. | Tin |
Refinery or Smelter Name | 3TG Material |
Zhaojun Maifu | Gold |
Zhe Jiang Guang Yuan Noble Metal Smelting Factory | Gold |
Zhongkuang Gold Industry Co., Ltd. | Gold |
Zhongshan Hyper-Toxic Substance Monopolized Co., Ltd. | Gold |
Zhongshan Poison Material Proprietary Co., Ltd. | Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | Gold |
Zhuhai toxic materials Monopoly Ltd. | Gold |
Zhuzhou Smelting Group Co., Ltd | Gold |
*RMI-Conforming
**RMI-Active
The refineries and smelters identified in the above table are located in the following countries:
Australia Belgium Brazil Canada Germany India Indonesia Italy Japan Kazakhstan Kingdom of Saudi Arabia Kyrgyzstan Lithuania Malaysia Mexico Myanmar Netherlands New Zealand |
Peoples Republic of China Philippines Republic of Korea Russian Federation Singapore South Africa Sudan Switzerland Taiwan, Province of China Thailand Turkey Uganda United Arab Emirates United States of America Uzbekistan Vietnam Zambia Zimbabwe |
In view of the Russian Federation’s invasion of Ukraine, on March 31, 2022 we informed our suppliers that we have suspended purchasing products containing precious metal of Russian origin.
3.3 Design and Implementation of a Strategy to Respond to Risks
Of our 39 suppliers who indicated that we obtain from them products containing any 3TG, 36 sell us products containing gold, either exclusively or together with other component parts containing other 3TG. In response to the CMRT and follow-up inquiries, we determined that 37 of those 39 suppliers sourced some or all of their 3TG from RMI-conformant or RMI-approved refineries.
We will continue to work closely with our suppliers to mitigate the risk that any minerals contained in our products may have directly or indirectly supported conflict by encouraging and, when deemed practicable, requiring them to source only from sub-suppliers who are able to and do certify that their 3TG are supplied by identified smelters and refineries that participate in an independent validation scheme or appropriate institutional mechanism.
3.4 Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. We do support such audits, however, by encouraging our direct suppliers to source only from upstream suppliers who can certify that the 3TG they provide were processed by smelters and refineries which participate in an independent validation scheme or appropriate institutional mechanism.
3.5 Report on supply chain due diligence
As required by the Rule, the Company will file a public report annually on Form SD and, if required, a conflict minerals report.
4. Efforts to determine mine or location of origin
Considering the Company’s position as a downstream purchaser of fully assembled products and components, we have determined that requesting our suppliers to complete the CMRT and provide information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain. Nevertheless, due to lack of complete information, the Company is unable to determine and to describe all facilities used to process the 3TG used in the products that we contract to have manufactured or the mine or country of origin of such 3TG. Nor have we been able to determine whether such 3TG come from recycled or scrap sources.
5. Steps to be taken to mitigate risk
We intend to take the following steps to improve the due diligence conducted to further mitigate the risk that any of the 3TG used in our products could benefit armed groups in the Covered Countries:
(i) | Continue to engage with our suppliers and direct them to training resources to improve the content of the supplier survey responses. |
(ii) | Further engage our suppliers found to be sourcing from smelters or refineries that are not certified as conflict-free to use, as an alternative, certified conflict-free processing sources. |
(iii) | Work with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance. |