EX-1.01 2 exhibit10153118.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01

Best Buy Co., Inc.
Conflict Minerals Report
For The Year Ended December 31, 2017

This Conflict Minerals Report for Best Buy Co., Inc. (“Best Buy”, “we”, “us” or “our”) covers the reporting period from January 1, 2017 to December 31, 2017, and is presented in accordance with the Securities Exchange Act of 1934, Rule 13p-1 (the “conflict minerals law”).

This Conflict Minerals Report is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD and both documents are posted on our website at www.investors.bestbuy.com

Introduction

The Democratic Republic of the Congo (“DRC”) and its adjoining countries (Covered Countries) have massive reserves of tin, tantalum, tungsten and gold (collectively known as “3TG”), all of which are commonly used in the manufacturing of many consumer products. Occasionally, these minerals are illegally mined and traded in the eastern DRC and surrounding areas by armed groups who use funds derived from mining to fuel violence and commit human rights violations. As such, these minerals, regardless of where they are mined, are known as “conflict minerals.”

In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act, section 1502 (the “Act”). Section 1502 specifically relates to conflict minerals and requires companies covered under the Act to annually file a Form SD with the United States Securities and Exchange Commission (“SEC”) to disclose whether the 3TG used in their products directly or indirectly benefited armed groups in the DRC. This Conflict Minerals Report, which is an exhibit to our Specialized Disclosure Report on Form SD, describes the design of our conflict minerals program and provides an account of how our program was applied in 2017 to determine, to the best of our ability, the source, chain of custody and facilities used to process the minerals used in Best Buy’s private label products, which are referred to as Exclusive Brands (“ExB”).

While we have increased our engagement with upstream actors such as smelters and refiners, we still have limited engagement with parties beyond the first-tier suppliers in our supply chain. Consequently, identifying, with certainty, the smelters, refiners and recyclers and the source of the materials they process is a significant challenge. We seek to address this challenge in part by participating in and, in some cases, leading collaborative industry efforts to gather accurate data about the sources of 3TG and encourage smelters to be validated as conflict-free.

Products

Best Buy is a leading provider of technology products, services and solutions. We offer these products and services to the customers who visit our stores, engage with Geek Squad Agents or use our websites or mobile applications. We have retail operations in the U.S., Canada and Mexico.

The ExB product categories, under brand names Insignia, Dynex, Rocketfish, Platinum and Modal, in which we believe contain tin, tungsten, tantalum, gold or a combination of these four metals and are therefore within scope of our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts include the following:
Product Category
Product Examples
Appliances
Refrigerators, shredders, coffee makers, toasters, blenders, etc.
Computing and Mobile Phones
Tablets, monitors, keyboards, mice, chargers, mobile chargers, cables, etc.
Consumer Electronics
TVs, DVD players, video cables, stereos, speakers, sound bars, radios, etc.
Entertainment
Charging stations, power packs, steering wheel combos, etc.

Reasonable Country of Origin Inquiry (“RCOI”)

Pursuant to the conflicts minerals law, we conducted a RCOI on the source of 3TG necessary to the functionality and/or production (“necessary 3TG”) of our products to determine whether any of the necessary 3TG originated in the DRC or an adjoining country or were from recycled or scrap sources. As part of our RCOI process, we conducted the following activities:


1


•
Reviewed past Minerals Reporting Templates ("MRTs"), utilized a 3TG risk assessment tool and consulted with our engineering team to identify 92 active, first-tier suppliers we knew or had reason to believe used necessary 3TG in the production of ExB products (“relevant suppliers”);
•
Used the MRT created by the Responsible Minerals Initiative (“RMI”) to survey relevant suppliers, requesting the identification of the facilities that processed the necessary 3TG they utilized and the country of origin from which the ores (i.e., unrefined minerals) were sourced;
•
Reviewed information provided by the 92 relevant suppliers to determine the completeness and reasonableness of their responses and verified the processing facilities they identified by comparing against the list of known smelters and refiners as provided by RMI;
•
Reviewed country of origin information available to Best Buy through our membership in RMI (member ID V1720151223); and
•
Conducted additional research on the 3TG processing facilities identified by relevant suppliers, including direct contact, in an attempt to augment the country of origin information gathered through our membership in RMI.

Based on the results of our RCOI, we had reason to believe that some of the necessary 3TG used in ExB products may have been processed by facilities that sourced from the DRC or an adjoining country and may not have been from recycled or scrap sources. In compliance with the Act, we then exercised due diligence on the source and chain of custody of the necessary 3TG processed by these facilities that conformed to an internationally recognized due diligence framework.

Due Diligence

To determine, to the best of our ability, the source and chain of custody of the necessary 3TG used in ExB products, we conducted due diligence on our supply chain. Our due diligence measures were developed to ascertain if the minerals originated from the DRC or an adjoining country and, if so, whether armed groups directly or indirectly benefited as a result. Additional measures were designed to mitigate risks identified through the implementation of our due diligence process.

Design of our Due Diligence Measures

Our due diligence process is designed to conform to, in all material aspects given our downstream position in the supply chain, the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition and the related supplements on Tin, Tantalum, Tungsten and Gold (collectively, the “OECD Guidance”), an internationally recognized due diligence framework. In accordance with the 5-step OECD Guidance, the design of our due diligence includes, but is not limited to, the following:

1.
Maintaining strong company management system through the adoption of a Conflict Minerals Policy, the implementation of a conflict minerals governance structure and strengthened engagement with our suppliers.

2.
Identifying and assessing risks by identifying relevant suppliers to engage in our RCOI and due diligence efforts, determining a reasonable engagement approach to gather conflict mineral sourcing information, and reviewing and validating smelter information provided by suppliers to determine risks.

3.
Responding to identified risks by reporting to senior management the findings derived from our RCOI and due diligence efforts, designing training for relevant suppliers to improve their systems of transparency and control and devising and implementing a risk mitigation strategy that seeks to ensure necessary 3TG in the supply chain are conflict-free.

4.
Supporting independent, 3rd-party audits of smelters and refiners’ due diligence via our membership in an industry association that developed an audit program.

5.
Reporting on due diligence through our Specialized Disclosure Report on Form SD and Conflict Minerals Report filed with the SEC and the inclusion of conflict minerals content in our annual Corporate Responsibility and Sustainability report.

Due Diligence Measures Performed

We worked with peers across multiple industries to ensure the implementation of our due diligence process was aligned with the OECD Guidance and complemented and amplified the industry approach. The primary objective of this alignment was to maximize the efficiency and effectiveness of our efforts to identify smelters and refiners and encourage their participation in RMI’s Responsible Minerals Assurance Process (“RMAP”) or an equivalent program, including the London Bullion Market

2


Association’s (“LBMA”) Good Delivery program and the Responsible Jewellery Council’s (“RJC”) Chain of Custody program. For this reporting period, we performed the due diligence measures described below on the source and chain of custody of necessary 3TG in the ExB supply chain that we knew or had reason to believe originated from the DRC or a Covered Countries and may not have been from recycled or scrap sources:

OECD Guidance Step 1: Maintaining a strong company management system
•
We published an updated Conflict Minerals Policy that specifically requires our suppliers to utilize smelters and refiners (“SORs”) who have successfully completed a 3rd-party audit of their due diligence practices;
•
The policy, communicated to all relevant suppliers, also requires suppliers to have a conflict minerals policy, provide an annual MRT that identified the SORs in their supply chain, and apply relevant aspects of the OECD Guidance to their sourcing practices. These requirements were assessed and reinforced when we conducted social compliance audits at supplier factories;
•
Our Conflict Minerals policy expectations were further reinforced through contract language that obliges our suppliers to meet the policy requirements;
•
We conducted 3rd party MRT Validation audits to assess the due diligence capabilities of key ExB suppliers, better understand their level of alignment with OECD Guidance, and drive corrective actions that improved the quality of data received from the suppliers;
•
We maintained a conflict minerals governance structure comprised of an operations team and an executive committee that included the department heads from Legal, External Reporting, Corporate Responsibility & Sustainability, Exclusive Brands and Communications and Public Affairs as well as a senior executive from Human Resources. The program is ultimately managed by our Chief Communications and Public Affairs officer;
•
We further strengthened the engagement with relevant ExB suppliers by providing in-person and online training regarding the Conflict Minerals law, our policy requirements and their role in supporting our RCOI and due diligence efforts;
•
We tracked our program performance across a set of KPI as detailed in the table below:
Conflict Mineral Program Key Performance Indicators
 
Percent of relevant ExB suppliers who attended training
89
%
Percent of relevant ExB suppliers who received training material
100
%
Percent of products containing necessary 3TG that have had their supply chains surveyed
100
%
Percent of relevant ExB suppliers who returned a MRT
100
%
Percent of relevant ExB suppliers who have a conflict minerals policy
96
%

OECD Guidance Step 2: Identifying and assessing risks
•
We reviewed data collected via our RCOI and due diligence efforts to determine if smelters in our supply chain may have been sourcing from a Covered Country and directly or indirectly financed or benefited armed groups in the DRC or an adjoining country;
•
We conducted outreach to smelters and refiners who had not been audited to determine their level of conformance to the RMI standard or another independent third-party’s standard and to encourage their participation in such a program;
•
We engaged 18 smelters and refiners to assess their sourcing practices and request country of origin information and/or to better understand the challenges they face to demonstrate their alignment with the OECD Guidance via a third-party audit;
•
We further assessed the level of risk posed by SORs reported to be in our supply chain via shared industry insights, media and other stakeholder reports, publicly available information, and the results of 3rd party audits, including audit schemes from RMI, LBMA and RJC.

OECD Guidance Step 3: Responding to identified risks
•
We reported the findings of our RCOI and due diligence measures, the subsequent risks identified, and the risk mitigation strategies to the conflict minerals executive committee;
•
We designed, implemented, and monitored risk mitigation strategies for suppliers who didn’t comply with our CM policy and SORs that had not successfully completed a 3rd party audit, including communications that reinforced our policy, providing additional training, conducted audits with corrective action plans and efforts to terminate business with some SORs who were deemed high-risk and refused to complete a third-party audit;
•
We helped smelters and refiners prepare for a RMAP audit and complete corrective action plans post-audit, as needed;
•
Monitored progress on SORs who implemented post-audit corrective action plans through our membership in RMI to ensure improvements were made in the SOR’s due diligence capabilities;

3


•
We took steps to disengage from 21 smelters in our supply chain who were assessed as high-risk due to their refusal to be transparent about their sourcing practices and locations.

OECD Guidance Step 4: Supporting independent, 3rd party audits of smelter and refiners’ due diligence
•
We contributed to the development and implementation of an effective smelter audit program through our membership in the RMI, which administers the Responsible Minerals Assessment Process audits;
•
We attended the annual RMI conference to gather best practices and collaborate with industry peers;
•
We supported many RMI activities including serving on the RMI Steering Committee, which sets the strategic direction for the organization, serving as Chair of the Smelter Engagement Team (“SET”), which conducts coordinated outreach to known smelters around the world to encourage them to participate in the RMAP or an equivalent program and leading the China SET, which works with smelters and refiners based in China.

OECD Guidance Step 5: Reporting on due diligence
•
We disclosed information regarding our due diligence effort on the sourcing of 3TG via our Specialized Disclosure Report and this Exhibit 1.01 Conflict Minerals Report filed with the SEC and we will include information on our conflict minerals due diligence efforts in our fiscal 2018 Corporate Responsibility and Sustainability Report, which we plan to release in the summer of 2018.

Results of Due Diligence Performed

We conducted the due diligence process described above to identify SORs and ascertain source and chain of custody information for the necessary 3TG in our ExB supply chain. In 2017, nearly 96% of the processing facilities reported by relevant suppliers have been found conformant to the RMI, LBMA, or RJC standard via an independent, third-party audit or they have committed to go through an audit. Nevertheless, based on our due diligence process and the subsequent information we gathered, we are unable to determine the origin of all the 3TG used in our products and whether armed groups directly or indirectly benefited. This is primarily due to incomplete information from suppliers who were unable to identify all the SORs used in their supply chain, company level MRTs in which we are unable to discern which of the reported SORs processed the necessary 3TG in our products, and the lack of transparency among smelters who have not yet been audited. Further complicating our ability to determine the origin of all the necessary 3TG is our downstream position in which we have no contractual relationship with upstream actors.

Of the 266 smelters and refiners provided by relevant ExB suppliers, we identified 21 for which we had reason to believe that at least a portion of the 3TG they processed may have originated in the DRC or an adjoining country and may not have been from recycled or scrap sources. All 21 of these processing facilities have been found conformant through RMAP or another independent, third-party audit scheme. Furthermore, we have not identified a supplier, smelter or refiner who we have reason to believe may be sourcing from the DRC or an adjoining country and directly or indirectly benefiting armed groups.

We are also aware that accusations, including poor labor practices and inadequate health and safety conditions at source mines, have been leveled against a few of the conformant smelters reported to be in our supply chain. We take these allegations seriously and we are monitoring 3rd party investigations and taking additional due diligence steps, including directly engaging these smelters. Based on the results of these efforts, we may take additional action, up to and including the removal of these smelters from our supply chain.

Please see the table below for the status of facilities reported to us by relevant ExB suppliers and see Attachment A for the list of smelters and refiners, their location and the countries from where they source, which is provided in aggregate by metal.
Metal
# of SORs
Conformant(1)
Active or TI-CMC Member(1)
Unknown(1)
Gold
112
88%
5%
7%
Tantalum
38
100%
0%
0%
Tin
74
95%
1%
4%
Tungsten
42
98%
0%
2%
Totals
266
93%
3%
4%
(1)
Facility status is defined as the following:

4


Facility Status
Status Definition
Conformant
Facilities as of April 28, 2018 that conform with a third-party due diligence audit standard
Active
Facilities that have committed to a RMAP audit or are participating in another independent third-party audit program
Unknown
Facilities that have not committed to undergo a RMAP audit and are not participating in another program

Efforts to Determine Mine of Location of Origin

While the design of our conflict minerals program is intended to identify the source and chain of custody of the necessary 3TG used in ExB products, the lack of transparency between smelters and refiners and the mine location where they source ore makes the identification of mine sites challenging. This is made more difficult by the lack of information about mine sites, especially among artisanal mines and in regions with poor governance and security. As such, we rely on MRTs received from relevant suppliers, RMI’s RCOI reports which provide country of origin information, and public information from a variety of sources including SOR disclosures, media reports, NGO reports and government reports to identify mine locations.

Future Steps to Optimize Our Due Diligence Efforts

Best Buy is committed to being a socially and environmentally responsible corporation and this commitment extends throughout the length of our value chain, from the sourcing of raw material to the responsible recycling of products. We recognize that this commitment is a journey and one that we cannot take on our own. This challenge is exacerbated given the complexity of our supply chain, which is, in essence, in a constant state of flux. As a result, we will continue to focus our efforts on collaborating across industries to improve the systems of transparency and control in our supply chain. We will also continue our engagement with relevant suppliers to build their knowledge so they are able to provide more complete and accurate information on the source of conflict minerals in our ExB supply chain and, furthermore, to impress upon them our expectation that they also apply the OECD Guidance in good faith.

Steps we intend to take in 2018 include:
•
Working with a variety of stakeholders on the development and implementation of grievance mechanism that supports the efforts of multiple audit programs, including those from RMI, LBMA and RJC;
•
Seeking to deepen our relationship with key stakeholders, such as the Shanghai Gold Exchange;
•
Conducting addition MRT Validation audits at key supplier and leverage the learning from these audits to update our training material that is delivered to all relevant suppliers;
•
Participating in RMI meetings to gather best practices and collaborate with industry peers.





5


Attachment A

The majority of the MRT responses we received from relevant suppliers provided data at a company level, meaning they listed the names of smelters and refiners they believe supplied 3TG for all the products they produced, not just the products they produced for Best Buy. Therefore, the processing facilities listed in the table below represent the smelters and refiners provided by our suppliers, but we do not have sufficient information to confirm whether these are the actual smelters that processed necessary 3TG used in our products. Additionally, we are unable to conclusively determine the country of origin information for our necessary 3TG but based on the data gathered from suppliers, processing facilities, public information and RMI, we believe that the sources may include the countries listed in the table below.
Metal
Processing Facility Name(1)
Location of Facility(1)
Facility Status(2)
Gold
Abington Reldan Metals, LLC
United States of America
 Unknown
Gold
Advanced Chemical Company
United States of America
Conformant
Gold
Aida Chemical Industries Co., Ltd.
Japan
Conformant
Gold
Al Etihad Gold Refinery DMCC
United Arab Emirates
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
Conformant
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Brazil
Conformant
Gold
Argor-Heraeus S.A.
Switzerland
Conformant
Gold
Asahi Pretec Corp.
Japan
Conformant
Gold
Asahi Refining Canada Ltd.
Canada
Conformant
Gold
Asahi Refining USA Inc.
United States of America
Conformant
Gold
Asaka Riken Co., Ltd.
Japan
Conformant
Gold
AU Traders and Refiners
South Africa
Conformant
Gold
Aurubis AG
Germany
Conformant
Gold
Bangalore Refinery
India
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Conformant
Gold
Boliden AB
Sweden
Conformant
Gold
C. Hafner GmbH + Co. KG
Germany
Conformant
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Conformant
Gold
Cendres + Metaux S.A.
Switzerland
Conformant
Gold
Chimet S.p.A.
Italy
Conformant
Gold
Chugai Mining
Japan
Unknown
Gold
Daejin Indus Co., Ltd.
Korea, Republic of
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
China
Conformant
Gold
DODUCO Contacts and Refining GmbH
Germany
Conformant
Gold
Dowa
Japan
Conformant
Gold
DSC (Do Sung Corporation)
Korea, Republic of
Conformant
Gold
Eco-System Recycling Co., Ltd.
Japan
Conformant
Gold
Elemetal Refining, LLC
United States of America
Unknown
Gold
Emirates Gold DMCC
United Arab Emirates
Conformant
Gold
Geib Refining Corporation
United States of America
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
China
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
China
Conformant
Gold
Heimerle + Meule GmbH
Germany
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
China
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
Conformant
Gold
HwaSeong CJ CO., LTD.
Korea, Republic of
Unknown
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Conformant
Gold
Istanbul Gold Refinery
Turkey
Conformant

6


Metal
Processing Facility Name(1)
Location of Facility(1)
Facility Status(2)
Gold
Japan Mint
Japan
Conformant
Gold
Jiangxi Copper Co., Ltd.
China
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Russian Federation
Conformant
Gold
JSC Uralelectromed
Russian Federation
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Conformant
Gold
Kazzinc
Kazakhstan
Conformant
Gold
Kennecott Utah Copper LLC
United States of America
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
Poland
Active
Gold
Kojima Chemicals Co., Ltd.
Japan
Conformant
Gold
Korea Zinc Co., Ltd.
Korea, Republic of
Conformant
Gold
Kyrgyzaltyn JSC
Kyrgyzstan
Conformant
Gold
L'azurde Company For Jewelry
Saudi Arabia
Unknown
Gold
L'Orfebre S.A.
Andorra
Active
Gold
LS-NIKKO Copper Inc.
Korea, Republic of
Conformant
Gold
Materion
United States of America
Conformant
Gold
Matsuda Sangyo Co., Ltd.
Japan
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
China
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
China
Conformant
Gold
Metalor Technologies S.A.
Switzerland
Conformant
Gold
Metalor USA Refining Corporation
United States of America
Conformant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Mexico
Conformant
Gold
Mitsubishi Materials Corporation
Japan
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
India
Conformant
Gold
Modeltech Sdn Bhd
Malaysia
Active
Gold
Morris and Watson
New Zealand
Unknown
Gold
Moscow Special Alloys Processing Plant
Russian Federation
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Turkey
Conformant
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Conformant
Gold
Nihon Material Co., Ltd.
Japan
Conformant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Austria
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Russian Federation
Conformant
Gold
OJSC Novosibirsk Refinery
Russian Federation
Conformant
Gold
PAMP S.A.
Switzerland
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
Russian Federation
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
Conformant
Gold
PX Precinox S.A.
Switzerland
Conformant
Gold
Rand Refinery (Pty) Ltd.
South Africa
Conformant
Gold
Remondis Argentia B.V.
Netherlands
Active
Gold
Republic Metals Corporation
United States of America
Conformant
Gold
Royal Canadian Mint
Canada
Conformant
Gold
SAAMP
France
Conformant
Gold
SAFINA A.S.
Czech Republic
Active
Gold
Samduck Precious Metals
Korea, Republic of
Conformant
Gold
Samwon Metals Corp.
Korea, Republic of
Unknown
Gold
SAXONIA Edelmetalle GmbH
Germany
Conformant
Gold
SEMPSA Joyeria Plateria S.A.
Spain
Conformant

7


Metal
Processing Facility Name(1)
Location of Facility(1)
Facility Status(2)
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
China
Unknown
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
Conformant
Gold
Singway Technology Co., Ltd.
Taiwan, Province of China
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Russian Federation
Conformant
Gold
Solar Applied Materials Technology Corp.
Taiwan, Province of China
Conformant
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Conformant
Gold
SungEel HiMetal Co., Ltd.
Korea, Republic of
Conformant
Gold
T.C.A S.p.A
Italy
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
China
Conformant
Gold
Tokuriki Honten Co., Ltd.
Japan
Conformant
Gold
Torecom
Korea, Republic of
Conformant
Gold
Umicore Brasil Ltda.
Brazil
Conformant
Gold
Umicore Precious Metals Thailand
Thailand
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
Conformant
Gold
United Precious Metal Refining, Inc.
United States of America
Conformant
Gold
Valcambi S.A.
Switzerland
Conformant
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
Conformant
Gold
WIELAND Edelmetalle GmbH
Germany
Conformant
Gold
Yamakin Co., Ltd.
Japan
Conformant
Gold
Yokohama Metal Co., Ltd.
Japan
Conformant
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
Conformant
Tantalum
D Block Metals, LLC
United States of America
Conformant
Tantalum
Exotech Inc.
United States of America
Conformant
Tantalum
F&X Electro-Materials Ltd.
China
Conformant
Tantalum
FIR Metals & Resource Ltd.
China
Conformant
Tantalum
Global Advanced Metals Aizu
Japan
Conformant
Tantalum
Global Advanced Metals Boyertown
United States of America
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
China
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
China
Conformant
Tantalum
H.C. Starck Co., Ltd.
Thailand
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Conformant
Tantalum
H.C. Starck Inc.
United States of America
Conformant
Tantalum
H.C. Starck Ltd.
Japan
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Germany
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Germany
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
China
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
Conformant
Tantalum
KEMET Blue Metals
Mexico
Conformant
Tantalum
KEMET Blue Powder
United States of America
Conformant
Tantalum
LSM Brasil S.A.
Brazil
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
India
Conformant
Tantalum
Mineracao Taboca S.A.
Brazil
Conformant

8


Metal
Processing Facility Name(1)
Location of Facility(1)
Facility Status(2)
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Conformant
Tantalum
NPM Silmet AS
Estonia
Conformant
Tantalum
Power Resources Ltd.
Macedonia
Conformant
Tantalum
QuantumClean
United States of America
Conformant
Tantalum
Resind Industria e Comercio Ltda.
Brazil
Conformant
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
China
Conformant
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation
Conformant
Tantalum
Taki Chemical Co., Ltd.
Japan
Conformant
Tantalum
Telex Metals
United States of America
Conformant
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
China
Conformant
Tin
Alpha
United States of America
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
Viet Nam
Unknown
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
Conformant
Tin
China Tin Group Co., Ltd.
China
Conformant
Tin
CV Ayi Jaya
Indonesia
Conformant
Tin
CV Dua Sekawan
Indonesia
Conformant
Tin
CV Gita Pesona
Indonesia
Conformant
Tin
CV United Smelting
Indonesia
Conformant
Tin
CV Venus Inti Perkasa
Indonesia
Conformant
Tin
Dowa
Japan
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Viet Nam
Unknown
Tin
EM Vinto
Bolivia (Plurinational State of)
Conformant
Tin
Estanho de Rondonia S.A.
Brazil
Unknown
Tin
Fenix Metals
Poland
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
China
Conformant
Tin
Gejiu Jinye Mineral Company
China
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
China
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
China
Conformant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
China
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
China
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
China
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
China
Conformant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
China
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
China
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
Conformant
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
Conformant
Tin
Melt Metais e Ligas S.A.
Brazil
Conformant
Tin
Metallic Resources, Inc.
United States of America
Conformant
Tin
Metallo Belgium N.V.
Belgium
Conformant
Tin
Metallo Spain S.L.U.
Spain
Conformant
Tin
Mineracao Taboca S.A.
Brazil
Conformant
Tin
Minsur
Peru
Conformant
Tin
Mitsubishi Materials Corporation
Japan
Conformant
Tin
Modeltech Sdn Bhd
Malaysia
Active
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Conformant

9


Metal
Processing Facility Name(1)
Location of Facility(1)
Facility Status(2)
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Conformant
Tin
Operaciones Metalurgical S.A.
Bolivia (Plurinational State of)
Conformant
Tin
PT Aries Kencana Sejahtera
Indonesia
Conformant
Tin
PT Artha Cipta Langgeng
Indonesia
Conformant
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Conformant
Tin
PT Babel Inti Perkasa
Indonesia
Conformant
Tin
PT Bangka Prima Tin
Indonesia
Conformant
Tin
PT Bangka Tin Industry
Indonesia
Conformant
Tin
PT Belitung Industri Sejahtera
Indonesia
Conformant
Tin
PT Bukit Timah
Indonesia
Conformant
Tin
PT DS Jaya Abadi
Indonesia
Conformant
Tin
PT Eunindo Usaha Mandiri
Indonesia
Conformant
Tin
PT Inti Stania Prima
Indonesia
Conformant
Tin
PT Karimun Mining
Indonesia
Conformant
Tin
PT Kijang Jaya Mandiri
Indonesia
Conformant
Tin
PT Lautan Harmonis Sejahtera
Indonesia
Conformant
Tin
PT Menara Cipta Mulia
Indonesia
Conformant
Tin
PT Mitra Stania Prima
Indonesia
Conformant
Tin
PT Panca Mega Persada
Indonesia
Conformant
Tin
PT Premium Tin Indonesia
Indonesia
Conformant
Tin
PT Prima Timah Utama
Indonesia
Conformant
Tin
PT Rajehan Ariq
Indonesia
Conformant
Tin
PT Refined Bangka Tin
Indonesia
Conformant
Tin
PT Sariwiguna Binasentosa
Indonesia
Conformant
Tin
PT Stanindo Inti Perkasa
Indonesia
Conformant
Tin
PT Sukses Inti Makmur
Indonesia
Conformant
Tin
PT Sumber Jaya Indah
Indonesia
Conformant
Tin
PT Timah (Persero) Tbk Kundur
Indonesia
Conformant
Tin
PT Timah (Persero) Tbk Mentok
Indonesia
Conformant
Tin
PT Tinindo Inter Nusa
Indonesia
Conformant
Tin
PT Tommy Utama
Indonesia
Conformant
Tin
Resind Industria e Comercio Ltda.
Brazil
Conformant
Tin
Rui Da Hung
Taiwan, Province of China
Conformant
Tin
Soft Metais Ltda.
Brazil
Conformant
Tin
Thaisarco
Thailand
Conformant
Tin
White Solder Metalurgia e Mineracao Ltda.
Brazil
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
Conformant
Tin
Yunnan Tin Company Limited
China
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
Japan
Conformant
Tungsten
ACL Metais Eireli
Brazil
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
Viet Nam
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
China
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
China
 Unknown
Tungsten
Global Tungsten & Powders Corp.
United States of America
Conformant

10


Metal
Processing Facility Name(1)
Location of Facility(1)
Facility Status(2)
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Germany
Conformant
Tungsten
H.C. Starck Tungsten GmbH
Germany
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
China
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
Conformant
Tungsten
Hydrometallurg, JSC
Russian Federation
Conformant
Tungsten
Japan New Metals Co., Ltd.
Japan
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
Conformant
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Conformant
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
China
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
Conformant
Tungsten
Kennametal Fallon
United States of America
Conformant
Tungsten
Kennametal Huntsville
United States of America
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
Conformant
Tungsten
Moliren Ltd.
Russian Federation
Conformant
Tungsten
Niagara Refining LLC
United States of America
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Viet Nam
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Philippines
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
China
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Viet Nam
Conformant
Tungsten
Unecha Refractory metals plant
Russian Federation
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
Viet Nam
Conformant
Tungsten
Wolfram Bergbau und Hutten AG
Austria
Conformant
Tungsten
Woltech Korea Co., Ltd.
Korea, Republic of
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
China
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
China
Conformant
Country of origin for the gold processed by the facilities listed above may include:
Benin, Bolivia (Plurinational State of), Burkina Faso, Canada, Chile, China, Columbia, Ecuador, Eritrea, Ghana, Guatemala, Guinea, Guyana, Honduras, Mali, Nicaragua, Panama, Peru, Russian Federation, South Africa, Senegal, Togo and the United States of America
Country of origin for the tantalum processed by the facilities listed above may include:
Austria, Bolivia (Plurinational State), Brazil, Burundi, China, Columbia, Democratic Republic of the Congo, Ethiopia, France, Guinea, Guyana, India, Kazakhstan, Madagascar, Malaysia, Mozambique, Namibia, Nigeria, Russian Federation, Rwanda, Sierra Leone, Thailand, United States of America and Zimbabwe
Country of origin for the tin processed by the facilities listed above may include:
Argentina, Australia, Bolivia, Brazil, Burundi, China, Columbia, Democratic Republic of the Congo, Germany, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Thailand, United Kingdom, Uganda, Viet Nam and Zimbabwe
Country of origin for the tungsten processed by the facilities listed above may include:
Australia, Austria, Bolivia (Plurinational State of), Brazil, Burundi, Cambodia, Canada, China, Columbia, Democratic Republic of the Congo, Japan, Mexico, Mongolia, Nigeria, Portugal, Russian Federation, Rwanda, Spain, United Kingdom, United States of America, Uzbekistan and Viet Nam
(1)
Facility name and location as reported by the Responsible Minerals Initiative.
(2)
Facility status is defined as the following:
Facility Status
Status Definition
Conformant
Facilities as of April 28, 2018 that conform with a third-party due diligence audit standard
Active
Facilities that have committed to a RMAP audit or are participating in another independent third-party audit program
Unknown
Facilities that have not committed to undergo a RMAP audit and are not participating in another audit program

11