Delaware | 1-12696 | 77-0207692 |
(State or Other Jurisdiction of Incorporation) | (Commission file number) | (I.R.S. Employer Identification No.) |
Not Applicable |
(Former name or former address, if changed since last report) |
x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017. |
Exhibit Number | Description |
Date: June 4, 2018 | PLANTRONICS, INC. | ||
By: | /s/ Mary Huser | ||
Name: | Mary Huser | ||
Title: | Senior Vice President, General Counsel and Corporate Secretary |
• | Plantronics has a company Conflict Minerals team consisting of representatives from the Compliance, Legal, Operations/Materials, Quality, and Supplier Quality Engineering departments. |
• | Plantronics has a conflict minerals policy statement publicly available at https://www.plantronics.com/us/en/about/corporate-responsibility/product-stewardship. |
• | Plantronics maintains a grievance reporting system open to both employees and suppliers through our ethics reporting system at https://www.plantronics.com/us/en/about/corporate-responsibility/product-stewardship. Alternatively, grievances specifically relating to Conflict Minerals may be submitted directly to RMI at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. |
• | In addition to any annual survey using the CMRT, supplier obligations and requirements have been incorporated into the Supplier Code of Conduct, which is available on the corporate governance section of our website. In addition, Conflict Minerals Requirements, including due diligence and participation in an annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document. |
• | Plantronics purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause. |
• | Plantronics establishes and maintains long term relationships with the majority of our first tier Original Design, Contract, and Custom Part Manufacturers to facilitate engagement with suppliers to improve due diligence performance. |
• | Since we have limited direct relationships with any facilities processing 3TG, we are an active participant in the Conflict Free Sourcing Initiative (RMI) (http://www.responsiblemineralsinitiative.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the smelter or refiner level and further upstream. |
• | Conflict Minerals materials records are maintained pursuant to our records retention policy. |
• | The Conflict Minerals Team includes a section that provides information regarding conflict minerals program progress and findings to upper management in a formal quarterly compliance report. |
• | We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures. |
• | Since CY2014 we have used a software tool to improve management and auditability of supplier communications, as well as to request, receive, evaluate, store, and determine statistics on incoming CMRTs. The software is linked to the RMI database and is regularly updated regarding smelter and refiner operational status, conformance to third party audit standards, as well as RCOI information. |
• | Starting in CY 2015 our supplier quality team has conducted Conflict Minerals Ongoing Compliance surveys of selected first tier suppliers’ conflict minerals due diligence programs. Suppliers were selected based on the criticality of components to Plantronics products and the amount of 3TG likely present and the number of 3TG processing facilities in their supply chain, based on previous years’ surveys. These suppliers were primarily Original Design Manufacturers (ODMs) and cable or transducer suppliers. These surveys assessed policy, training, record retention and data validation. Seven such surveys were performed in 2017, two of the surveys found supplier deficiencies which were addressed by corrective action plans, both of which were successfully completed. In addition, any new suppliers being considered for components or products must also undergo the Conflict Minerals Compliance Survey to be approved. |
• | Prior to conducting the CY2017 supplier survey Plantronics conducted face to face one-on-one training with newly qualified critical component or product suppliers. Training was primarily focused on ensuring a complete smelter list by proper scoping of products and components to identify all likely locations of 3TG, including parts and components purchased by the 1st tier supplier. |
• | We conducted a supplier survey of the 81 direct first tier suppliers providing products or components within scope of the rule; necessary for the functionality of our products and likely to contain 3TG. The survey required that the supplier return the then current version of the CMRT (5.0x or higher). Our |
• | Reminders, late notices and delinquent notices were sent to non-responsive suppliers. Commodity Managers were involved in escalation at the time of the delinquent notices. While we did not find it necessary to restrict business or disengage from any currently active suppliers due to failure to respond to the survey, a number of suppliers used only for Clarity products were not responsive, as the survey was done following the sale of the Clarity business and Plantronics no longer has a relationship with these suppliers. |
• | All incoming CMRTs underwent a two-step review process. The first step is a PASS/FAIL check by our Conflict Minerals software for completeness and internal consistency of the declaration and submitted smelter list. A message was automatically sent by the software system to suppliers submitting CMRTs containing errors, with an explanation of the error and a request for corrective action and re-submission. |
• | Once CMRTs passed this first evaluation, they were then evaluated by internal compliance engineers on an ACCEPT/MODIFY basis for consistency with the known content and complexity of the products or components provided. A message was sent to suppliers submitting CMRTs found insufficient or incomplete with an explanation and request for corrective action. We continued to communicate with those suppliers to improve the content and quality of their responses. Other than Clarity suppliers, greater than 95% of the suppliers responded by returning a CMRT, and eventually 98% of those responses were accepted after review and, in some cases, correction. |
• | In addition to direct suppliers, we used a data mining service to obtain conflict minerals information, also using the RMI CMRT, from manufacturers of critical and high usage off-the-shelf components with whom we had no direct relationship. |
• | Facilities processing 3TG reported by our supply chain were categorized, based on information available through RMI, as: |
• | Legitimate Smelters or Refiners (SORs). |
• | Entities determined to not be legitimate or active SORs during the reporting period. |
• | Entities alleged to be SORs, whose business could not be determined during the reporting period. |
• | In addition to SORs known to, or believed to, source from the covered countries who were not validated as conflict free, Plantronics identified non-legitimate or alleged smelters as a source of risk, since the actual source of the 3TG is not known. |
• | We have continuously conducted research into “alleged” SORs - companies reported that were not on any list of known SORs- reported in our supplier survey to determine the nature of these entities’ business. This effort is done both through collaborative efforts in RMI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the final number of “alleged” SORs has been significantly reduced progressively from the number in previous reporting years, from 83 in CY2013 to 46 in CY2014 to none in CY 2015, CY2016, and CY2017 final survey results. This is attributable to determining that many of the alleged SORs were indeed legitimate SORs or legitimate SOR aliases, or determination of the company’s actual business, as well as improved supplier reporting. |
• | We asked suppliers initially reporting non-smelters or alleged smelters to verify the information and if possible, identify actual smelters. We gave feedback concerning the actual nature of a non-smelter’s business to the supplier when such information was available, primarily through RMI collaborative efforts. |
• | We continued to work within RMI teams to determine the legitimacy of any “alleged SORs” reported by our supply chain or other RMI members. |
• | We encouraged known smelters not yet validated as Conflict Free to participate in Conflict Free Smelter Program (CFSP). |
• | We conducted outreach in coordination with RMI to encourage legitimate SORs reported by our supply chain that have not been validated as DRC conflict free by a recognized conflict free program such as Conflict Free Smelter Program, London Bullion Market Association, Responsible Jewelry Council or TI-CMC, to enter such a program. |
• | Because Plantronics has few direct business relationships with smelters, we worked within industry initiatives to implement validation of DRC conflict free smelters as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by CFSP to determine smelters’ Due Diligence Practices. |
• | Our Form SD and this Report together constitute our annual report on our Conflict Minerals Due Diligence. These have been filed with the SEC and are available on our website at https://www.plantronics.com/us/en/about/corporate-responsibility/product-stewardship. |
• | Most of our direct supplier responses represented their supply chain at a company-level rather than being product- specific. Therefore, the list of processing facilities contained in this report may contain more facilities than those that actually process the conflict minerals contained in our products. The total number of unique entities reported as smelters or refiners by the Plantronics supplier base as result of CY 2017 Supplier Survey was 320. Of these, 309 have been confirmed as being legitimate operating SORs by RMI., 11 are known to not be legitimate operational SORs, and there were no reported entities whose status could not be confirmed as of our cutoff date of May 01, 2018. |
• | Of the 309 legitimate SORs reported by the supplier base, 250 had been validated as being in conformance with a RMI recognized conflict free audit protocol (RMAP, London Bullion Market Association, or Responsible Jewelry Council). Another 13 were in process or communication with CFSP, or participating in another recognized program, but had not achieved validated status as of May 04, 2018. |
• | Forty six legitimate reported SORs are not participating in a compliance scheme and have status of “Not Validated” fall into three categories: |
• | Outreach required: (28) Have not yet been convinced to participate, but efforts to encourage them should continue. |
• | Communication Suspended (not interested): (7) Have stated clearly that they do not want to participate. |
• | Communication Suspended (temporarily not operating): (1) Not currently operating, but intend to re-start. |
• | Other Listed Status Categories are: |
• | Non-conformant: (6) Do not conform, failed audit, did not complete re-audit or corrective action in a timely manner. |
• | Due Diligence required: (4) There may be issues other than DRC conflict involved. |
• | The 11 entities reported by our supply chain that are not currently considered legitimate smelters had all been classified as operating smelters and listed on the CMRT at some point. They were reclassified by RMI due to either a change in their business operations or they either temporarily or permanently suspended operations. A number of these smelters currently listed as not legitimate may have been in operation for part of CY2017, so are included on the smelter list. Where information is available as to when they ceased operations, it is noted. |
• | The remaining legitimate smelters that are not conformant as yet require outreach to encourage participation in a conflict free program. Plantronics actively participates in RMI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls. We also interact directly with selected smelters to help guide them through the CFSP audit process. |
• | Of the 309 legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that 146 of the SORs sourced or may have sourced any minerals from the covered countries. |
• | Of the remaining smelters with definitive RCOI information available through RMI or other publicly available information, 22 were known or reasonably believed to directly or indirectly source minerals from the DRC, the surrounding countries or countries known as possible routes for smuggling or export of minerals out of the DRC. All 22 are RMAP Conformant. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. The countries believed to be the source of 3TG in our products are listed in Table II. |
• | Although the number of SORs reported by our supply chain that have not been validated as conflict free has decreased year over year, the smelter information collected from our suppler base continued to include a number of legitimate smelters or refiners that had not been audited and validated as DRC Conflict Free by the RMAP, or any other recognized organization. The existence of such facilities in our supply chain is sufficient to prevent us from declaring with certainty that no armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free. |
• | During CY 2017 and CY 2018 to date, Plantronics has become of aware of OECD Annex II risks in the 3TG supply chain unrelated to financing conflict in the DRC and adjoining countries. These risks include, but are not limited to, material sourced in conflict risk areas other than the DRC, smelters in countries under sanction or wholly or partially owned by individuals under sanction, or securing raw materials from sanctioned entities. Other concerns are child or forced labor and money laundering. There are some SORs on CY2017 smelter list that may require further due diligence. |
• | In Co-ordination with RMI, engage directly with selected smelters to help guide them through the CFSP audit process. To the extent possible, attend metals industry conferences in conjunction with RMI to use direct contact to encourage participation in validation efforts. |
• | Take advantage of added RMI resources by adding a link on our website to RMI conflict minerals specific grievance system in addition to the existing PLT company grievance system, and utilize the RMI incident reporting tool to evaluate risk and red flags in upstream supply chain. |
• | Strongly encourage our supply chain to source only from validated conflict free smelters, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible. |
• | Work with our supply chain to reduce or discontinue sourcing materials from SORs that have consistently refused to participate in any conflict free programs, or SORs that have failed audits or declined to undergo re-audits. |
• | Engage a third party audit to validate status of selected suppliers who report only validated conflict free smelters in their supply chain and who have also passed Conflict Minerals process survey by Plantronics Supplier Engineering team. |
• | Develop policies and practices to address supply chain issues not related to DRC conflict that have been revealed during the Conflict Minerals Supply Chain Survey and participation in RMI activities. |
Metal | Smelter Name | Location of smelter | Status | Audit By |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant | RMAP |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant | RJC |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant | LBMA |
Metal | Smelter Name | Location of smelter | Status | Audit By |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant | LBMA |
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant | LBMA |
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant | LBMA |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant | LBMA |
Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant | RJC |
Gold | Aurubis AG | GERMANY | Conformant | LBMA |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant | LBMA |
Gold | Boliden AB | SWEDEN | Conformant | LBMA |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant | RJC |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant | LBMA |
Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant | LBMA |
Gold | Chimet S.p.A. | ITALY | Conformant | LBMA |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant | LBMA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant | LBMA |
Gold | Heimerle + Meule GmbH | GERMANY | Conformant | LBMA |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant | LBMA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant | LBMA |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant | LBMA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant | LBMA |
Gold | Istanbul Gold Refinery | TURKEY | Conformant | LBMA |
Gold | Italpreziosi | ITALY | Conformant | RJC |
Gold | Japan Mint | JAPAN | Conformant | LBMA |
Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant | LBMA |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant | LBMA |
Gold | Kazzinc | KAZAKHSTAN | Conformant | LBMA |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant | RJC |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant | LBMA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant | LBMA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant | LBMA |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant | RJC |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant | RJC |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant | RJC |
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant | RJC |
Metal | Smelter Name | Location of smelter | Status | Audit By |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant | RJC |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant | LBMA |
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant | LBMA |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | RMAP |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant | LBMA |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant | LBMA |
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant | LBMA |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant | RJC |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | PAMP S.A. | SWITZERLAND | Conformant | LBMA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant | LBMA |
Gold | PX Precinox S.A. | SWITZERLAND | Conformant | LBMA |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant | LBMA |
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Conformant | RJC |
Gold | Royal Canadian Mint | CANADA | Conformant | LBMA |
Gold | SAAMP | FRANCE | Conformant | RJC |
Gold | Safimet S.p.A | ITALY | Conformant | RJC |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant | LBMA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant | LBMA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant | LBMA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant | LBMA |
Gold | T.C.A S.p.A | ITALY | Conformant | LBMA |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant | LBMA |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant | LBMA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant | LBMA |
Gold | Umicore Brasil Ltda. | BRAZIL | Conformant | LBMA |
Gold | Umicore Precious Metals Thailand | THAILAND | Conformant | LBMA |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant | LBMA |
Gold | Valcambi S.A. | SWITZERLAND | Conformant | RJC |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant | LBMA |
Metal | Smelter Name | Location of smelter | Status | Audit By |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant | LBMA |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant | RMAP |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant | RMAP |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant | RMAP |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant | RMAP |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | RMAP |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant | RMAP |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant | RMAP |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant | RMAP |
Tantalum | KEMET Blue Metals | MEXICO | Conformant | RMAP |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant | RMAP |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | RMAP |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant | RMAP |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Conformant | RMAP |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant | RMAP |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant | RMAP |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant | RMAP |
Tin | Thaisarco | THAILAND | Conformant | RMAP |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant | RMAP |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant | RMAP |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant | RMAP |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant | RMAP |
Gold | Bangalore Refinery | INDIA | On RMI Active List | |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | On RMI Active List | |
Gold | L'Orfebre S.A. | ANDORRA | On RMI Active List | |
Gold | Modeltech Sdn Bhd | MALAYSIA | On RMI Active List | |
Gold | Remondis Argentia B.V. | NETHERLANDS | On RMI Active List | |
Gold | SAFINA A.S. | CZECH REPUBLIC | On RMI Active List | |
Tin | Modeltech Sdn Bhd | MALAYSIA | On RMI Active List | |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | On RMI Active List | |
Gold | Chugai Mining | JAPAN | Not validated | |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not validated | |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not validated | |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Not validated |
Metal | Smelter Name | Location of smelter | Status | Audit By |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not validated | |
Gold | Guangdong Jinding Gold Limited | CHINA | Not validated | |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not validated | |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not validated | |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not validated | |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not validated | |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Not validated | |
Gold | Lingbao Gold Co., Ltd. | CHINA | Not validated | |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not validated | |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not validated | |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not validated | |
Gold | Pease & Curren | UNITED STATES OF AMERICA | Not validated | |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not validated | |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not validated | |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Not validated | |
Gold | Sai Refinery | INDIA | Not validated | |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not validated | |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Not validated | |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not validated | |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not validated | |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not validated | |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not validated | |
Tin | Estanho de Rondonia S.A. | BRAZIL | Not validated | |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not validated | |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not validated | |
Tin | Super Ligas | BRAZIL | Not validated | |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not validated | |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not validated | |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not validated | |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Not validated | |
Gold | Morris and Watson | NEW ZEALAND | Not validated | |
Gold | Morris and Watson Gold Coast | AUSTRALIA | Not validated | |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Not validated | |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not validated |
Metal | Smelter Name | Location of smelter | Status | Audit By |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Due Diligence Required | |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Due Diligence Required | |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Due Diligence Required | |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Non-Conformant | |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | Non-Conformant | |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Non-Conformant | |
Gold | Schone Edelmetaal B.V.** | NETHERLANDS | Not a Legitimate Smelter | |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd.** | CHINA | Not a Legitimate Smelter | |
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd.** | CHINA | Not a Legitimate Smelter | |
Tin | PT O.M. Indonesia** | INDONESIA | Not a Legitimate Smelter | |
Tin | VQB Mineral and Trading Group JSC* | VIET NAM | Not a Legitimate Smelter | |
Gold | So Accurate Group, Inc.* | UNITED STATES OF AMERICA | Not a Legitimate Smelter | |
Tantalum | Duoluoshan* | CHINA | Not a Legitimate Smelter | |
Tantalum | King-Tan Tantalum Industry Ltd.* | CHINA | Not a Legitimate Smelter | |
Tin | Cooperativa Metalurgica de Rondonia Ltda.* | BRAZIL | Not a Legitimate Smelter | |
Tin | PT Cipta Persada Mulia* | INDONESIA | Not a Legitimate Smelter | |
Tin | PT Justindo* | INDONESIA | Not a Legitimate Smelter | |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd.**** | CHINA | Non-Conformant | |
Gold | Elemetal Refining, LLC**** | UNITED STATES OF AMERICA | Non-Conformant | |
Gold | Tony Goetz NV**** | BELGIUM | Non-Conformant | |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant**** | RUSSIAN FEDERATION | Conformant | LBMA |
Gold | Universal Precious Metals Refining Zambia**** | ZAMBIA | Not validated | |
Gold | Sudan Gold Refinery**** | SUDAN | Not validated | |
Gold | Fidelity Printers and Refiners Ltd.**** | ZIMBABWE | Due Diligence required |
Mineral | Countries of Origin |
Tungsten | Democratic Republic of Congo, Burundi, Rwanda, China, Vietnam, Russia, Canada, Bolivia, Australia, Austria, Spain, Portugal, United States, DRC, Mexico, Mongolia, Uzbekistan, Uganda |
Tantalum | Democratic Republic of Congo, Rwanda, Burundi, Brazil, Mozambique, China, Nigeria, Australia, Uganda, Bolivia, Colombia, Mongolia, Nigeria, Portugal, Russia, Spain, Mozambique |
Tin | Bolivia, Brazil, Myanmar, China, Indonesia, Peru, Australia, Democratic Republic of Congo, Malaysia, Nigeria, Rwanda, Vietnam, Burundi, Mongolia, Niger, Portugal, Russia, Tanzania, Thailand, Uganda |
Gold | China, Australia, Russia, United States, Peru, Canada, South Africa, Mexico, Uzbekistan, Ghana, Brazil, Papua New Guinea; Democratic Republic of Congo, Kazakhstan, Argentina, Tanzania, Mali, Dominican Republic, Columbia, Philippines Chile, Burkina Faso, Ivory Coast, Mongolia, Turkey, Guinea, Senegal, Togo |