PLANTRONICS, INC. (dba "POLY") CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2019
Introduction
This Conflict Minerals Report for the calendar year ended December 31, 2019 (“CY 2019”) is presented by Plantronics, Inc. (dba “Poly” formerly Plantronics and Polycom) (NYSE: PLT) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).
Poly is a global company that manufactures and contracts to manufacture communications headsets, audio and video products and related equipment, as listed on our Form SD of which this report is a part, from a global supply chain with many levels. We work with our supplier base to identify the facilities processing Tin, Tantalum, Tungsten and Gold (3TG) in our supply chain.
As part of the RCOI described in Form SD, Plantronics performed a supplier survey using the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) during the second half of CY2019. Fifty-six (56) direct first tier suppliers providing components used in Plantronics products within scope of the rule as described further in the Form SD were included in the survey utilized for both RCOI and Due Diligence. The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Plantronics products may have originated in the Democratic Republic of Congo or the adjoining countries (the “covered countries”) and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.
Design and Execution of Due Diligence
We first designed and implemented the majority of our due diligence measures in preparation for the reporting year CY 2013 with incremental modifications we have made over time to improve and refine the process, such as implementing supplier survey software and onsite supplier audits. These measures were continued in CY 2019 and are described herein. They are designed to conform, in all material respects, to the framework in The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2016) including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies (collectively the “OECD Guidance”). In accordance with the five step OECD Guidance, our measures are designed to determine, to the best of our ability, the source of the 3TG materials necessary for the functionality and/or production of our products, to ascertain if the materials originated in one of the covered countries, and if so, whether armed groups directly or indirectly benefited as a result.
1. | Establish Strong Company Management Systems |
a. | Poly has a company Conflict Minerals team consisting of senior representatives from Quality (Senior Director, Quality Excellence), Operations/Materials (Procurement Director, NPD and Sr. Global Supply Manager), Legal (Chief Compliance Counsel), Compliance (Director, Global Compliance), and members of their staffs. |
b. | Plantronics has a conflict minerals policy statement publicly available at: https://www.poly.com/us/en/company/corporate-responsibility/product-stewardship. |
c. | We maintain a grievance reporting system open to both employees and suppliers through our ethics reporting system at https://www.poly.com/us/en/company/corporate-responsibility/product-stewardship. Alternatively, grievances specifically relating to Conflict Minerals may be submitted directly to RMI at http://www.responsiblemineralsinitiative.org/minerals-due-diligence/risk-management/grievance-mechanism/. |
d. | In addition to any annual survey using the CMRT, supplier obligations and requirements in this regard have been incorporated into the Supplier Code of Conduct, which is also available on the Corporate Social Responsibility section of our website. In addition, Conflict Minerals Requirements, including due diligence and participation in annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document. |
e. | Poly purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause. |
f. | Poly 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. |
g. | Since we have limited direct relationships with any facilities processing 3TG, we are an active participant in the Responsible Minerals Initiative (RMI) (http://www.responsiblemineralsinitiative.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the SOR level and further upstream. |
h. | Conflict Minerals materials records are maintained pursuant to our records retention policy. |
i. | The formal Quarterly Compliance report includes a section providing conflict minerals program progress and findings to upper management. |
j. | We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures. |
k. | 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 SOR operational status, conformance to third party audit standards, as well as RCOI information. |
l. | 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 are 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 are primarily Original Design Manufacturers (ODMs) and cable or transducer suppliers. These surveys assess policy, training, record retention and data validation. |
In 2019, eleven (11) surveys of existing suppliers, which being evaluated with components or products potentially containing 3TG were performed the Conflict Minerals Compliance survey. The deficiencies were addressed by corrective action plans and were successfully completed. In addition, any new suppliers being considered for components or products potentially containing 3TG must also undergo the Conflict Minerals Compliance Survey to be approved.
2. | Identified and Assessed Risk in the Supply Chain |
• | Prior to and during CY 2019 we conducted face to face one-on-one training as well as teleconference training with newly qualified critical component or product suppliers. Training was primarily focused on ensuring a complete SOR 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 fifty-six (56) 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 current version of the CMRT (5.11 or higher). Our request included information to inform the suppliers of Poly’s reporting obligations under the Conflict Minerals Rule as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. A link to the Poly’s Conflict Minerals policy was included in the request. |
• | Reminders, late notices, delinquent notices and phone calls were sent and made to non-responsive suppliers. |
Commodity Managers, buyers, supplier quality engineers were involved in escalation after the time of the delinquent notices. We have not found it necessary to restrict business or disengage from any currently active suppliers due to failure to respond to the survey at this point. There may be potential corrective actions pending.
• | 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 SOR 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. |
• | In addition to direct suppliers, we used a data mining service to obtain conflict minerals information, also using the RMI CMRT, from thirty-six (36) manufacturers of critical and high usage off-the-shelf components with whom we had no direct relationship. |
• | 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. Greater than ninety percent (90%) of the suppliers responded by returning a CMRT, and eventually ninety-eight percent (98%) of those responses were accepted after review and, in some cases, correction. |
• | Sixty-three percent (63%) of returned CMRTs are provided on company level, thirty-seven percent (37%) are on product level, and ninety percent (90%) of the CMRTs indicated covered country sourcing of at least one metal. |
• | Facilities processing 3TG reported by our supply chain are categorized, based on information available through RMI, as |
◦ | SORs eligible to participate in a recognized audit program. |
◦ | Entities determined to not be eligible, 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 possibly, source from the covered countries and who were not validated as conflict free, Poly believes non-eligible, alleged and non-responsive SORs declining to participate in any audit program as a source of risk, since the actual source of the 3TG is not known. |
3. | Designed and Implemented a Strategy to Respond to Identified Risks |
• | We have 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. We asked suppliers 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. This effort was done both through collaborative efforts in RMI, and our own independent research in areas where we have associates that speak the local language. |
• | There were one hundred ninety-two (192) SORs reported this year that were not active or eligible, which had previously been on the CMRT SOR list and had either ceased operations or changed their business type. We gave feedback concerning the actual reason for removal, such as timing of ceased operations as this information was available through RMI. |
• | We are members and active participants in RMI and a number of working groups, including Due Diligence Practices, SOR Engagement (SET), China SET, and SOR Disposition teams and work within these teams to determine the legitimacy of “alleged SORs” reported by our supply chain or other RMI members as well as conducting 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 Responsible Minerals Assurance Process, London Bullion Market Association, Responsible Jewelry Council or TI-CMC, to enter such a program. |
• | We require that suppliers provide information regarding all sources of 3TG in their supply chain. We review this information for accuracy and consistency. We request further information when a response is considered insufficient. We inform suppliers of potential high risk SORs in their supply chain, and request confirmation of the SORs’ presence and possible disengagement. In 2019, we directed our suppliers to remove from our supply chain 8 smelters and refiners that were delisted from a third-party program, had environmental issues, or didn’t commit to responsible |
sourcing of minerals basing on RMI RCOI.
4. | Carry out independent 3rd Party Audit of SORs’ Due Diligence Practices |
Because Poly has few direct business relationships with SORs, we worked within industry initiatives to implement validation of DRC conflict free SORs as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by RMAP and cross-recognized programs London Bullion Market Association (LBMA) and Responsible Jewelry Council -(RJC) to determine SORs’ Due Diligence Practices.
5. | Report Annually on Supply Chain Due Diligence |
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.poly.com/us/en/company/corporate-responsibility/product-stewardship.
Results of due diligence performed
• | 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 SORs by the Plantronics supplier base as result of CY 2019 Supplier Survey was four hundred ninety-three (493). Of these, two hundred eighty-six (286) have been confirmed as being legitimate operating SORs by RMI, one hundred ninety-two (192) are known to not be operational SORs during CY 2019, fifteen (15) are reported with status could not be confirmed as of our cutoff date of March 20, 2020. |
• | Of the two hundred eighty-six (286) legitimate SORs reported by the supplier base, two hundred thirty-six (236) had been validated as being in conformance with a RMI cross-recognized conflict free audit protocol (RMAP, London Bullion Market Association, or Responsible Jewelry Council). Another thirteen (13) were actively engaged in the process, in communication with RMAP, or participating in another cross-recognized program, but had not achieved conformant status as of March 20, 2020. |
• | Thirty-seven (37) eligible reported SORs are not participating in a compliance scheme and have status of: |
◦ | Outreach required: twenty-eight (28) have not yet been convinced to participate in any audit program, but efforts to encourage them should continue. |
◦ | Communication Suspended (not interested): four (4) have stated clearly that they do not want to participate. |
◦ | Non-conformant: five (5) do not conform, failed audit, previously conformant, but did not complete re-audit or corrective action in a timely manner. |
• | One hundred ninety-two (192) entities were reported by our supply chain that are not currently considered eligible. These SORs had all been classified as operating SORs and listed on the CMRT at some time. They were reclassified by RMI due to either a change in their business operations or having either temporarily or permanently suspended operations. These are not included on the Smelter list. |
• | The remaining SORs 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. |
• | Of the two hundred eighty-six (286) legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that one hundred and seven (107) of the SORs sourced or may have sourced any minerals from the covered countries. |
• | Of the remaining SORs with definitive RCOI information available through RMI or other publicly available information, forty-four (44) 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 forty-four (44) 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. All countries believed to be the source of 3TG in our products during 2019 are listed in Table II. |
• | The percentage of SORs reported by our supply chain that have been validated as conformant to a recognized program has increased year over year. |
Smelters and Refiners Reported by Our Supply Chain by Year | |||
Calendar Year | Total Eligible | Total Conformant | % Conformant |
2014 | 159 | 76 | 47.80% |
2015 | 299 | 214 | 71.57% |
2016 | 336 | 246 | 73.21% |
2017 | 320 | 250 | 78.13% |
2018 | 324 | 255 | 78.70% |
2019 | 286 | 236 | 82.52% |
• | The SOR information collected from our supplier base continued to include a number of eligible SORs that had not been audited and validated as conformant by the RMAP, or any other cross recognized program. 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. |
• | From CY 2017 to the present, Poly has become of aware of OECD Annex II or other 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, SORs 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. We will keep monitoring the SOR status in our supply chain and working closely with our suppliers as well as RMI to implement due diligence. |
Steps to be taken to further mitigate risk
We intend to take the following steps where possible to build on momentum established in previous years to improve the due diligence conducted, and to further mitigate the risk that the necessary conflict minerals in our products benefit armed groups in the Covered Countries or facilitate any other types of human rights violations.
• | In coordination with RMI, engage directly with selected SORs to help guide them through the RMAP audit process. To the extent possible, attend metals industry conferences in conjunction with RMI to use direct contact to encourage participation in validation schemes. As gold appears to exhibit the highest risk in multiple risk categories, focus outreach and due diligence efforts on gold refiners. |
• | 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 RMI incident reporting tool to evaluate risk and red flags in upstream supply chain. |
• | Strongly encourage our supply chain to source only from conformant SORs, 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. |
• | Implement procedures to facilitate removal of SORs considered high risk for reasons other than DRC conflict; US or other sanctions or OECD Annex II issues. |
Table I. Plantronics SOR List
The list of reported SORs and status is as of Mar 20, 2020. RCOI data from RMI is as of March 11, 2020. The list includes one hundred seventy-nine (179) SORs that are either known to obtain at least some minerals from the covered countries or are SORs where the source of the minerals was not disclosed and could not be determined. Gold refiners validated as conformant through LBMA or RJC are included in this list, since they are not required to disclose the country of origin of their minerals. The list does not include those SORs that source only from outside the covered countries as determined through RCOI, or process only recycled or scrap materials. As the majority of our suppliers responded to surveys at a company level rather than
with respect to specific products, and due to the complexity of the electronics supply chain, as well as the diversity of both our products and our suppliers’ products, we cannot conclude with certainty that material from all of the SORs reported by our supply chain and included in this report are actually contained in Plantronics’ products.
“Country” refers to the location of the facility, not the source of minerals. The SOR location was not used for RCOI, since it does not necessarily determine the source of the ore, although SOR location near abundant mineral resources can be an indicator of mineral sourcing.
Status is defined as:
Conformant: SORs that have been audited and have been validated as compliant with the RMAP SOR Program or cross recognized (LBMA, RJC) assessment protocols. This includes SORs that were compliant as of 12/31/2019 as well as SORs that have completed audits and become conformant in 2020 prior to this report.
Active or In Communication: On RMI Active list or in communication with RMI. SORs on the Active list have committed to undergo a RMAP audit.
Outreach Required or Not Interested: Thirty-two (32) eligible SORs who have not yet completed a RMAP or cross recognized audit validating a conflict free process. This status includes some SORs indicating that they do not want to participate in a recognized validation system. Many claim the reason to be that they process only scrap or ore from their own mines and do not source ore from the covered countries. While this may be true, with no audit for verification, they are considered as “may source from covered countries”.
Non-Conformant: Five (5) SORs that failed RMAP audit, did not complete audit or re-audit corrective actions in the allotted time, or have previously been audited and have been conformant with the RMAP SOR Program or cross recognized (LBMA, RJC) assessment programs, but have not undergone a re-audit within the required time frame.
TABLE I
Metal | Status | |||
Gold | Kazzinc | KAZAKHSTAN | CID000957 | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | Conformant |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Conformant |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Conformant |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Conformant |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Conformant |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 | Conformant |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 | Conformant |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Conformant |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | Conformant |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Conformant |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | Conformant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | Conformant |
Gold | PAMP S.A. | SWITZERLAND | CID001352 | Conformant |
Gold | Aurubis AG | GERMANY | CID000113 | Conformant |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Conformant |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | Conformant |
Gold | Boliden AB | SWEDEN | CID000157 | Conformant |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Conformant |
Gold | Japan Mint | JAPAN | CID000823 | Conformant |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | Conformant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Conformant |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Conformant |
Gold | Chimet S.p.A. | ITALY | CID000233 | Conformant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | Conformant |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Conformant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Conformant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Conformant |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 | Conformant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Conformant |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | Conformant |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | Conformant |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 | Conformant |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Conformant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Conformant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | Conformant |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Conformant |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Conformant |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 | Conformant |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | Conformant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | Conformant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Conformant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Conformant |
Gold | Royal Canadian Mint | CANADA | CID001534 | Conformant |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Conformant |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | Conformant |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Conformant |
Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Conformant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 | Conformant |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Conformant |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | Conformant |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | Conformant |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | Conformant |
Gold | T.C.A S.p.A | ITALY | CID002580 | Conformant |
Gold | Marsam Metals | BRAZIL | CID002606 | Conformant |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Conformant |
Gold | SAAMP | FRANCE | CID002761 | Conformant |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 | Conformant |
Gold | 8853 S.p.A. | ITALY | CID002763 | Conformant |
Gold | Italpreziosi | ITALY | CID002765 | Conformant |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Conformant |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | In Communication |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 | In Communication |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 | In Communication |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Non-Conformant |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | Non-Conformant |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 | Not Interested |
Gold | Morris and Watson | NEW ZEALAND | CID002282 | Not Interested |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 | Not Interested |
Gold | SAFINA A.S. | CZECHIA | CID002290 | Active |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 | Outreach Required |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 | Outreach Required |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | Outreach Required |
Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 | Outreach Required |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | Outreach Required |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | Outreach Required |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | Outreach Required |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | Outreach Required |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | Outreach Required |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 | Outreach Required |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | Outreach Required |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | Outreach Required |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | Outreach Required |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | Outreach Required |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | Outreach Required |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 | Outreach Required |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 | Outreach Required |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | Outreach Required |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 | Outreach Required |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 | Outreach Required |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 | Outreach Required |
Gold | Sai Refinery | INDIA | CID002853 | Outreach Required |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 | Outreach Required |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 | Conformant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Conformant |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 | Conformant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Conformant |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | Conformant |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Conformant |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 | Conformant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | Conformant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | Conformant |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 | Conformant |
Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | Conformant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Conformant |
Tantalum | PRG Dooel | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 | Conformant |
Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | CID003402 | Active |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Conformant |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Conformant |
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 | Conformant |
Tin | Thaisarco | THAILAND | CID001898 | Conformant |
Tin | Yunnan Tin Company Limited | CHINA | CID002180 | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | CID002774 | Conformant |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | Conformant |
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | CID002773 | Conformant |
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 | In Communication |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | Non-Conformant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | CID002572 | Non-Conformant |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 | Non-Conformant |
Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 | Active |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 | Outreach Required |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | Outreach Required |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | Outreach Required |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | Outreach Required |
Tin | Super Ligas | BRAZIL | CID002756 | Outreach Required |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Conformant |
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 | Conformant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Conformant |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | Conformant |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | Conformant |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 | Conformant |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | Conformant |
Tungsten | GEM Co., Ltd. | CHINA | CID003417 | In Communication |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 | In Communication |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | Not Interested |
Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA | CID003448 | Active |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 | Active |
Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | CID002647 | Active |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 | Active |
TABLE II
The Countries of Origin for the minerals present in Poly products are believed to potentially include, but may not be limited to, the following. Information is from RMI SORs, news reports, industry associations, metals brokers’ reports, and USGS reports (Countries listed for 3T are reported to account for ~98% of global mined ore). Data also checked for plausibility against RMI known countries from which conformant 3TG SORs source information was included in RMI RCOI reports.
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