0000914025-22-000044.txt : 20220601 0000914025-22-000044.hdr.sgml : 20220601 20220531174707 ACCESSION NUMBER: 0000914025-22-000044 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20211231 1.02 20211231 FILED AS OF DATE: 20220601 DATE AS OF CHANGE: 20220531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PLANTRONICS INC /CA/ CENTRAL INDEX KEY: 0000914025 STANDARD INDUSTRIAL CLASSIFICATION: TELEPHONE & TELEGRAPH APPARATUS [3661] IRS NUMBER: 770207692 STATE OF INCORPORATION: DE FISCAL YEAR END: 0402 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-12696 FILM NUMBER: 22984962 BUSINESS ADDRESS: STREET 1: 345 ENCINAL ST CITY: SANTA CRUZ STATE: CA ZIP: 95061-1802 BUSINESS PHONE: 8314203002 MAIL ADDRESS: STREET 1: 345 ENCINAL STREET STREET 2: PO BOX 1802 CITY: SANTA CRUZ STATE: CA ZIP: 95061-1802 FORMER COMPANY: FORMER CONFORMED NAME: PI PARENT CORP DATE OF NAME CHANGE: 19931025 SD 1 cy21formsd.htm SD Document

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT


PLANTRONICS, INC.

(Exact name of Registrant as Specified in its Charter)

Delaware1-12696
(State or Other Jurisdiction of Incorporation) (Commission file number)

345 Encinal Street
Santa Cruz, California 95060
(Address of Principal Executive Offices including Zip Code)

(831) 420-3002
(Registrant's Telephone Number, Including Area Code)

Lisa Bodensteiner (831) 458-7510
Executive Vice President and Chief Legal and Compliance Officer

(Name and telephone number, including area code, of the
person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
 
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .



Introduction
This Form SD for Plantronics Inc. ("Poly", “Company,” “we” or “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1, 2021 to December 31, 2021.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Companies subject to Rule 13p-1 are required to perform certain procedures and to disclose information about the use of "conflict minerals" which include coltan, cassiterite, gold, wolframite, or their derivatives, which are limited to tungsten, tantalum and tin and gold ("3TG") that are necessary to the functionality of the products such companies manufacture or contract to manufacture. In accordance with Rule 13p-1, Poly conducted an evaluation to determine which products sold by Poly were manufactured or contracted to be manufactured and would fall under the scope of Rule 13p-1. Poly then conducted an evaluation of the components and parts used in these products to determine the likely presence of the 3TG. This evaluation was done by reviewing specifications, drawings, material declarations submitted by suppliers, and conflict Minerals Reporting Templates (CMRTs) submitted by suppliers in previous reporting years.

Our evaluation led to the conclusion that all of our products manufactured or contracted to be manufactured contain components we believe are likely to contain 3TG necessary for the functionality of those products and are therefore within the scope of Rule 13p-1 and the related rules and regulations.

Upon determination of the presence of 3TG in our products, Poly evaluated suppliers from whom we had purchased materials used in products manufactured in calendar year 2021. The full supplier list of two hundred forty-six (246) direct suppliers was filtered to exclude those suppliers providing services, packaging, collateral, or tooling which are not necessary to the functionality of the products, narrowing the list to two hundred and five (205) direct suppliers of materials necessary to the functionality of our products. We used engineering evaluation, material disclosures and previous year submissions to determine that fifty-three (53) suppliers, which represent over 98 percent of our direct spend, provided materials, components and products contained or were likely to contain 3TG. We conducted a Reasonable Country of Origin Inquiry (RCOI) by asking those suppliers providing components and parts deemed necessary for the functionality of the products and expected or known to contain 3TG to complete the Responsible Mineral Initiative (RMI) Conflict Minerals Reporting Template (CMRT) to verify the presence of 3TG and to determine the facilities – smelters or refiners (SORs) -processing those minerals with the greatest possible specificity. We analyzed the information gathered through this supply chain survey. The data on which we relied to determine the country of origin of the minerals was obtained through our membership in the RMI, using the Reasonable Country of Origin Inquiry report for member 0001695384. We also did additional evaluation of SOR’s potential geographic sourcing using sources such as publicly available financial reports, news stories, and non-governmental organization information. This inquiry led us to conclude that 3TG in our products could originate from any of the following sources:

1) recycled or scrap material.
2) countries with known active ore production that are not identified as conflict regions.
3) known or possible countries for smuggling or export of minerals out of the DRC.
4) the DRC and adjoining countries.

Poly therefore conducted further due diligence in accordance with 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) and related Supplements including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies, on those SORs known to or believed to possibly source minerals from the DRC, surrounding countries or countries that are considered possible smuggling routes of materials from the conflict area (South Africa, Kenya and Mozambique) that are not adjoining countries. We support and actively participate in an industry initiative, the Responsible Mineral Initiative’s Responsible Minerals Assurance Process (RMAP), a program that audits SORs’ due diligence activities and can provide information regarding the country of origin of the minerals.

There is significant overlap between our RCOI efforts and our due diligence measures performed. The description of Poly’s Due Diligence is in the Conflict Minerals Report filed as an exhibit as part of this Disclosure.






Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 - Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 - Exhibits

Item 3.01 Exhibits

The following exhibit is filed as part of this report:




SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized. 

    
Date:  May 31, 2022PLANTRONICS, INC.
   
 By:/s/ Lisa Bodensteiner
 Name:Lisa Bodensteiner
 Title:Executive Vice President and Chief Legal and Compliance Officer


EX-1.01 2 cy21cmrex101.htm EX-1.01 Document


PLANTRONICS, INC. (POLY) CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2021

Introduction
This Conflict Minerals Report for the calendar year ended December 31, 2021 (“CY 2021”) is presented by Plantronics, Inc. (“Poly”, “Company”, “we” or “our”) (NYSE: POLY) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”). Companies subject to Rule 13p-1 are required to perform certain procedures and to disclose information about the use of “conflict minerals” which include coltan, cassiterite, gold, wolframite, or their derivatives, which are limited to tungsten, tantalum and tin and gold (“3TG”) that are necessary to the functionality of the products such companies manufacture or contract to manufacture.

Poly Products
Poly is a leading global communications technology company that designs, manufactures, and markets integrated communications and collaboration solutions for professionals. We offer a comprehensive selection of premium audio and video products designed to work in an era where work is no longer a place and enterprise work forces are increasingly distributed. Our products and services are designed and engineered to connect people with high fidelity and incredible clarity. They are professional-grade, easy to use, and work seamlessly with major video and audio-conferencing platforms. Our major product categories are Headsets, Voice, Video, and Services. Headsets include wired and wireless communication headsets; Voice includes open Session Initiation Protocol and native ecosystem desktop phones, as well as conference room phones and speakerphones; Video includes conferencing solutions and peripherals, such as cameras, speakers, and microphones; Services includes a broad portfolio of offerings including video interoperability, maintenance and troubleshooting support for our solutions, as well as professional, hosted, and managed services that are grounded in our deep expertise aimed at helping our customers achieve their collaboration goals. Additionally, our cloud management and analytics software enables Information Technology administrators to configure and update firmware, monitor device usage, troubleshoot, and gain a deep understanding of user behavior. All of our solutions are designed to integrate seamlessly with a wide range of Unified Communications & Collaboration, Unified Communication as a Service, and Video as a Service platforms, allowing our customers the flexibility to use the communications platform of their choice.

Poly conducted an evaluation of Poly products sold by Poly that were manufactured or contracted to be manufactured in CY 2021 to determine the likely presence of the 3TG. This evaluation was done by reviewing specifications, drawings, material declarations submitted by suppliers, and Conflict Minerals Reporting Templates (CMRTs) submitted by suppliers in previous reporting years. Our evaluation led to the conclusion that all of our products manufactured or contracted to be manufactured contain components we believe are likely to contain 3TG necessary for the functionality of those products and are therefore within the scope of Rule 13p-1 and the related rules and regulations.

Poly’s Conflict Minerals Program
Poly is fully committed to sourcing 3TG responsibly.

As a downstream company, Poly does not directly purchase 3TG from mines, smelters or refiners, nor has business relationship with these entities or visibility of the 3TG movement in the industry, but does purchase components, materials and products that may contain 3TG. Therefore, Poly collaborates



with suppliers, industry peers, and other stakeholders to meet program goals and customer expectations.

We are members and active participants in the Responsible Minerals Initiative (RMI). The RMI provides members with tools such as CMRTs and resources to make responsible sourcing decisions. In addition, in 2021, we served as co-chair of the China Smelter Engagement Team (SET) to help and encourage smelters or refiners (SORs) participate in a third-party audit program.

Reasonable Country of Origin Inquiry (RCOI)
Upon determination of the presence of 3TG in our products, Poly conducts a RCOI to determine whether any necessary 3TG contained in the products originated from the Democratic Republic of the Congo (the “DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, or Angola (collectively the “Covered Countries”), or were from recycled or scrap sources.

Poly evaluated suppliers from whom we had purchased materials used in products manufactured in calendar year 2021. The full supplier list of two hundred and forty-six (246) direct suppliers excludes those that provide services, packaging, collateral, or tooling which are not necessary to the functionality of the products, narrowing the list to two hundred and five (205) direct suppliers of materials necessary to the functionality of our products. We used engineering evaluation, material disclosures and previous year submissions to determine that fifty-three (53) suppliers, which represent over 98 percent of our direct spend, provided materials, components and products contained or were likely to contain 3TG.

We conducted a RCOI by asking those 53 suppliers providing components and parts deemed necessary for the functionality of the products and expected or known to contain 3TG to complete the Conflict Minerals Reporting Template (CMRT) to verify the presence of 3TG and to determine the facilities – smelters or refiners - processing those minerals with the greatest possible specificity. We analyzed the information gathered through this supply chain survey. The data on which we relied to determine the country of origin of the minerals was obtained through our membership in the RMI (member ID 0001695384).

The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Poly products may have originated in the Covered Countries and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.

Design of Due Diligence Measures
Poly’s due diligence measures for Conflict Minerals 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.

Due Diligence Measures Performed



Poly has designed due diligence measures modeled after the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (Third Editions, OECD 2016) and related Supplements (the “OECD Guidance”). For this reporting period, the due diligence measures we performed described below:

OECD Step 1: Establish Strong Internal Company Management System

Poly maintains a cross functional 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 Legal and Compliance Officer), Compliance (Director, Global Compliance), and members of their staff.

Poly’s Conflict Minerals Policy states our expectations for suppliers to share our commitments and conduct due diligence practices to assure products and components supplied to Poly are DRC Conflict-free, the policy is publicly available at: https://www.poly.com/us/en/company/corporate-responsibility/product-stewardship. We continue to enhance control methods and procedures in which an escalation process is created for discrepancies and findings that route to the commodity managers and/or CPO as appropriate, related records are maintained pursuant to our records retention policy.

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/. Submissions under either reporting system can be made anonymously to voice concerns and/or report suspected non-compliance.

In addition to the annual survey using the CMRT, our supplier quality team conducts Conflict Minerals Ongoing Compliance surveys of selected first tier suppliers’ conflict minerals due diligence programs. These surveys assess policy, training, record retention and data validation. 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. Poly purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause.

Poly establishes and maintains long term relationships with the majority of our first tier original design manufacturers, contract manufacturers, and component suppliers to facilitate engagement and improve due diligence performance of 3TG facilities.

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.

We use a software tool to analyze data and information based upon incoming CMRTs and to improve management and auditability of supplier communications. 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.




OECD Step 2: Identified and Assessed Risk in the Supply Chain

We conducted a supplier survey of the fifty-three (53) 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 (6.01 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.

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-eight (38) 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 Environmental Compliance Managers 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. Eventually, one hundred percent (100%) of the suppliers responded by returning a CMRT, and ninety-eight percent (98%) of those responses were accepted after review and, in some cases, required follow up corrections.

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.

In 2021, sixteen (16) surveys of existing suppliers were performed using the Conflict Minerals Compliance survey to evaluate for components or products potentially containing 3TG. No deficiencies were found and the surveys were successfully completed. In addition, suppliers



being considered for components or products potentially containing 3TG must also undergo the Conflict Minerals Compliance Survey to be approved as a new supplier to Poly.

OECD Step 3: Designed and Implemented a Strategy to Respond to Identified Risks

We reported the findings derived from our RCOI and due diligence efforts to the Poly Conflict Minerals team, which include top management from Procurement, Compliance, Quality and Legal departments.

We are members and active participants in RMI, and we co-chair in China Smelter Engagement Team, which is a working group under RMI that conducts outreach in coordination with RMI to encourage SORs 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 Tungsten Industry-Conflict Minerals Council, to enter such a program.

We use a risk mitigation strategy for suppliers who did not comply with Poly’s Conflict Minerals Policy, including collaborative efforts from cross functional departments within Poly to communicate with suppliers to reinforce our policies and requirements. We provide remote training and support to suppliers, and conduct supplier audits including corrective action plans for suppliers to remediate deficiencies identified.

We require suppliers provide information regarding all sources of 3TG in their supply chain. We review this information for accuracy and consistency. We give feedback to suppliers of their RCOI in their supply chain and 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 2021, we directed our suppliers to remove 4 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. Because one direct supplier was unable to meet our expectation to disengage with one high-risk smelter in due time, we arranged to source an alternative conforming component from another supplier, and the high-risk smelter was removed from our purchases in 2022.

OECD Step 4: Carry Out Independent 3rd Party Audit of Supply Chain Due Diligence

Poly worked within industry initiatives to implement validation of DRC conflict free SORs as outlined in OECD Guidance for downstream companies. We supported RMI’s Responsible Minerals Assurance Process (RMAP) initiative through directly or indirectly engaging with SORs to encourage them to participate in the program or other recognized third-party schemes.

We relied on the results of audits conducted by RMAP and cross-recognized programs London Bullion Market Association (LBMA), Responsible Jewelry Council (RJC) and Tungsten Industry- Conflict Minerals Council (TI-CMC) to determine SORs’ Due Diligence Practices.

OECD Step 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

In 2021, sixty-eight percent (68%) of returned CMRTs from our direct suppliers are provided on company level, and thirty-two percent (32%) are on product level, therefore, the list of processing facilities contained in this report may contain more facilities than those that actually processed the conflict minerals contained in our products.

The total number of unique entities reported as SORs by the Poly supplier base as result of the 2021 Supplier Survey was three hundred and fourteen (314). Of these, two hundred and ninety-eight (298) have been confirmed as being legitimate operating SORs by RMI, sixteen (16) are known to not be operational SORs during 2021, and there were no SORs that were reported with status that could not be confirmed as of our cutoff date of March 17, 2022.

Of the two hundred and ninety-eight (298) legitimate SORs reported by the supplier base, two hundred and thirty-two (232) had been validated as being in conformance with a RMI cross-recognized conflict free audit protocol (RMAP, LBMA, or RJC). Another nineteen (19) 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 17, 2022. Forty-seven (47) eligible reported SORs are not participating in a compliance scheme and have status of:

*Outreach Required: thirty-two (32) have not yet been convinced to participate in any audit program, but efforts to encourage them will continue. On-site outreach during the COVID-19 pandemic was not possible, making it more difficult to communicate with certain suppliers. We relied on virtual outreach as an alternative approach to communicate with suppliers to participate in audit programs.

*Non-conformant: ten (10) do not conform, failed audit, previously conformant, but did not complete re-audit or corrective action in a timely manner. On March 7, 2022, LBMA suspended six (6) Russia-located gold facilities from LBMA’s Good Delivery List (GDL) in light of UK/EU/US sanctions. Poly is working diligently to remove these smelters from our supply chain.

*Communication Suspended: five (5) are not interested in participating in a third-party audit program.

Sixteen (16) 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.

Of the two hundred and ninety-eight seven (298) legitimate SORs reported by the supplier base, we determined during RCOI that, as of Mar 17, 2022, that there was no reason to believe that one hundred and thirteen (113) 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, twenty-two (22) were known or reasonably believed to directly or indirectly source minerals from the DRC or the surrounding countries and may not have been from recycled or scrap sources. All twenty-two (22) SORs are conformant through RMAP



or other independent, third-party audit program. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. All origin countries believed to be the source of 3TG in our products during 2021 are listed in Table II.

Smelters and Refiners Reported by Our Supply Chain by Year
Reporting YearTotal EligibleTotal Conformant% Conformant
20141597648%
201529921472%
201633624673%
201732025078%
201832425579%
201928623683%
202027623786%
202129823278%

We believe that the conformance rate declined year over year as a result of continuing impacts of the pandemic, inability to conduct onsite visits in many instances and the global impacts of the conflict in Ukraine, including Russian sanctions.

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.

Poly is 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.

Inherent Limitations on Due Diligence Measures

As a downstream actor and purchaser of products which contain conflict minerals, our due diligence measures can only provide reasonable, not absolute, assurance relating to the sourcing of conflict minerals. Our processes are based on seeking data from our direct suppliers and those suppliers obtaining similar information from their supply chains to identify the original sources of the necessary conflict minerals. We also rely on information from mineral sourcing validation programs that may provide incomplete or inaccurate information and may be subject to fraud. Despite our efforts, our ability to influence suppliers is limited when we are multiple tiers away from the smelters in the supply chain.

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.

Continue to extend follow up to those suppliers that did not respond in 2021 in efforts to increase conformance and compliance

Continue to reference the Poly Supplier Code of Conduct in purchaser orders and direct our suppliers to our Conflicts Minerals Policy Statement

In coordination with RMI and industry peers, engage directly with selected SORs to help guide them through the RMAP audit process, and encourage participation in validation schemes through RMI

Encourage our supply chain to source only from SORs either actively pursuing or assessed as conformant to a recognized third party scheme or confirmed as 100% recyclers 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, including United States government or other sanctions or OECD Annex II issues

Table I. Plantronics, Inc SOR List

The list of reported SORs and status is as of March 17, 2022. RCOI data from RMI is as of March 15, 2022. The list includes all the two hundred and ninety eight (298) legitimate SORs reported by Poly supplier base, 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 Poly’s 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.

Active: On RMI Active list and have committed to undergo a RMAP or cross recognized third-party audit.

In Communication: On RMI list and not yet active, but in communication with RMAP and/or member company.

Communication Suspended: On RMI list and communication with RMI towards a RMAP audit has been suspended.




Outreach Required: 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: 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.

Metal
Smelter: Smelter Name
Country
Status
Gold
8853 S.p.A.
ITALY
Conformant
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Conformant
Gold
Agosi AG
GERMANY
Conformant
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Alexy Metals
UNITED STATES OF AMERICA
Active
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
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Outreach Required
Gold
AU Traders and Refiners
SOUTH AFRICA
Non-conformant1
Gold
Augmont Enterprises Private Limited
INDIA
Active
Gold
Aurubis AG
GERMANY
Conformant
Gold
Bangalore Refinery
INDIA
Conformant
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
C.I Metales Procesados Industriales SAS
COLOMBIA
Active
Gold
Caridad
MEXICO
Outreach Required
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
Gold
Cendres + Metaux S.A.
SWITZERLAND
Conformant
Gold
CGR Metalloys Pvt Ltd.
INDIA
Outreach Required
Gold
Chimet S.p.A.
ITALY
Conformant
Gold
Chugai Mining
JAPAN
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Conformant
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Outreach Required
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Outreach Required
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. East Plant
JAPAN
Conformant
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
Conformant
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Conformant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
Outreach Required



Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Conformant
Gold
GGC Gujrat Gold Centre Pvt. Ltd.
INDIA
Active
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Conformant
Gold
Guangdong Jinding Gold Limited
CHINA
Outreach Required
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Outreach Required
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Outreach Required
Gold
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
Heraeus Germany GmbH Co. KG
GERMANY
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Outreach Required
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Outreach Required
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Communication Suspended
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
In Communication
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
Istanbul Gold Refinery
TURKEY
Conformant
Gold
Italpreziosi
ITALY
Conformant
Gold
Japan Mint
JAPAN
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Conformant
Gold
JSC Novosibirsk Refinery
RUSSIAN FEDERATION
Non-conformant2
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Non-conformant2
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
In Communication
Gold
Kazzinc
KAZAKHSTAN
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Conformant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Non-conformant1
Gold
Lingbao Gold Co., Ltd.
CHINA
Outreach Required
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Outreach Required
Gold
L'Orfebre S.A.
ANDORRA
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Outreach Required
Gold
Marsam Metals
BRAZIL
Conformant
Gold
Materion
UNITED STATES OF AMERICA
Conformant
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
Gold
Metal Concentrators SA (Pty) Ltd.
SOUTH AFRICA
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
Morris and Watson
NEW ZEALAND
In Communication
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Non-conformant2
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant



Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Conformant
Gold
NH Recytech Company
KOREA, REPUBLIC OF
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
Non-conformant2
Gold
PAMP S.A.
SWITZERLAND
Conformant
Gold
Pease & Curren
UNITED STATES OF AMERICA
Communication Suspended
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Outreach Required
Gold
Planta Recuperadora de Metales SpA
CHILE
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Non-conformant2
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
Gold
PX Precinox S.A.
SWITZERLAND
Conformant
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Outreach Required
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Outreach Required
Gold
REMONDIS PMR B.V.
NETHERLANDS
Conformant
Gold
Royal Canadian Mint
CANADA
Conformant
Gold
SAAMP
FRANCE
Conformant
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Communication Suspended
Gold
Safimet S.p.A
ITALY
Conformant
Gold
SAFINA A.S.
CZECHIA
Conformant
Gold
Sai Refinery
INDIA
Outreach Required
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Conformant
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Communication Suspended
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
Gold
Shandong Gold Smelting Co., Ltd.
CHINA
Conformant
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Outreach Required
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Outreach Required
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
Non-conformant2
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Conformant
Gold
Sovereign Metals
INDIA
Outreach Required
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Outreach Required
Gold
Sudan Gold Refinery
SUDAN
Outreach Required
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
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Outreach Required
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Conformant
Gold
Torecom
KOREA, REPUBLIC OF
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
Yunnan Copper Industry Co., Ltd.
CHINA
Outreach Required
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
Tantalum
AMG Brasil
BRAZIL
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
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
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 de Mexico
MEXICO
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
Conformant
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
QuantumClean
UNITED STATES OF AMERICA
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Conformant
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Conformant
Tantalum
TANIOBIS Co., Ltd.
THAILAND
Conformant
Tantalum
TANIOBIS GmbH
GERMANY
Conformant
Tantalum
TANIOBIS Japan Co., Ltd.
JAPAN
Conformant
Tantalum
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Conformant
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
CHINA
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tin
Alpha
UNITED STATES OF AMERICA
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Outreach Required
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
Conformant
Tin
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
BRAZIL
Active
Tin
CRM Synergies
SPAIN
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
Active
Tin
Dowa
JAPAN
Conformant
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
Estanho de Rondonia S.A.
BRAZIL
Conformant
Tin
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Conformant
Tin
Fenix Metals
POLAND
Conformant



Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
Outreach Required
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Non-conformant3
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
Tin
Luna Smelter, Ltd.
RWANDA
Conformant
Tin
Ma'anshan Weitai Tin Co., 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
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Outreach Required
Tin
Novosibirsk Processing Plant Ltd.
RUSSIAN FEDERATION
Active
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Conformant
Tin
Pongpipat Company Limited
MYANMAR
Outreach Required
Tin
PT Aries Kencana Sejahtera
INDONESIA
In Communication
Tin
PT Artha Cipta Langgeng
INDONESIA
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
Conformant
Tin
PT Babel Surya Alam Lestari
INDONESIA
Conformant
Tin
PT Bangka Serumpun
INDONESIA
Conformant
Tin
PT Bukit Timah
INDONESIA
Active
Tin
PT Menara Cipta Mulia
INDONESIA
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
Conformant
Tin
PT Mitra Sukses Globalindo
INDONESIA
Active
Tin
PT Prima Timah Utama
INDONESIA
Conformant
Tin
PT Rajawali Rimba Perkasa
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
Active
Tin
PT Timah Nusantara
INDONESIA
Active
Tin
PT Timah Tbk Kundur
INDONESIA
Conformant
Tin
PT Timah Tbk Mentok
INDONESIA
Conformant
Tin
PT Tinindo Inter Nusa
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
Super Ligas
BRAZIL
Active
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Conformant
Tin
Thaisarco
THAILAND
Conformant
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CHINA
Active



Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Outreach Required
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Non-conformant3
Tungsten
A.L.M.T. Corp.
JAPAN
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
Conformant
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Active
Tungsten
Artek LLC
RUSSIAN FEDERATION
Outreach Required
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
China Molybdenum Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Outreach Required
Tungsten
Cronimet Brasil Ltda
BRAZIL
Conformant
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Haichuang 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
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
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 Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Communication Suspended
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd.
CHINA
Conformant
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Conformant
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Conformant
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Masan High-Tech Materials
VIET NAM
Conformant
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Conformant
Tungsten
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
Active
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Conformant
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
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



1: SORs were removed from Poly direct suppliers by end of CY2021.
2: Smelters were conformant in reporting year 2021 and their status changed to non-conformant in March 2022. On March 7, 2022 outside of the reporting year, RMAP identified these entities as non-conformant pursuant to the London Bullion Market Association (LBMA) suspension from the LBMA’s Good Delivery List in light of violation of certain UK/EU/US sanctions.
3: Smelters were conformant in reporting year 2021, and their status changed to non-conformant in Feb 2022 due to failed the re-assessment by RMAP.

TABLE II- Country of Origin for Minerals

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.

Gold: Argentina, Australia, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Democratic Republic of Congo*, Dominican Republic, Ghana, Guinea, Ivory Coast, Kazakhstan, Mali, Mexico, Mongolia, Papua New Guinea, Peru, Philippines, Russia, Senegal, South Africa, Tanzania*, Togo, Turkey, United States of America, Uzbekistan

Tantalum: Australia, Bolivia, Brazil, Burundi*, China, Colombia, Democratic Republic of Congo*, Mongolia, Mozambique, Nigeria, Portugal, Russia, Rwanda, Spain, Uganda*

Tin: Australia, Bolivia, Brazil, Burundi*, China, Democratic Republic of Congo*, Indonesia, Malaysia, Mongolia, Myanmar, Niger, Nigeria, Peru, Portugal, Russia, Rwanda*, Tanzania*, Thailand, Uganda*, Vietnam

Tungsten: Australia, Austria, Bolivia, Burundi*, Canada, China, Democratic Republic of Congo*, Mexico, Mongolia, Portugal, Russia, Rwanda*, Spain, Uganda*, United States of America, Uzbekistan, Vietnam

* Covered Countries for the purposes of Rule 13p-1