UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
XEROX HOLDINGS CORPORATION
XEROX CORPORATION
(Exact name of registrant as specified in its charter)
New York | 001-39013 | 83-3933743 | ||
New York | 001-04471 | 16-0468020 | ||
(State or other jurisdiction of incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) |
P. O. Box 4505
201 Merritt 7
Norwalk, Connecticut
06851-1056
Registrants telephone number, including area code: (203) 968-3000
Not Applicable
(Former name or former address, if changed since last 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, 2019 to December 31, 2019. |
Section 1 Conflicts Minerals Disclosure
Items 1.01 and 1.02 Conflicts Minerals Disclosure and Report, Exhibit
This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available on the Xerox website under Supplier Governance - Conflict Minerals at www.xerox.com/en-us/about/supplier-relations/governance as well as the SECs EDGAR database at www.sec.gov. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Xerox Corporation (Xerox) is a workplace technology company, building and integrating software and hardware for enterprises large and small. As customers seek to manage information across digital and physical platforms, we deliver a seamless, secure and sustainable experience. Whether inventing the copier, the Ethernet, the laser printer or more, Xerox has long defined the modern work experience and continues to do so with investments in artificial intelligence (AI), sensors and services for Internet of Things (IoT), digital packaging, 3-D printing and Clean Technologies (cleantech). Geographically, our footprint spans approximately 160 countries and allows us to deliver our technology and solutions to customers of all sizes, regardless of complexity or number of customer locations. In 2019, Xeroxs products included but were not limited to multifunction printers/copiers, scanners, and multifunction/all in one printers, digital printing equipment, production printers & digital presses, continuous feed printers, wide format printers and consumables (e.g., toner cartridges).
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019 as required by Items 1.01 and 1.02 of this Form.
Forward Looking Statements
This Specialized Disclosure Report on Form SD and any exhibits to this Report may contain forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. The words anticipate, believe, estimate, expect, intend, will, should, targeting, projecting, driving and similar expressions, as they relate to us, our performance and/or our technology, are intended to identify forward-looking statements. These statements reflect managements current beliefs, assumptions and expectations and are subject to a number of factors that may cause actual results to differ materially. Such factors include but are not limited to: the effects of the COVID-19 and similar pandemics; our ability to address our business challenges in order to reverse revenue declines, reduce costs and increase productivity so that we can invest in and grow our business; our ability to attract and retain key personnel; changes in economic and political conditions, trade protection measures, licensing requirements and tax laws in the United States and in the foreign countries in which we do business; the imposition of new or incremental trade protection measures such as tariffs and import or export restrictions; changes in foreign currency exchange rates; our ability to successfully develop new products, technologies and service offerings and to protect our intellectual property rights; the risk that multi-year contracts with governmental entities could be terminated prior to the end of the contract term and that civil or criminal penalties and administrative sanctions could be imposed on us if we fail to comply with the terms of such contracts and applicable law; the risk that partners, subcontractors and software vendors will not perform in a timely, quality manner; actions of competitors and our ability to promptly and effectively react to changing technologies and customer expectations; our ability to obtain adequate pricing for our products and services and to maintain and improve cost efficiency of operations, including savings from restructuring actions; the risk that confidential and/or individually identifiable information of ours, our customers, clients and employees could be inadvertently disclosed or disclosed as a result of a breach of our security systems due to cyber attacks or other intentional acts; reliance on third parties, including subcontractors, for manufacturing of products and provision of services; the exit of the United Kingdom from the European Union; our ability to manage changes in the printing environment and expand equipment placements; interest rates, cost of borrowing and access to credit markets; funding requirements associated with our employee pension and retiree health benefit plans; the risk that our operations and products may not comply with applicable worldwide regulatory requirements, particularly environmental regulations and directives and anti-corruption laws; the outcome of litigation and regulatory proceedings to which we may be a party; any impacts resulting from the restructuring of our relationship with Fujifilm Holdings Corporation; and the shared services arrangements entered into by us as part of Project Own It. Additional risks that may affect Xeroxs operations and other factors that are set forth in the Risk Factors section, the Legal Proceedings section, the Managements Discussion and Analysis of Financial Condition and Results of Operations section and other sections of Xerox Holdings Corporations and Xerox Corporations combined 2019 Annual Report on Form 10-K, as well as in Xerox Holdings Corporations and Xerox Corporations Quarterly Reports on Form 10-Q and Current Reports on Form 8-K filed with the Securities and Exchange Commission. These forward-looking statements speak only as of the date of this Report or as of the date to which they refer, and Xerox assumes no obligation to update any forward looking statements as a result of new information or future events or developments, except as required by law.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this Report to be signed on its behalf by the undersigned duly authorized.
Date: May 20, 2020
XEROX HOLDINGS CORPORATION XEROX CORPORATION | ||
By: | /s/ Steven J. Bandrowczak | |
Steven J. Bandrowczak | ||
President and Chief Operations Officer |
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EXHIBIT INDEX
Exhibit |
Description | |
1.01 | Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019 |
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Exhibit 1.01
Conflict Minerals Report
Xerox Holdings Corporation
Xerox Corporation
For the Year Ended December 31, 2019
This report for the year ended December 31, 2019 is made by Xerox Holdings Corporation and its subsidiaries, including Xerox Corporation, (collectively, Xerox) in compliance with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule).
The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (3TG). These requirements apply to registrants regardless of the geographic origin of the conflict minerals and whether or not the trading in those minerals benefits armed groups.
If a registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries), or a registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the source and chain of custody of those conflict minerals. The registrant must annually submit a specialized disclosure (Form SD) and Conflict Minerals Report (CMR) to the SEC that includes a description of those due diligence measures.
1. | COMPANY OVERVIEW |
Xerox Corporation is a workplace technology company, building and integrating software and hardware for enterprises large and small. As customers seek to manage information across digital and physical platforms, we deliver a seamless, secure and sustainable experience. Whether inventing the copier, the Ethernet, the laser printer or more, Xerox has long defined the modern work experience and continues to do so with investments in artificial intelligence (AI), sensors and services for Internet of Things (IoT), digital packaging, 3-D printing and Clean Technologies (cleantech). Geographically, our footprint spans approximately 160 countries and allows us to deliver our technology and solutions to customers of all sizes, regardless of complexity or number of customer locations. In 2019, Xeroxs products included but were not limited to multifunction printers/copiers, scanners, and multifunction/all in one printers, digital printing equipment, production printers & digital presses, continuous feed printers, wide format printers and consumables (e.g., toner cartridges). Xerox products are more fully described on our Xerox website, which can be accessed at www.xerox.com.
The content of any website referred to in this CMR is included for general information only and is not incorporated by reference in this Report.
2. | OUR CONFLICT MINERALS PROGRAM |
2.1 Supply Chain - Reasonable Country of Origin Inquiry
Xerox is many steps removed from the mining of conflict minerals. The origin of conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The 3TG smelters or refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores. Xerox has conducted an
analysis of our products and found that, although we do not directly purchase conflict minerals from our suppliers, Xerox purchases products, component parts and materials that contain metals, some of which contain conflict minerals. We rely on our Tier 1 suppliers to provide information on the origin of the conflict minerals contained in components that are included in our products by using the RMI Conflict Minerals Reporting Template (CMRT), which allows us to perform our Reasonable Country of Origin Inquiry (RCOI).
2.2 Supplier Risk Assessment
Because of the size of our company, the complexity of our products and the depth and breadth of our supply chain, it is difficult to identify sources upstream from our direct suppliers. As a result, Xerox conducted a product review to determine products in scope and developed a supplier risk assessment process, through which the conflict minerals program is implemented, managed and monitored. With a goal of targeting 3TG minerals, this risk assessment process was developed to identify those suppliers whose products may contain the presence of tin, tantalum, tungsten and gold.
We conducted a survey of these suppliers to determine whether the conflict minerals in components contained in our products originated from the DRC or adjoining countries. This supply-chain survey was conducted with our Tier 1 production suppliers using the CMRT, which contains questions about the facilities used to process these minerals, as well as supplier RCOI. The goal of this activity was to identify, where applicable, the 3TG smelters or refiners who contribute refined conflict minerals to Xerox components, assemblies and Original Equipment Manufacturer (OEM) Products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters or refiners that provide material to a companys supply chain. It includes questions regarding a companys conflict-free policy, engagement with its direct suppliers, and a listing of the smelters or refiners the company and its suppliers use. Our supplier survey request also included the Responsible Minerals Initiative (RMI), informational links on available conflict mineral and smelter information. In 2019, Xerox surveyed 195 suppliers with an 80% response rate, estimated to represent over 95% of production spend of 3TG surveyed suppliers and 60% of our 2019 total spend with all production suppliers.
The responses contained information regarding the names and locations of 3TG smelters or refiners which process necessary conflict minerals used by our suppliers, which are ultimately incorporated into our products. We have designed and adopted a risk management plan that summarizes our risk mitigation efforts. Under our risk-assessment process, we perform due diligence reviews of supplier responses for their use of 3TG and conduct follow-up actions on suppliers, encouraging further requests for accurate, complete or missing template information where responses identified red flags based on our risk assessment of the level of risk of the commodities supplied to us.
In 2019, we partnered with Assent Compliance and continued to refine our process of evaluating the CMRTs to assist with our ongoing risk assessment by analyzing supplier responses and providing feedback to suppliers on errors and corrections. We also provide a hot-line for supplier communication. In addition, we provide monthly reports and systematic management reviews to our senior management and elevate non-responsive issues as necessary.
2.3 Company Management Systems
Policy
Xerox has adopted a company policy which is posted on our website under Supplier Governance - Conflict Minerals at www.xerox.com/en-us/about/supplier-relations/governance
Internal Team
Xerox has established a management system for conflict minerals. Our management system includes a Senior Management Steering Committee sponsored by the Chief Operations Officer who reports directly to our CEO and who is responsible for signing the Form SD, as well as senior executives from Global Procurement, Environment Health Safety & Sustainability, and Legal. Our team of functional subject matter experts is responsible for implementing our conflict minerals compliance strategy. Senior management is provided with updates and results of our conflict minerals program efforts on a regular basis.
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2.4 Control Systems
Controls include, but are not limited to, our Code of Business Conduct for our employees, our Supplier Code of Conduct (adopted from the Responsible Business Alliance (RBA), and a conflict minerals contract clause incorporated in our Multi-National Master Purchasing Agreement for new contracts.
Xerox worked with the RBA in the early stages to support the RMI and continues to be a member of the RMI, a group assisting in the development of tools and processes to improve conflict minerals due diligence. As outlined 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, 3RD Edition, (OECD 2016), which is the internationally recognized standard on which our companys system is based. We support the RMI, an industry initiative that audits smelters and refiners due diligence activities. The data on which we relied for certain statements in this declaration was obtained through our membership in the RMI, using the RMI Compliant Smelter Sourcing Information Report created specifically for Xerox.
In addition, our current standard supplier contracts also require our suppliers to adopt a policy on the responsible sourcing of minerals, implement due diligence processes to support that policy, and complete and return to Xerox the RMI CMRT.
2.5 Grievance Mechanism
We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Xerox policies. This is communicated annually in our employee code of ethics training process and the supplier ethics letter. This mechanism helps us to identify and assess risk.
3. DUE DILIGENCE
3.1 Design of Due Diligence
Xerox designed its due diligence measures to be in conformity, in all material respects, with internationally recognized due diligence framework OECD 2016.
3.2 Smelter or Refiner Results*
Our due diligence process includes participation in RMI and following the OECD implementation framework. We requested that our suppliers complete the CMRT survey in order to obtain information about 3TG smelters or refiners in our supply chain. We have determined that these actions represent the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
We analyzed and compared all the 3TG smelter and refiner data we received against information obtained from the RMI smelter database. For the calendar year 2019, our due diligence identified 305 smelters and refiners as potential sources of 3TG minerals that were reported to be in our supply chain.
In order to provide compliance status, we completed additional analysis of the 305 smelters and refiners.
Of which**
| 234 are Responsible Minerals Assurance Process (RMAP) Conformant |
| 7 are RMAP Active |
| 7 are RMAP Non-Conformant |
| 57 are not yet enrolled in the RMAP Of these 40 require further outreach, 12 are in communication with the RMI, 2 are in the due diligence vetting process and 3 are currently subject to RMI due diligence review. |
Due to the outbreak of Covid-19 there have been restrictions on audits and delays to some RMAP activity.
* | Note: The data above was obtained from the RMI and via Assent Compliance as of 31/3/2020 |
** | Audit definitions as per RMI - http://www.responsiblemineralsinitiative.org/smelter-links/database-field-definitions/ |
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Smelters or refiners verified as conflict-free or in the audit process**
* | Note: The data above was obtained from the RMI and via Assent Compliance as of 31/3/2020 |
2014 | 2015 | 2016 | 2017 | 2018 | 2019 | |||||||||||||||||||
Tantalum |
34 of 45 (75 | %) | 47 of 55 (85 | %) | 47 of 53 (83 | %) | 41 of 45 (91 | %) | 40 of 43 (93 | %) | 38 of 38 (100 | %) | ||||||||||||
Tin |
51 of 253 (20 | %) | 84 of 172 (49 | %) | 82 of 152 (54 | %) | 79 of 129 (61 | %) | 84 of 124 (68 | %) | 49 of 58 (84 | %) | ||||||||||||
Tungsten |
32 of 51 (63 | %) | 43 of 60 (72 | %) | 43 of 49 (88 | %) | 45 of 51 (88 | %) | 44 of 49 (90 | %) | 49 of 52 (94 | %) | ||||||||||||
Gold |
71 of 206 (34 | %) | 129 of 176 (73 | %) | 139 of 183 (76 | %) | 143 of 180 (79 | %) | 147 of 181 (79 | %) | 117 of 157 (75 | %) | ||||||||||||
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Total |
188 of 555 (34 | %) | 303 of 463 (65 | %) | 311 of 437 (71 | %) | 308 of 405 (76 | %) | 315 of 397 (79 | %) | 253 of 305 (83 | %) | ||||||||||||
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4. | DETERMINATION |
The information received from our due diligence efforts from suppliers or other sources is not sufficient to determine the origin of all 3TG our products contain, whether the 3TG come from recycled or scrap sources, the facilities used to process them, their country of origin, or their mine or location of origin. If any supplier reported to us a facility for which we had information that triggered one of our potential risk indicators, then we requested the supplier investigate whether or not that facility contributed 3TG to Xerox products, and if the supplier reported that it did, we asked that the supplier remove the facility from our supply chain.
Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the 3TG minerals in our products include the RMI compliant smelters listed in Appendix I below. We have found no reasonable basis for concluding that these refiners, or the other smelters preparing to be audited, sourced 3TG minerals that directly or indirectly finance or benefit armed groups of the conflict region of the Covered Countries.
Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the 3TG minerals in our products or whether the 3TG minerals in our products are from recycled or scrap sources. However, based on the information provided by our suppliers, as well as from the RMI and other sources, we believe that the countries of origin of the 3TG minerals contained in our products include the countries listed in Appendix II below as well as recycled and scrap sources. Pursuant to the Rule, this report is not subject to an independent private sector audit.
Through our participation in the RMI, we continue to support independent third-party audits through the RMI or other third party certification schemes.
In accordance with the OECD Guidance and the Rule, this CMR is available on our website under Supplier Governance - Conflict Minerals at www.xerox.com/en-us/about/supplier-relations/governance.
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5. | STEPS TO BE TAKEN IN 2020 TO MITIGATE RISK |
Xerox plans to undertake the following steps during 2020 to improve the due diligence conducted in order to further mitigate the risk that the necessary conflict minerals in our products do not benefit armed groups in the DRC or adjoining countries, including:
| Continue to strengthen engagement with relevant suppliers and to provide training, as appropriate, to help them understand and satisfy Xerox requirements related to 3TG minerals under the Rule. |
| Continue to review the process with distributors submitting CMRTs and develop best practices in obtaining 3TG mineral data. |
| Continue using internal escalation process within our supply chain organization when working with suppliers to obtain required information. |
| Continue to provide ongoing feedback to suppliers on errors and corrections required in connection with the CMRT assessment and notify suppliers of potential risks identified within the supply chain |
| Continue to participate as a member in the RBA and the RMI, including Conflict Free Smelter Program smelter validation and supplier outreach. |
| Continue to work with the OECD and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance. |
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Appendix 1*
Metal |
Standard Smelter Name |
Smelter Facility Location | ||
Gold | 8853 S.p.A. | ITALY | ||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||
Gold | Argor-Heraeus S.A. | SWITZERLAND | ||
Gold | Asahi Pretec Corp. | JAPAN | ||
Gold | Asahi Refining Canada Ltd. | CANADA | ||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||
Gold | Asaka Riken Co., Ltd. | JAPAN | ||
Gold | AU Traders and Refiners | SOUTH AFRICA | ||
Gold | Aurubis AG | GERMANY | ||
Gold | Bangalore Refinery | INDIA | ||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
Gold | Boliden AB | SWEDEN | ||
Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||
Gold | Cendres + Metaux S.A. | SWITZERLAND | ||
Gold | Chimet S.p.A. | ITALY | ||
Gold | Chugai Mining | JAPAN | ||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||
Gold | Dowa | JAPAN | ||
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
Gold | Heimerle + Meule GmbH | GERMANY | ||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
Gold | Istanbul Gold Refinery | TURKEY | ||
Gold | Italpreziosi | ITALY | ||
Gold | Japan Mint | JAPAN | ||
Gold | Jiangxi Copper Co., Ltd. | CHINA | ||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||
Gold | Kazzinc | KAZAKHSTAN | ||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
Gold | LOrfebre S.A. | ANDORRA | ||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||
Gold | Marsam Metals | BRAZIL | ||
Gold | Materion | UNITED STATES OF AMERICA | ||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||
Gold | Metalor Technologies S.A. | SWITZERLAND | ||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||
Gold | Mitsubishi Materials Corporation | JAPAN | ||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||
Gold | Nihon Material Co., Ltd. | JAPAN | ||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
A-2
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
Gold | PAMP S.A. | SWITZERLAND | ||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
Gold | PX Precinox S.A. | SWITZERLAND | ||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
Gold | REMONDIS PMR B.V. | NETHERLANDS | ||
Gold | Royal Canadian Mint | CANADA | ||
Gold | SAAMP | FRANCE | ||
Gold | Safimet S.p.A | ITALY | ||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | T.C.A S.p.A | ITALY | ||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||
Gold | Torecom | KOREA, REPUBLIC OF | ||
Gold | Umicore Brasil Ltda. | BRAZIL | ||
Gold | Umicore Precious Metals Thailand | THAILAND | ||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||
Gold | Valcambi S.A. | SWITZERLAND | ||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||
Gold | WIELAND Edelmetalle GmbH | GERMANY | ||
Gold | Yamakin Co., Ltd. | JAPAN |
A-3
Gold | Yokohama Metal Co., Ltd. | JAPAN | ||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||
Tantalum | F&X Electro-Materials Ltd. | CHINA | ||
Tantalum | FIR Metals & Resource Ltd. | CHINA | ||
Tantalum | Global Advanced Metals Aizu | JAPAN | ||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||
Tantalum | H.C. Starck Ltd. | JAPAN | ||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | KEMET Blue Metals | MEXICO | ||
Tantalum | LSM Brasil S.A. | BRAZIL | ||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
Tantalum | Mineracao Taboca S.A. | BRAZIL | ||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
Tantalum | NPM Silmet AS | ESTONIA | ||
Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | ||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
A-4
Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||
Tin | Alpha | UNITED STATES OF AMERICA | ||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||
Tin | China Tin Group Co., Ltd. | CHINA | ||
Tin | Dowa | JAPAN | ||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | Fenix Metals | POLAND | ||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
Tin | Luna Smelter, Ltd. | RWANDA | ||
Tin | Maanshan Weitai Tin Co., Ltd. | CHINA | ||
Tin | Magnus Minerais Metais e Ligas Ltda. | BRAZIL | ||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||
Tin | Metallo Belgium N.V. | BELGIUM | ||
Tin | Metallo Spain S.L.U. | SPAIN | ||
Tin | Mineracao Taboca S.A. | BRAZIL | ||
Tin | Minsur | PERU | ||
Tin | Mitsubishi Materials Corporation | JAPAN | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
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Tin | PT Artha Cipta Langgeng | INDONESIA | ||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
Tin | PT Menara Cipta Mulia | INDONESIA | ||
Tin | PT Mitra Stania Prima | INDONESIA | ||
Tin | PT Refined Bangka Tin | INDONESIA | ||
Tin | PT Timah Tbk Kundur | INDONESIA | ||
Tin | PT Timah Tbk Mentok | INDONESIA | ||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
Tin | Soft Metais Ltda. | BRAZIL | ||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||
Tin | Thaisarco | THAILAND | ||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||
Tin | Yunnan Tin Company Limited | CHINA | ||
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||
Tungsten | A.L.M.T. Corp. | JAPAN | ||
Tungsten | ACL Metais Eireli | BRAZIL | ||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
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Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
* | Smelter or refiner names as reported by the RMI as of 31/3/2020. |
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APPENDIX II
Known countries of origin from which conformant 3TG minerals refiners source **
Argentina | Finland | Mongolia | Somaliland | |||
Australia | France | Morocco | South Africa | |||
Austria | Georgia | Mozambique | Spain | |||
Azerbaijan | Germany | Myanmar | Suriname | |||
Benin | Ghana | Namibia | Swaziland | |||
Bolivia | Guatemala | Netherlands | Sweden | |||
Botswana | Guinea | New Zealand | Taiwan | |||
Brazil | Guyana | Nicaragua | Tajikistan | |||
Burkina Faso | Honduras | Niger | Tanzania | |||
Burundi | India | Nigeria | Thailand | |||
Canada | Indonesia | Papua New Guinea | Togo | |||
Chile | Iran | Peru | Turkey | |||
China | Ivory Coast | Phillipines | Uganda | |||
Colombia | Japan | Portugal | United Kingdom of Great Britain and Northern Ireland | |||
Congo, Democratic Republic of the | Kazakhstan | Puerto Rico | United States of America | |||
Cuba | Kenya | Russian Federation | Uruguay | |||
Cyprus | Laos | Rwanda | Uzbekistan | |||
Dominican Republic | Liberia | Saudi Arabia | Venezuela | |||
Ecuador | Madagascar | Senegal | Vietnam | |||
Egypt | Malaysia | Serbia | Zambia | |||
Eritrea | Mali | Sierra Leone | Zimbabwe | |||
Ethiopia | Mauritania | Slovakia | ||||
Fiji | Mexico | Solomon Islands |
** | As per RMI Compliant Smelter Sourcing RCOI information as of 31/3/2020. |
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