Exhibit 1.01
Johnson & Johnson
Conflict Minerals Report
For the Calendar Year Ended December 31, 2017
Introduction
Johnson & Johnson is the parent company of various consolidated subsidiaries (together, the “Company”) engaged in the manufacture and sale of a broad range of products in the health care field across three business segments: Consumer, Pharmaceutical and Medical Devices.
Pursuant to the requirements of Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the “Rule”), this Conflict Minerals Report describes, for the period from January 1, 2017 to December 31, 2017, the measures the Company has taken to conduct due diligence on the source and chain of custody of the conflict minerals contained in, and necessary to the functionality or production of, the products in its supply chain. Under the Rule, “conflict minerals” are defined as columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten, and gold (or “3TG”).
Products and Supply Chain
All product lines manufactured or contracted to be manufactured by the Company throughout its three business segments were assessed to determine whether they potentially contain 3TG. Through the screening process, product teams determined, to the best of their knowledge, that the following product lines (the “in-scope products”) contain 3TG or have a high likelihood of containing 3TG: (i) in the Company’s Pharmaceutical and Consumer segments, a small number of products that contain electronic components, including pharmaceutical diagnostics products and consumer plug-in and/or battery-operated devices; and (ii) in the Medical Devices segment, many categories of medical devices due to the presence of metal alloys and electronic components, including, but not limited to:
• | orthopaedic, trauma and spine products; |
• | surgery and energy products; |
• | products to treat cardiovascular disease, including electrophysiology products; |
• | vision surgical products; |
• | blood glucose monitoring and insulin delivery products; and |
• | sterilization and disinfection products to reduce surgical infection. |
The broad and complex range of in-scope products may contain necessary conflict minerals within the following components:
• | Tantalum, used in capacitors and certain alloys; |
• | Tin, used in soldered components; |
• | Tungsten, used in coatings and certain alloys; and |
• | Gold, used in circuit boards and electronic components. |
The Company’s supply chains are complex and fragmented. As a “downstream” company, the Company is many tiers removed in the minerals supply chain from smelters or refiners (“SORs”) that process the metals found in its final products, and there are many intervening third parties between the original sources of conflict minerals and the Company. The Company, therefore, must rely on its immediate suppliers, with which it has business relationships, to provide information regarding the sourcing of 3TG in the in-scope products. The Company’s immediate suppliers, in turn, typically are also downstream in the minerals supply chain and have similar challenges in achieving supply chain transparency.
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In addition, because the Company manufactures and sells highly-regulated health care products, its existing suppliers have gone through lengthy, rigorous, and multi-level regulatory and quality assessments and approvals. Therefore, it can be very difficult to switch to another supplier if an existing supplier who meets our criteria is not responsive to the Company’s conflict minerals program.
Reasonable Country of Origin Inquiry
The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG in materials, components and finished goods supplied to the Company, including the following steps:
• | With the assistance of a third-party vendor (the “Vendor”) with expertise in supply chain due diligence, the Company engaged its 402 immediate, potential in-scope 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. These suppliers were asked to complete and submit the Conflict Minerals Reporting Template v.5.0 or higher (“CMRT”). The CMRT is a standardized reporting survey form developed by the Conflict-Free Sourcing Initiative, now the Responsible Minerals Initiative (“RMI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the SORs in the 3TG supply chain. |
• | The Vendor followed up with all unresponsive suppliers via both automated emails and one-on-one emails, including offering assistance and further information about the requirements of the Rule and the Company’s expectations. If after these outreach efforts a supplier still did not respond to the survey, the relevant Company supplier relationship manager (“SRM”) was asked to directly contact the supplier to request a response. |
• | The Vendor identified and followed up on incomplete or contradictory answers in each CMRT form submitted. |
• | Suppliers that responded that the materials or goods they supplied to the Company did not contain 3TG were removed from the scope of the survey only after verification of this information from Company SRMs and product stewards. |
• | The Company’s conflict minerals team focused additional engagement efforts on potential 3TG suppliers deemed higher-priority based on spend volume. |
• | The Company received responses from approximately 70% of all final in-scope suppliers, not including suppliers who responded but did not report for the full 2017 calendar year. |
• | The Vendor verified whether the metals processors identified by suppliers in their survey responses are actual SORs or recyclers of 3TG by comparing the alleged SOR names to RMI’s Standard Smelter List, resulting in a list of 320 SORs verified to exist. |
• | The Vendor researched and reviewed mine information for the verified SORs to determine, to the best of its knowledge, the country of origin of the minerals processed by those SORs. This information was also compared to the country of origin data available to the Company as a member of RMI. |
On the basis of its RCOI, the Company has reason to believe that at least some of the 3TG contained in the in-scope products originated in the Democratic Republic of Congo (DRC) or an adjoining country (together, the “covered countries”), and not from recycled or scrap sources. Accordingly, the Company conducted due diligence on the source and chain of custody of these conflict minerals.
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Due Diligence
The Company’s due diligence measures, described below, were designed to conform, in all material respects, with the internationally recognized due diligence framework set forth 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, including the Supplements on 3T and gold. These measures took into account the OECD’s recommendations for companies in the downstream segments of the supply chain, which typically are several tiers removed from, and have no direct relationships with, SORs.
1. Company Management Systems
The Company has implemented a conflict minerals compliance program (the “Program”) with the following components:
Policy Statement
• | In January 2018, the Company updated its Statement on Conflict Minerals, which can be found on the Johnson & Johnson website at: https://www.jnj.com/about-jnj/company-statements/statement-on-conflict-minerals, and which sets forth the expectation that the Company’s suppliers source materials from suppliers that also source responsibly, including from conformant mines in the covered countries. |
Internal Team
• | In 2013, the Company established a centralized, cross-functional conflict minerals governance team (the “Core Team”) to oversee the implementation of the Program. The Core Team includes representation from the following functions: Procurement; Legal; Finance; Environment, Health, Safety & Sustainability (EHS&S) Product Stewardship and Internal Audit. The Core Team reports to senior management on Program developments and progress. |
• | Members of the Core Team participate in industry groups, forums, and conferences focused on compliance with the Rule and responsible sourcing of conflict minerals. |
Control Systems and Supply Chain Transparency
• | The Company has engaged the Vendor to facilitate supplier engagement and assist the Company in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Program. |
• | To further strengthen the Program and supply chain due diligence, , the Company continues to be a member of RMI, a cross-industry organization that provides resources, tools and information to help companies source conformant minerals, including a list of confirmed SORs and RMI’s Responsible Minerals Assurance Process (the “RMAP”), which validates SORs as conformant based on independent third-party audits. |
• | Based on learnings from the prior years’ conflict minerals campaigns, members of the Core Team monitored and provided input to the Vendor’s activities and analyses related to the 2017 CMRT survey process. |
• | The Core Team and the Vendor maintain electronic records of product and supply chain information collected through their due diligence activities carried out under the Program. Documentation related to the annual supplier surveys is retained for at least five years. |
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Supplier Engagement
• | In support of its Statement on Conflict Minerals, the Company has incorporated conflict mineral provisions into the standard terms of its Supply Chain master supply agreement template. Because most supply contracts have multi-year terms, it will take a number of years to integrate these provisions into supplier contracts as new supplier relationships are formed and existing suppliers renew their contracts. |
• | The Company has also revised and communicated its Responsibility Standards for Suppliers (https://www.jnj.com/partners/responsibility-standards-for-suppliers) which requires all suppliers to be compliant with the requirements in the Johnson & Johnson’s Statement on Conflict Minerals. |
• | To promote more timely and accurate responses from suppliers, members of the Core Team created an internal training program that requires all internal SRMs who have direct relationships with the Company’s immediate, potential 3TG suppliers to participate in a training module to educate them on conflict minerals, the conflict minerals reporting requirements, and the Program. |
• | To ensure suppliers understand its expectations, the Company has, through the Vendor, provided video and written training on conflict minerals and the CMRT. This training includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel, as needed. |
Grievance Mechanism
• | The Company has a dedicated conflict minerals electronic mailbox used for communications with suppliers. In addition, the Company has a hotline (www.CredoHotline.com) that provides a mechanism for anyone to anonymously report conduct they know or believe is in violation of Company guidelines or policies, including any concerns related to the conflict minerals supply chain. |
2. Risk Identification and Assessment
Although the Company requested information at a product level, a substantial majority of all supplier survey responses consisted of information at a company level-i.e., the supplier provided information about SORs in its supply chain generally, not just for the products or components supplied to the Company. Information in those surveys, therefore, may not be relevant to any of the Company’s products and may identify SORs that are not actually in the Company’s supply chain. The number of product-level supplier survey responses increased slightly over the previous year. Although the information provided in these product-level responses may be incomplete and has not been confirmed, the Company believes that there is a greater likelihood that the SORs listed in these responses are in the Company’s supply chain, compared to the SORs listed in company-level survey responses.
The Vendor attempted to match each verified SOR from the supplier survey responses to lists of conformant SORs (i.e., SORs validated or certified as conformant under internationally-recognized programs such as the RMAP, the London Bullion Market Association Good Delivery program (“LBMA”) and the Responsible Jewellery Council Chain-of-Custody Certification program (“RJC”)). SORs classified as actively pursuing conformance under the RMAP also were identified. For the 2017 reporting year, 20 SORs listed in suppliers’ survey responses were confirmed to source from covered countries, and all 20 of these SORS were validated as conformant.
To further assess the potential risk that 3TG in its supply chain could be associated with armed conflict, the Company focused on the verified SORs that are not conformant or actively seeking conformant status, and (a) are confirmed to source from countries with a high risk of supporting armed conflict, including the covered countries, or (b) whose country of origin sourcing is unknown. Such SORs are considered to be higher risk.
The Vendor also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities sourcing practices on behalf of its compliance partners. The Company was a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.
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3. Risk Response Strategy
Through its membership in RMI, the Company helps to encourage and support independent third-party audits of SORs’ supply chain due diligence practices. For any SOR that has not been validated through such an audit and which the Company determines to be of particular high risk-for example, because of reliable evidence of sourcing from covered countries-the Company (a) seeks to confirm from its relevant immediate suppliers whether 3TG processed by the SOR is in fact in its supply chain, and (b) places additional emphasis on advocating for the SOR to participate in a conformance assessment program such as the RMAP.
If the sourcing due diligence practices of a non-validated, high-risk SOR confirmed to be in the Company’s supply chain do not improve, the Company will work to develop corrective action, which may include encouraging its immediate suppliers to transition sourcing away from that SOR.
4. Audit of Due Diligence Practices of SORs
The Company supports internationally-recognized assessment programs, such as the RMAP, that facilitate and confirm independent third-party audits of SORs’ supply chain due diligence practices.
5. Annual Reporting on Supply Chain Due Diligence
The Company reports annually on its supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC.
Determinations
Based on the above-described due diligence efforts, the Company does not have conclusive information regarding the country of origin of, or facilities used to process, the necessary conflict minerals in its products for the 2017 reporting period.
Set forth in Annex A is a list of (a) SORs reported in product-level supplier survey responses which, although not confirmed, are believed to have a greater likelihood of being in the Company’s supply chain, and (b) SORs reported in company-level supplier survey responses for which there is reliable data regarding country of origin sourcing or conformant (or actively seeking conformant) status, based on RMI data as of April 5, 2018. The Company is unable to determine whether any of the facilities listed in Annex A in fact processed conflict minerals in its products.
Based on RMI’s country of origin data as of April 5, 2018, which is organized by risk-based categories, Annex B provides an aggregated list of the countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, in addition to recycled and scrap sources.
The Company’s efforts to determine the mine or location of origin of the necessary conflict minerals in its products with the greatest possible specificity consisted of the implementation of the Program and due diligence measures described above in this Conflict Minerals Report.
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Risk Mitigation Steps
The Company believes that it will take time for the various supply chain and industry participants to institute programs and agreed processes to gather verifiable information on conflict minerals sourcing and chain of custody. Accordingly, the Company’s due diligence is an iterative process and progress is expected to be incremental over time. To work toward this progress:
• | Seek to Improve Supplier Engagement. With the goal of increasing the response rate and quality of survey responses, including increasing the number of product-level survey responses, the Company plans to continue to reach out to suppliers, support education and training for suppliers, and integrate expectations regarding the Program into new supplier contracts and those coming up for renewal. |
• | Continue to Enhance and Refine Due Diligence Processes. Based on learnings from the 2017 supplier survey process, the Core Team plans to continue to work internally and with the Vendor to enhance its supplier survey and due diligence processes. |
• | Support Efforts to Encourage SOR Participation in RMAP. The Company expects to continue to participate as a member of RMI to support programs, such as the RMAP, that facilitate and validate independent third-party audits of SORs’ supply chain due diligence practices. |
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ANNEX A
The following is a list of (a) SORs reported in product-level supplier surveys, and (b) SORs reported in company-level supplier surveys for which country of origin sourcing is known or which have conformed (or actively seeking conformance) status, based on RMI data as of April 5, 2018. SORs that have been validated by RMI to have conformant sourcing, are in the process of being validated or are certified by LBMA and/or RJC, are indicated by asterisk. The Company is unable to determine whether any of the facilities listed below in fact processed conflict minerals in its products.
Metal | SOR Name | Smelter Facility |
Gold | Abington Reldan Metals, LLC | UNITED STATES |
Gold | Advanced Chemical Company* | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd.* | JAPAN |
Gold | Al Etihad Gold LLC* | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | UZBEKISTAN |
Gold | AngloGold Ashanti Córrego do Sítio Mineração* | 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 |
Gold | Asaka Riken Co., Ltd.* | JAPAN |
Gold | AU Traders and Refiners | TURKEY |
Gold | Aurubis AG* | SOUTH AFRICA |
Gold | Bangalore Refinery* | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | INDIA |
Gold | Boliden AB* | PHILIPPINES |
Gold | C. Hafner GmbH + Co. KG* | SWEDEN |
Gold | CCR Refinery - Glencore Canada Corporation* | GERMANY |
Gold | Cendres + Métaux S.A. | MEXICO |
Gold | Chimet S.p.A.* | CANADA |
Gold | Daejin Indus Co., Ltd.* | SWITZERLAND |
Gold | DODUCO Contacts and Refining GmbH* | ITALY |
Gold | Dowa | JAPAN |
Gold | DSC (Do Sung Corporation)* | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd. | CHINA |
Gold | Emirates Gold DMCC | GERMANY |
Gold | Geib Refining Corporation* | GERMANY |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | JAPAN |
Gold | HeeSung* | KOREA, REPUBLIC OF |
Gold | Heimerle + Meule GmbH* | JAPAN |
Gold | Heraeus Metals Hong Kong Ltd. | UNITED STATES |
Gold | Heraeus Precious Metals GmbH & Co. KG* | UNITED ARAB EMIRATES |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | ZIMBABWE |
Gold | Ishifuku Metal Industry Co., Ltd. | INDIA |
Gold | Istanbul Gold Refinery* | UNITED STATES |
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Gold | Italpreziosi* | CHINA |
Gold | Japan Mint | CHINA |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CHINA |
Gold | JSC Uralelectromed | CHINA |
Gold | JX Nippon Mining & Metals Co., Ltd.* | KOREA, REPUBLIC OF |
Gold | Kazzinc* | GERMANY |
Gold | Kennecott Utah Copper LLC* | CHINA |
Gold | KGHM Polska Miedz Spolka Akcyjna* | GERMANY |
Gold | Kojima Chemicals Co., Ltd. | CHINA |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC* | CHINA |
Gold | L'Orfebre S.A.* | JAPAN |
Gold | LS-NIKKO Copper Inc.* | TURKEY |
Gold | Marsam Metals* | ITALY |
Gold | Materion* | JAPAN |
Gold | Matsuda Sangyo Co., Ltd.* | CHINA |
Gold | Metalor Technologies (Hong Kong) Ltd.* | RUSSIAN FEDERATION |
Gold | Metalor Technologies (Singapore) Pte., Ltd.* | RUSSIAN FEDERATION |
Gold | Metalor Technologies (Suzhou) Ltd.* | JAPAN |
Gold | Metalor Technologies S.A. | UNITED ARAB EMIRATES |
Gold | Metalor USA Refining Corporation | KAZAKHSTAN |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V.* | KAZAKHSTAN |
Gold | Mitsubishi Materials Corporation* | UNITED STATES |
Gold | Mitsui Mining and Smelting Co., Ltd.* | POLAND |
Gold | MMTC-PAMP India Pvt., Ltd.* | JAPAN |
Gold | Modeltech Sdn Bhd* | KOREA, REPUBLIC OF |
Gold | Moscow Special Alloys Processing Plant* | KYRGYZSTAN |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | RUSSIAN FEDERATION |
Gold | Nihon Material Co., Ltd. | SAUDI ARABIA |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CHINA |
Gold | Ohura Precious Metal Industry Co., Ltd. | CHINA |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)* | ANDORRA |
Gold | OJSC Novosibirsk Refinery* | KOREA, REPUBLIC OF |
Gold | PAMP S.A. | CHINA |
Gold | Planta Recuperadora de Metales SpA* | BRAZIL |
Gold | Prioksky Plant of Non-Ferrous Metals* | UNITED STATES |
Gold | PT Aneka Tambang (Persero) Tbk* | JAPAN |
Gold | PX Précinox S.A.* | CHINA |
Gold | Rand Refinery (Pty) Ltd.* | SINGAPORE |
Gold | Remondis Argentia B.V.* | CHINA |
Gold | Republic Metals Corporation* | SWITZERLAND |
Gold | Royal Canadian Mint* | UNITED STATES |
Gold | SAAMP* | MEXICO |
Gold | Safimet S.p.A* | JAPAN |
Gold | SAFINA A.S.* | JAPAN |
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Gold | Samduck Precious Metals* | INDIA |
Gold | SAXONIA Edelmetalle GmbH* | MALAYSIA |
Gold | Schone Edelmetaal B.V. | NEW ZEALAND |
Gold | SEMPSA Joyería Platería S.A. | AUSTRALIA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | RUSSIAN FEDERATION |
Gold | Sichuan Tianze Precious Metals Co., Ltd.* | TURKEY |
Gold | Singway Technology Co., Ltd. | UZBEKISTAN |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* | JAPAN |
Gold | Solar Applied Materials Technology Corp.* | AUSTRIA |
Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
Gold | SungEel HiTech* | RUSSIAN FEDERATION |
Gold | T.C.A S.p.A* | RUSSIAN FEDERATION |
Gold | Tanaka Kikinzoku Kogyo K.K.* | SWITZERLAND |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | UNITED STATES |
Gold | Tokuriki Honten Co., Ltd. | CHINA |
Gold | Torecom* | CHILE |
Gold | Umicore Brasil Ltda.* | RUSSIAN FEDERATION |
Gold | Umicore Precious Metals Thailand* | INDONESIA |
Gold | Umicore S.A. Business Unit Precious Metals Refining* | SWITZERLAND |
Gold | United Precious Metal Refining, Inc.* | SOUTH AFRICA |
Gold | Valcambi S.A. | CHINA |
Gold | Western Australian Mint trading as The Perth Mint* | NETHERLANDS |
Gold | WIELAND Edelmetalle GmbH* | UNITED STATES |
Gold | Yamamoto Precious Metal Co., Ltd.* | CANADA |
Gold | Yokohama Metal Co., Ltd.* | FRANCE |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | UNITED STATES |
Gold | Asaka Riken Co., Ltd.* | Italy |
Gold | Changsha South Tantalum Niobium Co., Ltd.* | CZECH REPUBLIC |
Gold | D Block Metals, LLC | INDIA |
Gold | Exotech Inc.* | KOREA, REPUBLIC OF |
Gold | F&X Electro-Materials Ltd. | KOREA, REPUBLIC OF |
Gold | FIR Metals & Resource Ltd.* | GERMANY |
Gold | Global Advanced Metals Aizu* | NETHERLANDS |
Gold | Global Advanced Metals Boyertown* | SPAIN |
Gold | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
Gold | Guangdong Zhiyuan New Material Co., Ltd.* | CHINA |
Gold | H.C. Starck Co., Ltd.* | CHINA |
Gold | H.C. Starck Hermsdorf GmbH* | TAIWAN |
Gold | H.C. Starck Inc.* | RUSSIAN FEDERATION |
Gold | H.C. Starck Ltd.* | TAIWAN |
Gold | H.C. Starck Smelting GmbH & Co. KG | LITHUANIA |
Gold | H.C. Starck Tantalum and Niobium GmbH | SUDAN |
Gold | Hengyang King Xing Lifeng New Materials Co., Ltd.* | JAPAN |
Gold | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | KOREA, REPUBLIC OF |
Gold | Jiangxi Tuohong New Raw Material* | ITALY |
Gold | Jiujiang Janny New Material Co., Ltd.* | JAPAN |
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Gold | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA |
Gold | Jiujiang Tanbre Co., Ltd.* | JAPAN |
Gold | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Gold | KEMET Blue Metals | BELGIUM |
Gold | KEMET Blue Powder | KAZAKHSTAN |
Gold | King-Tan Tantalum Industry Ltd.* | KOREA, REPUBLIC OF |
Gold | LSM Brasil S.A.* | BRAZIL |
Gold | Metallurgical Products India Pvt., Ltd.* | THAILAND |
Gold | Mineracao Taboca S.A.* | BELGIUM |
Gold | Mitsui Mining and Smelting Co., Ltd.* | UNITED STATES |
Gold | Ningxia Orient Tantalum Industry Co., Ltd. | ZAMBIA |
Gold | NPM Silmet AS* | SWITZERLAND |
Gold | Power Resources Ltd.* | AUSTRALIA |
Gold | QuantumClean* | GERMANY |
Gold | Resind Industria e Comercio Ltda.* | JAPAN |
Gold | RFH Tantalum Smeltry Co., Ltd.* | JAPAN |
Gold | Solikamsk Magnesium Works OAO | CHINA |
Gold | Taki Chemicals* | CHINA |
Gold | DS PRETECH Co., Ltd.* | KOREA, REPUBLIC OF |
Gold | NH Recytech Company* | KOREA, REPUBLIC OF |
Tantalum | Telex Metals* | JAPAN |
Tantalum | Ulba Metallurgical Plant JSC* | CHINA |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | UNITED STATES |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tantalum | Alpha* | UNITED STATES |
Tantalum | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | CHINA |
Tantalum | Chifeng Dajingzi Tin Industry Co., Ltd.* | CHINA |
Tantalum | China Tin Group Co., Ltd.* | JAPAN |
Tantalum | CV Ayi Jaya* | UNITED STATES |
Tantalum | CV Dua Sekawan* | CHINA |
Tantalum | CV Gita Pesona* | CHINA |
Tantalum | CV Tiga Sekawan* | THAILAND |
Tantalum | CV United Smelting* | GERMANY |
Tantalum | CV Venus Inti Perkasa* | UNITED STATES |
Tantalum | Dowa* | JAPAN |
Tantalum | EM Vinto* | GERMANY |
Tantalum | Fenix Metals* | GERMANY |
Tantalum | Gejiu Fengming Metallurgy Chemical Plant* | CHINA |
Tantalum | Gejiu Jinye Mineral Company* | CHINA |
Tantalum | Gejiu Kai Meng Industry and Trade LLC* | CHINA |
Tantalum | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
Tantalum | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | CHINA |
Tantalum | Guangdong Hanhe Non-ferrous Metal Limited Company* | CHINA |
Tantalum | Guanyang Guida Nonferrous Metal Smelting Plant* | CHINA |
Tantalum | HuiChang Hill Tin Industry Co., Ltd.* | MEXICO |
Tantalum | Huichang Jinshunda Tin Co., Ltd.* | UNITED STATES |
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Tantalum | Jiangxi Ketai Advanced Material Co., Ltd.* | CHINA |
Tantalum | Jiangxi New Nanshan Technology Ltd.* | BRAZIL |
Tantalum | Magnu's Minerais Metais e Ligas Ltda.* | INDIA |
Tantalum | Malaysia Smelting Corporation (MSC)* | BRAZIL |
Tantalum | Melt Metais e Ligas S.A.* | JAPAN |
Tantalum | Metallic Resources, Inc.* | CHINA |
Tantalum | Metallo Belgium N.V.* | ESTONIA |
Tantalum | Metallo Spain S.L.U.* | MACEDONIA |
Tantalum | Mineracao Taboca S.A.* | UNITED STATES |
Tantalum | Minsur* | BRAZIL |
Tantalum | Mitsubishi Materials Corporation* | CHINA |
Tantalum | Modeltech Sdn Bhd* | RUSSIAN FEDERATION |
Tantalum | O.M. Manufacturing (Thailand) Co., Ltd.* | JAPAN |
Tantalum | O.M. Manufacturing Philippines, Inc.* | UNITED STATES |
Tantalum | Operaciones Metalurgical S.A.* | KAZAKHSTAN |
Tantalum | PT Aries Kencana Sejahtera* | CHINA |
Tantalum | PT Artha Cipta Langgeng* | CHINA |
Tin | PT ATD Makmur Mandiri Jaya* | UNITED STATES |
Tin | PT Babel Inti Perkasa | VIET NAM |
Tin | PT Bangka Prima Tin* | CHINA |
Tin | PT Bangka Serumpun* | CHINA |
Tin | PT Bangka Tin Industry* | CHINA |
Tin | PT Belitung Industri Sejahtera | CHINA |
Tin | PT Bukit Timah* | INDONESIA |
Tin | PT DS Jaya Abadi* | INDONESIA |
Tin | PT Eunindo Usaha Mandiri* | INDONESIA |
Tin | PT Inti Stania Prima* | INDONESIA |
Tin | PT Karimun Mining* | INDONESIA |
Tin | PT Kijang Jaya Mandiri* | INDONESIA |
Tin | PT Lautan Harmonis Sejahtera* | JAPAN |
Tin | PT Menara Cipta Mulia | VIET NAM |
Tin | PT Mitra Stania Prima* | BOLIVIA |
Tin | PT O.M. Indonesia | BRAZIL |
Tin | PT Panca Mega Persada* | POLAND |
Tin | PT Premium Tin Indonesia* | CHINA |
Tin | PT Prima Timah Utama* | CHINA |
Tin | PT Refined Bangka Tin* | CHINA |
Tin | PT Sariwiguna Binasentosa* | CHINA |
Tin | PT Stanindo Inti Perkasa* | CHINA |
Tin | PT Sukses Inti Makmur | CHINA |
Tin | PT Sumber Jaya Indah* | CHINA |
Tin | PT Timah (Persero) Tbk Kundur* | CHINA |
Tin | PT Timah (Persero) Tbk Mentok* | CHINA |
Tin | PT Tinindo Inter Nusa* | CHINA |
Tin | PT Tommy Utama* | CHINA |
Tin | Resind Industria e Comercio Ltda.* | CHINA |
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Tin | Rui Da Hung* | BRAZIL |
Tin | Soft Metais Ltda.* | MALAYSIA |
Tin | Thaisarco* | BRAZIL |
Tin | White Solder Metalurgia e Mineração Ltda.* | UNITED STATES |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | BELGIUM |
Tin | Yunnan Tin Company Limited* | SPAIN |
Tin | A.L.M.T. TUNGSTEN Corp.* | BRAZIL |
Tin | ACL Metais Eireli* | PERU |
Tin | Asia Tungsten Products Vietnam Ltd.* | JAPAN |
Tin | Chenzhou Diamond Tungsten Products Co., Ltd.* | MALAYSIA |
Tin | Chongyi Zhangyuan Tungsten Co., Ltd. | VIET NAM |
Tin | Fujian Jinxin Tungsten Co., Ltd.* | THAILAND |
Tin | Ganzhou Haichuang Tungsten Co., Ltd.* | PHILIPPINES |
Tin | Ganzhou Huaxing Tungsten Products Co., Ltd.* | BOLIVIA |
Tin | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | MYANMAR |
Tin | Ganzhou Seadragon W & Mo Co., Ltd.* | INDONESIA |
Tin | Global Tungsten & Powders Corp.* | INDONESIA |
Tin | Guangdong Xianglu Tungsten Co., Ltd.* | INDONESIA |
Tin | H.C. Starck Smelting GmbH & Co.KG* | INDONESIA |
Tin | H.C. Starck Tungsten GmbH* | INDONESIA |
Tin | Hunan Chenzhou Mining Co., Ltd.* | INDONESIA |
Tin | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* | INDONESIA |
Tin | Hunan Chunchang Nonferrous Metals Co., Ltd.* | INDONESIA |
Tin | Hunan Litian Tungsten Industry Co., Ltd.* | INDONESIA |
Tin | Hydrometallurg, JSC* | INDONESIA |
Tin | Japan New Metals Co., Ltd.* | INDONESIA |
Tin | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | INDONESIA |
Tin | Jiangxi Gan Bei Tungsten Co., Ltd.* | INDONESIA |
Tin | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | INDONESIA |
Tin | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | INDONESIA |
Tin | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.* | INDONESIA |
Tin | Jiangxi Yaosheng Tungsten Co., Ltd.* | INDONESIA |
Tin | Kennametal Fallon* | INDONESIA |
Tin | Kennametal Huntsville* | INDONESIA |
Tin | Malipo Haiyu Tungsten Co., Ltd.* | INDONESIA |
Tin | Moliren Ltd* | INDONESIA |
Tin | Niagara Refining LLC* | INDONESIA |
Tin | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | INDONESIA |
Tin | Philippine Chuangxin Industrial Co., Inc.* | INDONESIA |
Tin | South-East Nonferrous Metal Company Limited of Hengyang City* | INDONESIA |
Tin | Tejing (Vietnam) Tungsten Co., Ltd.* | INDONESIA |
Tin | Unecha Refractory metals plant* | INDONESIA |
Tin | Vietnam Youngsun Tungsten Industry Co., Ltd.* | INDONESIA |
Tin | Wolfram Bergbau und Hütten AG* | INDONESIA |
Tin | Woltech Korea Co., Ltd.* | INDONESIA |
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Tin | Xiamen Tungsten (H.C.) Co., Ltd.* | BRAZIL |
Tin | Xiamen Tungsten Co., Ltd.* | TAIWAN |
Tin | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | BRAZIL |
Tin | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Brazil |
Tin | Thaisarco* | THAILAND |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda.* | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CHINA |
Tin | Yunnan Tin Company Limited* | CHINA |
Tungsten | A.L.M.T. TUNGSTEN 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 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 | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp.* | UNITED STATES |
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 |
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 Dayu Longxintai Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.* | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA |
Tungsten | Kennametal Fallon* | UNITED STATES |
Tungsten | Kennametal Huntsville* | UNITED STATES |
Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
Tungsten | Moliren Ltd* | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC* | UNITED STATES |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | VIET NAM |
Tungsten | Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES |
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Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | CHINA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | VIET NAM |
Tungsten | Unecha Refractory metals plant* | RUSSIAN FEDERATION |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd.* | VIET NAM |
Tungsten | Wolfram Bergbau und Hütten 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 |
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ANNEX B
Countries of Origin
Below is an aggregated list of countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, based on data available from RMI as of March 16, 2018.
Argentina | Laos |
Australia | Madagascar |
Austria | Malaysia |
Benin | Mali |
Bolivia | Mexico |
Brazil | Mongolia |
Burkina Faso | Mozambique |
Burundi | Myanmar |
Cambodia | Namibia |
Canada | Nicaragua |
Chile | Nigeria |
China | Panama |
Colombia | Peru |
Democratic Republic of Congo | Portugal |
Ecuador | Russia Federation |
Eritrea | Rwanda |
Ethiopia | Senegal |
France | Sierra Leone |
Germany | South Africa |
Ghana | Spain |
Guatemala | Thailand |
Guinea | Togo |
Guyana | Uganda |
Honduras | United Kingdom |
India | United States of America |
Indonesia | Uzbekistan |
Japan | Viet Nam |
Kazakhstan | Zimbabwe |
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