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Exhibit 1.01
CONFLICT MINERALS REPORT
For The Year Ended December 31, 2019
Introduction
This Conflict Minerals Report (“Report”) of Quidel Corporation for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule”). Numerous terms in this Report are defined in Item 1.01 of Form SD promulgated under the Rule, and the reader is referred to Form SD and Release No. 34-67716 issued by the Securities and Exchange Commission (“SEC”) on August 22, 2012 for such definitions. Unless the context otherwise requires, references below in this Conflict Minerals Report to “Quidel”, “we”, “our” or “us” refer to Quidel Corporation and its consolidated subsidiaries.
The terms “Conflict Minerals” or “3TG” are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. The Rule requires us to undertake in good faith a reasonable country of origin inquiry to determine whether any of the 3TG in our products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country, which for the purposes of the Rule are Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (together with the DRC, collectively defined as the “Covered Countries”) or were from recycled or scrap sources.
Company Overview
Quidel’s products are marketed under various brand names, including, among others, Quidel®, QuickVue®, QuickVue +®, Sofia®, Triage®, AmpliVue®, Solana®, Virena®, MicroVueTM, Lyra®, FreshCellsTM, D3®, FastPoint®, ReadyCells®, Super E-MixTM, InflammaDry®, AdenoPlus®, ELVIRA®, ELVIS® and Thyretain®. Quidel's products aid in the detection and diagnosis of many critical diseases and conditions, including, among others, infectious diseases, cardiovascular diseases and conditions, women’s health, gastrointestinal diseases, autoimmune diseases, bone health and thyroid diseases. Quidel’s principal executive offices are located at 9975 Summers Ridge Road, San Diego, CA 92121.
Description of Our Products Covered by this Report
This Report relates to Quidel products: (i) for which 3TG are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by Quidel; and (iii) for which the manufacture was completed during calendar year 2019. During this reporting period, we identified that our Sofia®, Virena®, AmpliVue®, Solana®, Triage® equipment and QuickVue® iFOB products that include test strips that we manufactured or contracted to manufacture may contain 3TG that are necessary to the functionality of the products.
Quidel’s supply chain is complex and there are many third parties in the supply chain between the ultimate manufacture of Quidel products and the original sources of Conflict Minerals. In this regard, Quidel does not purchase 3TG directly from mines, smelters or refiners. Quidel must therefore rely on its suppliers to provide information regarding the origin of the 3TG that is contained in Quidel products. Moreover, Quidel believes that
the smelters and refiners of the 3TG are best situated to identify the sources of 3TG, and therefore has taken steps to identify the applicable smelters and refiners of 3TG in Quidel’s supply chain.
Conflict Minerals Compliance Program
Our due diligence processes and efforts have been designed to conform with the five-step framework recommended by the Second Edition of The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). In addition, we used the standard Conflict Minerals Reporting Template (the “Template”), along with other resources employed by a third-party consultant, to obtain information necessary to prepare this Report.
(1) Establish Strong Management Systems
Conflict Minerals Compliance Team - We have established a team comprised of representatives from our Operations, Supply Chain management, Finance, and Legal departments to review the Rule, the adopting release associated with the Rule and the related FAQs published by the SEC staff. As in prior years, we have continued to focus our efforts on processes to communicate with suppliers and record and store responses to our inquiries. In 2019, we also engaged a recognized third party professional agency to assist us in our efforts to implement the due diligence process in accordance with the OECD Guidance.
Conflict Minerals Policy - We have adopted a policy on Conflict Minerals, which is posted on our website at quidel.com through the “Investor Relations” link under the heading “Corporate Governance.” Our policy includes principles that we expect all of our suppliers to: prohibit human rights abuses and unethical practices; source materials from socially responsible suppliers and sub-suppliers in pursuit of conflict free supply chains; abide by applicable legal standards and requirements; and cooperate with us as necessary for us to meet our disclosure requirements.
System of Controls and Transparency over Supply Chain - We continue to try to identify upstream actors in our supply chain through the utilization of the Template and the resources employed by our third-party consultant.
Supplier Engagement - As in the prior years, in 2019, we engaged a recognized third-party professional agency to assist us in engaging suppliers, including by providing access to the third-party's Conflict Minerals Supplier Resource Center and to escalate communications as needed to obtain requested information and raise awareness of our Conflicts Minerals Compliance Program.
Grievance Mechanism - We provide an ethics hotline to report any concerns about violations of Quidel’s Code of Conduct, which provides a mechanism for escalating any issues and concerns, including those related to Conflict Minerals.
Maintain Records - We retain documentation with respect to our due diligence compliance process and in accordance with record retention requirements that are designed to to ensure the retaining of relevant documentation.
(2) Identify and Assess Risk in the Supply Chain
We seek to identify and assess risks in the supply chain, including by adopting processes to identify whether 3TG “necessary to the functionality of the products” has been identified and by implementing processes to collect, review, and record data from suppliers and follow up with suppliers regarding source information. We also conducted a third party analysis of the collected supplier information, comparing the information against a national database gathered from various industries over the years. Utilizing the database and other data points, we collaborated with our third-party consultant to establish a ranking system that identified possible risk patterns in the supplier/smelter data, allowing us to further scrutinize the supply chain and country of origin information.
(3) Design and Implement a Strategy to Respond to Identified Risks
If, based on red flags that are identified, we determine that there is a reasonable risk that a supplier is sourcing Conflict Minerals that are directly or indirectly financing or benefiting armed groups, we encourage suppliers to comply with our Conflict Minerals Policy. Our third-party consultant also applied quality assurance measures in connection with aggregation of the collected data.
(4) Third Party Audit
We do not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain with Conflict Minerals. However, we do rely upon the industry (for example, the Responsible Minerals Initiative (“RMI”) efforts to influence smelters and refiners to get audited and certified through RMI’s Responsible Minerals Assurance Process (“RMAP”), the London Bullion Market Association Good Delivery Program or the Responsible Jewellery Council Chain-of-Custody Certification.
(5) Reporting
We filed Form SD and this Report with the SEC and have made this Report available on our website at quidel.com through the “Investor Relations” link under the heading “Governance.” The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.
Reasonable Country of Origin Inquiry
Quidel has conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any 3TG in Quidel’s products originated in the DRC or an adjoining country or were from recycled or scrap sources through use of the Template and engagement with our third-party consultant. As a part of our RCOI, through our third-party consultant, we surveyed the 9 suppliers that were identified as in-scope for conflict mineral regulatory purposes. These suppliers were each contacted as part of the RCOI process and given a deadline of April 11, 2020 to respond to inquiries. 100% of these suppliers responded to us.
For those supply chains with smelters or refiners and associated mine countries of origin that are thought to be sourcing from a Covered Country, additional investigation was done to determine the source and chain-of-custody of the regulated metals. We relied on the following internationally accepted audit standards to determine which smelters or refiners are considered “DRC Conflict Free”: the Responsible Minerals Assurance Process, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification. If the smelter or refiner is not certified by these internationally-recognized schemes, our third-party consultant may attempt to contact the smelter to gain more information about their sourcing practices. Internet research is also performed to determine whether there are any outside sources of information regarding the smelter’s sourcing practices, including through access to data and working groups as a vendor member of the RMI. Up to three contact attempts are made to gather information on mine country of origin and sourcing practices.
None of our suppliers were able to identify the smelters or refiners used for a particular part, component, or product that was supplied to us and that was later incorporated into our Products. Therefore, we are unable to identify with certainty the specific facilities used to process the 3TG in our products. There were approximately 297 identified smelters/refiners that have been reported to us by our suppliers. A list of smelters and refiners identified by our suppliers is included on Annex I below along with certain country of origin information provided to us.
Independent Private Sector Audit
An independent private sector audit of this Report is not required at this time.
Limitations
As a downstream purchaser of 3TG, our due diligence measures cannot provide absolute assurance regarding the
source and chain of custody of the necessary Conflict Minerals. Our due diligence processes are based on the necessity of seeking data from our suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary Conflict Minerals. We also rely on third-party audit programs and other industry efforts and information.
A number of factors could introduce errors or otherwise affect our determinations, including, but not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers, errors or omissions by smelters, confusion over requirements of SEC final rules, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the reporting process, oversights or errors in conflict free smelter audits, Covered Country sourced materials being declared secondary materials, certification programs not being equally advanced for all industry segments and metals, and smuggling of Conflict Minerals to countries beyond the Covered Countries.
Forward-Looking Statements
This Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our future plans and initiatives for our due diligence process and to mitigate the risk about the sourcing of 3TG. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; lack of progress in smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities) or these plans not being effective. In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in the Company’s most recently submitted Quarterly or Annual Reports. Except as required by law, we undertake no obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.
Continuous Improvement
To help mitigate the risk that 3TG in our products benefit armed groups in the Covered Countries, we endeavor to continuously improve upon our supply chain due diligence efforts, including through the following measures:
•Continue to assess the presence of 3TG in our supply chain;
•Communicate with suppliers to continue to obtain a high response rate for the RCOI process; and
•Continue to compare RCOI results to information collected via independent conflict free smelter validation programs such as the RMAP.
Annex I
Smelters and Refiners
In connection with our reasonable country of origin inquiry and due diligence, as applicable, our suppliers identified to us the smelters and refiners listed below, sorted by mineral, as potentially having processed the necessary 3TG contained in our in-scope products in 2019.
| | | | | | | | |
| Metal | Official Smelter Name | Smelter Country |
| Gold | 8853 S.p.A. | Italy |
| Gold | Abington Reldan Metals, LLC | United States |
| Gold | Advanced Chemical Company | United States |
| Gold | African Gold Refinery | Uganda |
| 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 |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| 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 | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Chimet S.p.A. | Italy |
| Gold | Chugai Mining | Japan |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| 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 | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| | | | | | | | |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Geib Refining Corporation | United States |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| 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 Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States |
| 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 | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | LT Metal Ltd. | Korea, Republic of |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
| Gold | Materion | United States |
| 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 |
| 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 | Modeltech Sdn Bhd | Malaysia |
| Gold | Morris and Watson | New Zealand |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | NH Recytech Company | Korea, Republic of |
| 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 |
| Gold | OJSC Novosibirsk Refinery | Russian Federation |
| Gold | PAMP S.A. | Switzerland |
| Gold | Pease & Curren | United States |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| 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 | QG Refining, LLC | United States |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Royal Canadian Mint | Canada |
| Gold | SAAMP | France |
| Gold | Sabin Metal Corp. | United States |
| Gold | Safimet S.p.A | Italy |
| Gold | SAFINA A.S. | Czech Republic |
| Gold | Sai Refinery | India |
| Gold | Samduck Precious Metals | Korea, Republic of |
| Gold | SAMWON METALS Corp. | Korea, Republic of |
| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Singway Technology Co., Ltd. | Taiwan |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan |
| Gold | Sovereign Metals | India |
| | | | | | | | |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Sudan Gold Refinery | Sudan |
| 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 | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Tony Goetz NV | Belgium |
| 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 |
| 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 |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | CP Metals Inc. | United States |
| Tantalum | D Block Metals, LLC | United States |
| Tantalum | Exotech Inc. | United States |
| 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 |
| 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 |
| 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 | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | PRG Dooel | Macedonia, The Former Yugoslav Republic Of |
| Tantalum | QuantumClean | United States |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Telex Metals | United States |
| 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 |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
| 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 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam |
| Tin | EM Vinto | Bolivia |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| 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 | Ma'anshan Weitai Tin Co., Ltd. | China |
| Tin | Magnu's 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 |
| Tin | Metallo Belgium N.V. | Belgium |
| Tin | Metallo Spain S.L.U. | Spain |
| Tin | Minsur | Peru |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| | | | | | | | |
| Tin | Operaciones Metalurgicas S.A. | Bolivia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Precious Minerals and Smelting Limited | India |
| 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 | Rui Da Hung | Taiwan |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Super Ligas | Brazil |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam |
| Tin | Thaisarco | Thailand |
| Tin | Tin Technology & Refining | United States |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
| 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. 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 | China Molybdenum Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | CNMC (Guangxi) PGMA 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 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| 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 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 Xianglu Tungsten Co., Ltd. | China |
| | | | | | | | |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | Kennametal Fallon | United States |
| Tungsten | Kennametal Huntsville | United States |
| Tungsten | KGETS CO., LTD. | Korea, Republic of |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan |
| 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 |
| 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 |
We note the following in connection with the information in the table above: The smelters and refiners listed in the table were identified by our suppliers as being part of our 2019 supply chain. Some of the suppliers may have reported to us smelters and refiners that were not in our supply chain (i) since they reported at a “company level,” meaning that they reported to us the 3TG contained in all of their products, not just the products that they sold to us, or (ii) due to over-inclusiveness in the information received from their suppliers. In addition, the smelters and refiners reflected above may not be all of the smelters and refiners in our 2019 supply chain, since many of the suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in scope products. All information in the table is as of April 11, 2020.
Country of Origin Information
For 2019, we were not able to determine the country of origin of the 3TG processed by approximately 25% of the identified smelters or refiners. In addition, approximately 20% of the identified smelters and refiners have not been certified as currently compliant with RMAP assessment protocols of the RMI or other accredited organizations.
The countries of origin of the 3TG processed by the smelters and refiners listed above may have included countries in each of the categories listed below. The countries below are sorted by OECD risk level, with L1 being the lowest level of risk and L3 being the highest.
L1 - Countries with little to no risk countries with known active metal production but are not identified as conflict regions or plausible areas of smuggling, export or transit of minerals out of conflict affected regions, such as Argentina, Armenia, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Czech Republic, Estonia, Germany, India, Indonesia, Italy, Kazakhstan, New Zealand, Russian Federation, Saudi Arabia, Spain, Turkey, the United States, and Zimbabwe.
L2 - Low to medium risk countries with known plausible involvement in the smuggling, export or transit of mineral out of conflict affected regions, such as the United Arab Emirates.
L3 - High risk countries currently defines as the Democratic Republic of Congo (DRC) and its nine adjoining countries (Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia).
In addition, some of the listed smelters and refiners may have processed 3TG originating from recycled or scrap sources.
