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Exhibit 1.01
Allegro MicroSystems, Inc. – 2024 Conflict Minerals Report
Introduction
This Conflict Minerals Report of Allegro MicroSystems, Inc. (the “Company”, “Allegro”, “we”, or “our”), for the year ended December 31, 2024 (the “Report”), is presented in compliance with Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). This Report should be read in conjunction with the definitions set forth by the U.S. Securities and Exchange Commission (the “SEC”) within the Form SD – Specialized Disclosure Report – Instructions. “Conflict Minerals” or “3TG” refers to the four specific metals, tantalum, tin, tungsten, and gold, regardless of country of origin or whether they benefit, or finance, armed conflict and violence.
Rule 13p-1 of the Exchange Act imposes reporting obligations for SEC reporting companies whose products contain Conflict Minerals that are necessary to the functionality or production of their products. Such companies must, in good faith, conduct a reasonable country of origin inquiry (the “RCOI”) designed to determine the country of origin of the Conflict Minerals. If the Conflict Minerals necessary for the functionality or production of a company’s products may have originated in the Democratic Republic of the Congo, and adjoining countries (the “Covered Countries”), and may not be solely from recycled or scrap resources, a company must also conduct due diligence on the source and chain of custody of those Conflict Minerals to determine if the Conflict Minerals benefited, or financed, armed conflict and violence.
For the year ended December 31, 2024, the Company has determined that Conflict Minerals were necessary to the functionality and production of our products and has conducted an RCOI, as described in this Report. Based on the RCOI, some of the Conflict Minerals used in the Company’s products may have originated in the Covered Countries and may not have only originated from scrap and recycled sources. The Company performed due diligence measures on the source and chain of custody of these Conflict Minerals, as described in this Report.
This Report describes our products and the review and diligence process undertaken for products that were manufactured or contracted to be manufactured during calendar year 2024 and that contain Conflict Minerals. Pursuant to the April 29, 2014 “Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule,” issued by Keith F. Higgins, Director, SEC Division of Corporate Finance, the Company is not required to describe its products as “DRC Conflict Free” or “DRC Conflict Undeterminable.” Moreover, the Company is not required to obtain, and has not obtained, an independent private sector audit of this Report.
For important disclosures regarding the website references and forward-looking statements contained in this Report, please see the section of the Report titled “Additional Information.”
Company and Product Descriptions
The Company is a leading global designer, developer, fabless manufacturer and marketer of sensor integrated circuits (“ICs”) and application-specific power ICs, enabling the most important emerging technologies in the automotive and industrial markets. With the broadest portfolio of magnetic sensor IC solutions available, underpinned by our strong position in the automotive market, we are the leading magnetic sensor supplier worldwide based on market share. Our products are foundational to automotive and industrial electronic systems. Our sensor ICs enable our customers to precisely measure motion, speed, position and current, while our power ICs include high-temperature and high-voltage capable motor drivers, power management ICs, light emitting diode driver ICs and isolated gate drivers. We believe that our technology expertise, combined with our deep applications knowledge and strong customer relationships, enable us to develop solutions that provide more value to customers than typical ICs. Compared to a typical IC, our solutions are more integrated, intelligent and sophisticated for complex applications and easier for customers to use.
Our product portfolio includes over 1,500 products across a range of high-performance analog mixed-signal semiconductors. We apply our deep technology know-how to deliver magnetic sensing IC and power IC solutions to: (i) sense speed, position, and current and to enable electric powertrains, improve vehicle fuel efficiency and meet customer demands for lower CO2 emissions, enable safer cars through advanced driver assistance systems and safety features, and enhance factory automation and clean energy systems; (ii) regulate systems to improve safety and power efficiency and ultimately reduce solution size; and (iii) drive motors through our advanced, proprietary algorithms that provide industry-leading reliability and energy efficiency, with minimal audible noise and vibration.
For the calendar year 2024, our in-scope products that contain Conflict Minerals that may have originated from a Covered Country included both our magnetic sensor and power ICs. Conflict Minerals were necessary to the functionality and production of our ICs for the year ended December 31, 2024.
Overview of Allegro’s Ethical Minerals Program
We are committed to the ethical and responsible sourcing of minerals and have enacted our Ethical Minerals Sourcing Policy to prevent the Conflict Minerals procured for manufacturing from directly, or indirectly, benefiting armed groups, violence, or human rights violations in the Covered Countries. Our Ethical Minerals Sourcing Policy is publicly available on our website (https://www.allegromicro.com/en/design-support/quality-and-environment under “Policies and Declarations”). This policy, which includes Conflict Minerals, Cobalt and Mica, is the foundation for our ethical minerals program and is designed to improve mineral sourcing decisions through:
•Installing company-wide programs and procedures supporting the Responsible Minerals Initiative (“RMI”) aimed at eradicating armed conflict, violence, and human right violations.
•Mapping mineral supply chains and minerals sources utilizing RCOI data, smelter databases, and the Responsible Minerals Assurance Program (“RMAP”) to identify smelters or refiners (“SORs”) as conformant to the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected High Risk Areas (the “OECD Guidance”).
•Requiring suppliers to have a policy or program in place that aims to have all Conflict Minerals utilized ethically sourced, conflict free and reported to stakeholders within the Conflict Minerals Reporting Template (“CMRT”).
•Working to improve Conflict Minerals sourcing decisions and communicating with stakeholders concerning Conflict Minerals supply chain changes that need attention.
•Taking corrective actions to enable ethical sourcing and a conflict-free 3TG supply chain.
•When SOR facilities cannot be confirmed or denied as sourcing from Covered Countries, those suppliers may be audited and subjected to an executive decision on future sourcing options.
Reasonable Country of Origin Inquiry
RCOI Process
For the year ended December 31, 2024, we utilized the following process to conduct our RCOI. We conducted an annual survey utilizing the CMRT to survey our supply chain for any Conflict Minerals necessary for production and manufacturing to identify the SOR facilities our suppliers use when manufacturing components used in our products. Any suppliers that may use Conflict Minerals were identified, provided our Ethical Minerals Sourcing Policy, Ethical Minerals Training Guide, and the latest version of the CMRT, and asked to complete and return the CMRT. Submitted supplier CMRTs were then reviewed for accuracy and completeness. Any areas of concern were identified to the supplier for more details and any amendments. The SOR facilities were then cross-checked with the RMI facilities database and RMI RCOI data, which contains the status of all facilities as active and conformant and countries of origin. For any facilities identified to not be active and conformant to RMAP, or another responsible mineral validation program, we attempted to contact the SOR facility directly to request that the countries of origin be identified for the Conflict Minerals used in the manufacturing of components used in our products. As part of that outreach, we encouraged the contacted SOR facility to engage in the RMI’s RMAP. We also encouraged our suppliers to contact the SOR facility to engage in the RMI’s RMAP. All RCOI surveys and direct communications with SOR facilities were retained within our compliance database and reviewed.
RCOI Results
The results of our RCOI for the year ending December 31, 2024, are as follows:
o100% of suppliers identified as utilizing Conflict Minerals that are necessary for the production and manufacturing of our parts provided responses to the CMRT.
o167 SOR facilities were identified on suppliers’ CMRTs. 25 of these SOR facilities were removed from the supply chain during the due diligence process. Of these 25 SOR facilities, 19 were found to have temporarily or permanently ceased operations and six were found to be nonconformant as a result of allowing their audit cycles to lapse.
oOf the 142 SOR facilities remaining, we have reason to believe that 34 may have sourced Conflict Minerals from Covered Countries and have confirmed, per the RMI, that all 34 are in conformance with RMAP. All 142 SOR facilities were audited by the RMI and validated against RMAP as conformant.
Based on the RCOI conducted by the Company described above, we have reason to believe that some of the Conflict Minerals used in the Company’s products may have originated in the Covered Countries and may not have only originated from scrap and recycled sources. Therefore, we exercised due diligence on the source and chain of custody of Conflict Minerals, in accordance with our ethical minerals program.
Design of Allegro’s Ethical Minerals Program and Due Diligence Process
Allegro has implemented management systems and due diligence processes, including an internal written procedure (our “Ethical Minerals Program”) as a key component for supply chain management, compliance disclosures, and reporting as related to the Conflict Minerals necessary to the functionality or production of products that the Company manufactures and contracts to manufacture. Our Ethical Minerals Program is designed to conform with the five-step framework contained in the OECD Guidance. Our Ethical Minerals Program works in connection with our Supplier Code of Conduct, which is publicly available on our website (https://www.allegromicro.com/en/about-allegro/corporate-responsibility).
Ethical Minerals Program
The following is a summary of the steps we take as part of our Ethical Minerals Program, as it relates to the OECD Guidance:
Step 1: Maintain strong company management systems
•Ethical Mineral Sourcing Policy: We maintain a supply chain mineral sourcing policy that is regularly reviewed and updated. The scope of this policy is minerals that originate from conflict affected high risk areas identified by the OECD (“CAHRAs”), including the Covered Countries. This policy is aligned to the OECD Guidance, requires our suppliers to have a similar policy in place, and establishes the importance of responsible mineral supply chains to Allegro. This policy is publicly available on our website (https://www.allegromicro.com/en/design-support/quality-and-environment under “Policies and Declarations”).
•Internal Ethical Minerals Team: We established an internal team that is tasked with enforcing our Ethical Minerals Sourcing Policy and implementing our Ethical Minerals Program. Our Director of Quality Management Systems leads our Ethical Minerals Program, reporting to our Vice President of Global Quality. The internal team provides reports every other week to stakeholders and the Director of Quality Management Systems, and monthly reports to the Vice President of Global Quality to manage the supply chain. These monthly reports include any escalations related to nonconformant SORs that cannot be removed from the supply chain, metrics on CMRTs and Extended Minerals Reporting Templates (“EMRTs”), and information on any suppliers from whom we have not been able to obtain a CMRT. In 2024, no internal reporting was necessary regarding nonconformant SOR facilities that could not be removed from the supply chain or unresponsive suppliers because we did not have any instances of either of these types of events occurring.
•RMI Membership: We are a member of the Responsible Business Alliance (“RBA”) and a full member of the RMI. As regular participants in RMI’s members-only meetings and work groups, we benefit from industry-wide learning and can engage with other industry stakeholders. An integral part of our Ethical Minerals Program is the RCOI data the RMI provides to us in connection with our risk assessment and due diligence practices.
•Supplier Compliance Management System: A third-party management system is maintained by our internal ethical minerals team and is utilized for the approval or rejection of a supplier’s compliance documents, including the CMRT and EMRT. This is a multi-tiered approval system that has numerous controls in place to ensure compliance records are acceptable according to Company policies. This database is used to internally maintain records that are related to the responsible sourcing of minerals, including annual and ad hoc updates, supplier training materials, and supplier documents.
•Due Diligence Tools: We utilize the latest CMRT published by the RMI to survey our suppliers, map our supply chain, and identify the SORs that process the necessary Conflict Minerals contained in our products and the minerals’ country of origin. Our internal monitoring and control tools are used in connection with our supplier compliance management system to identify when smelters are dispositioned from the RMI’s conformant facilities list and which suppliers utilize those facilities and require engagement and supply chain updates.
•Supplier Engagement: To routinely engage with our suppliers, we have established our compliance management system to request annual updates to the CMRT, provide the supply chain with training materials, and communicate our Ethical Minerals Sourcing Policy. The training materials that are provided to our supply chain are aligned with the training provided by the RMI and are updated regularly to provide the most up to date information on the CMRT and Conflict Minerals. These training materials also provide details relating to Cobalt and Mica and the EMRT. These training materials contain an acknowledgment letter that must be signed and returned to the Company stating
that the materials have been reviewed and are understood. We have also established supplier contacts within the ethical minerals team that are directly responsible for supplier outreach. These supplier contacts utilize a report provided every other week with information from our supplier compliance management system to assist with supplier engagement. On a monthly basis, we report directly to suppliers regarding the status of their compliance records, including the CMRT and EMRT. Other members of the ethical minerals team also engage with suppliers via meetings, email, and phone when additional information is required or updates are needed relating to supply chain mapping, traceability, smelter dispositions, or corrective actions. Additionally, our process for supplier engagement includes supplier scorecards. Conflict Minerals are integrated into the supplier scorecard to provide suppliers with feedback on whether they are meeting the Company’s expectations on Conflict Minerals and how performance can be improved.
•Objective Evidence: Documents that are directly related to Conflict Minerals are stored within our management system including the CMRT and EMRT. Our management system also serves as a record retention platform, keeping a historical archive of all supplier documents and past records related to Conflict Minerals.
•Company Grievance Mechanism: We implemented a grievance mechanism for our employees, suppliers, and any other stakeholders to report any concerns, anonymously, as they relate to the responsible sourcing of minerals and corporate responsibility. We also encourage our suppliers and any other stakeholder to report any grievances to the RMI. Our corporate grievance mechanism is available 24 hours a day, seven days a week by telephone or online on our website (https://investors.allegromicro.com/corporate-governance). The RMI’s grievance mechanism is available on the RMI website (https://mineralsgrievanceplatform.org/).
Step 2: Identify and assess risks in the supply chain
•Risk Assessment Scope: The scope of our risk assessment includes reviewing data from third-party tools and information systems from the RMI, conducting annual surveys of all direct suppliers, spot checking nonconformant SOR facilities as needed, and ensuring compliance with our Supplier Code of Conduct and Ethical Minerals Sourcing Policy. Expectations are communicated to all suppliers within our Supplier Code of Conduct.
•Risk Assessment Tools: Our risk assessment process relies heavily on third-party tools and information systems from the RMI. The third-party tools used for assessing the risks associated with Conflict Minerals are the CMRT, RMI Facilities Database, and RCOI data, as well as the platforms available on the RMI website, which include RBA Online, Risk Readiness Assessment, and Material Insights. These tools are used to verify details on our suppliers’ CMRTs and identify risks by analyzing the supply chain map. We have developed the CMRT Checker Tool for crosschecking all SORs across all our suppliers’ CMRTs against the RMI’s Facilities Database. This tool allows us to monitor the applicable facilities for dispositions, request updates from suppliers when needed, and assess risks in the supply chain. The EMRT is another third-party tool that is used to assess risks in the supply chain as they are related to Cobalt and Mica, allowing for the supply chain to be mapped and risks assessed in a similar capacity to the CMRT.
•Annual Survey: Our risk assessment process involves conducting an annual survey of all direct suppliers to identify any Conflict Minerals in our products that may have originated in Covered Countries. This survey is designed to disclose the SORs that processed the Conflict Minerals and the country of origin. When we receive a CMRT from a supplier, it goes through an approval process within our database management system to verify the details as both accurate and complete. If there are any concerns relating to the CMRT’s accuracy or completeness, it is sent back to the supplier requesting additional details be provided. Our database management system sends notifications to customers automatically when it is time to provide an update to the CMRT. This database management system is utilized for annual and ad hoc updates of suppliers’ CMRTs and EMRTs.
•Perform Spot Checks: Spot checks are performed as necessary at SOR facilities that are not conformant to a responsible mineral sourcing validation program by attempting to have the facility engage with RMAP and allow us to review and audit their due diligence practices, mineral trade routes, chain of custody information, and mineral country of origin information, in person, virtually, or via third party auditing firms that have been approved by the RMI. If a SOR facility does not allow us to perform a spot check in person or virtually, the issue would be escalated to our VP of Global Quality, and an executive decision would be required to send a third-party auditing firm to the facility or remove the facility from the supply chain altogether. The RMI approved third party auditing firms are listed on the RMI’s website (https://www.responsiblemineralsinitiative.org/rmap/rmap-assessment-firm-and-assessor-approval/)
Step 3: Execute a strategy to respond to identified risks
•Risk Management Plan: Our risk management plan is heavily reliant on the RMI’s RMAP to validate SOR facilities as active and conformant to the OECD Guidance. RMAP is designed as a due diligence measure that audits the procurement, smelting, and refining practices of facilities processing Conflict Minerals from the Covered Countries, or other CAHRAs, that may not be from recycled or scrap resources. The RCOI data provided by the RMI bimonthly
allows for an RCOI to be performed to identify and respond to any location-based risks.
•Risk Monitoring: We have a monitoring, measuring, and reporting process in place to monitor risks on an ongoing basis. This process is set forth in our written ethical minerals procedure that we utilize as part of our Conflict Minerals Program. Records of supplier CMRTs that have, and have not, been obtained are monitored and reported from the compliance module within both the supplier compliance dashboard and the quality management system (“QMS”) records dashboard. The supplier compliance dashboard produces and distributes a report every other week detailing this information to all internal Conflict Minerals stakeholders. The QMS records dashboard produces and distributes a monthly report to individual suppliers and supply chain stakeholders.
•Reporting Findings: In addition to the biweekly supplier compliance report that is produced, any findings are presented to the Company’s VP of Global Quality in a monthly report, containing any necessary escalations related to securing the Conflict Minerals supply chain. Escalations are processed by the VP of Global Quality to bring suppliers into conformance, otherwise they are removed from the supply chain by enforcing our Supplier Code of Conduct and Ethical Minerals Sourcing Policy.
•Report Findings to Senior Management: Status updates are provided to our VP of Global Quality and our Director, Quality Management Systems summarizing the information gathered during our annual survey for Conflict Minerals, results of the risk assessment, due diligence activities, and risk mitigation efforts.
Step 4: Carry out independent third-party audit of SORs’ due diligence practices
•Our membership to the RMI allows us to utilize RMAP. RMAP is a third-party assessment of the management systems and mineral sourcing practices of SORs for compliance with OECD Guidance and RMAP standards. RMAP is an integral part of our due diligence process.
•Our membership to RMI allows us to utilize the RCOI data, which is a product of the RMI’s RMAP audit activities. The RCOI data updates are distributed every other month for use in supply chain traceability activities.
•A member of our ethical minerals team is an active participant in the RMI’s work groups that are responsible for the ongoing improvement of the RMI’s templates, programs, and initiatives.
Step 5: Report annually on supply chain due diligence
•We are not a direct purchaser of Conflict Minerals; our supply chain partners purchase Conflict Minerals on our behalf to enable us to manufacture our products. We impose our Ethical Minerals Sourcing Policy upon our supply chain, requiring them to provide a CMRT annually and make updates, as requested. After performing due diligence on a supplier’s CMRT, the CMRT is approved by our ethical minerals team members and is rolled up into our company-level CMRT, along with the approved CMRTs from our other suppliers. If the supplier CMRT is not approved, the supplier is given the opportunity to comply with our Ethical Minerals Sourcing Policy and supplier outreach begins. If supplier outreach is not successful in bringing the supplier into compliance with our Ethical Minerals Sourcing Policy, the CMRT is escalated to the leadership of the ethical minerals team. This process allows for annual updates to our company-level CMRT. If the ethical minerals team leadership is not successful in bringing the supplier into conformance with our Supplier Code of Conduct and Ethical Minerals Sourcing Policy, the supplier is removed from the supply chain entirely.
•We prepare a Form – Specialized Disclosure Report on Conflict Minerals (“Form SD”) on an annual basis that includes the contents of our company-level CMRT, due diligence description and results, and conclusions. Our Form SD is publicly filed with the SEC and available on the SEC’s website at www.sec.gov. In addition, this Report is available on our website at https://www.allegromicro.com/en/about-allegro/corporate-responsibility/sustainability.
Supplier Outreach
Our supplier outreach efforts for the Conflict Minerals necessary for the production or manufacturing of our products for the reporting period ending December 31, 2024, are as follows:
oConducted a survey of all applicable suppliers with the CMRT to identify the SOR facilities within our supply chain that process the Conflict Minerals necessary for the production or manufacturing of our products.
oReviewed the CMRTs provided by suppliers for completeness and accuracy and communicated any concerns with suppliers to obtain additional information and details.
oOur response rate for supplier CMRTs was 100% for calendar year 2024.
oValidated SOR facilities as active and conformant to RMAP.
oMonitored, tracked, and reported on suppliers that fell out of conformance with our Ethical Minerals Sourcing Policy in biweekly and monthly compliance status reports to internal and external stakeholders.
oMitigated risks identified on supplier CMRTs by directly communicating with suppliers to engage SOR facilities to participate in RMAP and align to the OECD Guidance.
oOur ethical minerals team received quarterly consultations from a third-party consulting firm to review our Ethical Minerals Program and align with industry best practices.
Results of Due Diligence Process
The results of our due diligence efforts for the reporting period ending December 31, 2024, are as follows:
o167 SOR facilities were identified using the CMRT. Of those 167 SOR facilities, 25 were removed from the supply chain during due diligence. Of these 25 SOR facilities, 19 temporarily or permanently ceased operations and six allowed their RMAP audit cycles to lapse resulting in a nonconformant status. The remaining 142 SOR facilities are conformant for calendar year 2024.
oWe requested our suppliers to engage with the supply chain to remove any and all nonconformant SOR facilities from the supply chain or to communicate with any nonconformant SOR facilities to bring them into conformance. All six nonconformant smelters were successfully removed from the supply chain.
oWe requested our suppliers to engage with the supply chain to confirm that any and all inactive SOR facilities have been removed from the supply chain. All 19 inactive smelters were successfully confirmed to be removed from the supply chain.
oAfter engaging with our suppliers, we upheld our Supplier Code of Conduct and Ethical Minerals Sourcing Policy by removing any and all inactive facilities from the supply chain, engaging in ongoing monitoring, and working with supply chain partners to ensure conformance to RMAP is maintained.
Conclusion
For the period ended December 31, 2024, the Company has concluded, in good faith, that it contracts with others to manufacture and produce parts where Conflict Minerals are necessary for the functionality or production of our products. Based on our RCOI, we have reason to believe that some of the Conflict Minerals used in the manufacturing of our products may have originated in Covered Countries and may not only be from recycled or scrap resources. The Company has exercised due diligence on the source and chain of custody of those Conflict Minerals in accordance with our Ethical Minerals Program and OECD Guidance.
A summary of the results of our due diligence process for the year ended December 31, 2024 is provided in the table below, and a detailed disclosure by Conflict Mineral type of each facility in our supply chain that provides Conflict Minerals, including the company name, unique company identifier, and country location is provided on the following pages.
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|
|
|
|
Year Ended December 31, 2024: |
Active and Conformant: |
Non-Conformant*: |
Inactive: |
Total: |
Tin |
39 |
4 |
17 |
60 |
Tantalum |
26 |
0 |
1 |
27 |
Tungsten |
25 |
0 |
1 |
26 |
Gold |
52 |
2 |
0 |
54 |
Total: |
142 |
6 |
19 |
167 |
*Non-conformance due to lapsed RMAP audit cycles; all non-conformant SORs removed from supply chain
Additional Information
References to websites in this Report are provided for reference and general information only, and the contents of such websites are not incorporated by reference into this Report, nor are they deemed to be “filed” with the SEC to the extent that this Report is incorporated by reference into any filing pursuant to the Exchange Act.
This Report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. All statements contained in Report that do not relate to matters of historical fact should be considered forward-looking statements. In some cases, you can identify forward-looking statements by terms such as “anticipate,” “believe,” “could,” “expect,” “should,” “plan,” “intend,” “estimate,” “target,” “mission,” “may,” “will,” “would,” “project,” “predict,” “contemplate,” “potential,” or the negative thereof and similar words and expressions. Forward-looking statements are based on management’s current expectations, beliefs, and assumptions and on information currently available to us. Such statements are subject to a number of known and unknown risks, uncertainties and assumptions, and actual results may differ materially from those expressed or implied in the forward-looking statements due to various important factors discussed under the caption “Risk Factors” in our Annual Report on Form 10-K for the year ended March 28, 2025, filed with the SEC on May 22, 2025, as any such factors may be updated or supplemented from time to time in our other filings with the SEC, which are accessible on the SEC’s website at www.sec.gov and the Investors Relations page of our website at investors.allegromicro.com. All forward-looking statements speak only as of the date of this Report and, except as required by applicable law, we do not plan to publicly update or revise any forward-looking statements contained herein, whether as a result of any new information, future events, changed circumstances or otherwise.
Tin Facilities:
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|
|
|
Company Identifier |
Conflict Mineral |
Company Name |
Country |
CID000228 |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
CID000292 |
Tin |
Alpha |
UNITED STATES OF AMERICA |
CID000402 |
Tin |
Dowa |
JAPAN |
CID000438 |
Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) |
CID000468 |
Tin |
Fenix Metals |
POLAND |
CID000538 |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
CID001070 |
Tin |
China Tin Group Co., Ltd. |
CHINA |
CID001105 |
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
CID001142 |
Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA |
CID001173 |
Tin |
Mineracao Taboca S.A. |
BRAZIL |
CID001182 |
Tin |
Minsur |
PERU |
CID001191 |
Tin |
Mitsubishi Materials Corporation |
JAPAN |
CID001231 |
Tin |
Jiangxi New Nanshan Technology Ltd. |
CHINA |
CID001314 |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
CID001337 |
Tin |
Operaciones Metalurgicas S.A. |
BOLIVIA (PLURINATIONAL STATE OF) |
CID001453 |
Tin |
PT Mitra Stania Prima |
INDONESIA |
CID001477 |
Tin |
PT Timah Tbk Kundur |
INDONESIA |
CID001482 |
Tin |
PT Timah Tbk Mentok |
INDONESIA |
CID001539 |
Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA |
CID001898 |
Tin |
Thaisarco |
THAILAND |
CID002036 |
Tin |
White Solder Metalurgia e Mineracao Ltda. |
BRAZIL |
CID002158 |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
CID002180 |
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CHINA |
CID002468 |
Tin |
Magnu’s Minerais Metais e Ligas Ltda. |
BRAZIL |
CID002503 |
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
CID002517 |
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
CID002593 |
Tin |
PT Rajehan Ariq |
INDONESIA |
CID002696 |
Tin |
PT Cipta Persada Mulia |
INDONESIA |
CID002756 |
Tin |
Super Ligas |
BRAZIL |
CID002773 |
Tin |
Aurubis Beerse |
BELGIUM |
CID002774 |
Tin |
Aurubis Berango |
SPAIN |
CID003116 |
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CHINA |
CID003190 |
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA |
CID003325 |
Tin |
Tin Technology & Refining |
UNITED STATES OF AMERICA |
CID003387 |
Tin |
Luna Smelter, Ltd. |
RWANDA |
CID003449 |
Tin |
PT Mitra Sukses Globalindo |
INDONESIA |
CID003524 |
Tin |
CRM Synergies |
SPAIN |
CID003582 |
Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
BRAZIL |
CID003868 |
Tin |
PT Putera Sarana Shakti (PT PSS) |
INDONESIA |
Tungsten Facilities:
|
|
|
|
Company Identifier |
Conflict Mineral |
Company Name |
Country |
CID000004 |
Tungsten |
A.L.M.T. Corp. |
JAPAN |
CID000105 |
Tungsten |
Kennametal Huntsville |
UNITED STATES OF AMERICA |
CID000218 |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
CID000258 |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
CID000568 |
Tungsten |
Global Tungsten & Powders LLC |
UNITED STATES OF AMERICA |
CID000825 |
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
CID000966 |
Tungsten |
Kennametal Fallon |
UNITED STATES OF AMERICA |
CID002044 |
Tungsten |
Wolfram Bergbau und Hutten AG |
AUSTRIA |
CID002082 |
Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
CID002315 |
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
CID002316 |
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
CID002317 |
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
CID002318 |
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
CID002319 |
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
CID002320 |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
CID002321 |
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
CID002494 |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
CID002513 |
Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
CHINA |
CID002541 |
Tungsten |
H.C. Starck Tungsten GmbH |
GERMANY |
CID002542 |
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
CID002543 |
Tungsten |
Masan High-Tech Materials |
VIETNAM |
CID002551 |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
CID002589 |
Tungsten |
Niagara Refining LLC |
UNITED STATES OF AMERICA |
CID002641 |
Tungsten |
China Molybdenum Tungsten Co., Ltd. |
CHINA |
CID003407 |
Tungsten |
Lianyou Metals Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
Tantalum Facilities:
|
|
|
|
Company Identifier |
Conflict Mineral |
Company Name |
Country |
CID000460 |
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
CID000616 |
Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED |
CHINA |
CID000914 |
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
CID000917 |
Tantalum |
JiuJiang Tanbre Co., Ltd. |
CHINA |
CID001163 |
Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
CID001192 |
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
|
|
|
|
CID001200 |
Tantalum |
NPM Silmet AS |
ESTONIA |
CID001277 |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
CID001522 |
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CHINA |
CID001869 |
Tantalum |
Taki Chemical Co., Ltd. |
JAPAN |
CID001891 |
Tantalum |
Telex Metals |
UNITED STATES OF AMERICA |
CID001969 |
Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
CID002492 |
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
CID002504 |
Tantalum |
D Block Metals, LLC |
UNITED STATES OF AMERICA |
CID002505 |
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
CID002506 |
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
CID002508 |
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA |
CID002539 |
Tantalum |
KEMET de Mexico |
MEXICO |
CID002544 |
Tantalum |
TANIOBIS Co., Ltd. |
THAILAND |
CID002545 |
Tantalum |
TANIOBIS GmbH |
GERMANY |
CID002548 |
Tantalum |
Materion Newton Inc. |
UNITED STATES OF AMERICA |
CID002549 |
Tantalum |
TANIOBIS Japan Co., Ltd. |
JAPAN |
CID002550 |
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
GERMANY |
CID002557 |
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES OF AMERICA |
CID002558 |
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
CID002842 |
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
Gold Facilities:
|
|
|
|
Company Identifier |
Conflict Mineral |
Company Name |
Country |
CID000019 |
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
CID000035 |
Gold |
Agosi AG |
GERMANY |
CID000058 |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
BRAZIL |
CID000077 |
Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
CID000082 |
Gold |
Asahi Pretec Corp. |
JAPAN |
CID000090 |
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
CID000113 |
Gold |
Aurubis AG |
GERMANY |
CID000157 |
Gold |
Boliden Ronnskar |
SWEDEN |
CID000176 |
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
CID000185 |
Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
CID000233 |
Gold |
Chimet S.p.A. |
ITALY |
CID000401 |
Gold |
Dowa |
JAPAN |
CID000425 |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
JAPAN |
CID000694 |
Gold |
Heimerle + Meule GmbH |
GERMANY |
CID000707 |
Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
CID000711 |
Gold |
Heraeus Germany GmbH Co. KG |
GERMANY |
CID000807 |
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
CID000814 |
Gold |
Istanbul Gold Refinery |
TURKEY |
CID000920 |
Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA |
CID000924 |
Gold |
Asahi Refining Canada Ltd. |
CANADA |
|
|
|
|
Company Identifier |
Conflict Mineral |
Company Name |
Country |
CID000937 |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
CID000981 |
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
CID001078 |
Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
CID001113 |
Gold |
Materion |
UNITED STATES OF AMERICA |
CID001119 |
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
CID001147 |
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
CID001149 |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
CID001152 |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
CID001153 |
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
CID001157 |
Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA |
CID001161 |
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
MEXICO |
CID001188 |
Gold |
Mitsubishi Materials Corporation |
JAPAN |
CID001193 |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
CID001259 |
Gold |
Nihon Material Co., Ltd. |
JAPAN |
CID001325 |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
CID001352 |
Gold |
PAMP S.A. |
SWITZERLAND |
CID001512 |
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
CID001534 |
Gold |
Royal Canadian Mint |
CANADA |
CID001585 |
Gold |
SEMPSA Joyeria Plateria S.A. |
SPAIN |
CID001622 |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
CID001761 |
Gold |
Solar Applied Materials Technology Corp. |
TAIWAN, PROVINCE OF CHINA |
CID001798 |
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
CID001875 |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
CID001916 |
Gold |
Shangdong Gold (Laizhou) |
CHINA |
CID001938 |
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
CID001980 |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
CID001993 |
Gold |
United Precious Metal Refining, Inc. |
UNITED STATES OF AMERICA |
CID002030 |
Gold |
Western Australian Mint (T/a The Perth Mint) |
AUSTRALIA |
CID002224 |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
CID002290 |
Gold |
SAFINA A.S. |
CZECHIA |
CID002778 |
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
CID002779 |
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
Facilities Removed During Due Diligence:
|
|
|
|
Company Identifier |
Conflict Mineral |
Company Name |
Country |
CID000211 |
Tantalum |
Changsha South Tantalum Niobium Co., Ltd |
CHINA |
CID000309 |
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
CID000313 |
Tin |
PT Premium Tin Indonesia |
INDONESIA |
|
|
|
|
CID000766 |
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
CID000969 |
Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA |
CID001399 |
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
CID001402 |
Tin |
PT Babel Inti Perkasa |
INDONESIA |
CID001406 |
Tin |
PT Babel Surya Alam Lestari |
INDONESIA |
CID001428 |
Tin |
PT Bukit Timah |
INDONESIA |
CID001458 |
Tin |
PT Prima Timah Utama |
INDONESIA |
CID001460 |
Tin |
PT Refined Bangka Tin |
INDONESIA |
CID001463 |
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
CID001468 |
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
CID001486 |
Tin |
PT Timah Nusantara |
INDONESIA |
CID001490 |
Tin |
PT Tinindo Inter Nusa |
INDONESIA |
CID001493 |
Tin |
PT Tommy Utama |
INDONESIA |
CID002455 |
Tin |
CV Venus Inti Perkasa |
INDONESIA |
CID002570 |
Tin |
CV Ayi Jaya |
INDONESIA |
CID002762 |
Gold |
L’Orfebre S.A. |
ANDORRA |
CID002816 |
Tin |
PT Sukses Inti Makmur (SIM) |
INDONESIA |
CID002835 |
Tin |
PT Menara Cipta Mulia |
INDONESIA |
CID003205 |
Tin |
PT Bangka Serumpun |
INDONESIA |
CID003381 |
Tin |
PT Rajawali Rimba Perkasa |
INDONESIA |
CID003831 |
Tin |
DS Myanmar |
MYANMAR |
CID004065 |
Tin |
Mining Minerals Resources SARL |
CONGO, DEMOCRATIC REPUBLIC OF THE |