Specialized Disclosure Report Relating to the Use of Conflict Minerals — Rule 13p-1 Filing Table of Contents
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1: SD Specialized Disclosure Report Relating to the Use HTML 17K
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2: EX-1.01 Conflict Minerals Report HTML 177K
This Conflict Minerals Report (the “Report”) of Omnicell, Inc. (“Omnicell” or the “Company”) has been prepared pursuant
to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period from January 1, 2019 to December 31, 2019 (the “Reporting Period”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which the Company collectively refers to in this Report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their
derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries,” for the purposes of the Rule and this Report, are the Democratic Republic of the Congo (“DRC”) and each adjoining country. Certain other terms in this Report are defined in SEC Release No. 34-67716 issued by the Securities and Exchange Commission (“SEC”) on August 22, 2012, and the reader is referred to those sources for such definitions.
Company and Product Overview
Omnicell is headquartered in the United States with a small number of operations offices located globally. The Company is a provider of medication management automation solutions and adherence tools for healthcare
systems and pharmacies. The Company’s product offerings help enable healthcare providers to improve patient safety, increase efficiency, lower costs, tighten regulatory compliance and address population health challenges.
This Report relates to products: (i) for which Conflict Minerals are necessary to their functionality or production; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2019. These products, which are referred to in this Report collectively as the “Covered Products,” are the following: secure dispensing systems; storage, retrieval and packaging systems; supply management systems; pharmacy sealers; sterile
compounding solutions; semi-automated filling equipment and pharmacy-automated systems for medication packaging.
As a “downstream” purchaser of products or components that contain Conflict Minerals, the Company is at the end of a very long supply chain where it manufactures or contracts to manufacture products and does not directly source Conflict Minerals from mines, smelters or refiners nor specifically design Conflict Minerals into its products.
1
Reasonable Country-of-Origin Inquiry
The
Company identified the following categories of suppliers that it reasonably believed represent the highest risk of providing products or components potentially containing Conflict Minerals: original equipment manufacturers, contract manufacturers, and electromechanical and metals suppliers (including off-the-shelf suppliers). Based on these criteria, the Company reviewed its list of suppliers for Covered Products the manufacture of which was completed in 2019 and determined that 33 suppliers fell within scope. For those 33 suppliers, the Company conducted a good faith, reasonable country-of-origin inquiry (“RCOI”) regarding the Conflict Minerals that were necessary to the functionality or production
of the Covered Products (the “necessary Conflict Minerals”). The RCOI was reasonably designed to determine whether any of the necessary Conflict Minerals originated in the Covered Countries and whether any of the necessary Conflict Minerals may have been from recycled or scrap sources. To that end, these suppliers were contacted and asked to complete the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). With the assistance of its third-party consultant, the Company reviewed and analyzed the quality of the responses and assessed the risk level of these suppliers. Of the 33 suppliers contacted, 97% responded to the request, with 91% (or 30 suppliers) providing CMRTs and 6% (or two suppliers) providing a company policy or declaration in lieu of a completed CMRT. One supplier returned a CMRT without completing any
supplier-specific information, which the Company is not including as a “responsive” supplier.
Design of Due Diligence
The Company’s due diligence measures have been designed to conform, in all material respects, to the internationally recognized due diligence framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), consistent with the
Company’s position in the minerals supply chain as a downstream purchaser. The scope of the Company’s due diligence remained on Conflict Minerals - namely tin, tantalum, tungsten and gold.
Description of Due Diligence Measures
The Company’s due diligence measures performed with respect to Covered Products for the Reporting Period included the following:
1.OECD Step 1 – Establish Strong Company Management Systems
•Conflict Minerals team. A cross-functional team comprised of individuals from the Company's supplier quality department across various sites and the legal department is responsible for implementing various aspects of its Conflict Minerals program and reporting to the executive team as needed to provide updates regarding the
Company’s Conflict Minerals program.
2
•System of controls and transparency. The Company maintains a Conflict Minerals Due Diligence Handbook integrated within its quality management systems as a standard operating procedure, as well as an electronic database for collecting and retaining supplier responses and other information necessary to support its Conflict Minerals inquiry and reporting.
•Strengthen engagement with suppliers. In addition to the initial outreach to in-scope suppliers directing suppliers to the
Company’s Conflict Minerals policy and requesting that they complete the CMRT, the Company communicates its risk analysis review findings to selected suppliers the Company considers to have an ineffective conflict minerals program based on a review of completed CMRTs, and follows up with these suppliers regarding incomplete or inconsistent responses (through quarterly business reviews or other means). As the Company has entered into new contracts, or as contracts renew, the
Company has also included Conflict Minerals-related provisions in its contracts with direct suppliers regarding responsible sourcing and related reporting requirements.
•Grievance mechanism. The Company’s publicly available Conflict Minerals policy directs suppliers and other stakeholders to report any questions or concerns about the policy by emailing the Company at conflictminerals@omnicell.com.
2.OECD Step 2
– Identify and Assess Risk in the Supply Chain
To identify risk in its supply chain, the Company relied on its suppliers to provide information on the presence, use, source and chain of custody of the Conflict Minerals contained in supplier products or components included in the Covered Products by requesting that in-scope suppliers complete the CMRT. With the assistance of its third-party consultant, the Company reviewed suppliers’ completed CMRTs. The Company continues to follow up (through quarterly business reviews or other means) with selected suppliers it considers to have an ineffective conflict minerals program based primarily on
a review of plausibility, consistency and gaps in information provided in their completed CMRTs, as well as sourcing practices and policies, in addition to the three suppliers that did not provide completed CMRTs. The Company’s consultant compared the names of smelters and refiners listed by suppliers in completed CMRTs against lists published by the RMI and the U.S. Department of Commerce to verify that the identified facilities are known metal processors. The Company’s consultant also compared the identified smelters and facilities against lists published by the Responsible Minerals Assurance Process (“RMAP”), developed by the RMI, of smelters and refiners that have been certified as conflict-free (i.e., conformant with RMAP assessment protocols) or that are “active” in the RMAP process
(i.e., they have agreed to participate in the RMAP but the audit process has not yet been completed).
3.OECD Step 3 – Design and Implement a Strategy to Respond to Risk
The Company has developed a strategy for addressing supply chain risks identified in the course of its due diligence, including where suppliers do not cooperate or ultimately, notwithstanding encouragement from the Company, do not source from smelters or refiners that have been certified as conflict-free by the RMAP. This risk-mitigation strategy includes, with respect to suppliers the Company
considers to have an ineffective conflict minerals program based on a review of completed CMRTs, cautioning the supplier, providing additional education and other corrective actions, giving the supplier an opportunity to address the risks, monitoring and tracking performance (through the incorporation of Conflict Minerals requirements into the Company’s contracts with direct suppliers as well as its quarterly business review and scoring process with in-scope suppliers) and escalating issues to management as appropriate. If such a supplier is unable to source from smelters or refiners that have been
3
certified as conflict-free,
the Company will need to review the risk on a case-by-case basis and determine proper strategies, such as alternate sourcing, if reasonably available.
4.OECD Step 4 – Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
As a downstream purchaser, the Company relies on the RMAP to perform independent third-party audits of the smelters and refiners within its supply chain. The Company encourages its suppliers to implement responsible sourcing, in particular, to use Conflict Minerals only from smelters or refiners that
have been certified as conflict-free through the RMAP.
5.OECD Step 5 – Report on Supply Chain Due Diligence
The
due diligence measures described above revealed the following:
•As discussed above, of the 33 in-scope suppliers reviewed for the Reporting Period, 97% responded to the request to complete a CMRT, with 30 suppliers providing CMRTs with detailed information, and two suppliers providing a company policy or declaration in lieu of a completed CMRT. One supplier returned a CMRT without completing any supplier-specific information, which the Company is not including as a "responsive" supplier.
•The Company believes this response rate of in-scope suppliers indicates that its Conflict Minerals program generally continues to be more widely accepted
among its suppliers and manufacturers than in the initial years of the program.
•Of the 30 suppliers that provided a CMRT, 18 suppliers reported having Conflict Minerals in their products. Of these 18 suppliers, 12 suppliers were considered to have an ineffective conflict minerals program based primarily on a review of plausibility, consistency and gaps in information provided in their completed CMRTs, as well as sourcing practices and policies. The Company followed up with certain of these suppliers, in addition to the three suppliers that did not provide completed CMRTs, through quarterly business reviews or other means.
During the Reporting Period, the Company re-examined
its policy regarding the timing of future supplier training and on-site assessments performed by its third-party consultant. As a result, the Company did not provide training or conduct any on-site assessments of suppliers through its third-party consultant as planned during the Reporting Period, but anticipates doing so commencing as early as 2021.
Identified Smelters and Refiners
The Company has listed on Appendix 1 the smelters and refiners identified by its suppliers in completed CMRTs as a result of the Company’s RCOI and due diligence. Out of the 17 suppliers that
provided CMRT smelter lists, six provided the smelters at the product or similar level (i.e., they provided information for the particular types
4
of products and components they supplied to the Company) and 11 provided smelters at the company level (i.e., they provided information regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components used in the Covered Products). As a result, some of the smelters and refiners reported to the
Company and identified on Appendix 1 may not actually have been used to process the necessary Conflict Minerals in the Covered Products.
Identified Countries of Origin
The Company does not have sufficient information to reliably determine the countries of origin of all of the necessary Conflict Minerals in the Covered Products given that certain suppliers provided inconsistent or incomplete responses or provided information at the company level. However, based on information provided by the Company’s in-scope suppliers in completed CMRTs, the
Company believes that the countries of origin may include the countries listed on Appendix 2. As discussed above, because some suppliers provided information at the company level, there may be countries of origin identified on Appendix 2 that are not the countries of origin of the necessary Conflict Minerals actually included in the Covered Products.
Efforts to Determine Mine or Location of Origin
The Company’s efforts to determine the mines or locations of origin included the use of the due diligence measures described above.
Future Due Diligence and Risk Mitigation Measures
As
the Company further develops its Conflict Minerals program, the Company intends to take the following steps to further enhance its due diligence measures and to mitigate the risk that, with respect to any of the Covered Products, necessary Conflict Minerals were used, directly or indirectly, to finance or benefit armed groups in the Covered Countries:
•Continue to communicate risk analysis review findings to certain suppliers the Company considers to have an ineffective conflict minerals program based on a review of completed CMRTs, through quarterly business reviews and
other means, in order to improve the accuracy and completeness of and mitigate issues with suppliers’ CMRT responses;
•Continue to encourage its suppliers to implement responsible sourcing by using Conflict Minerals only from smelters or refiners that have been certified as conflict-free through the RMAP;
•Continue to utilize a third-party consultant to review completed CMRTs from suppliers and prepare the related risk assessment; and
•Provide training in future years to certain suppliers the Company considers to have an ineffective conflict minerals program based on a review of completed CMRTs during prior years, and select several of these suppliers to undergo an on-site assessment, to be
performed by the Company’s third-party consultant, of the CMRT information provided by these suppliers. The objective of the assessment would be to improve comprehension and performance for the following reporting period. The Company anticipates providing such training and conducting such assessments commencing as early as 2021.
5
Inherent Limitations on Due Diligence Measures
The Company’s supply chain with respect to the Covered Products
is complex, and its procurement and manufacturing process is significantly removed from the sourcing, mining, smelting and refining of Conflict Minerals. As a result, the Company does not have direct contractual relationships with smelters, refiners or mines, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and, therefore, has taken steps to identify the applicable smelters and refiners of necessary Conflict Minerals in the Company’s supply chain using the CMRT. However,
tracing these minerals to their sources is a challenge that requires the Company to rely on its direct suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the necessary Conflict Minerals. The information provided by suppliers or third-party consultants or auditors may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited.
Cautionary Note on Forward-Looking Statements
Forward-looking
statements in this Report are made pursuant to the safe harbor provisions of Section 21E of the Exchange Act, and other federal securities laws. Investors are cautioned that statements in this Report that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, future supplier audits and assessments and the timing thereof, future due diligence and risk mitigation efforts, strategy and future reporting, constitute forward-looking statements that involve risks and uncertainties. Words such as “expects,””anticipates,”“targets,”“goals,”“projects,””intends,”“plans,”“believes,”“seeks,”“estimates,”“evaluates,” variations of these words, and similar expressions are intended
to identify such forward-looking statements. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, the impact on the Company and its suppliers
of public health crises such as the ongoing global coronavirus (COVID-19) pandemic, as well as the possibility of future regulatory changes.
The Company has provided information as of the date of this Report, and undertakes no obligation to revise or update any forward-looking statements for any reason. Subsequent events, such as the inability or unwillingness of any of our suppliers, smelters or refiners to comply with Omnicell’s Conflict Minerals policy, may affect its future disclosures and determinations under the Rule. In addition, the Company’s due diligence and reporting obligations under the Rule may change in the future and its ability to implement certain processes or obtain information from its suppliers may differ materially
from those anticipated or implied in this Report.
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Appendix 1
Identified Smelters and Refiners
Based on the information that was provided by the Company’s suppliers in completed CMRTs, the Company believes that, to the extent reasonably determinable by the Company, the facilities that may have been used to process the necessary Conflict Minerals contained in the Covered
Products included the smelters and refiners identified below. However, as noted above, where the Company’s suppliers provided information on a division- or company-wide basis regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components supplied to the Company for use in the Covered Products, the smelters and refiners reported to the Company by those suppliers may not actually have been used to process the necessary Conflict Minerals in the Covered Products.
Mineral
Smelter
or refiner ID
Smelter or refiner name
RMAP-conformant*
Location of smelter or refiner
Gold
CID002763
8853 S.p.A.
Yes
ITALY
Tungsten
CID000004
A.L.M.T. Corp.
Yes
JAPAN
Gold
CID002708
Abington
Reldan Metals, LLC
No
UNITED STATES
Gold
CID001754
Accurate Refining Group
No
UNITED STATES
Tungsten
CID002833
ACL Metais Eireli
Yes
BRAZIL
Gold
CID000015
Advanced Chemical Company
Yes
UNITED
STATES
Gold
CID003185
African Gold Refinery
No
UGANDA
Gold
CID000019
Aida Chemical Industries Co., Ltd.
Yes
JAPAN
Gold
CID000028
Aktyubinsk Copper Company TOO
No
KAZAKHSTAN
Gold
CID002560
Al
Etihad Gold Refinery DMCC
Yes
UNITED ARAB EMIRATES
Gold
CID000035
Allgemeine Gold-und Silberscheideanstalt A.G.
Yes
GERMANY
Gold
CID000041
Almalyk Mining and Metallurgical Complex (AMMC)
Yes
UZBEKISTAN
Tin
CID000292
Alpha
Yes
UNITED
STATES
Tin
CID002825
An Thai Minerals Co., Ltd.
No
VIETNAM
Tin
CID002703
An Vinh Joint Stock Mineral Processing Company
No
VIETNAM
Gold
CID000058
AngloGold Ashanti Corrego do Sitio Mineracao
Yes
BRAZIL
Gold
CID000077
Argor-Heraeus
S.A.
Yes
SWITZERLAND
Gold
CID000082
Asahi Pretec Corp.
Yes
JAPAN
Gold
CID000924
Asahi Refining Canada Ltd.
Yes
CANADA
Gold
CID000920
Asahi Refining USA Inc.
Yes
UNITED
STATES
Gold
CID000090
Asaka Riken Co., Ltd.
Yes
JAPAN
Tantalum
CID000092
Asaka Riken Co., Ltd.
Yes
JAPAN
Tungsten
CID002502
Asia Tungsten Products Vietnam Ltd.
Yes
VIETNAM
Gold
CID000103
Atasay
Kuyumculuk Sanayi Ve Ticaret A.S.
No
TURKEY
Gold
CID002850
AU Traders and Refiners
Yes
SOUTH AFRICA
Gold
CID002851
AURA-II
No
UNITED STATES
Gold
CID000113
Aurubis AG
Yes
GERMANY
Gold
CID002863
Bangalore
Refinery
Yes
INDIA
7
Mineral
Smelter or refiner ID
Smelter or refiner name
RMAP-conformant*
Location of smelter or refiner
Gold
CID000128
Bangko
Sentral ng Pilipinas (Central Bank of the Philippines)
Yes
PHILIPPINES
Gold
CID000141
Bauer Walser AG
No
GERMANY
Gold
CID000157
Boliden AB
Yes
SWEDEN
Gold
CID000176
C. Hafner
GmbH + Co. KG
Yes
GERMANY
Gold
CID000180
Caridad
No
MEXICO
Gold
CID000185
CCR Refinery - Glencore Canada Corporation
Yes
CANADA
Gold
CID000189
Cendres + Metaux S.A.
Yes
SWITZERLAND
Gold
CID003382
CGR
Metalloys Pvt Ltd.
No
INDIA
Tantalum
CID000211
Changsha South Tantalum Niobium Co., Ltd.
Yes
CHINA
Tungsten
CID002513
Chenzhou Diamond Tungsten Products Co., Ltd.
Yes
CHINA
Tin
CID000228
Chenzhou
Yunxiang Mining and Metallurgy Co., Ltd.
Yes
CHINA
Tin
CID003190
Chifeng Dajingzi Tin Industry Co., Ltd.
Yes
CHINA
Gold
CID000233
Chimet S.p.A.
Yes
ITALY
Tungsten
4CHN003
China
Minmetals Corp.
No (Unknown)
CHINA
Tin
CID001070
China Tin Group Co., Ltd.
Yes
CHINA
Tungsten
CID000258
Chongyi Zhangyuan Tungsten Co., Ltd.
Yes
CHINA
Gold
CID000264
Chugai Mining
Yes
JAPAN
Tin
CID000278
CNMC
(Guangxi) PGMA Co., Ltd.
No
CHINA
Tungsten
CID000281
CNMC (Guangxi) PGMA Co., Ltd.
No
CHINA
Gold
1CHL014
Codelco
No (Unknown)
CHILE
Tin
CID000295
Cooperativa Metalurgica de Rondônia
Ltda.
No
BRAZIL
Tantalum
CID000004
CP Metals Inc.
Yes
UNITED STATES
Tin
CID002570
CV Ayi Jaya
Yes
INDONESIA
Tin
CID002592
CV Dua Sekawan
Yes
INDONESIA
Tin
2IDN003
CV
Duta Putra Bangka
No
INDONESIA
Tin
CID000306
CV Gita Pesona
Yes
INDONESIA
Tin
CID000307
CV JusTindo
No
INDONESIA
Tin
2IDN005
CV Makmur Jaya
No
INDONESIA
Tin
CID000315
CV
United Smelting
Yes
INDONESIA
Tin
CID002455
CV Venus Inti Perkasa
Yes
INDONESIA
Tantalum
CID002504
D Block Metals, LLC
Yes
UNITED STATES
Gold
CID000328
Daejin Indus Co., Ltd.
No
KOREA,
REPUBLIC OF
Gold
1KOR083
DaeryongENC
No (Unknown)
KOREA, REPUBLIC OF
Gold
CID000343
Daye Non-Ferrous Metals Mining Ltd.
No
CHINA
Tungsten
CID002518
Dayu Jincheng Tungsten Industry Co., Ltd.
No
CHINA
Tungsten
CID000345
Dayu
Weiliang Tungsten Co., Ltd.
No
CHINA
Gold
CID002867
Degussa Sonne / Mond Goldhandel GmbH
No
GERMANY
Gold
CID003348
Dijllah Gold Refinery FZC
No
UNITED ARAB EMIRATES
Gold
CID000362
DODUCO
Contacts and Refining GmbH
Yes
GERMANY
Tin
CID003356
Dongguan CiEXPO Environmental
No
CHINA
8
Mineral
Smelter
or refiner ID
Smelter or refiner name
RMAP-conformant*
Location of smelter or refiner
Tantalum
CID000410
Douluoshan Sapphire Rare Metal Co Ltd
No
CHINA
Gold
CID000401
Dowa
Yes
JAPAN
Tin
CID000402
Dowa
Yes
JAPAN
Gold
CID003195
DS
PRETECH Co., Ltd.
Yes
KOREA, REPUBLIC OF
Gold
CID000359
DSC (Do Sung Corporation)
Yes
KOREA, REPUBLIC OF
Tantalum
CID002590
E.S.R. Electronics
No
UNITED STATES
Gold
CID000425
Eco-System
Recycling Co., Ltd.
Yes
JAPAN
Tin
CID002572
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
SOE Shyolkovsky Factory of Secondary Precious Metals
Yes
RUSSIAN FEDERATION
Tin
CID001758
Soft
Metais Ltda.
Yes
BRAZIL
Gold
CID001761
Solar Applied Materials Technology Corp.
Yes
TAIWAN
Tantalum
CID001769
Solikamsk Magnesium Works OAO
Yes
RUSSIAN FEDERATION
Tungsten
CID002815
South-East
Nonferrous Metal Company Limited of Hengyang City
No
CHINA
Gold
CID003383
Sovereign Metals
No
INDIA
Gold
CID003153
State Research Institute Center for Physical Sciences and Technology
No
LITHUANIA
Gold
CID002567
Sudan
Gold Refinery
No
SUDAN
Gold
CID001798
Sumitomo Metal Mining Co., Ltd.
Yes
JAPAN
Gold
CID002918
SungEel HiMetal Co., Ltd.
Yes
KOREA, REPUBLIC OF
Gold
CID001810
Super Dragon Technology
Co., Ltd.
No
TAIWAN
Tin
CID002756
Super Ligas
No
BRAZIL
Gold
CID002580
T.C.A S.p.A
Yes
ITALY
Tantalum
CID001869
Taki Chemical Co., Ltd.
Yes
JAPAN
Gold
CID001875
Tanaka
Kikinzoku Kogyo K.K.
Yes
JAPAN
Tungsten
CID001889
Tejing (Vietnam) Tungsten Co., Ltd.
Yes
VIETNAM
Tantalum
CID001891
Telex Metals
Yes
UNITED STATES
Tin
CID002834
Thai Nguyen
Mining and Metallurgy Co., Ltd.
Yes
VIETNAM
Tin
CID001898
Thaisarco
Yes
THAILAND
15
Mineral
Smelter
or refiner ID
Smelter or refiner name
RMAP-conformant*
Location of smelter or refiner
Gold
CID001916
The Refinery of Shandong Gold Mining Co., Ltd.
Yes
CHINA
Tin
CID003325
Tin Technology & Refining
Yes
UNITED STATES
Gold
CID001938
Tokuriki
Honten Co., Ltd.
Yes
JAPAN
Gold
CID001947
Tongling Nonferrous Metals Group Co., Ltd.
No
CHINA
Gold
CID002587
Tony Goetz NV
No
BELGIUM
Gold
CID002615
TOO Tau-Ken-Altyn
Yes
KAZAKHSTAN
Gold
CID001955
Torecom
Yes
KOREA,
REPUBLIC OF
Tantalum
CID002571
Tranzact, Inc.
No
UNITED STATES
Tin
CID002574
Tuyen Quang Non-Ferrous Metals Joint Stock Company
No
VIETNAM
Tantalum
CID001969
Ulba Metallurgical Plant JSC
Yes
KAZAKHSTAN
Gold
CID001977
Umicore
Brasil Ltda.
Yes
BRAZIL
Gold
CID002314
Umicore Precious Metals Thailand
Yes
THAILAND
Gold
CID001980
Umicore S.A. Business Unit Precious Metals Refining
Yes
BELGIUM
Tungsten
CID002724
Unecha
Refractory metals plant
Yes
RUSSIAN FEDERATION
Gold
CID001993
United Precious Metal Refining, Inc.
Yes
UNITED STATES
Gold
CID002854
Universal Precious Metals Refining Zambia
No
ZAMBIA
Gold
CID002003
Valcambi
S.A.
Yes
SWITZERLAND
Tungsten
CID002011
Vietnam Youngsun Tungsten Industry Co., Ltd.
No
VIETNAM
Tin
CID002015
VQB Mineral and Trading Group JSC
No
VIETNAM
Gold
CID002030
Western Australian
Mint (T/a The Perth Mint)
Yes
AUSTRALIA
Tin
CID002036
White Solder Metalurgia e Mineracao Ltda.
Yes
BRAZIL
Gold
CID002778
WIELAND Edelmetalle GmbH
Yes
GERMANY
Tungsten
CID002044
Wolfram
Bergbau und Hutten AG
Yes
AUSTRIA
Tungsten
4RUS013
Wolfram Company CJSC
No
RUSSIAN FEDERATION
Tungsten
CID002843
Woltech Korea Co., Ltd.
Yes
KOREA, REPUBLIC OF
Tungsten
CID002320
Xiamen
Tungsten (H.C.) Co., Ltd.
Yes
CHINA
Tungsten
CID002082
Xiamen Tungsten Co., Ltd.
Yes
CHINA
Tungsten
CID002830
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Yes
CHINA
Tungsten
CID002095
Xinhai
Rendan Shaoguan Tungsten Co., Ltd.
Yes
CHINA
Tantalum
CID002508
XinXing HaoRong Electronic Material Co., Ltd.
Yes
CHINA
Gold
CID002100
Yamakin Co., Ltd.
Yes
JAPAN
Tantalum
CID001522
Yanling
Jincheng Tantalum & Niobium Co., Ltd.
Yes
CHINA
Tantalum
CID002307
Yichun Jin Yang Rare Metal Co., Ltd.
No
CHINA
Gold
CID002129
Yokohama Metal Co., Ltd.
Yes
JAPAN
Tin
CID002158
Yunnan
Chengfeng Non-ferrous Metals Co., Ltd.
Yes
CHINA
Gold
CID000197
Yunnan Copper Industry Co., Ltd.
No
CHINA
Tin
CID002180
Yunnan Tin Company Limited
Yes
CHINA
16
Mineral
Smelter
or refiner ID
Smelter or refiner name
RMAP-conformant*
Location of smelter or refiner
Tin
CID003397
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
Yes
CHINA
Gold
CID002214
Zhongkuang Gold Industry Co., Ltd.
No
CHINA
Gold
CID002224
Zhongyuan
Gold Smelter of Zhongjin Gold Corporation
Yes
CHINA
Tantalum
CID002232
Zhuzhou Cemented Carbide Group Co., Ltd.
No
CHINA
*“Yes” means the smelter or refiner is conformant with RMAP assessment protocols as reported by the RMI. “Active” means the smelter or refiner is active in the RMAP process (i.e., it has agreed to participate in the RMAP but the audit process has not yet been completed). “No”
means the smelter or refiner is a known metal processor based on information available from the RMI or the Department of Commerce but has not been certified as conflict-free through the RMAP and is not active in the RMAP process. “No (Unknown)” means the Company was unable to verify such facility as a known metal processor based on information available from the RMI or the U.S. Department of Commerce.
17
Appendix 2
Identified Countries of Origin
Angola
Luxembourg
Argentina
Madagascar
Armenia
Malaysia
Australia
Mali
Austria
Mexico
Belarus
Mongolia
Belgium
Morocco
Bermuda
Mozambique
Bolivia
Myanmar
Brazil
Namibia
Burundi
Netherlands
Cambodia
New
Zealand
Canada
Niger
Central African Republic
Nigeria
Chile
Papua New Guinea
China
Peru
Colombia
Philippines
Czech Republic
Poland
Democratic Republic of the Congo
Portugal
Djibouti
Republic
of the Congo
Ecuador
Russian Federation
Egypt
Rwanda
Estonia
Saudi Arabia
Ethiopia
Sierra Leone
Finland
Singapore
France
Slovakia
Germany
South Africa
Ghana
South
Sudan
Guinea
Spain
Guyana
Suriname
Hong Kong
Sweden
Hungary
Switzerland
India
Taiwan
Indonesia
Tajikistan
Ireland
Tanzania
Israel
Thailand
Italy
Turkey
Ivory
Coast
Uganda
Japan
United Arab Emirates
Jersey
United Kingdom
Kazakhstan
United States
Kenya
Uzbekistan
Korea, Republic of
Vietnam
Kyrgyzstan
Zambia
Laos
Zimbabwe
18
Dates Referenced Herein and Documents Incorporated by Reference
