UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Microsoft Corporation
(Exact Name of Registrant as Specified in Its Charter)
Washington
(State or Other Jurisdiction
of Incorporation)
001-37845 | 91-1144442 | |
(Commission File Number) |
(IRS Employer Identification No.) |
One Microsoft Way, Redmond, Washington | 98052-6399 | |
(Address of Principal Executive Offices) | (Zip Code) |
(425) 882-8080
(Registrants Telephone Number, Including Area Code)
(Former Name or Former Address, if Changed Since Last Report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the period from January 1 to December 31, 2018. |
Section 1 - Conflict Minerals Disclosure
Items 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Microsofts Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at: http://download.microsoft.com/download/B/1/A/B1A33754-D15B-4A0D-8463-A9253C03CF07/Microsoft_Conflict_Minerals_Report_2019.pdf
Item 1.02 Exhibits
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this form SD.
Section 2 - Exhibits
Item 2.01 - Exhibits
Exhibit 1.01 - Conflict Minerals Report
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
MICROSOFT CORPORATION | ||
(Registrant) | ||
Date: May 31, 2019 |
/s/ BRADFORD L. SMITH | |
Bradford L. Smith | ||
President and Chief Legal Officer |
Exhibit 1.01
MICROSOFT CORPORATION
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2018
I. | INTRODUCTION |
This Conflict Minerals Report (CMR) for MICROSOFT CORPORATION (Microsoft) is filed as an exhibit to Microsofts Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule) for the 2018 reporting year. The report covers all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule. The Rule imposes certain due diligence and reporting obligations on US Securities and Exchange Commission (SEC) registrants whose manufactured products (including products contracted to be made for each registrant) contain conflict minerals necessary to the functionality or production of those products. The Rule defines conflict minerals to include cassiterite, columbite-tantalite, gold, wolframite and their derivatives limited to tin, tantalum, tungsten, and gold (collectively referred to as 3TGs).
Microsoft develops, licenses, and supports a wide range of software products, services and hardware devices that deliver new opportunities, greater convenience, and enhanced value to peoples lives. Microsoft is committed to the responsible sourcing of raw materials globally in support of human rights, labor, health and safety, environmental protection, and business ethics. Our commitment and strategy are outlined in Microsofts Responsible Sourcing of Raw Materials (RSRM) policy. Under our policy, Microsoft takes a holistic approach to the responsible sourcing of raw materials while working toward the use of conflict-free minerals in our devices. We strive to avoid harming communities through an inadvertent de facto embargo of minerals from Conflict Affected and High Risk Areas (CAHRAs), including the Democratic Republic of the Congo (DRC) or DRC-adjoining countries. The Rule defines the DRC and any of its adjoining countries as a Covered Country.
The number of Responsible Minerals Assurance Process (RMAP)1 conformant smelters or refiners (SORs) in our supply chain remained consistent at 252. Since our last CMR filing, we have taken the following actions to improve our raw material due diligence:
| Leveraged the results from the full integration of the RSRM program into our Social and Environmental Accountability (SEA) audit process to drive improvements in our supply chain for raw material sourcing; |
| Visited a tin smelter in China to understand the Responsible Minerals Initiative (RMI) smelter preaudit and to help us have a clearer picture of upstream and downstream suppliers; |
| Strengthened external partnerships to increase on-the-ground risk mitigation and enhance Microsofts due diligence capabilities; and |
| Strengthened internal partnerships to identify raw material risk at an early product development stage. |
1 | Please note: this CMR contains references and hyper-text links to non-Microsoft, external websites. These links are provided for informational purposes only. Their inclusion in this CMR does not establish Microsofts endorsement of or assumption of liability for content posted on these external websites. |
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Microsoft devices contain one or more 3TGs and are within the Rules scope. Devices manufactured during the 2018 reporting year included:
| Surface line of computers and other intelligent devices; |
| Xbox gaming/entertainment consoles and accessories; |
| HoloLens, a self-contained holographic computer; and |
| Personal computing accessories (mice, headsets, and keyboards). |
On the basis of our Reasonable Country of Origin Inquiry (RCOI) (see Section II), we determined that 3TGs contained in our devices may have originated in a Covered Country. Therefore, we are submitting this CMR, which describes the conflict minerals due diligence we performed during the 2018 reporting year, as an exhibit to our Form SD. We have published the CMR externally on our responsible sourcing website.
The manufacture of our devices during any specified time period may include raw materials sourced before, as well as during, that time period. Some 3TGs used during the 2018 reporting year may have been smelted and refined prior to the Rules initial reporting period. While such 3TGs are excluded from the Rules scope, our RCOI and supply chain due diligence conducted for the 2018 reporting year may have included such minerals.
II. | REASONABLE COUNTRY OF ORIGIN INQUIRY |
Our RCOI corresponds to the first and second steps of the five-step OECD Due Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). The OECD Guidance provides a detailed due diligence framework to support responsible global supply chain management of minerals and is currently the only internationally recognized framework for raw material due diligence. The OECD Guidance (including its Supplements) applies to each of the 3TGs and to Microsoft as a downstream company.
Microsoft does not source directly from 3TG raw material providers. We source products from suppliers, which source materials, components, and products from their sub-tier suppliers. Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG raw materials providers and processors (also known as SORs). We refer collectively in this CMR to directly contracted strategic suppliers as in-scope suppliers. Due to our extended supply chain, we leverage our in-scope suppliers to provide information on the sources and chains of custody of 3TGs necessary to the manufacture of our devices. We provide more detail on our supply chain due diligence process in Section III. The graphic below demonstrates Microsofts span of influence with its suppliers.
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A. | Establish Strong Company Management Systems |
1. | Company Policies |
The Microsoft Global Human Rights Statement and Supplier Code of Conduct define our expectations concerning ethical business, employment, environmental, and worker safety practices. Microsofts RSRM policy describes our commitment and strategy to responsibly source raw materials used in our devices. Microsoft is committed to indirectly source raw materials in support of human rights, labor, health and safety, environment, and ethics. This pledge extends to the harvesting, extraction, and transportation of raw materials globally and to all substances used in our devices unbounded by specific materials or locations. Our policy supports implementation of programs that are region-specific and work toward the use of conflict-free minerals in our devices.
We require our suppliers to conform to these policies and to include them in their contracts with their sub-tier suppliers. Our supplier specifications and internal procedures establish supplier requirements for the responsible sourcing of raw materials, including 3TGs. We audit our suppliers to ensure these requirements are met.
2. | Internal Management Team |
A cross-functional team supports Microsofts responsible sourcing and 3TG compliance activities. A General Manager of the Devices Group sponsors the team. The team consists of representatives from Strategic Sourcing; Responsible Sourcing/Social and Environmental Accountability; Manufacturing; Accounting/Finance; Internal Audit; Experiences and Devices Group; Corporate, External and Legal Affairs; Business and Corporate Responsibility; Information Services; and Product Environmental Compliance.
This team meets quarterly to assess the programs progress, identify steps necessary to meet our compliance obligations, and identify areas for continuous improvement. The team also trains other internal stakeholders on their roles and responsibilities for implementing and supporting Microsofts responsible sourcing program. Team members are responsible for developing, reviewing, filing, and publishing the CMR.
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3. | System of Supply Chain Controls and Transparency |
Our suppliers provide us information concerning the source and chain of custody of raw materials from Conflict-Affected and High-Risk Areas (CAHRAs), including 3TGs, contained in the products and components they supply to us. Many of our in-scope suppliers are also subject to the Rule. These suppliers rely on information provided by their suppliers to meet their compliance obligations. Our contracts require all Microsoft in-scope suppliers to identify every substance contained in the materials, components, and products supplied to us, including 3TGs, by weight. Our in-scope suppliers are responsible for communicating our sourcing requirements and specifications to their sub-tier suppliers, including our raw material due diligence requirements.
In addition, we require all in-scope suppliers to submit a Conflict Minerals Reporting Template (CMRT) annually and provide updated data upon request or when sourcing practices change. These CMRTs are evaluated for completeness, data integrity, due diligence thoroughness, and sourcing risk. Potential risks may include a failure to fully complete the CMRT, data inconsistencies, and possible sourcing from a CAHRA. Microsoft investigates each identified issue and engages with suppliers to address all concerns regarding conformance to Microsoft policies, procedures, and specifications. In cases where the supplier is identified as sourcing from a CAHRA, suppliers are required to submit a CMRT more frequently and further assess and mitigate risk with their sub-tier suppliers.
If we find that a supplier has introduced unmitigated risk to the Microsoft supply chain, such as using an upstream SOR that does not conform to Microsofts RSRM policy or specifications, Microsoft requires corrective action to address the non-conformance. The response time for corrective action is calibrated to the severity of the identified risk. Risks are mitigated by supplier engagement, corrective actions, training, and/or additional audits. These controls and related documentation are detailed in H02050 - Microsoft Supplier Social and Environmental Accountability Manual and Microsoft internal operating procedures.
Microsoft works with impacted suppliers to find sources for RMAP conformant minerals. If a supplier does not commit to a RMAP conformant source within a reasonable time period, Microsoft places the supplier on restricted status and no new Microsoft business is awarded until the non-conformance is resolved. Microsoft may also terminate its business relationship with the supplier.
Microsoft is a long-standing member of the Responsible Business Alliance. In 2008, the RBA initiated the Conflict Free Smelter Program, which evolved to become the Responsible Minerals Assurance Process (RMAP) in 2018. The RMAP is one of the most utilized and respected resources for addressing supply chain responsible sourcing issues. The RMAP uses independent third-party audits to assess and monitor whether SORs process 3TGs from sources that directly or indirectly finance or benefit armed groups in a Covered Country. Microsoft also financially supports the Industrial Technology Research Institutes Tin Supply Chain Initiative (iTSCi), which has established a system of traceability and due diligence in Covered Countries.
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We partner closely with Pact, the Initiative for Responsible Mining Assurance (IRMA), and Alliance for Responsible Mining (ARM). These organizations address human rights concerns in mining and leverage data and technology to bring about even greater change. Empowered by digital technology, Microsoft and our partners are working to drive transformations in the mining sector by addressing issues of increased scope and complexity. We believe this integrated approach improves conditions for the people working in raw material supply chains.
Our primary relationships are further described below:
| Pact: Since 2014, we have supported a Pact project in the DRC to reduce child labor in mining. The results in Pacts Watoto Inje Ya Mungoti (Children Out of Mining) project verify the effectiveness of Pacts approach, data, and experience. The Children Out of Mining report states: This project reached 4,100 beneficiaries, of whom 1,881 were children. Bans on child labor were enforced at 23 mine sites in the target area by the end of the project. Reduction in child labor between 77 percent and 97 percent over the course of the project to date. Yves Bawa, Pact country director for DRC, Rwanda, and Burundi notes that, Microsoft was one of our first partners on this important issue. Its seed funding helped us achieve groundbreaking progress in the first two years of work. We announced a new, expanded commitment in 2017 to continue this work as it is evident that this proven strategy can improve the livelihood of impoverished workers who labor in artisanal cobalt mines. |
| Initiative for Responsible Mining Assurance (IRMA): IRMA established a multi-stakeholder and independently verifiable responsible mining assurance system that improves social and environmental performance through the development of global mining standards for large- scale mines. Our partnership involves more than just participation we are bringing technology to help scope, scale, and implement effective programs. Microsoft donated a technology platform to IRMA that will allow the organization to better implement these assurance standards. By pairing the technology platform with Power BI, a cloud-based business analytics service, stakeholders will be able to track mining performance against the assurance standards. This real-time information, presented in an easy-to-see and easy-to-use interface, will help mining companies and Non-Governmental Organizations (NGOs) overcome the inherent difficulties of scope and complexity of responsible mining programs to create new insights and inspire additional progress. With learnings from this engagement, we hope to enable additional NGO partners to expand their work to create sustainable mining communities. |
| Alliance for Responsible Mining (ARM): ARM sets standards for responsible artisanal and small-scale mining and supports and creates opportunities for gold miners, providing them with incentives to become responsible economic, technological, and environmental enterprises. Seed funding from Microsoft helped ARM secure further resources to develop a Market Entry Standard for Artisanal and Small-scale Gold Miners. Microsoft continues to support an ASM gold mining project in Peru which has attracted additional donors, furthering ARMs efforts to develop certified gold mining sites throughout the region. |
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4. | Supplier Engagement |
Given the complexities of the global mineral supply chain, we work closely with our suppliers around the world to ensure they share and duplicate our commitment with their upstream suppliers. RMAPs Reasonable Practices to Identify Sources of Conflict Minerals: Practical Guidance for Downstream Companies states, all of the [OECD Guidances] red flag triggers are contained in the upstream portion of the supply chain (e.g., SORs and mine of origin). Because these conflict mineral supply chain triggers are directed to upstream companies, rather than downstream manufacturers such as Microsoft, we mitigate raw material sourcing risks by working with our in- scope suppliers to identify raw material SORs and encourage those facilities to become RMAP conformant or use an alternate facility that is RMAP conformant. We also participate in industry- wide initiatives that assess SOR conformance with the OECD Guidance as recommended by RMAP guidance.
We drive responsible sourcing through our extended supply chain by surveying our in-scope suppliers sourcing of raw materials in their upstream supply chains. We also use tools that include supplier and smelter capability building and support broader industry efforts to promote responsible mining and sourcing. Finally, we conduct audits of our contracted suppliers to verify conformance to Microsoft requirements. More information is set forth below.
| Supplier Requirements: We require our in-scope suppliers to meet our material disclosure requirements and related responsible sourcing policies through contractual provisions and product specifications. We communicate, monitor, and track supplier adherence to these requirements, ensuring conformance through the Microsoft Audit Management System (AMS). These policies and procedures are outlined in Section III, and the public can access them on Microsofts Responsible Sourcing Website. We also train our directly contracted suppliers to meet our requirements through classes, educational forums, and direct communications. |
| Capability Building and Partnerships: We work closely with our supply chain partners to build their raw material suppliers capabilities for achieving our responsible sourcing goals. With the empowerment of digital technology, Microsoft and our partners can drive transformations in the mining sector by addressing issues of increased scope and complexity. We invest in industry programs, such as the RMAP, to increase suppliers abilities and provide platforms to them for sharing best practices. |
| Supplier Audits: Microsoft conducts audits of its directly contracted suppliers to assess their conformance to Microsoft requirements. All new contracted in-scope suppliers undergo an Initial Capability Assessment (ICA) to verify conformance. Existing contracted in-scope suppliers also undergo a Sustaining Maintenance Audit (SMA) on an annual, biannual, or triannual basis depending on their risk level. Suppliers must establish and maintain a corporate policy and effective procedures for the responsible sourcing of raw materials. Microsoft selects and retains only those business partners committed to meeting these requirements. A failure by a supplier or sub-tier supplier to conform to these requirements may constitute a breach of the suppliers contractual agreement with Microsoft, resulting in possible business termination. |
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5. | Grievance Mechanism |
Microsofts Global Human Rights Statement expresses our commitment to provide an anonymous grievance reporting mechanism for our employees and other stakeholders who may be impacted by our operations. Microsofts Business Conduct Hotline allows employees and others to anonymously ask compliance questions or report concerns regarding Microsofts business operations, including our responsible sourcing of raw materials policy or those of our suppliers. We investigate and, where appropriate, take remedial action to address reported concerns. We also participate in industry efforts to develop grievance mechanisms to address responsible sourcing of raw materials related issues.
B. | Identify and Assess Risk in the Supply Chain |
We took the following steps to identify and assess supplier conflict mineral sourcing risk during the 2018 reporting year2:
| Following the Rule and SEC guidance, we generated a list of potential in-scope suppliers. |
| We surveyed all potential in-scope suppliers to determine the status of any 3TGs contained in devices manufactured during the 2018 reporting year by utilizing the RMAP-standard CMRT and the services of a third-party solution provider. The survey followed OECD Guidance as tailored for Microsofts role as a downstream company. Our survey included questions regarding the suppliers raw material due diligence policies and procedures, its practices for engaging with its upstream suppliers, the SORs from which its 3TGs were sourced, and the origins of 3TGs contained in the suppliers products. |
| We reviewed all supplier CMRT submissions to validate their completion and to identify contradictions or inconsistencies. We worked with our third-party solution provider to obtain updated responses from suppliers when necessary. |
| We identified 174 active in-scope suppliers for the 2018 reporting year. Of these suppliers, we received survey responses from 171 of those suppliers - a 98 percent response rate. |
2 | Microsoft completed its supplier conflict mineral sourcing data analysis for the 2018 reporting year on April 12, 2019. |
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Figure 1. Response Rate for Active In-scope Suppliers (2013-2018 Reporting Years)
Response Rate for Surveyed Active In-scope Suppliers
III. | DUE DILIGENCE DESIGN AND PERFORMANCE |
On the basis of our RCOI, we determined that 3TGs contained in our devices may have originated in one or more Covered Country. Accordingly, we designed and performed due diligence on the source and chain-of-custody of those 3TGs.
A. | Due Diligence Design |
Our 3TGs due diligence process conformed to the third and fourth steps of the five-step OECD Guidance. The first and second steps of the five-step OECD Guidance were addressed in Section II.
B. | Due Diligence Performed |
1. | Design and Implement a Strategy to Respond to Risks |
Microsoft required its suppliers to minimize the possible sourcing of 3TGs from CAHRAs through contract requirements incorporating Microsofts supplier specifications.
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a. | Microsoft Supplier Specifications - H00594, H00642 and H02050 |
Microsoft required identification of all materials, including 3TGs, used in packaging and hardware products and parts on a component-by-component level using its supplier specification H00594, Restricted Substances for Hardware Products.
H02050, Microsofts Supplier Social and Environmental Accountability Manual, required all in-scope suppliers to:
| Post a responsible sourcing policy, conforming to the OECD Guidance, on their website; |
| Exercise due diligence on the source and chain of custody of high risk raw materials, including 3TGs, contained in materials, components, or products supplied to Microsoft; |
| Identify, by name, each SOR that has processed or otherwise handled 3TGs contained in those materials, components, or products; |
| Encourage those SORs to participate in RMAP or an equivalent third-party responsible mineral audit scheme; |
| Confirm that 3TGs in their supply chain are sourced from available SORs that are conformant with the RMAP or an equivalent independent private sector audit firm; and |
| Notify Microsoft immediately if minerals used in the supplied materials, components, or products may contain 3TGs sourced from a CAHRA. |
H02050 required all in-scope suppliers to impose these same requirements on their sub-tier suppliers and to assist sub-tier suppliers with appropriate training and support. To facilitate this process, Microsoft required suppliers to utilize the CMRT provided by the RMAP and available at www.conflictfreesourcing.org.
b. | Responsible Sourcing Program Manual Processes to Implement OECD Guidance |
Microsoft used the OECD Guidance to review supplier CMRT data and identify potential red flags for the sourcing of raw materials. The red flags, which required additional supplier due diligence, included the following:
| The minerals originated from or were transported via a CAHRA; |
| The minerals were claimed to have originated from a country that has limited known reserves for the mineral in question; |
| The minerals were claimed to have originated from a country in which minerals from a CAHRA are known to transit; |
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| The companys suppliers or other known upstream companies had shareholder or other interests in companies that supply minerals or operate in one of the red flag locations of mineral origin and transit; and |
| The companys suppliers or other known upstream companies were known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months. |
Microsofts program includes an escalation process that requires an in-scope supplier to find an alternative to a non-RMAP conformant source of 3TGs for use in materials, components, or products supplied to Microsoft or risk termination as a Microsoft supplier. To date, we have not encountered an RSRM issue with a supplier warranting contract termination.
Microsofts Supplier Social and Environmental Accountability Program Manual requires self- assessment, monitoring, and internal reporting of the RSRM programs progress and conformance. We utilize supplier survey updates, supplier communications, supplier social and environmental accountability audits, and new supplier briefings to prevent the introduction of new raw material sourcing risks to our supply chain. We leverage Microsofts SEA Committee meetings with senior management to report findings and receive program guidance.
c. | Industry and Partner Engagement |
Microsoft participated in or has been a member of several industry-wide responsible mining and smelting initiatives: RMAP, ITRIs iTSCi program, PPA, IRMA, Pact, and ARM. We also conducted smelter outreach on behalf of the RMAP Smelter Engagement Team to further the RMAP program.
2. | Carried Out Independent Third-Party Audit of Supply Chain Due Diligence |
As contemplated by the OECD Guidance, our due diligence program leveraged independent SOR audits. The audits conformed to the RMAP and other similar programs. Microsoft obtained SOR data from the RMAP Conformant Smelter List using Reasonable Country of Origin Inquiry Data for member MSFT. The list identifies SORs that have undergone assessment through the RMAP or industry equivalent programs, such as Responsible Jewelry Council (RJC) or London Bullion Market Association (LBMA). We used the list to support certain statements contained in this CMR. Microsoft also participated in RMAPs Smelter Engagement Team during the 2018 reporting year.
3. | Reported on Supply Chain Due Diligence |
We have filed our CMR with the SEC and concurrently posted it on our website. These disclosures meet the fifth step of the OECD Guidance. The results of our program are presented in Microsofts Devices Groups FY18 Sustainability Report. The Corporate Social Responsibility website provides additional information about Microsofts Responsible Sourcing of Raw Materials Program.
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IV. | SOR INFORMATION |
A. | 3TG Processing Facilities |
Our supplier survey data revealed 311 potential 3TG SORs, which processed 3TGs, in the Microsoft supply chain. We validated the data by removing duplicate SORs, reconciling multiple SOR names for a single entity, and eliminating otherwise invalid SOR names. We then verified if the alleged SORs were active and participants in the RMAP audit program. We determined that 299 SORs met this criteria.
The Figures below provide a visual depiction of the 299 SORs identified in Microsofts supply chain by RMAP audit status. Figure 2 categorizes the SORs by RMAP audit status and reporting year. Figure 2 indicates that, for the 2018 Reporting Year, the number of conformant SORs remained stable at 252. Figure 3 categorizes the SORs by 3TG mineral and audit status.
Figure 2. Identified SORs by RMAP Audit Status (2013-2018 Reporting Years)
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Figure 3: Identified SORs by 3TG and Audit Status
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Table 1 (below) summarizes the conflict mineral status of the 299 SORs identified in Microsofts supply chain, which processed 3TGs, during the 2018 reporting year. The RMAP classifies audit status in the following manner:
| Conformant: SOR has been audited and found to conform with the relevant audit protocols, including RMAP, LBMA, or RJC; |
| Outreach Required: SOR is not yet active and outreach is needed by RMAP member companies to encourage SOR participation in RMAP; |
| Active: SOR has been engaged but is not yet conformant; |
| In Communication: SOR is not yet active but is in communication with RMAP and/or member company; |
| Communication Suspended Not Interested: SOR has strongly communicated a lack of interest in participation; |
| Non-Conformant: SOR was audited but found not to conform to the relevant RMAP protocol |
| RMI Due Diligence Vetting Restriction Not Applicable: SOR cannot be audited as per RMIs due diligence vetting process; |
| Due Diligence Vetting Process: SOR does not meet RMIs requirements for participation according to the due diligence vetting process |
| RMI Due Diligence Review Unable to Proceed: SOR has not met the threshold for Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted |
| Communication Suspended Temporarily Ceased Operations: SOR has temporarily ceased operations |
Table 1: RMAP Audit Status of Identified SORs in Microsoft Supply Chain
Number of SORs |
RMAP Audit Status | |
252 |
Conformant (Indicates RMAP, LBMA and/or RJC conformant) | |
26 |
Outreach Required | |
6 |
Active | |
3 |
In Communication | |
5 |
Communication Suspended - Not Interested | |
5 |
Non-Conformant | |
0 |
RMI Due Diligence Vetting Restriction - Not Applicable | |
1 |
Due Diligence Vetting Process | |
1 |
RMI Due Diligence Review Unable to Proceed | |
0 |
Communication Suspended - Temporarily Ceased Operations |
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Figures 4-7 show the geographic distribution of the 299 SORs identified in the Microsoft supply chain by 3TG mineral for the 2018 reporting year. The circle size corresponds to the relative number of times our in-scope suppliers identified each 3TG SOR in their completed CMRT form.
Figure 4: Location and Relative Number of Identified SORs - Tin
Figure 5: Location and Relative Number of Identified SORs -Tantalum
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Figure 6: Location and Relative Number of Identified SORs - Tungsten
Figure 7: Location and Relative Number of Identified SORs - Gold
Appendix A provides the complete list of 299 SORs identified in Microsofts supply chain which processed 3TGs during the 2018 reporting year. Appendix A lists each SOR by metal, official smelter name, smelter country, and audit status.
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B. | 3TG Countries of Origin |
The table below lists countries of origin for the 299 SORs identified in Microsofts supply chain which processed 3TGs during the 2018 reporting year.
Countries of Origin identified by RMAP Conformant SORs |
Additional Possible Countries of Origin | |
Australia
Austria
Benin
Bolivia
Brazil
Burundi
Chile
China
Colombia
Congo, Democratic Republic of the
Ecuador
Eritrea
Ethiopia
Ghana
Guinea
Guyana
India
Indonesia
Laos
Madagascar
Malaysia
Mali
Mauritania
Mongolia
Mozambique
Myanmar
Nicaragua
Niger
Nigeria
Peru
Portugal
Russian Federation
Rwanda
Sierra Leone
South Africa
Swaziland
Taiwan
Tanzania
Thailand
Togo
|
These countries were identified through research or were listed in supplier CMRTs. These countries require continued due diligence and investigation.
Andorra
Belgium
Canada
Estonia
France
Germany
Italy
Japan
Kazakhstan
Korea
Kyrgyzstan
Lithuania
Macedonia
Mexico
Netherlands
New Zealand
Philippines
Poland
Saudi Arabia
Singapore
Spain
Sweden
Switzerland
Turkey
United Arab Emirates
United States
Uzbekistan
Vietnam |
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Uganda
United Kingdom of Great Britain and
United States of America
Venezuela |
Figure 8 provides a graphical presentation of the countries of origin for SORs identified in Microsofts supply chain which processed 3TGs during the 2018 reporting year.
Figure 8: Country-of-Origin Information for SORs Identified in Microsofts Supply Chain
For the identified conflict-free SORs for which minerals sourcing information is available from RMAP3:
| 38 smelters, or 13 percent of total smelters, processed recycled or scrap material; and |
| 22 SORs, or 7 percent of total smelters sourced from Covered Countries and were RMAP compliant. |
C. | 3TG Mines or Locations of Origin |
Microsoft obtained Reasonable Country of Origin data through our membership in the RMAP using the Reasonable Country of Origin Inquiry Data for member MSFT. We used this data to determine the 3TG country of origin of SORs identified in Microsofts supply chain. Microsoft supports the continued refinement and expansion of the list of participating SORs in the RMAP audit program through our membership.
3 | All numbers include both direct and indirect sourcing. |
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We contact all non-conformant SORs identified in our supply chain each reporting year and encourage SORs to participate in the RMAP. We also require suppliers reporting non-conformant SORs to contact these SORs and request the SORs to join the CFSP. We actively support outreach events to increase RMAP SOR coverage. We funded a third party to help educate SORs and prepare them for the audit process. We also offered to visit SORs to facilitate their participation in the RMAP.
V. | IMPROVEMENTS |
The results of Microsofts key 2018 reporting year efforts are detailed below:
| The number of RMAP-conformant SORs identified in Microsofts supply chain remained consistent at 252; |
| Renewed and extended its engagement with external responsible sourcing organizations, such as Pact, IRMA, and ARM. These organizations are committed to advancing responsible sourcing on a global basis by developing mining standards and addressing issues such as child labor in the mining industry. We partner closely with them and leverage data and technology to bring about even greater change. With the further empowerment that digital technology can provide toward overcoming increased scope and complexity, Microsoft and our partners can drive positive transformations in the mining sector. We believe this integrated approach is the most effective way to improve conditions for the people working in raw material supply chains and the environment; |
| Continued to increase Microsofts level of engagement with suppliers and internal stakeholders by holding supplier forums, webinars, and in-person trainings, and by providing technical resources; |
| Leveraged the integrated RSRM program in our SEA audit process to drive improvements in the supply chain; |
| Ensured commitment to transparency by maintaining Microsofts publicly available excerpt of Microsofts Supplier Social and Environmental Accountability Program Manual, which includes Responsible Sourcing of Raw Material Requirements; and |
| Strengthened internal partnerships to identify raw material risk at an early product development stage. |
VI. | FUTURE ACTIONS |
Microsoft is committed to the responsible sourcing of raw materials used in our hardware products in support of human rights, labor, health and safety, environmental protection, and business. We will continue to advance implementation of our RSRM policy in our supply chain to promote supply chain identification and risk assessment, standardized requirements and verification, capability building, transparency, and strategic partnerships.
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We will continue to encourage SORs to participate in the RMAP and expand our knowledge about 3TGs in our supply chain. Our ability to identify, assess, and mitigate risks associated with our raw materials sourcing will improve with ongoing due diligence efforts with both our direct and sub- tier partners. Consistent with our commitments, we intend to take the following steps to improve our responsible sourcing of raw materials due diligence efforts:
| Enhance our use of digital technology to improve supply chain information and risk mitigation; |
| Increase use of external data sources to proactively identify raw material risk in CAHRAs; |
| Continue our active participation in the RMAP Smelter Engagement Team to bring non- conformant SORs into the RMAP; and |
| Further our engagement with organizations like IRMA, ARM, and Pact to establish global responsible sourcing standards and support programs in the mineral supply chain. |
Microsofts efforts to address human rights and advance economic opportunities in Africa do not end with our responsible sourcing programs. In 2013, Microsoft launched its 4Afrika Initiative. We started investing in start-ups, partners, small-to-medium enterprises, governments and youth on the African continent. Our focus has been on delivering affordable access to the internet, developing skilled workforces and investing in local technology solutions. Africa has the potential to lead the technology revolution and so were empowering those with the right ideas to drive economic development, inclusive growth and digital transformation. At Microsoft, were very fortunate to have played a part in realising this potential, building strong partnerships to accelerate digital transformation and create sustained societal impact. For more information, visit our 4Afrika web-page.
19
APPENDIX A
Conflict Mineral Status of Identified SORs1
This Appendix lists the 299 SORs which, to the extent known, processed 3TGs that were used to manufacture Microsoft devices during the 2018 reporting year. The SORs are listed by metal, official smelter name, melter country, and audit status.
RMI Smelter ID |
Metal |
Official Smelter Name |
Smelter |
Audit Status | ||||
CID001798 |
Gold | Sumitomo Metal Mining Co., Ltd. | JP | Conformant | ||||
CID002082 |
Tungsten | Xiamen Tungsten Co., Ltd. | CN | Conformant | ||||
CID000035 |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | DE | Conformant | ||||
CID002550 |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | DE | Conformant | ||||
CID000233 |
Gold | Chimet S.p.A. | IT | Conformant | ||||
CID000937 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JP | Conformant | ||||
CID002593 |
Tin | CV Tiga Sekawan | ID | Conformant | ||||
CID000493 |
Gold | OJSC Novosibirsk Refinery | RU | Conformant | ||||
CID002765 |
Gold | Italpreziosi | IT | Conformant | ||||
CID000814 |
Gold | Istanbul Gold Refinery | TR | Conformant | ||||
CID002724 |
Tungsten | Unecha Refractory metals plant | RU | Conformant | ||||
CID000499 |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CN | Conformant | ||||
CID002320 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CN | Conformant | ||||
CID000823 |
Gold | Japan Mint | JP | Conformant | ||||
CID001909 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CN | Outreach Required | ||||
CID000522 |
Gold | Refinery of Seemine Gold Co., Ltd. | CN | Outreach Required | ||||
CID000468 |
Tin | Fenix Metals | PL | Conformant | ||||
CID000616 |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CN | Conformant | ||||
CID001736 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CN | Conformant | ||||
CID001200 |
Tantalum | NPM Silmet AS | EE | Conformant | ||||
CID000460 |
Tantalum | F&X Electro-Materials Ltd. | CN | Conformant | ||||
CID002551 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CN | Conformant | ||||
CID002548 |
Tantalum | H.C. Starck Inc. | US | Conformant | ||||
CID002516 |
Gold | Singway Technology Co., Ltd. | TW | Conformant | ||||
CID001070 |
Tin | China Tin Group Co., Ltd. | CN | Conformant | ||||
CID000425 |
Gold | Eco-System Recycling Co., Ltd. | JP | Conformant | ||||
CID001192 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JP | Conformant | ||||
CID001993 |
Gold | United Precious Metal Refining, Inc. | US | Conformant | ||||
CID000825 |
Tungsten | Japan New Metals Co., Ltd. | JP | Conformant | ||||
CID002778 |
Gold | WIELAND Edelmetalle GmbH | DE | Conformant | ||||
CID002319 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CN | Conformant | ||||
CID000128 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PH | Conformant |
1 | Data as of April 12, 2019. |
A-1
CID002030 |
Gold | Western Australian Mint (T/a The Perth Mint) | AU | Conformant | ||||
CID001259 |
Gold | Nihon Material Co., Ltd. | JP | Conformant | ||||
CID000258 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CN | Conformant | ||||
CID000004 |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JP | Conformant | ||||
CID002918 |
Gold | SungEel HiMetal Co., Ltd. | KR | Conformant | ||||
CID001314 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | TH | Conformant | ||||
CID002827 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PH | Conformant | ||||
CID002509 |
Gold | MMTC-PAMP India Pvt., Ltd. | IN | Conformant | ||||
CID001490 |
Tin | PT Tinindo Inter Nusa | ID | Conformant | ||||
CID001428 |
Tin | PT Bukit Timah | ID | Conformant | ||||
CID002845 |
Tungsten | Moliren Ltd. | RU | Conformant | ||||
CID002589 |
Tungsten | Niagara Refining LLC | US | Conformant | ||||
CID003190 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CN | Conformant | ||||
CID000328 |
Gold | Daejin Indus Co., Ltd. | KR | Conformant | ||||
CID001397 |
Gold | PT Aneka Tambang (Persero) Tbk | ID | Conformant | ||||
CID000924 |
Gold | Asahi Refining Canada Ltd. | CA | Conformant | ||||
CID000090 |
Gold | Asaka Riken Co., Ltd. | JP | Conformant | ||||
CID002835 |
Tin | PT Menara Cipta Mulia | ID | Conformant | ||||
CID001916 |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CN | Conformant | ||||
CID002539 |
Tantalum | KEMET Blue Metals | MX | Conformant | ||||
CID001889 |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VN | Conformant | ||||
CID002580 |
Gold | T.C.A S.p.A | IT | Conformant | ||||
CID002494 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CN | Conformant | ||||
CID001161 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MX | Conformant | ||||
CID002003 |
Gold | Valcambi S.A. | CH | Conformant | ||||
CID001453 |
Tin | PT Mitra Stania Prima | ID | Conformant | ||||
CID002468 |
Tin | Magnus Minerais Metais e Ligas Ltda. | BR | Conformant | ||||
CID001105 |
Tin | Malaysia Smelting Corporation (MSC) | MY | Conformant | ||||
CID001977 |
Gold | Umicore Brasil Ltda. | BR | Conformant | ||||
CID001352 |
Gold | PAMP S.A. | CH | Conformant | ||||
CID002557 |
Tantalum | Global Advanced Metals Boyertown | US | Conformant | ||||
CID002044 |
Tungsten | Wolfram Bergbau und Hutten AG | AT | Conformant | ||||
CID002816 |
Tin | PT Sukses Inti Makmur | ID | Conformant | ||||
CID000306 |
Tin | CV Gita Pesona | ID | Conformant | ||||
CID000359 |
Gold | DSC (Do Sung Corporation) | KR | Conformant | ||||
CID000402 |
Tin | Dowa | JP | Conformant | ||||
CID001175 |
Tantalum | Mineracao Taboca S.A. | BR | Conformant | ||||
CID001463 |
Tin | PT Sariwiguna Binasentosa | ID | Conformant | ||||
CID001142 |
Tin | Metallic Resources, Inc. | US | Conformant | ||||
CID001078 |
Gold | LS-NIKKO Copper Inc. | KR | Conformant | ||||
CID000942 |
Tin | Gejiu Kai Meng Industry and Trade LLC | CN | Conformant | ||||
CID002503 |
Tin | PT ATD Makmur Mandiri Jaya | ID | Conformant | ||||
CID002506 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CN | Conformant | ||||
CID002314 |
Gold | Umicore Precious Metals Thailand | TH | Conformant | ||||
CID002542 |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | DE | Conformant | ||||
CID002773 |
Tin | Metallo Belgium N.V. | BE | Conformant |
A-2
CID002776 |
Tin | PT Bangka Prima Tin | ID | Conformant | ||||
CID000211 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CN | Conformant | ||||
CID000113 |
Gold | Aurubis AG | DE | Conformant | ||||
CID001277 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CN | Conformant | ||||
CID001761 |
Gold | Solar Applied Materials Technology Corp. | TW | Conformant | ||||
CID000929 |
Gold | JSC Uralelectromed | RU | Conformant | ||||
CID001419 |
Tin | PT Bangka Tin Industry | ID | Conformant | ||||
CID001191 |
Tin | Mitsubishi Materials Corporation | JP | Conformant | ||||
CID002318 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CN | Conformant | ||||
CID002455 |
Tin | CV Venus Inti Perkasa | ID | Conformant | ||||
CID002512 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CN | Conformant | ||||
CID002849 |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CN | Conformant | ||||
CID001471 |
Tin | PT Sumber Jaya Indah | ID | Conformant | ||||
CID001898 |
Tin | Thaisarco | TH | Conformant | ||||
CID001163 |
Tantalum | Metallurgical Products India Pvt., Ltd. | IN | Conformant | ||||
CID001769 |
Tantalum | Solikamsk Magnesium Works OAO | RU | Conformant | ||||
CID002919 |
Gold | Planta Recuperadora de Metales SpA | CL | Conformant | ||||
CID001477 |
Tin | PT Timah (Persero) Tbk Kundur | ID | Conformant | ||||
CID001119 |
Gold | Matsuda Sangyo Co., Ltd. | JP | Conformant | ||||
CID002545 |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | DE | Conformant | ||||
CID002517 |
Tin | O.M. Manufacturing Philippines, Inc. | PH | Conformant | ||||
CID002649 |
Tungsten | Hydrometallurg, JSC | RU | Conformant | ||||
CID000401 |
Gold | Dowa | JP | Conformant | ||||
CID000291 |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CN | Conformant | ||||
CID000969 |
Gold | Kennecott Utah Copper LLC | US | Conformant | ||||
CID001980 |
Gold | Umicore S.A. Business Unit Precious Metals Refining |
BE | Conformant | ||||
CID003191 |
Tantalum | Jiujiang Janny New Material Co., Ltd. | CN | Conformant | ||||
CID001325 |
Gold | Ohura Precious Metal Industry Co., Ltd. | JP | Conformant | ||||
CID002582 |
Gold | Remondis Argentia B.V. | NL | Conformant | ||||
CID001149 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CN | Conformant | ||||
CID002549 |
Tantalum | H.C. Starck Ltd. | JP | Conformant | ||||
CID001482 |
Tin | PT Timah (Persero) Tbk Mentok | ID | Conformant | ||||
CID001458 |
Tin | PT Prima Timah Utama | ID | Conformant | ||||
CID001421 |
Tin | PT Belitung Industri Sejahtera | ID | Conformant | ||||
CID000292 |
Tin | Alpha | US | Conformant | ||||
CID002530 |
Tin | PT Inti Stania Prima | ID | Conformant | ||||
CID000082 |
Gold | Asahi Pretec Corp. | JP | Conformant | ||||
CID002973 |
Gold | Safimet S.p.A | IT | Conformant | ||||
CID000058 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BR | Conformant | ||||
CID002850 |
Gold | AU Traders and Refiners | ZA | Conformant | ||||
CID000707 |
Gold | Heraeus Ltd. Hong Kong | CN | Conformant | ||||
CID002558 |
Tantalum | Global Advanced Metals Aizu | JP | Conformant | ||||
CID002568 |
Tantalum | KEMET Blue Powder | US | Conformant | ||||
CID002513 |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CN | Conformant |
A-3
CID002459 |
Gold | Geib Refining Corporation | US | Conformant | ||||
CID000176 |
Gold | C. Hafner GmbH + Co. KG | DE | Conformant | ||||
CID002492 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CN | Conformant | ||||
CID002036 |
Tin | White Solder Metalurgia e Mineracao Ltda. | BR | Conformant | ||||
CID002605 |
Gold | Korea Zinc Co., Ltd. | KR | Conformant | ||||
CID001147 |
Gold | Metalor Technologies (Suzhou) Ltd. | CN | Conformant | ||||
CID002706 |
Tin | Resind Industria e Comercio Ltda. | BR | Conformant | ||||
CID002541 |
Tungsten | H.C. Starck Tungsten GmbH | DE | Conformant | ||||
CID001182 |
Tin | Minsur | PE | Conformant | ||||
CID001969 |
Tantalum | Ulba Metallurgical Plant JSC | KZ | Conformant | ||||
CID000228 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CN | Conformant | ||||
CID002508 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CN | Conformant | ||||
CID001891 |
Tantalum | Telex Metals | US | Conformant | ||||
CID001188 |
Gold | Mitsubishi Materials Corporation | JP | Conformant | ||||
CID002129 |
Gold | Yokohama Metal Co., Ltd. | JP | Conformant | ||||
CID002830 |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CN | Conformant | ||||
CID001193 |
Gold | Mitsui Mining and Smelting Co., Ltd. | JP | Conformant | ||||
CID002833 |
Tungsten | ACL Metais Eireli | BR | Conformant | ||||
CID002321 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CN | Conformant | ||||
CID001204 |
Gold | Moscow Special Alloys Processing Plant | RU | Conformant | ||||
CID001534 |
Gold | Royal Canadian Mint | CA | Conformant | ||||
CID000914 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CN | Conformant | ||||
CID002606 |
Gold | Marsam Metals | BR | Conformant | ||||
CID002505 |
Tantalum | FIR Metals & Resource Ltd. | CN | Conformant | ||||
CID002579 |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CN | Conformant | ||||
CID000568 |
Tungsten | Global Tungsten & Powders Corp. | US | Conformant | ||||
CID000966 |
Tungsten | Kennametal Fallon | US | Conformant | ||||
CID001508 |
Tantalum | QuantumClean | US | Conformant | ||||
CID000077 |
Gold | Argor-Heraeus S.A. | CH | Conformant | ||||
CID001875 |
Gold | Tanaka Kikinzoku Kogyo K.K. | JP | Conformant | ||||
CID001460 |
Tin | PT Refined Bangka Tin | ID | Conformant | ||||
CID000309 |
Tin | PT Aries Kencana Sejahtera | ID | Conformant | ||||
CID001326 |
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | RU | Conformant | ||||
CID000801 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CN | Conformant | ||||
CID001231 |
Tin | Jiangxi New Nanshan Technology Ltd. | CN | Conformant | ||||
CID000189 |
Gold | Cendres + Metaux S.A. | CH | Conformant | ||||
CID001955 |
Gold | Torecom | KR | Conformant | ||||
CID002842 |
Tantalum | Jiangxi Tuohong New Raw Material | CN | Conformant | ||||
CID003205 |
Tin | PT Bangka Serumpun | ID | Conformant | ||||
CID002829 |
Tin | PT Kijang Jaya Mandiri | ID | Conformant | ||||
CID001938 |
Gold | Tokuriki Honten Co., Ltd. | JP | Conformant | ||||
CID002243 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CN | Conformant | ||||
CID002543 |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VN | Conformant |
A-4
CID003116 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CN | Conformant | ||||
CID001457 |
Tin | PT Panca Mega Persada | ID | Conformant | ||||
CID000981 |
Gold | Kojima Chemicals Co., Ltd. | JP | Conformant | ||||
CID000957 |
Gold | Kazzinc | KZ | Conformant | ||||
CID001402 |
Tin | PT Babel Inti Perkasa | ID | Conformant | ||||
CID001468 |
Tin | PT Stanindo Inti Perkasa | ID | Conformant | ||||
CID002502 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VN | Conformant | ||||
CID002224 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CN | Conformant | ||||
CID001498 |
Gold | PX Precinox S.A. | CH | Conformant | ||||
CID002500 |
Tin | Melt Metais e Ligas S.A. | BR | Conformant | ||||
CID001173 |
Tin | Mineracao Taboca S.A. | BR | Conformant | ||||
CID000015 |
Gold | Advanced Chemical Company | US | Conformant | ||||
CID000438 |
Tin | EM Vinto | BO | Conformant | ||||
CID000041 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZ | Conformant | ||||
CID001399 |
Tin | PT Artha Cipta Langgeng | ID | Conformant | ||||
CID000456 |
Tantalum | Exotech Inc. | US | Conformant | ||||
CID002180 |
Tin | Yunnan Tin Company Limited | CN | Conformant | ||||
CID002547 |
Tantalum | H.C. Starck Hermsdorf GmbH | DE | Conformant | ||||
CID000538 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CN | Conformant | ||||
CID001337 |
Tin | Operaciones Metalurgical S.A. | BO | Conformant | ||||
CID002100 |
Gold | Yamakin Co., Ltd. | JP | Conformant | ||||
CID001622 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CN | Conformant | ||||
CID000315 |
Tin | CV United Smelting | ID | Conformant | ||||
CID001157 |
Gold | Metalor USA Refining Corporation | US | Conformant | ||||
CID001076 |
Tantalum | LSM Brasil S.A. | BR | Conformant | ||||
CID000766 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CN | Conformant | ||||
CID002774 |
Tin | Metallo Spain S.L.U. | ES | Conformant | ||||
CID002858 |
Tin | Modeltech Sdn Bhd | MY | Conformant | ||||
CID001555 |
Gold | Samduck Precious Metals | KR | Non Conformant | ||||
CID002707 |
Tantalum | Resind Industria e Comercio Ltda. | BR | Conformant | ||||
CID001869 |
Tantalum | Taki Chemical Co., Ltd. | JP | Conformant | ||||
CID000264 |
Gold | Chugai Mining | JP | Active | ||||
CID000917 |
Tantalum | Jiujiang Tanbre Co., Ltd. | CN | Conformant | ||||
CID002844 |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CN | Non Conformant | ||||
CID000362 |
Gold | DODUCO Contacts and Refining GmbH | DE | Conformant | ||||
CID001522 |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CN | Conformant | ||||
CID001756 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RU | Conformant | ||||
CID001512 |
Gold | Rand Refinery (Pty) Ltd. | ZA | Conformant | ||||
CID001493 |
Tin | PT Tommy Utama | ID | Conformant | ||||
CID001585 |
Gold | SEMPSA Joyeria Plateria S.A. | ES | Conformant | ||||
CID000092 |
Tantalum | Asaka Riken Co., Ltd. | JP | Conformant | ||||
CID001153 |
Gold | Metalor Technologies S.A. | CH | Conformant | ||||
CID002504 |
Tantalum | D Block Metals, LLC | US | Conformant |
A-5
CID002848 |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CN | Conformant | ||||
CID002592 |
Tin | CV Dua Sekawan | ID | Conformant | ||||
CID000855 |
Gold | Jiangxi Copper Co., Ltd. | CN | Conformant | ||||
CID000689 |
Gold | HeeSung Metal Ltd. | KR | Conformant | ||||
CID000807 |
Gold | Ishifuku Metal Industry Co., Ltd. | JP | Conformant | ||||
CID000875 |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CN | Conformant | ||||
CID002815 |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CN | Conformant | ||||
CID000778 |
Gold | HwaSeong CJ CO., LTD. | KR | Communication Suspended - Not Interested | ||||
CID002843 |
Tungsten | Woltech Korea Co., Ltd. | KR | Conformant | ||||
CID002544 |
Tantalum | H.C. Starck Co., Ltd. | TH | Conformant | ||||
CID000760 |
Tin | Huichang Jinshunda Tin Co., Ltd. | CN | Conformant | ||||
CID001386 |
Gold | Prioksky Plant of Non-Ferrous Metals | RU | Conformant | ||||
CID000651 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CN | Outreach Required | ||||
CID000218 |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CN | Conformant | ||||
CID002863 |
Gold | Bangalore Refinery | IN | Conformant | ||||
CID000019 |
Gold | Aida Chemical Industries Co., Ltd. | JP | Conformant | ||||
CID000313 |
Tin | PT Premium Tin Indonesia | ID | Conformant | ||||
CID002777 |
Gold | SAXONIA Edelmetalle GmbH | DE | Conformant | ||||
CID000920 |
Gold | Asahi Refining USA Inc. | US | Conformant | ||||
CID001539 |
Tin | Rui Da Hung | TW | Conformant | ||||
CID001908 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CN | Conformant | ||||
CID000694 |
Gold | Heimerle + Meule GmbH | DE | Conformant | ||||
CID000769 |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CN | Conformant | ||||
CID001220 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TR | Conformant | ||||
CID002779 |
Gold | Ogussa Osterreichische Gold- und Silber- Scheideanstalt GmbH | AT | Conformant | ||||
CID002095 |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CN | Conformant | ||||
CID000157 |
Gold | Boliden AB | SE | Conformant | ||||
CID001029 |
Gold | Kyrgyzaltyn JSC | KG | Conformant | ||||
CID000711 |
Gold | Heraeus Precious Metals GmbH & Co. KG | DE | Conformant | ||||
CID002561 |
Gold | Emirates Gold DMCC | AE | Conformant | ||||
CID000185 |
Gold | CCR Refinery - Glencore Canada Corporation | CA | Conformant | ||||
CID001113 |
Gold | Materion | US | Conformant | ||||
CID001152 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SG | Conformant | ||||
CID002847 |
Tantalum | Power Resources Ltd. | MK | Conformant | ||||
CID002317 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CN | Conformant | ||||
CID002761 |
Gold | SAAMP | FR | Conformant | ||||
CID001758 |
Tin | Soft Metais Ltda. | BR | Conformant | ||||
CID002316 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CN | Conformant | ||||
CID000105 |
Tungsten | Kennametal Huntsville | US | Conformant | ||||
CID002312 |
Gold | Guangdong Jinding Gold Limited | CN | Outreach Required | ||||
CID002762 |
Gold | LOrfebre S.A. | AD | Conformant | ||||
CID002158 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CN | Conformant |
A-6
CID003153 |
Gold | State Research Institute Center for Physical Sciences and Technology |
LT | Outreach Required | ||||
CID002315 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CN | Conformant | ||||
CID002560 |
Gold | Al Etihad Gold LLC | AE | Conformant | ||||
CID001236 |
Gold | Navoi Mining and Metallurgical Combinat | UZ | Outreach Required | ||||
CID001434 |
Tin | PT DS Jaya Abadi | ID | Conformant | ||||
CID002572 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VN | Non Conformant | ||||
CID003325 |
Tin | Tin Technology & Refining | US | Conformant | ||||
CID000448 |
Tin | Estanho de Rondonia S.A. | BR | Outreach Required | ||||
CID001056 |
Gold | Lingbao Gold Co., Ltd. | CN | Outreach Required | ||||
CID002866 |
Gold | Morris and Watson Gold Coast | AU | Communication Suspended - Not Interested | ||||
CID001032 |
Gold | Lazurde Company For Jewelry | SA | RMI Due Diligence Review - Unable to Proceed | ||||
CID001562 |
Gold | Samwon Metals Corp. | KR | Communication Suspended - Not Interested | ||||
CID001362 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CN | Outreach Required | ||||
CID003182 |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CN | Active | ||||
CID002511 |
Gold | KGHM Polska Miedz Spolka Akcyjna | PL | Active | ||||
CID000555 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CN | Conformant | ||||
CID001619 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CN | Outreach Required | ||||
CID002853 |
Gold | Sai Refinery | IN | Outreach Required | ||||
CID002857 |
Gold | Modeltech Sdn Bhd | MY | Non Conformant | ||||
CID002763 |
Gold | 8853 S.p.A. | IT | Conformant | ||||
CID002282 |
Gold | Morris and Watson | NZ | Communication Suspended - Not Interested | ||||
CID002703 |
Tin | An Vinh Joint Stock Mineral Processing Company | VN | Outreach Required | ||||
CID002645 |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CN | Conformant | ||||
CID002708 |
Gold | Abington Reldan Metals, LLC | US | Non Conformant | ||||
CID002872 |
Gold | Pease & Curren | US | Outreach Required | ||||
CID000343 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CN | In Communication | ||||
CID000767 |
Gold | Hunan Chenzhou Mining Co., Ltd. | CN | Outreach Required | ||||
CID003195 |
Gold | DS PRETECH Co., Ltd. | KR | Conformant | ||||
CID000956 |
Gold | Kazakhmys Smelting LLC | KZ | In Communication | ||||
CID001093 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CN | Outreach Required | ||||
CID002852 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | IN | Outreach Required | ||||
CID002756 |
Tin | Super Ligas | BR | Outreach Required | ||||
CID002478 |
Tin | PT Tirus Putra Mandiri | ID | Conformant | ||||
CID002573 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VN | Outreach Required | ||||
CID001406 |
Tin | PT Babel Surya Alam Lestari | ID | Conformant | ||||
CID003189 |
Gold | NH Recytech Company | KR | Active |
A-7
CID002865 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RU | Outreach Required | ||||
CID001546 |
Gold | Sabin Metal Corp. | US | Outreach Required | ||||
CID000180 |
Gold | Caridad | MX | Communication Suspended - Not Interested | ||||
CID003381 |
Tin | PT Rajawali Rimba Perkasa | ID | Active | ||||
CID000671 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CN | Outreach Required | ||||
CID002615 |
Gold | TOO Tau-Ken-Altyn | KZ | In Communication | ||||
CID000103 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TR | Due Diligence Vetting Process | ||||
CID002867 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | DE | Outreach Required | ||||
CID001058 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CN | Outreach Required | ||||
CID001947 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CN | Outreach Required | ||||
CID002574 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VN | Outreach Required | ||||
CID003356 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CN | Active | ||||
CID000197 |
Gold | Yunnan Copper Industry Co., Ltd. | CN | Outreach Required |
A-8