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
(Registrant’s 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, 2020. |
Section 1 - Conflict Minerals Disclosure
Items 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Microsoft’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at: https://aka.ms/conflictmineralreport
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 27, 2021 |
/s/ BRADFORD L. SMITH | |
| Bradford L. Smith | ||
| President and Chief Legal Officer | ||
Exhibit 1.01
MICROSOFT CORPORATION
CONFLICT MINERALS REPORT
FOR 2020 REPORTING YEAR
| I. | INTRODUCTION |
This Conflict Minerals Report (“CMR”) for MICROSOFT CORPORATION (“Microsoft”) is filed as an exhibit to Microsoft’s Form SD1 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, (the “Rule”) for the 2020 Reporting Year (January 1, 2020-December 31, 2020). The CMR covers all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule.2 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 gold, cassiterite, columbite-tantalite and wolframite or their derivatives, which are limited to tin, tantalum, and tungsten (collectively referred to as “3TGs”) that are sourced from the Democratic Republic of the Congo (“DRC”) or an adjoining country.
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 people’s lives. Microsoft devices contain one or more 3TGs and are within the Rule’s scope. During the 2020 Reporting Year, covered devices included the Surface line of computers, tablets, and accessories; Xbox gaming/entertainment consoles and accessories; personal computing accessories (mice, headsets, and keyboards); HoloLens, a self-contained holographic computer; and service, spare, and replacement parts for such devices.
Microsoft is committed to the responsible sourcing of raw materials globally and is committed to sourcing minerals for use in our devices that do not directly or indirectly finance armed conflict or benefit armed groups. Our commitment and strategy are outlined in Microsoft Devices Responsible Sourcing of Raw Materials (“RSRM”) policy. Our RSRM policy establishes a holistic approach to the responsible sourcing of raw materials. We hold ourselves and our supply chain accountable to address the human rights; labor, health, and safety; environmental protection; and business ethics risks associated with raw materials extraction, harvesting, processing, refining, and transportation. We envision a future where all raw materials used in our devices, unbounded by specific materials or locations, are sourced from responsible suppliers. We commit to the responsible sourcing of 3TG from Conflict Affected and High Risk Areas (“CAHRAs”), including the DRC or DRC-adjoining countries (each a “Covered Country” under the Rule), in order to minimize the harmful societal and economic impacts that would be caused by an inadvertent de facto embargo of 3TG minerals from such regions.
| 1 | Please see the Securities and Exchange Commission’s Form SD for more information about the Rule’s reporting requirements. |
| 2 | Throughout this CMR, we use “Microsoft,” “Microsoft Devices,” “we,” “our,” “us” and similar terms to refer to Microsoft Corporation and its subsidiaries and various interest entities subject to the Rule (collectively, “Microsoft”), unless otherwise indicated. |
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Based on our “Reasonable Country of Origin Inquiry” (“RCOI”), we determined that 3TGs that were necessary to the functionality or production of devices we manufactured or contracted to manufacture during the 2020 Reporting Year may have originated in a Covered Country. Therefore, we are submitting this CMR, which describes the conflict minerals due diligence we performed during the 2020 Reporting Year, as an exhibit to our Form SD. We have published the CMR externally on our Device’s Responsible Sourcing website.
Based on our RCOI and due diligence assessment, Microsoft found no reasonable basis for concluding that any 3TG Smelter or Refiner (“SOR”) that was identified in Microsoft Device’s supply chain for the 2020 Reporting Year sourced 3TGs in a manner that directly or indirectly financed or benefitted armed groups in a Covered Country. Key results of the 2020 Reporting Year were as follows:
| • | All but one in-scope supplier provided a response to Microsoft Device’s Conflict Minerals Reporting Template (“CMRT”) survey request by the designated due date – a 99.5% response rate. |
| • | Out of 301 Eligible SORs identified in Microsoft Device’s Supply Chain for the 2020 Reporting Year, 237 (78.7%) were conformant to an independent, third-party audit program for 3TGs regardless of the mineral country of origin. |
| • | Out of 301 Eligible SORs, 290 (96.3%) were conformant, active, or are reasonably believed to have supplied only conflict minerals from recycled or scrap sources or to have sourced 3TGs from outside the Covered Countries. |
| • | Out of 301 Eligible SORs, 51 (16.9%) reported sourcing 3TG from a Covered Country. Of those 51 SORs, 94.1% were conformant to an independent, third-party audit program for 3TGs, 3.9% were classified by as Active, and 2.0% as Outreach Required. |
This CMR contains links to internal and external websites for informational purposes only. References to such websites and information available through such websites are not incorporated into this CMR. Additionally, this CMR includes forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements are based on current expectations and assumptions regarding the future implementation of our responsible sourcing program and are subject to change. Forward-looking statements are not guarantees of future performance. Statements in this CMR are based on due diligence activities that were performed in good faith and to the best of our ability. They are based on information that was available to us at the time of this filing. Factors that could affect the accuracy of such statements include, but are not limited to, incomplete or incorrect data submitted by suppliers, amendments to the Rule or SEC guidance, or other issues.
| II. | DUE DILIGENCE FRAMEWORK |
Our CMR is based on Microsoft Devices’ Due Diligence Framework, which conforms in all material respects to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and its related Supplements (“OECD Guidance”). The OECD Guidance provides a detailed due diligence
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framework to support responsible global supply chain management of 3TGs and other mineral resources and is currently the leading international framework for raw material due diligence. The OECD Guidance applies to Microsoft as a “downstream company.”
As a “downstream company,” Microsoft does not directly source from 3TG raw material providers. Instead, we contract to manufacture products and components from our direct suppliers, which source materials, components, and products from their upstream suppliers, which, in turn, source materials, components and products from their upstream suppliers. Our supply chain contains many layers of upstream suppliers positioned between ourselves and 3TG raw material mines and SORs. In this CMR, we refer to our directly contracted suppliers as “in-scope suppliers” as they are the entities with which we contract to manufacture our devices pursuant to the Rule.3
We use contractual provisions to legally bind our in-scope suppliers to information disclosure and audit requirements regarding the sources and chains of custody of 3TGs necessary for the functionality or production of our covered devices. Because we lack contractual mechanisms to force indirect upstream suppliers to provide this information, our due diligence efforts are focused on our in-scope suppliers where we extert our greatest influence to impact supply chain sourcing decisions combined with our use of independent third-party audit programs for 3TGs to confirm SOR conformance. This is consistent with the Rule and OECD Guidance. The graphic below portrays Microsoft’s span of influence across the 3TG supply chain.
Microsoft Span of Influence across 3TG Supply Chain
| A. | Step #1: Establish Strong Company Management Systems |
| 1. | Company Policies |
Microsoft’s commitment to corporate responsibility and integrity guides everything we do as a company. We have high ethical standards governing the way we conduct our business, which also apply to our suppliers and business partners. Microsoft policies include the Microsoft Global Human Rights Statement, Standards of Business Conduct, and our Supplier Code of Conduct, which set expectations for Microsoft operations and those of our suppliers concerning legal and regulatory compliance; business practices and ethics; human rights and fair labor practices; health and safety; environmental protection; and data and privacy protection.
| 3 | Under SEC Guidance, a company is considered to be “contracting to manufacture” a product if it has some actual influence over the manufacturing of that product. This determination is based on facts and circumstances, considering the degree of influence a company exercises over the product’s manufacturing. |
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Our policies are based on internationally recognized standards, including the following declaration and covenants: Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and International Covenant on Economic, Social and Cultural Rights. Our business operations are informed by human rights guidelines described in the following documents: International Labour Organization’s (“ILO”) Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, and the United Nations Global Compact. As a global Information and Communications Technology company operating in more than 100 countries, we respect all human rights – civil, political, economic, social, and cultural; and we expect our suppliers to do the same.
Microsoft Devices’ RSRM policy describes our commitment and strategy to responsibly source raw materials used in our manufactured products. 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. This policy supports implementation of programs that are region-specific and advance the use of responsibly sourced minerals in our devices.
| 2. | Internal Management Team and Corporate Approval |
A cross-functional team supports Microsoft’s responsible sourcing and CMR compliance. Microsoft’s Senior Director of Responsible Sourcing and Supply Chain Security sponsors the team. The team consists of representatives from Manufacturing and Sourcing; Responsible Sourcing; Corporate, External and Legal Affairs; Information Services; Product Environmental Compliance; Global Trade; Finance; and Public Relations. The team meets as needed to assess the program’s 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 Microsoft’s responsible sourcing program. The team annually develops, reviews, and submits the final CMR to Microsoft’s President for approval and signature before being filed as an Exhibit to Microsoft’s Form SD and posted on the Microsoft website pursuant to the Rule.
| 3. | System of Supply Chain Controls, Data Disclosure, and Due Diligence Assurance |
Microsoft Devices’ Due Diligence Framework is based on a system of supply chain controls, data disclosure, and due diligence assurance. As a standard contractual requirement, we require our in-scope suppliers to provide us with information concerning 3TGs and other materials that are contained in the products and components they supply to us. Our environmental product compliance specifications – H00594, Restricted Substances for Hardware Products; and H00642, Microsoft Restricted Substances Control System for Hardware Products (both available at this link) – require in-scope suppliers to declare every substance contained in the materials, components, and products supplied to us, including 3TGs, by weight.
We require in-scope suppliers to annually submit a CMRT, which provides us with the source and chain of custody information for 3TGs that are contained in the products and components they supply to us. Our contracts also require our in-scope suppliers to obtain information from their upstream suppliers to meet these material disclosure requirements. Microsoft evaluates these supply chain disclosures to ensure data integrity and assess sourcing risk. Microsoft investigates any potential nonconformances and engages with such suppliers to address any failure to meet Microsoft specifications and requirements.
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For the 2020 Reporting Year, Microsoft expanded its scope of minerals due diligence. Microsoft already required its battery suppliers to report on their use of cobalt, using the RMI Cobalt Reporting Template (“CRT”) and, in 2020, we expanded that cobalt reporting requirement to all Devices suppliers. Further, Microsoft expanded the supplier raw material disclosure requirement to include five other designated critical minerals: aluminum, copper, lithium, magnesium, and nickel.
Microsoft Device’s Supplier Social and Environmental Accountability Manual (“H02050”) provides an operational framework for Microsoft to achieve supplier conformance with Microsoft’s Supplier Code of Conduct and other responsible sourcing requirements. H02050 establishes a minimum set of requirements that suppliers must meet, including compliance with all applicable laws and regulations with respect to labor, ethics, occupational health and safety, and protection of the environment. Suppliers are encouraged to go beyond legal compliance by committing to meet relevant international standards (i.e., ILO and relevant United Nations Conventions) and to commit to a process of continuous improvement. Suppliers are required to source responsibly, especially regarding certain raw materials, including 3TGs.
H02050 requires all suppliers to:
| • | Adopt a company policy for raw material sourcing, including a commitment to source raw materials from responsible sources and clearly communicate such policy to their suppliers and the public; |
| • | Exercise due diligence on the source and chain of custody of high-risk raw materials, including 3TGs, contained in materials, products, or parts supplied to Microsoft; |
| • | Identify each SOR that has processed or otherwise handled 3TGs contained in those materials, products, or parts; |
| • | Encourage those SORs to participate in the Responsible Mining Assurance Program (“RMAP”) or an equivalent independent, third-party audit program for 3TGs; |
| • | Confirm that 3TGs in their supply chain are sourced from available SORs that are conformant with the RMAP or an equivalent independent, third-party audit program for 3TGs; and |
| • | Timely communicate potential sourcing risks to Microsoft and propose a contingency plan and mitigation strategy to achieve conformance. |
Suppliers are required to establish a system to gather, examine, and verify traceability information of raw materials, including 3TGs, and request their upstream suppliers to disclose the location of extraction or harvesting activities or recycling sources in the raw material supply chain. Suppliers are required to engage with upstream suppliers to identify any potential responsible sourcing risks in their supply chains. Suppliers are required to assess and address responsible sourcing risks in their supply chains by reviewing relevant audit information, publicly available policies and reports, and by conducting a systematic third-party risk analysis.
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This transfer of material declaration data, source and chain of custody information, and risk assessment procedures across the raw material supply chain enables and facilitates raw material due diligence, mapping, and transparency. This system of supply chain controls allows Microsoft to establish and enforce its responsible sourcing policies and specifications throughout its supply chain to verify the conformance status of SORs.
If we find that a supplier has introduced responsible sourcing risk to the Microsoft supply chain, such as use of an upstream SOR that does not conform to Microsoft’s requirements, Microsoft engages with such supplier 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 and Microsoft internal operating procedures.
| 4. | Leveraging Industry Partnerships for Greater Impact |
We recognize that some supply chain due diligence challenges require industry-wide efforts and, as such, we leverage partnerships with industry peers and partners to scale our impact on a global scale. Microsoft is a long-standing member of the Responsible Business Alliance (“RBA”). In 2008, RBA initiated the Conflict Free Smelter Initiative, which is now known as the Responsible Minerals Initiative (“RMI”). The RMI is one of the most utilized and respected resources for supply chain minerals due diligence and is aligned to the OECD Guidance. The RMI operates and manages the RMAP, which uses independent, third-party audits to assess, monitor, and validate whether SORs process 3TGs from sources that directly or indirectly finance or benefit armed groups in a CAHRA, including Covered Countries. In 2020, Microsoft continued to provide direct financial support to the RMI upstream smelter due diligence fund to help further the reach and success of the RMI’s Responsible Minerals Assurance Process (RMAP).
Microsoft works with its in-scope suppliers to promote their use of SORs that are conformant to RMAP or another equivalent independent, third-party audit program for 3TGs. If a supplier does not commit to sourcing from a conformant SOR 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.
We also work outside of our supply chain to promote responsible mining practices in CAHRAs, including Covered Countries, by partnering with organizations, including the RMI, the Initiative for Responsible Mining Assurance (“IRMA”), the Public-Private Alliance for Responsible Minerals Trade (“PPA”), and others. In this manner, we go beyond the minimum due diligence established by the OECD Guidance to assess and reduce our supply chain sourcing risk and improve working conditions in raw material supply chains.
Global supply chain due diligence faced a unique challenge in 2020 when the COVID-19 pandemic (and its resulting global restrictions on travel) disrupted the auditing and verification process that is necessary for raw material sourcing due diligence. To meet this challenge, Microsoft supported an IRMA initiative that worked to continue the critical work of raw material sourcing due diligence in spite of COVID-19 travel restrictions. With Microsoft’s financial support, IRMA explored alternatives to in-person audits to enhance mining assurance programs and review mine performance. IRMA focused on filling gaps in the monitoring process, which is critical to ensuring purchaser confidence,
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positively contributing to environmental and social well-being, and reducing the risk of irresponsible mining practices. Simultaneously, also with Microsoft’s support, IRMA focused on developing enhanced distance-learning protocols that helped build the capacity of both mining companies and auditors, thereby, strengthening environmental and social responsibility during the COVID crisis.
| 5. | Supplier Engagement to Ensure Conformance |
We work closely with our in-scope suppliers to ensure that they share and extend our responsible sourcing commitment to their upstream suppliers. The RMI’s Reasonable Practices to Identify Sources of Conflict Minerals: Practical Guidance for Downstream Companies states, “all of the [OECD Guidance’s] red flag triggers are contained in the upstream portion of the supply chain (e.g., SORs and mine of origin).” Because these supply chain “red flag triggers” are associated with upstream sources rather than downstream manufacturers, such as Microsoft, we mitigate raw material sourcing risks by working with our in-scope suppliers to identify SORs, encourage those SORs to become conformant to RMAP or another independent third-party audit program, or use an alternate SOR that is conformant. We also participate in industry-wide initiatives that assess SOR conformance with the OECD 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 by using contractual provisions and Microsoft specifications. We conduct audits of our contracted suppliers to verify conformance to those requirements. We also use tools that include supplier capability building and supplier training, and we support broader industry efforts to promote responsible mining and sourcing. More information on these supplier engagement tools 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 (detailed above). We communicate, monitor, and track supplier adherence to these requirements, ensuring conformance through the Microsoft Audit Management System (“AMS”) and maintain supplier records for a minimum of five years. |
| • | Training: We train our in-scope suppliers to meet our responsible sourcing requirements through classes, educational forums, and direct communications. Leveraging the online component of our “SEA Academy” to scale social and environmental accountability training, we educate factory management, workers and third-party auditors as well as internal Microsoft teams with the goal of increasing sustainability and promoting aligned collaboration throughout our supply chain. The SEA Academy is part of the supplier on- boarding process. Existing suppliers and newly onboarded suppliers are required to complete the Supplier SEA mandatory courses to understand and implement Microsoft SEA requirements. |
| • | Capability Building and Partnerships: We work closely with our in-scope suppliers and third- party auditors to build suppliers’ raw material due diligence capabilities and advance conformance. We invest in industry programs, such as the RMAP, to increase suppliers’ abilities and provide platforms for sharing best practices. The Microsoft SEA Academy provides on-line training modules aimed at building our suppliers’ capabilities. |
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| • | Supplier Audits and Conformance Assurance: Microsoft requires audits of its directly contracted suppliers to assess their conformance to Microsoft requirements. Newly contracted suppliers undergo an Initial Capability Assessment (“ICA”) prior to onboarding and Sustaining Maintenance Audits (“SMA”) after onboarding on an annual, biannual, or triannual basis, depending on their risk level, to verify their initial conformance and to confirm their sustained conformance to our requirements (audits are conducted by Microsoft auditors or through an industry audit program). Suppliers must establish and maintain a corporate policy and effective procedures for the responsible sourcing of raw materials across their supply chains. Microsoft selects and retains business partners that have committed to meet these requirements. A failure by a supplier or their upstream suppliers to conform to these requirements may constitute a breach of the supplier’s contractual agreement with Microsoft and may result in business termination. |
| 6. | Grievance Mechanism |
Microsoft is committed to providing an anonymous grievance reporting mechanism for our employees and other stakeholders who may be impacted by our operations. Microsoft’s Business Conduct Hotline allows employees and others to anonymously ask compliance questions or report concerns regarding Microsoft’s business operations, including our responsible sourcing of raw materials policy, or those of our suppliers. Additionally, Microsoft continues to scale its Worker Voice Hotline Program4 in our supplier factories. This program provides workers with a reliable and anonymous reporting channel for raising workplace concerns. The Hotline is operated by a neutral third-party provider. We investigate and, where appropriate, take remedial action to address reported issues. We also participate in the development of industry grievance mechanisms that seek to address responsible sourcing of raw materials related issues.
| B. | Step #2: Identify and Assess Risk in the Supply Chain |
In order to make an RCOI determination for purposes of the Rule, Microsoft took the following steps, which are consistent with the OECD Guidance and our internal policies and procedures, to identify and assess 3TG sourcing risk in our supply chain during the 2020 Reporting Year:
| • | Following the Rule and SEC guidance, we generated a list of in-scope suppliers, consisting of suppliers with which we directly contracted for the manufacture of our covered devices during the 2020 Reporting Year. |
| • | We surveyed those in-scope suppliers to determine whether they used any 3TGs in the products or parts supplied to Microsoft during the 2020 Reporting Year by utilizing the CMRT and the services of a third-party solution provider. |
| • | Based on our suppliers’ CMRT responses, we excluded suppliers that did not report the use of 3TGs in the products or parts supplied to Microsoft during the 2020 Reporting Year from our in-scope supplier list. |
| 4 | Please see page 42 of our FY20 Devices Sustainability Report for more details regarding our Workers’ Voice Hotline Program. |
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| • | We reviewed all in-scope supplier CMRT responses to validate their completion and to identify any contradictions or inconsistencies. We worked with our third-party solution provider to obtain updated responses from suppliers when necessary. |
| • | For the 2020 Reporting Year, we identified 186 in-scope suppliers. Of the 186 in-scope suppliers, we received CMRT responses from 185 of those suppliers – a 99.5% response rate. Of those 185 suppliers, 136 reported the use of 3TGs in the products or parts supplied to Microsoft during the 2020 Reporting Year. From the CMRTs received from the 185 in-scope suppliers, 336 potential SORs were reported as processing 3TGs, including 3TGs sourced from Covered Countries, in Microsoft Devices for the 2020 Reporting Year. Of those 336 potential SORs, 301 were found to be eligible for the RMAP or an equivalent, independent, third-party audit program for 3TGs such as cross-recognized programs overseen by the London Bullion Market Association (“LBMA”) or Responsible Jewellery Council (“RJC”).5 |
Figure 1. Response Rate for In-scope Suppliers (2013-2020 Reporting Years)
| C. | Step #3: Design and Implement a Strategy to Respond to Risks |
Due to our RCOI, we determined that the 3TGs that were necessary to the functionality or production of covered devices during the 2020 Reporting Year may have originated in one or more Covered Country and may not have been from recycled or scrap sources. Accordingly, we designed and performed due diligence on the source and chain-of-custody of those 3TGs to assess our conflict minerals sourcing risk.
| 5 | Of the 35 SORs reported for the 2020 Reporting Year that are Not Eligible per RMAP SOR status designation (see p. 12), 9 were previously Eligible but have become “Not Eligible” between the end of 2020 and the time of reporting. |
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| 1. | Microsoft Supplier Specifications – H00594, H00642, and H02050 |
For the 2020 Reporting Year, Microsoft required its in-scope suppliers to conduct due diligence to address the potential sourcing of 3TGs from CAHRAs, including Covered Countries, through contract requirements incorporating Microsoft’s supplier specifications and responsible sourcing requirements as detailed above.
| 2. | Implementation of OECD Guidance |
The OECD Guidance applies to suppliers operating in a CAHRA or potentially supplying or using 3TGs from a CAHRA, including a Covered Country. The Guidance states that companies should review their mineral or metal sourcing practices to determine if the Guidance applies to them. The following “red flags” are listed as triggering OECD due diligence procedures:
| • | 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; |
| • | The company’s 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 company’s suppliers or other known upstream companies were known to have sourced minerals from a red flag location of mineral origin and transit during the last 12 months. |
Microsoft screened its in-scope supplier CMRT data for the 2020 Reporting Year against these ”red flag” triggers to assess the in-scope suppliers that required due diligence per the OECD Guidance.
| D. | Step #4: Independent Third-Party Audits of Supply Chain Due Diligence |
As contemplated by Step #4 of the OECD Guidance, our due diligence program leveraged independent SOR audits to provide assurance that the 3TG SORs that were identified in our supply chain for the 2020 Reporting Year conducted an appropriate level of conflict minerals due diligence. Microsoft obtained SOR data from the RMAP Conformant Smelter List6 using Reasonable Country of Origin Inquiry Data for member MSFT and used the SOR data to assess the conflict mineral audit status of our in-scope suppliers and to support our due diligence findings. Microsoft also participated in RMAP’s Smelter Engagement Team during the 2020 Reporting Year to promote SOR conformance.
| 6 | The RMAP Conformant Smelter list identifies the SORs that have undergone conformance audits through the RMAP or equivalent independent, third-party audit programs for 3TGs. |
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Microsoft’s Responsible Sourcing program includes an escalation process that requires an in-scope supplier to find alternative upstream suppliers if it is found to be sourcing from a non-conformant SOR or risk termination as a Microsoft supplier. We contact all non-conformant SORs identified in our supply chain each Reporting Year and encourage such SORs to participate in the RMAP. We also require suppliers reporting non-conformant SORs to contact these SORs and require such SORs to join the RMAP. We actively support outreach events to increase RMAP SOR conformance.
Recognizing the importance of broad and consistent participation in the RMAP program, Microsoft has begun to proactively engage directly with certain SORs where it is believed that a SOR is at risk of becoming non-conformant. Microsoft also asks its suppliers to engage directly with potentially non-conformant SORs in order to prevent the potential non-conformance from occurring and to develop Corrective Action Plans (“CAPs”) to identify sourcing alternatives in case the SORs become non-conformant. The goal is to establish an efficient and effective plan to remove potentially non-conformant SORs from our supply chain should any non-conformance occur. Although Microsoft’s Responsible Sourcing program already operates an escalation and engagement process should non-conformant SORs be detected, taking a proactive approach to potentially non-conformant SORs helps prevent potential non-conformances from occurring. Providing direct Microsoft and supplier feedback to SORs on the importance of RMAP participation and conformance leverages market-based incentives to ensure continued participation. During the 2020 Reporting Year, we did not identify a SOR nonconformance that supported business termination with any in-scope supplier.
| E. | Step #5: Report on Supply Chain Due Diligence |
Per the Rule, we have filed our CMR with the SEC and concurrently posted it on our Microsoft Devices Responsible Sourcing website. The results of our Responsible Sourcing program are also presented in Microsoft’s FY20 Devices Sustainability Report. The Microsoft Corporate Social Responsibility website provides additional information about Microsoft’s RSRM Program. Microsoft Devices requires our suppliers to implement high standards for responsible sourcing. Each year, Microsoft Devices publishes a list of its Top 100 Production Suppliers. Our FY20 Devices Sustainability Report also contains information regarding our RSRM program, including details regarding our sourcing of cobalt. These disclosures meet the fifth step of the OECD Guidance.
| III. | CONFLICT MINERAL DISCLOSURE |
| A. | 3TG SORs Identified in Microsoft Devices’ Supply Chain |
Our 2020 Reporting Year supply chain due diligence identified 336 potential SORs that were named by our in-scope suppliers as processing 3TGs. We verified that the identified SORs were actual SORs and eligible to participate in the RMAP audit program or an equivalent independent, third-party audit program for 3TGs. After verification, we validated the SOR data by removing duplicate SORs, reconciling multiple SOR names for a single entity, and eliminating otherwise invalid SOR names. Through this reconciliation process, we determined that 301 Eligible SORs processed 3TGs in Microsoft Devices’ supply chain during the 2020 Reporting Year.
| B. | Reasonable Countries of Origin of 3TGs |
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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 for the 301 Eligible SORs identified in Microsoft Devices’ 2020 supply chain. The RMAP classifies SOR audit status in the manner described in the table below. The breakdown of the identified 301 Eligible 3TG SORs (for which minerals sourcing information was available from RMAP or an equivalent, independent, third-party audit program for 3TGs) by their RMI Status is as follows:
| Audit Status |
Audit Status Description |
SORs | % | |||||
| Conformant | SOR has been audited and found to conform with a relevant, third-party audit protocol, including RMAP, London Bullion Market Association (“LBMA”), or Responsible Jewellery Council (“RJC”) | 237 | 78.7 | % | ||||
| Non-Conformant | SOR was audited but found not to conform to a relevant, third-party audit protocol or failed to renew its assessment | 8 | 2.7 | % | ||||
| Active | SOR has been engaged but is not yet conformant | 12 | 4.0 | % | ||||
| Communication Suspended | Not Interested: SOR has strongly communicated a lack of interest in participation | 4 | 1.3 | % | ||||
| Outreach Required | SOR is not yet active and outreach is needed by RMAP member companies to encourage SOR participation in RMAP | 36 | 12.0 | % | ||||
| In Communication | SOR is not yet active but is in communication with RMAP and/or member company | 2 | 0.7 | % | ||||
| 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 | 2 | 0.7 | % | ||||
Additionally, for the identified 301 Eligible 3TG SORs (for which minerals sourcing information was available from RMAP or an equivalent, independent, third-party audit program for 3TGs):
| • | 51 SORs (16.9%) sourced from Covered Countries, of which 48 (94.1%) were Conformant, 2 (3.9%) were Active, and 1 (2.0%) Required Outreach; and |
| • | 103 SORs (34.1%) processed recycled or scrap material. |
Based on this due diligence assessment, Microsoft found no reasonable basis for concluding that any SOR sourced 3TGs in a manner that directly or indirectly financed or benefitted armed groups in a Covered Country. The Figures below provide a visual depiction of the Eligible 301 SORs identified in Microsoft Devices’ 2020 Reporting Year supply chain by 3TG RMAP audit status (or by status to third party audit standards recognized by RMAP, including the LBMA and/or RJC). Figure 2 categorizes the SORs by 3TG audit status and Reporting Year. Figure 3 categorizes the SORs by 3TG mineral and audit status for the 2020 Reporting Year.
12
Figure 2. Identified SORs by Audit Status (2013-2020 Reporting Years)
Figure 3: Identified SORs by 3TG and Audit Status for 2020 Reporting Year
Figures 4-7 show the geographic distribution of the 301 Eligible SORs identified in the Microsoft Devices’ supply chain by 3TG mineral for the 2020 Reporting Year. The circle size corresponds to the relative number of times our in-scope suppliers identified each 3TG SOR in their CMRT form.
13
Figure 4: Location and Relative Number of Identified SORs – Tin
Figure 5: Location and Relative Number of Identified SORs – Tantalum
14
Figure 6: Location and Relative Number of Identified SORs – Tungsten
Figure 7: Location and Relative Number of Identified SORs – Gold
15
Appendix A provides the complete list of 301 Eligible SORs identified in Microsoft Devices’ supply chain which processed 3TGs during the 2020 Reporting Year. Appendix A lists each SOR by mineral, official name, and country of operation.
| C. | 3TG Countries of Origin |
The table below lists the countries of origin (source of raw material) for the 301 Eligible SORs identified in Microsoft Devices’ supply chain which processed 3TGs during the 2020 Reporting Year.
| Angola | Laos | |
| Argentina | Luxembourg | |
| Armenia | Madagascar | |
| Australia | Malaysia | |
| Austria | Mali | |
| Belarus | Mexico | |
| Belgium | Mongolia | |
| Bermuda | Morocco | |
| Bolivia | Mozambique | |
| Brazil | Myanmar | |
| Burundi | Namibia | |
| Cambodia | Netherlands | |
| Canada | New Zealand | |
| Central African Republic | Niger | |
| Chile | Nigeria | |
| China | Papua New Guinea | |
| Columbia | Peru | |
| Congo, Democratic Republic of the | Philippines | |
| Congo, Republic of the | Poland | |
| Czech Republic | Portugal | |
| Côte d’Ivoire | Russia | |
| Djibouti | Rwanda | |
| Ecuador | Saudi Arabia | |
| Egypt | Sierra Leone | |
| Estonia | Singapore | |
| Ethiopia | Slovakia | |
| Finland | South Africa | |
| France | South Sudan | |
| Germany | Spain | |
| Ghana | Suriname | |
| Guinea | Sweden | |
| Guyana | Switzerland | |
| Hong Kong | Taiwan | |
| Hungary | Tajikistan | |
| India | Tanzania | |
| Indonesia | Thailand | |
| Ireland | Turkey |
16
| Israel | Uganda | |
| Italy | United Arab Emirates | |
| Japan | United Kingdom | |
| Jersey | United States of America | |
| Kazakhstan | Uzbekistan | |
| Kenya | Vietnam | |
| Korea, Republic Of | Zambia | |
| Kyrgyzstan | Zimbabwe |
| IV. | IMPROVEMENTS |
Each year, we incorporate improvements in the implementation of our RSRM policy to responsibly source raw materials used in our manufactured products Our 2020 Reporting Year improvements included the following:
| • | We achieved our commitment to transparency by publicly reporting our responsible sourcing efforts and our RSRM programs; |
| • | We continued our support of our suppliers to increase their responsible sourcing capabilities through supplier forums, webinars, in-person trainings, and by providing technical resources; |
| • | We deepened and extended our engagements with external responsible sourcing organizations, including but not limited to the RMI, that are committed to advancing responsible sourcing on a global basis; |
| • | We expanded our supplier outreach effort through a supplementary outreach campaign to directly contact suppliers and encourage reporting; |
| • | We implemented a pilot program to randomly audit CMRT information submitted to us by suppliers to validate and confirm that the data we are reporting is as accurate and complete as possible; |
| • | We expanded our due diligence program across all in-scope suppliers to capture data on our sourcing of additional priority minerals including aluminum, cobalt, copper, lithium, magnesium, and nickel. |
| V. | FUTURE ACTIONS |
Microsoft is committed to the responsible sourcing of raw materials in support of human rights; labor, health and safety; and environmental protection. We will continue to advance implementation of our RSRM policy in our Devices’ supply chain to promote supply chain identification, traceability, risk assessment, and due diligence. Going forward, Microsoft will remain focused on internal and external
17
efforts to promote the responsible sourcing of minerals from CAHRAs, including Covered Countries, and pursue the following objectives:
| • | Expand our knowledge about 3TGs, cobalt, and other critical raw materials in order to effectively implement our RSRM strategy to promote the responsible sourcing of raw materials across our hardware supply chains for Surface, Xbox , and Hololen devices; |
| • | Require our in-scope suppliers to meet our requirements for responsibly sourcing raw materials and finding alternative upstream suppliers if they are found to be sourcing from non-conformant SORs; |
| • | Engage with our in-scope suppliers so that they utilize supplier best practices and tools for responsibly sourcing raw materials from CAHRAs, including Covered Countries; |
| • | Use digital technology to improve supply chain information and risk mitigation; |
| • | Further our engagement and partnerships with industry organizations and NGOs to improve mineral traceability, establish global responsible sourcing standards, and support due diligence programs in the mineral supply chain; |
| • | Leverage Full Material Disclosure and other supplier data to fine-tune supplier data requests and verify and confirm reported critical raw matrial information; and |
| • | Support the efforts of the RMI in developing the Minerals Agnostic Standard and Minerals Agnostic Reporting Template (“MART”), anticipated to be released in late 2021, which will significantly expand the scope of industry-wide minerals due diligence. |
18
APPENDIX A
Eligible SORs in Microsoft Devices’ Supply Chain for 2020 Reporting Year
This Appendix lists the 301 Eligible SORs which were identified in Microsoft Devices’ supply chain and which processed 3TGs during the 2020 Reporting Year. Please note that Eligible SORs are listed for each 3TG they processed. Therefore, certain Eligible SORs may be represented more than once.
| Mineral |
Official Name |
Country of Operation | ||
| Gold |
8853 S.p.A. | Italy | ||
| Tungsten |
A.L.M.T. Corp. | Japan | ||
| Gold |
Abington Reldan Metals, LLC | United States | ||
| Tungsten |
ACL Metais Eireli | Brazil | ||
| Gold |
Advanced Chemical Company | United States | ||
| Gold |
African Gold Refinery | Uganda | ||
| Gold |
Aida Chemical Industries Co., Ltd. | Japan | ||
| Gold |
Al Etihad Gold Refinery DMCC | United Arab Emirates | ||
| Tungsten |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | ||
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | ||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Tin |
Alpha | United States | ||
| Tantalum |
AMG Brasil | Brazil | ||
| Tin |
An Vinh Joint Stock Mineral Processing Company | Viet Nam | ||
| Gold |
AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | ||
| Gold |
Argor-Heraeus S.A. | Switzerland | ||
| Gold |
Asahi Pretec Corp. | Japan | ||
| Gold |
Asahi Refining Canada Ltd. | Canada | ||
| Gold |
Asahi Refining USA Inc. | United States | ||
| Gold |
Asaka Riken Co., Ltd. | Japan | ||
| Tantalum |
Asaka Riken Co., Ltd. | Japan | ||
| Tungsten |
Asia Tungsten Products Vietnam Ltd. | Viet Nam | ||
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||
| Gold |
AU Traders and Refiners | South Africa | ||
| Gold |
Aurubis AG | Germany | ||
| Gold |
Bangalore Refinery | India | ||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold |
Boliden AB | Sweden | ||
| Gold |
C. Hafner GmbH + Co. KG | Germany | ||
| Gold |
Caridad | Mexico | ||
| Gold |
CCR Refinery - Glencore Canada Corporation | Canada | ||
| Gold |
Cendres + Metaux S.A. | Switzerland | ||
| Gold |
CGR Metalloys Pvt Ltd. | India | ||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. | China | ||
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. | China |
A-1
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. | China | ||
| Gold |
Chimet S.p.A. | Italy | ||
| Tungsten |
China Molybdenum Co., Ltd. | China | ||
| Tin |
China Tin Group Co., Ltd. | China | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||
| Gold |
Chugai Mining | Japan | ||
| Tungsten |
CNMC (Guangxi) PGMA Co., Ltd. | China | ||
| Tin |
CV Ayi Jaya | Indonesia | ||
| Tin |
CV Venus Inti Perkasa | Indonesia | ||
| Tantalum |
D Block Metals, LLC | United States | ||
| Gold |
Daye Non-Ferrous Metals Mining Ltd. | China | ||
| Gold |
Degussa Sonne / Mond Goldhandel GmbH | Germany | ||
| Gold |
Dijllah Gold Refinery FZC | United Arab Emirates | ||
| Gold |
DODUCO Contacts and Refining GmbH | Germany | ||
| Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | ||
| Gold |
Dowa | Japan | ||
| Tin |
Dowa | Japan | ||
| Gold |
DSC (Do Sung Corporation) | Korea | ||
| Gold |
Eco-System Recycling Co., Ltd. East Plant | Japan | ||
| Gold |
Eco-System Recycling Co., Ltd. North Plant | Japan | ||
| Gold |
Eco-System Recycling Co., Ltd. West Plant | Japan | ||
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | ||
| Tin |
EM Vinto | Bolivia | ||
| Gold |
Emirates Gold DMCC | United Arab Emirates | ||
| Tin |
Estanho de Rondonia S.A. | Brazil | ||
| Tantalum |
Exotech Inc. | United States | ||
| Tantalum |
F&X Electro-Materials Ltd. | China | ||
| Tin |
Fenix Metals | Poland | ||
| Tantalum |
FIR Metals & Resource Ltd. | China | ||
| Gold |
Fujairah Gold FZC | United Arab Emirates | ||
| Tungsten |
Fujian Ganmin RareMetal Co., Ltd. | China | ||
| Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. | China | ||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. | China | ||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. | China | ||
| Gold |
GCC Gujrat Gold Centre Pvt. Ltd. | India | ||
| Gold |
Geib Refining Corporation | United States | ||
| Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | ||
| Tin |
Gejiu Fengming Metallurgy Chemical Plant | China | ||
| Tin |
Gejiu Kai Meng Industry and Trade LLC | China | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
A-2
| Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. | China | ||
| Tantalum |
Global Advanced Metals Aizu | Japan | ||
| Tantalum |
Global Advanced Metals Boyertown | United States | ||
| Tungsten |
Global Tungsten & Powders Corp. | United States | ||
| Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. | China | ||
| Gold |
Great Wall Precious Metals Co., Ltd. of CBPM | China | ||
| Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | ||
| Gold |
Guangdong Jinding Gold Limited | China | ||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. | China | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH | Germany | ||
| Tantalum |
H.C. Starck Inc. | United States | ||
| Tungsten |
H.C. Starck Tungsten GmbH | Germany | ||
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||
| Gold |
Heimerle + Meule GmbH | Germany | ||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||
| Gold |
Heraeus Metals Hong Kong Ltd. | China | ||
| Gold |
Heraeus Germany GmbH & Co. KG | Germany | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd. | China | ||
| Gold |
Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. | China | ||
| Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | ||
| Gold |
HwaSeong CJ CO., LTD. | Korea | ||
| Tungsten |
Hydrometallurg, JSC | Russia | ||
| Gold |
Industrial Refining Company | Belgium | ||
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||
| Gold |
International Precious Metal Refiners | United Arab Emirates | ||
| Gold |
Ishifuku Metal Industry Co., Ltd. | Japan | ||
| Gold |
Istanbul Gold Refinery | Turkey | ||
| Gold |
Italpreziosi | Italy | ||
| Gold |
JALAN & Company | India | ||
| Gold |
Japan Mint | Japan | ||
| Tungsten |
Japan New Metals Co., Ltd. | Japan | ||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||
| Gold |
Jiangxi Copper Co., Ltd. | China | ||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||
| Tungsten |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | ||
| Tin |
Jiangxi New Nanshan Technology Ltd. | China | ||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||
| Tantalum |
Jiangxi Tuohong New Raw Material | China | ||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
A-3
| Tantalum |
Jiujiang Tanbre Co., Ltd. | China | ||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||
| Tungsten |
JSC “Kirovgrad Hard Alloys Plant” | Russia | ||
| Gold |
JSC Novosibirsk Refinery | Russia | ||
| Gold |
JSC Uralelectromed | Russia | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd. | Japan | ||
| Gold |
Kaloti Precious Metals | United Arab Emirates | ||
| Gold |
Kazakhmys Smelting LLC | Kazakhstan | ||
| Gold |
Kazzinc | Kazakhstan | ||
| Tantalum |
KEMET Blue Metals | Mexico | ||
| Tungsten |
Kennametal Fallon | United States | ||
| Tungsten |
Kennametal Huntsville | United States | ||
| Gold |
Kennecott Utah Copper LLC | United States | ||
| Tungsten |
KGETS Co., Ltd. | Korea | ||
| Gold |
KGHM Polska Miedz Spolka Akcyjna | Poland | ||
| Gold |
Kojima Chemicals Co., Ltd. | Japan | ||
| Gold |
Korea Zinc Co., Ltd. | Korea | ||
| Gold |
Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold |
Kyshtym Copper-Electrolytic Plant ZAO | Russia | ||
| Gold |
L’azurde Company For Jewelry | Saudi Arabia | ||
| Tungsten |
Lianyou Metals Co., Ltd. | Taiwan | ||
| Gold |
Lingbao Gold Co., Ltd. | China | ||
| Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | ||
| Gold |
L’Orfebre S.A. | Andorra | ||
| Gold |
LS-NIKKO Copper Inc. | Korea | ||
| Gold |
LT Metal Ltd. | Korea | ||
| Tin |
Luna Smelter, Ltd. | Rwanda | ||
| Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | ||
| Tin |
Ma’anshan Weitai Tin Co., Ltd. | China | ||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||
| Tin |
Malaysia Smelting Corporation (MSC) | Malaysia | ||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. | China | ||
| Gold |
Marsam Metals | Brazil | ||
| Tungsten |
Masan Tungsten Chemical LLC (MTC) | Viet Nam | ||
| Gold |
Materion | United States | ||
| Gold |
Matsuda Sangyo Co., Ltd. | Japan | ||
| Tin |
Melt Metais e Ligas S.A. | Brazil | ||
| Tantalum |
Meta Materials | Macedonia | ||
| Tin |
Metallic Resources, Inc. | United States | ||
| Tin |
Metallo Belgium N.V. | Belgium | ||
| Tin |
Metallo Spain S.L.U. | Spain | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd. | India | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd. | China | ||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
A-4
| Gold |
Metalor Technologies (Suzhou) Ltd. | China | ||
| Gold |
Metalor Technologies S.A. | Switzerland | ||
| Gold |
Metalor USA Refining Corporation | United States | ||
| Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | ||
| Tin |
Mineracao Taboca S.A. | Brazil | ||
| Tantalum |
Mineracao Taboca S.A. | Brazil | ||
| Tin |
Minsur | Peru | ||
| Gold |
Mitsubishi Materials Corporation | Japan | ||
| Tin |
Mitsubishi Materials Corporation | Japan | ||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Gold |
MMTC-PAMP India Pvt., Ltd. | India | ||
| Tin |
Modeltech Sdn Bhd | Malaysia | ||
| Gold |
Modeltech Sdn Bhd | Malaysia | ||
| Tungsten |
Moliren Ltd. | Russia | ||
| Gold |
Morris and Watson | New Zealand | ||
| Gold |
Moscow Special Alloys Processing Plant | Russia | ||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | ||
| Gold |
Navoi Mining and Metallurgical Combinat | Uzbekistan | ||
| Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | ||
| Gold |
NH Recytech Company | Korea | ||
| Tungsten |
Niagara Refining LLC | United States | ||
| Gold |
Nihon Material Co., Ltd. | Japan | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | China | ||
| Tin |
Novosibirsk Processing Plant Ltd. | Russia | ||
| Tantalum |
NPM Silmet AS | Estonia | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin |
O.M. Manufacturing Philippines, Inc. | Philippines | ||
| Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||
| Gold |
Ohura Precious Metal Industry Co., Ltd. | Japan | ||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russia | ||
| Tin |
Operaciones Metalurgicas S.A. | Bolivia | ||
| Gold |
PAMP S.A. | Switzerland | ||
| Gold |
Pease & Curren | United States | ||
| Gold |
Penglai Penggang Gold Industry Co., Ltd. | China | ||
| Tungsten |
Philippine Chuangxin Industrial Co., Inc. | Philippines | ||
| Gold |
Planta Recuperadora de Metales SpA | Chile | ||
| Tin |
Pongpipat Company Limited | Myanmar | ||
| Tin |
Precious Minerals and Smelting Limited | India | ||
| Gold |
Prioksky Plant of Non-Ferrous Metals | Russia | ||
| Gold |
PT Aneka Tambang (Persero) Tbk | Indonesia | ||
| Tin |
PT Aries Kencana Sejahtera | Indonesia | ||
| Tin |
PT Artha Cipta Langgeng | Indonesia |
A-5
| Tin |
PT ATD Makmur Mandiri Jaya | Indonesia | ||
| Tin |
PT Babel Inti Perkasa | Indonesia | ||
| Tin |
PT Babel Surya Alam Lestari | Indonesia | ||
| Tin |
PT Bangka Serumpun | Indonesia | ||
| Tin |
PT Bukit Timah | Indonesia | ||
| Tin |
PT Lautan Harmonis Sejahtera | Indonesia | ||
| Tin |
PT Menara Cipta Mulia | Indonesia | ||
| Tin |
PT Mitra Stania Prima | Indonesia | ||
| Tin |
PT Prima Timah Utama | Indonesia | ||
| Tin |
PT Rajawali Rimba Perkasa | Indonesia | ||
| Tin |
PT Rajehan Ariq | Indonesia | ||
| Tin |
PT Refined Bangka Tin | Indonesia | ||
| Tin |
PT Stanindo Inti Perkasa | Indonesia | ||
| Tin |
PT Timah Tbk Kundur | Indonesia | ||
| Tin |
PT Timah Tbk Mentok | Indonesia | ||
| Tin |
PT Tinindo Inter Nusa | Indonesia | ||
| Gold |
PX Precinox S.A. | Switzerland | ||
| Gold |
QG Refining, LLC | United States | ||
| Tantalum |
QuantumClean | United States | ||
| Gold |
Rand Refinery (Pty) Ltd. | South Africa | ||
| Gold |
Refinery of Seemine Gold Co., Ltd. | China | ||
| Gold |
REMONDIS PMR B.V. | Netherlands | ||
| Tin |
Resind Industria e Comercio Ltda. | Brazil | ||
| Tantalum |
Resind Industria e Comercio Ltda. | Brazil | ||
| Gold |
Royal Canadian Mint | Canada | ||
| Tin |
Rui Da Hung | Taiwan | ||
| Gold |
SAAMP | France | ||
| Gold |
Sabin Metal Corp. | United States | ||
| Gold |
Safimet S.p.A | Italy | ||
| Gold |
SAFINA A.S. | Czech Republic | ||
| Gold |
Sai Refinery | India | ||
| Gold |
Samduck Precious Metals | Korea | ||
| Gold |
Samwon Metals Corp. | Korea | ||
| Gold |
SAXONIA Edelmetalle GmbH | Germany | ||
| Gold |
SEMPSA Joyeria Plateria S.A. | Spain | ||
| Gold |
Shandong Gold Smelting Co., Ltd. | China | ||
| Gold |
Shandong Humon Smelting Co., Ltd. | China | ||
| Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||
| Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | ||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. | China | ||
| Gold |
Singway Technology Co., Ltd. | Taiwan | ||
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals | Russia | ||
| Tin |
Soft Metais Ltda. | Brazil |
A-6
| Gold |
Solar Applied Materials Technology Corp. | Taiwan | ||
| Tantalum |
Solikamsk Magnesium Works OAO | Russia | ||
| Gold |
Sovereign Metals | India | ||
| Gold |
State Research Institute Center for Physical Sciences and Technology | Lithuania | ||
| Gold |
Sumitomo Metal Mining Co., Ltd. | Japan | ||
| Gold |
SungEel HiMetal Co., Ltd. | Korea | ||
| Tin |
Super Ligas | Brazil | ||
| Gold |
T.C.A S.p.A | Italy | ||
| Tantalum |
Taki Chemical Co., Ltd. | Japan | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K. | Japan | ||
| Tantalum |
TANIOBIS Co., Ltd. | Thailand | ||
| Tantalum |
TANIOBIS GmbH | Germany | ||
| Tantalum |
TANIOBIS Japan Co., Ltd. | Japan | ||
| Tantalum |
TANIOBIS Smelting GmbH & Co. KG | Germany | ||
| Tungsten |
TANIOBIS Smelting GmbH & Co. KG | Germany | ||
| Tantalum |
Telex Metals | United States | ||
| Tin |
Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | ||
| Tin |
Thaisarco | Thailand | ||
| Tin |
Tin Technology & Refining | United States | ||
| Gold |
Tokuriki Honten Co., Ltd. | Japan | ||
| Gold |
Tongling Nonferrous Metals Group Co., Ltd. | China | ||
| Gold |
TOO Tau-Ken-Altyn | Kazakhstan | ||
| Gold |
Torecom | Korea | ||
| Gold |
TSK Pretech | Korea | ||
| Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | ||
| Tantalum |
Ulba Metallurgical Plant JSC | Kazakhstan | ||
| Gold |
Umicore Precious Metals Thailand | Thailand | ||
| Gold |
Umicore S.A. Business Unit Precious Metals Refining | Belgium | ||
| Tungsten |
Unecha Refractory metals plant | Russia | ||
| Gold |
United Precious Metal Refining, Inc. | United States | ||
| Gold |
Valcambi S.A. | Switzerland | ||
| Gold |
Western Australian Mint (T/a The Perth Mint) | Australia | ||
| Tin |
White Solder Metalurgia e Mineracao Ltda. | Brazil | ||
| Gold |
WIELAND Edelmetalle GmbH | Germany | ||
| Tungsten |
Wolfram Bergbau und Hutten AG | Austria | ||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. | China | ||
| Tungsten |
Xiamen Tungsten Co., Ltd. | China | ||
| Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED | China | ||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | ||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. | China | ||
| Gold |
Yamakin Co., Ltd. | Japan | ||
| Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | ||
| Gold |
Yokohama Metal Co., Ltd. | Japan | ||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
A-7
| Gold |
Yunnan Copper Industry Co., Ltd. | China | ||
| Tin |
Yunnan Tin Company Limited | China | ||
| Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
A-8