Document





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

Specialized Disclosure Report


https://cdn.kscope.io/8b83a16226607a886e2167094dca909e-micronnamea051.jpg
MICRON TECHNOLOGY, INC.
(Exact name of registrant as specified in its charter)

Delaware1-1065875-1618004
(State or other jurisdiction of incorporation)(Commission File Number)(I.R.S. Employer Identification No.)

8000 South Federal Way
Boise, Idaho 83716-9632
(Address of principal executive offices)

David A. Zinsner
Senior Vice President and Chief Financial Officer
(208) 368-4000
(Name and telephone number, including area code, of the person to contact in connection with this 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 and Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.










Section 1 - Conflict Minerals Disclosure

Item 1.01.Conflict Minerals Disclosure and Report.

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), we conducted a reasonable country of origin inquiry (“RCOI”) to assess whether conflict minerals necessary to the functionality or production of products we manufactured or contracted to manufacture in calendar year 2019 originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) or were from recycled or scrap sources. The Rule defines conflict minerals as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives (tin, tantalum, and tungsten).

Based on the results of our RCOI, we have reason to believe that certain conflict minerals contained in our 2019 products may have originated in the Covered Countries and may not have been from recycled or scrap sources. We therefore conducted due diligence on the source and chain of custody of these minerals and prepared a Conflict Minerals Report, filed as Exhibit 1.01 hereto.

Conflict Minerals Disclosure

A copy of the Conflict Minerals Report for the calendar year ended December 31, 2019 is available on our website at http://www.micron.com/about/our-commitment/sourcing-responsibly/responsible-minerals-policy.

Item 1.02.Exhibit.

The Conflict Minerals Report for the calendar year ended December 31, 2019 is filed as Exhibit 1.01 hereto.


Section 2 - Exhibits

Item 2.01.Exhibits.

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.




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.

MICRON TECHNOLOGY, INC.
Date:May 28, 2020By:/s/ David A. Zinsner
Name:David A. Zinsner
Title:Senior Vice President and Chief Financial Officer


Document

Exhibit 1.01

Micron Technology, Inc.
Conflict Minerals Report
Calendar Year 2019

We1 prepared this Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). This CMR covers the calendar year reporting period ended December 31, 20192 and is filed as an exhibit to our Form SD. This CMR includes a description of the measures we have taken to exercise due diligence on the source and chain of custody of conflict minerals3 (specifically gold, and the derivatives tin, tantalum, and tungsten (collectively “3TG”)) necessary to the functionality or production of our memory and storage products4 manufactured during the year ended December 31, 2019.

Overview of Our Commitment to Responsible Sourcing:

In support of global responsible sourcing, we are committed to monitoring our supply chain with a goal to ensure that conflict minerals directly or indirectly supporting civil violence or human rights abuses in the Democratic Republic of the Congo (“DRC”) or adjoining countries are not used in the manufacture of Micron products. We also believe that responsible sourcing means continuing to support stable economic development in the DRC region (rather than a DRC embargo), and accordingly we do not prohibit our suppliers from using 3TG metals sourced from the region. Our conflict mineral supply chain monitoring program is consistent with 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 integrates tools developed by the Responsible Minerals Initiative (“RMI”).

Micron is a founding member of the Responsible Minerals Initiative, RMI (member ID MICR). We continue to support the RMI and its Responsible Minerals5 third-party auditing program, the Responsible Minerals Assurance Process (“RMAP”), as part of our commitment to drive ethical sourcing of 3TG metals throughout our supply chain. In 2019, we continued working with RMI and provided leadership through multiple RMI leadership working groups, including the Smelter Engagement, Multi-Stakeholder, Gold, Due Diligence Practices, Minerals Reporting Template and Plenary Working Groups. The Plenary Working Group is tasked with defining future directions, protocol, procedures, issue resolutions, recognition of other reporting organizations, training, oversight, and smelter and refiner engagements. To learn more about RMI’s initiatives to help companies achieve a responsible minerals supply chain and the Responsible Minerals Assurance Process visit: http://www.responsiblemineralsinitiative.org/.



__________________________
In this CMR, unless otherwise indicated or the context otherwise requires, “we,” “us,” “our,” “Micron,” and the “Company” refers to Micron Technology, Inc. and its subsidiaries.
Unless otherwise noted, any designation of years refers to calendar years.
Conflict minerals are those minerals regulated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. They include columbite-tantalite, also known as coltan (and its derivative tantalum); cassiterite (and its derivative tin); wolframite (and its derivative tungsten); and gold.
Memory and storage products include NAND, DRAM, NOR and 3D XPoint components, and products we sell that contain such components. The term “memory and storage products” does not include custom tools we make for our own use or sell to our former joint venture partner. Memory and storage products accounted for more than 99% of our revenue during 2019.
The term “Responsible Minerals” herein means the relevant smelters or refiners are verified as Conformant with the RMI’s RMAP or an equivalent third-party auditing program.



Micron’s Responsible Minerals Policy is published at https://www.micron.com/about/our-commitment/sourcing-responsibly/responsible-minerals-policy. To learn more about our conflict minerals supplier requirements, see our Micron Supplier Requirements Standard (“SRS”) at https://www.micron.com/about/our-commitment/sourcing-responsibly/suppliers. The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.

Overview of Micron’s Conflict Minerals Program:

We require our suppliers6 to source conflict minerals from smelters and refiners validated as Conformant7 with responsible minerals sourcing standards (such as the RMAP or standards enacted by the London Bullion Market Association (“LBMA”) or the Responsible Jewellery Council (“RJC”)). To ensure our suppliers meet our SRS requirements for responsible minerals sourcing, we make all suppliers aware of our commitment to responsible sourcing and our expectation that all smelters and refiners in our supply chain are Conformant with responsible minerals sourcing standards; conduct ongoing due diligence on the source and chain of custody of conflict minerals in our supply chain in conformance with the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas; encourage suppliers to adopt responsible sourcing practices; and collaborate with industry stakeholders through our leadership in the RMI. To further transparency in the conflict mineral supply chain, in addition to publicly reporting the results of our due diligence efforts annually, we share our due diligence results directly with our customers.

In 2019, we required all new suppliers to take a Supplier Compliance Training, which helped increase awareness of and focus on our requirement that Micron suppliers may only use Conformant smelters and refiners. As a result, during 2019 and for the third consecutive year, no supplier within our memory and storage products supply chain proposed adding any non-Conformant smelters or refiners. We also maintained our resolution process to quickly identify and remove smelters and refiners from our supply chain when they drop out of the RMI, LBMA or RJC programs and thus become non-Conformant.

Based on the information provided by our suppliers and our due diligence efforts through December 31, 2019, we identified a total of 240 smelters and refiners we believe were in our memory and storage products supply chain at any point during the year ended December 31, 2019, all of which were validated as Conformant at the time they entered our supply chain. 37 smelters and refiners that were reported to be in our memory and storage products supply chain during 2019 were subsequently determined to be inoperative or removed on or prior to December 31, 2019. Accordingly, we determined that 203 smelters and refiners were in our memory and storage products supply chain as of December 31, 2019, all of which were validated as Conformant.

1. Our Outreach to Suppliers and Reasonable Country of Origin Inquiry

Our goal is to ensure that all 3TG metals in our supply chain are sourced through responsible minerals smelters and refiners. In furtherance of that goal, we require that each supplier in our memory and storage products supply chain must participate in our Supplier Management Performance process. This process begins with our annual submission of an inquiry letter to our suppliers (including a link to the RMI Conflict Minerals Reporting Template (“CMRT”)). Through the CMRT we request information from suppliers regarding their 3TG supply chains, including the names and locations of smelters and refiners of 3TG as well as the country of origin of 3TG processed by such smelters and refiners. We then ask that suppliers review and acknowledge our Responsible Minerals Policy and our SRS, which sets out our expectations that all smelters and refiners in our supply chain are, and remain, validated as Conformant.
__________________________
The term “supplier(s)” refers to both incumbent and new suppliers and manufacturers that are likely to provide us with products containing 3TG metals that are necessary to the function or manufacture of our memory and storage products.
The term “Conformant” means that smelters or refiners are verified as Conformant with the RMI’s RMAP or an equivalent third-party auditing program.

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We applied our Supplier Management Performance process to each new supplier as they were added to our memory and storage products supply chain throughout the year and required all new suppliers to complete our formal Supplier Compliance Training program.

We make our suppliers aware that smelters and refiners that fail to become Conformant in one or more responsible sourcing auditing programs will be targeted for removal from our memory and storage products supply chain. In addition, the terms and conditions we include with every Micron purchase order further reinforce our responsible sourcing expectations and requirements with direct reference to our SRS. Throughout 2019, we worked with our suppliers to help raise awareness of our expectations, provide ongoing education concerning our requirements, and provide training through our risk mitigation and escalation process.

Our outreach to suppliers, which included our reasonable country of origin inquiry, did not provide us with complete information on the origin of 3TG from smelters and refiners reported to be in our memory and storage products supply chain in 2019. We had reason to believe, however, that at least some sourcing was from the DRC and adjoining countries. Accordingly, we conducted due diligence on the chain and custody of 3TG and prepared this Conflict Minerals Report.

2. Our Conflict Minerals Due Diligence Program

2.1 Our Conflict Minerals Due Diligence Program Design

We have designed our conflict minerals due diligence program in conformance with the principles of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) and the supplements thereto as applied to downstream companies.

2.2 Our Conflict Minerals Due Diligence for 2019 Products

2.2.1 Our Management System

For the year ended December 31, 2019, management of our conflict minerals program was provided by a cross-functional Conflict Minerals Steering Team, with representatives from Micron’s Procurement, Supply Chain, Quality, Finance, Sales, Sustainability and Legal departments, headed by a Senior Procurement Compliance Manager. The Steering Team met at least monthly during the year ended December 31, 2019 to review progress towards maintaining our goal of a responsibly-sourced supply chain. Oversight of the Conflict Minerals Steering Team was provided by a cross-functional Conflict Minerals Executive Team comprised of Vice President-level executives, which is charged with sponsoring and reviewing our conflict minerals program. The Steering Team reported to the Executive Team on a monthly basis during the year ended December 31, 2019. In addition, our Global Supply Chain Compliance Council, which includes a subset of our Conflict Minerals Executive Team, is charged with direct oversight of our responsible sourcing program. During the year ended December 31, 2019, the Steering Team reported to the Global Supply Chain Compliance Council quarterly to review our progress towards our goal of achieving a responsibly-sourced supply chain.

We also continued to incorporate our conflict minerals supplier requirements (i.e., that suppliers must report 100% of their supply chain and only source from Conformant smelters and refiners) into the terms and conditions of our purchase orders and supplier agreements, and maintained internal and third-party access to our ethics and compliance hotline, which can be used to report issues relating to conflict minerals. Our program included a ten-year record retention policy for our conflict minerals documents.

2.2.2 Our Risk Assessment

We collected, screened and analyzed CMRTs from all 3TG-exposed suppliers for the year ended December 31, 2019. We provided our suppliers with formal notification of Micron’s requirements to convey our expectations that they report to us, within fourteen days of any such occurrence, any changes to their supply chains that would affect their CMRT status.

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2.2.3 Our Risk Management

We reviewed all CMRT responses and updates received for the year ended December 31, 2019 and determined whether the disclosed smelters or refiners were recognized by RMI or equivalents as processors of 3TG metals, and if so, whether they had been validated as Conformant with these organizations. We reviewed supplier CMRTs for accuracy and overall adherence to our conflict minerals requirements, as delivered through our inquiry letter to suppliers, and we began our risk mitigation (and escalation processes, if necessary) set out in our conflict minerals procedures with suppliers having disclosed any smelters or refiners that were not Conformant. If a supplier reports a CMRT that includes smelters or refiners not yet listed as Conformant, we implement our risk mitigation procedures, beginning with direct outreach to the supplier and escalating discussions up the management structure of our respective companies. We work with these suppliers throughout the risk mitigation process to provide awareness of Micron’s goal to only source from Conformant smelters or refiners. During the year ended December 31, 2019, zero suppliers in our memory and storage products supply chain reported smelters or refiners not yet validated as Conformant in a responsible minerals auditing program. 37 smelters and refiners that were reported to be in our memory and storage products supply chain during 2019 were subsequently determined to be inoperative or removed on or prior to December 31, 2019.

We are members of multiple RMI working groups, including the RMI Smelter Engagement Working Group, which was tasked with identifying and influencing smelters in the supply chains of RMI members to join the RMAP and become validated as responsibly sourced. Micron also has additional RMI formal representation and leadership positions on multiple RMI working groups, including the Multi-Stakeholder, Due Diligence Practices, Minerals Reporting Template, Gold and Plenary Working Groups. Through our membership dues, we provide funding to DRC in-region agencies.

2.2.4 Smelter and Refiner Auditing

As we do not source 3TG metals directly from smelters or refiners, we rely on independent third-party auditing programs, such as the RMAP, LBMA, and RJC to coordinate audits of smelters and refiners in our memory and storage products supply chain.

2.2.5 Reporting

We report our annual due diligence results in our conflict minerals program to the U.S. Securities and Exchange Commission through the Form SD and the CMR. We make the CMR available on our company website.

3. Our Product Descriptions

Overview

We offer a broad portfolio of semiconductor memory and storage products. We conducted due diligence, as described in this CMR, to try to determine the source and chain of custody of the necessary 3TG metals contained in these memory and storage products. Our management assessment process led us to believe that at least some sourcing is from the DRC and adjoining countries. We were unable to determine the country of origin of some of the 3TG metals contained in memory and storage products we manufactured and sold during the year ended December 31, 2019 and/or whether some of the memory and storage products we manufactured and sold during the year ended December 31, 2019 contain 3TG metals that may have directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.

Description of Memory and Storage Products

During the year ended December 31, 2019, we manufactured or contracted to manufacture the following memory and storage products containing 3TG metals.


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Dynamic Random Access Memory (“DRAM”)

DRAM products are high-density, random access memory devices that provide high-speed data storage and retrieval with a variety of performance, pricing, and other characteristics.

Wafer, Component, and Module DRAM: Wafer, component, and module DRAM products offer high speed and bandwidth, primarily for use in computers, servers, networking devices, communications equipment, consumer electronics, automotive, and industrial applications.

Graphics DRAM: DRAM graphics products are high-performance, high-bandwidth, cost-effective memory products for use in applications such as game consoles, PC graphics cards and graphics processing unit-based data center solutions.

LPDRAM: LPDRAM products offer lower power consumption relative to other DRAM products and are used primarily in smartphones, tablets, automotive applications, laptop computers, and other mobile consumer devices that require low power consumption.

NAND

NAND products are electrically re-writeable, non-volatile semiconductor memory and storage devices that retain content when power is turned off. NAND is ideal for mass-storage devices due to its fast erase and write times, high density, and low cost per bit relative to other solid-state memory technologies. NAND-based storage devices are utilized in smartphones, SSDs, tablets, computers, automotive and industrial applications, networking, and other consumer applications. Removable storage devices, such as USB and Flash memory cards, are used with applications such as PCs, digital still cameras, and smartphones.

Wafer and Component NAND: Wafer and component NAND products are sold in component and wafer forms to various customers and partners that then incorporate these products into their end products.

Solid State Drives (“SSDs”): SSDs incorporate NAND, a controller, and firmware and are a significant portion of our net sales. We offer client, cloud, enterprise, and automotive SSDs which feature higher performance, reduced-power consumption, and enhanced reliability as compared to typical hard disk drives.

Multi-Chip Packages (“MCPs”) and Managed NAND: MCP products combine DRAM, NAND, and/or NOR and in some cases also include a controller and firmware. Our managed NAND includes e.MMC and universal flash storage (“UFS”) solutions, each of which combine high-capacity NAND with a high-speed controller and firmware in a small ball-grid array, and eMCP products, which combine an e.MMC/UFS solution with LPDRAM.

NOR Flash

NOR Flash products are electrically re-writeable semiconductor memory devices that offer fast read times and are used in automotive, industrial, connected home, and consumer applications.

3D XPoint Memory

3D XPoint is a category of non-volatile memory, which uses an innovative, transistor-less, cross point architecture to create a three-dimensional checkerboard where memory cells sit at the intersection of word lines and bit lines, allowing the cells to be addressed individually. As a result, data can be written and read in small sizes, leading to fast and efficient read/write processes. 3D XPoint technology has higher chip density than DRAM, and compared to NAND, has up to 1,000 times lower latency and exponentially greater endurance.


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Reported Smelters and Refiners Used to Process 3TG Metals

We identified 240 smelters and refiners that are recognized by RMI, LBMA or RJC to be processors of 3TG metals and that we believe were potentially in our memory and storage products supply chain for the year ended December 31, 2019. All of these smelters and refiners were validated as Conformant with a responsibly-sourced auditing program, though 37 smelters and refiners that were reported to be in our memory and storage products supply chain during 2019 were subsequently determined to be inoperative or removed on or prior to December 31, 2019. Many of our suppliers reported smelter and refiner information at the company level rather than limiting their responses to smelters and refiners associated with products sold to Micron. As a result, some reported smelters and refiners may not be associated with our memory and storage products. Appendix A sets forth a list of the names, locations, and status of all of the smelters and refiners in our memory and storage products supply chain as reported by our suppliers for the year ended December 31, 2019.

Throughout 2019, we worked with our suppliers in an effort to source only from smelters and refiners that were validated as Conformant with a responsibly-sourced auditing program. As of December 31, 2019, our memory and storage products supply chain included 203 smelters and refiners, all of which were validated as Conformant.

Aggregated Countries of Origin of 3TG Metals

Our due diligence efforts did not result in sufficient information to conclusively determine the countries of origin of all 3TG metals in our products due to the fact that the RJC does not report country of origin information for smelters and refiners that participate in its programs. Appendix B sets forth a list of countries of origin of 3TG metals that may be in our products based on information provided to us by our suppliers and RMI, which is available to us (and is therefore being disclosed) on an aggregated basis only for RMAP Conformant smelters.

Efforts to Determine the Mine or Location of Origin

RMI has an established audit protocol to assess whether smelters and refiners of 3TG metals employed policies, practices, and procedures to source responsibly-sourced minerals. RMI, through the RMAP, collects and provides access for its members to certain information regarding the origin of minerals processed at RMAP responsibly-sourced smelters and refiners.

We required the suppliers in our memory and storage products supply chain to complete the RMI CMRT, which requested information regarding the mine or location of origin of necessary conflict minerals processed by the smelters and refiners our suppliers identified as potentially associated with our 3TG metals supply chain. We reviewed the supplier responses as well as information available through the RMI on the mine or location of origin of 3TG metals processed by these smelters and refiners collectively. Because we were unable to confirm the supplier data, our list of the countries of origin in Appendix B reflects the aggregated list of countries provided by RMI for RMAP responsibly-sourced smelters and refiners.

4. 2020 Due Diligence Improvement Measures

During the 2020 reporting year, Micron intends to:

Continue to engage with and provide active participation and leadership in the various RMI working groups;

Continue to proactively work with all suppliers in an effort to accomplish our goal that all smelters and refiners in our supply chain are Conformant;

Continue to refine and improve our escalation processes to ensure quick remediation, including removal, of any smelter or refiner that loses Conformant status; and

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Expand our conflict minerals program to a broader Responsible Sourcing program designed to ensure responsible sourcing of additional minerals and include more geographies as solutions are deployed and implemented through RMI.

*****
This Conflict Minerals Report contains forward looking statements related to our conflict minerals diligence programs for 2020. We wish to caution you that such statements are predictions and that actual events or results may differ materially. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, levels of activity, performance or achievements. We are under no duty to update any of the forward-looking statements after the date of this Report to conform these statements to actual results.

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Appendix A
Reported 3TG Smelters and Refiners List

This table provides the names, locations, and status of all of the smelters and refiners in our memory and storage products supply chain as reported by our suppliers for the year ended December 31, 2019. The smelter and refiner names, locations, and status appear as they are listed in the RMI Smelter Database as of January 17, 2020. We cannot confirm that any or all smelters and refiners in this table processed the necessary 3TG metals contained in our products, as many of our in scope suppliers identified all smelters and refiners in their total supply chain rather than just those smelters and refiners associated with products sold to us.

Smelters and refiners noted with an asterisk (*) in this table represent the 37 smelters and refiners that were reported to be in our memory and storage products supply chain during 2019 and were subsequently determined to be inoperative or removed on or prior to December 31, 2019. Up-to-date information on the validation status of smelters and refiners participating in the RMAP is available at http://www.responsiblemineralsinitiative.org/smelters-refiners-lists.

MetalSmelter or Refinery NameLocationStatus
Gold8853 S.p.A.ItalyConformant
GoldAdvanced Chemical CompanyUnited StatesConformant
GoldAl Etihad Gold Refinery DMCC*United Arab EmiratesNon Conformant
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GermanyConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanConformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilConformant
GoldArgor-Heraeus S.A.SwitzerlandConformant
GoldAsahi Pretec Corp.JapanConformant
GoldAsahi Refining Canada Ltd.CanadaConformant
GoldAsahi Refining USA Inc.United StatesConformant
GoldAU Traders and RefinersSouth AfricaConformant
GoldAurubis AGGermanyConformant
GoldBangalore RefineryIndiaConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesConformant
GoldBoliden ABSwedenConformant
GoldC. Hafner GmbH + Co. KGGermanyConformant
GoldCCR Refinery - Glencore Canada CorporationCanadaConformant
GoldCendres + Metaux S.A.SwitzerlandConformant
GoldChimet S.p.A.ItalyConformant
GoldDowaJapanConformant
GoldEco-System Recycling Co., Ltd. East PlantJapanConformant
GoldEmirates Gold DMCCUnited Arab EmiratesConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaConformant
GoldHeimerle + Meule GmbHGermanyConformant
GoldHeraeus Metals Hong Kong Ltd.ChinaConformant
GoldHeraeus Precious Metals GmbH & Co. KGGermanyConformant



MetalSmelter or Refinery NameLocationStatus
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaConformant
GoldIshifuku Metal Industry Co., Ltd.JapanConformant
GoldIstanbul Gold RefineryTurkeyConformant
GoldItalpreziosiItalyConformant
GoldJapan MintJapanConformant
GoldJiangxi Copper Co., Ltd.ChinaConformant
GoldJSC UralelectromedRussiaConformant
GoldJX Nippon Mining & Metals Co., Ltd.JapanConformant
GoldKazzincKazakhstanConformant
GoldKennecott Utah Copper LLCUnited StatesConformant
GoldKGHM Polska Miedz Spolka AkcyjnaPolandConformant
GoldKojima Chemicals Co., Ltd.JapanConformant
GoldKorea Zinc Co., Ltd.South KoreaConformant
GoldKyrgyzaltyn JSCKyrgyzstanConformant
GoldL'Orfebre S.A.AndorraConformant
GoldLS-NIKKO Copper Inc.South KoreaConformant
GoldLT Metal Ltd.South KoreaConformant
GoldMarsam MetalsBrazilConformant
GoldMaterionUnited StatesConformant
GoldMatsuda Sangyo Co., Ltd.JapanConformant
GoldMetalor Technologies (Hong Kong) Ltd.ChinaConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeConformant
GoldMetalor Technologies (Suzhou) Ltd.ChinaConformant
GoldMetalor Technologies S.A.SwitzerlandConformant
GoldMetalor USA Refining CorporationUnited StatesConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoConformant
GoldMitsubishi Materials CorporationJapanConformant
GoldMitsui Mining and Smelting Co., Ltd.JapanConformant
GoldMMTC-PAMP India Pvt., Ltd.IndiaConformant
GoldMoscow Special Alloys Processing PlantRussiaConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyConformant
GoldNihon Material Co., Ltd.JapanConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RussiaConformant
GoldOJSC Novosibirsk RefineryRussiaConformant
GoldPAMP S.A.SwitzerlandConformant
GoldPlanta Recuperadora de Metales SpAChileConformant
GoldPrioksky Plant of Non-Ferrous MetalsRussiaConformant
GoldPT Aneka Tambang (Persero) TbkIndonesiaConformant
GoldPX Precinox S.A.SwitzerlandConformant
GoldRand Refinery (Pty) Ltd.South AfricaConformant



MetalSmelter or Refinery NameLocationStatus
GoldREMONDIS PMR B.V.NetherlandsConformant
GoldRoyal Canadian MintCanadaConformant
GoldSAAMPFranceConformant
GoldSafimet S.p.AItalyConformant
GoldSamduck Precious MetalsSouth KoreaConformant
GoldSAXONIA Edelmetalle GmbHGermanyConformant
GoldSEMPSA Joyeria Plateria S.A.SpainConformant
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaConformant
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaConformant
GoldSingway Technology Co., Ltd.TaiwanConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussiaConformant
GoldSolar Applied Materials Technology Corp.TaiwanConformant
GoldSumitomo Metal Mining Co., Ltd.JapanConformant
GoldT.C.A S.p.AItalyConformant
GoldTanaka Kikinzoku Kogyo K.K.JapanConformant
GoldThe Refinery of Shandong Gold Mining Co., Ltd.ChinaConformant
GoldTokuriki Honten Co., Ltd.JapanConformant
GoldUmicore Brasil Ltda.BrazilConformant
GoldUmicore Precious Metals ThailandThailandConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumConformant
GoldUnited Precious Metal Refining, Inc.United StatesConformant
GoldValcambi S.A.SwitzerlandConformant
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaConformant
GoldWIELAND Edelmetalle GmbHGermanyConformant
GoldYamakin Co., Ltd.JapanConformant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaConformant
TantalumD Block Metals, LLCUnited StatesConformant
TantalumExotech Inc.United StatesConformant
TantalumF&X Electro-Materials Ltd.ChinaConformant
TantalumFIR Metals & Resource Ltd.ChinaConformant
TantalumGlobal Advanced Metals AizuJapanConformant
TantalumGlobal Advanced Metals BoyertownUnited StatesConformant
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.*ChinaConformant
TantalumGuangdong Zhiyuan New Material Co., Ltd.ChinaConformant
TantalumH.C. Starck Co., Ltd.ThailandConformant
TantalumH.C. Starck Hermsdorf GmbHGermanyConformant
TantalumH.C. Starck Inc.United StatesConformant
TantalumH.C. Starck Ltd.JapanConformant
TantalumH.C. Starck Smelting GmbH & Co. KGGermanyConformant
TantalumH.C. Starck Tantalum and Niobium GmbHGermanyConformant



MetalSmelter or Refinery NameLocationStatus
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaConformant
TantalumJiangxi Tuohong New Raw MaterialChinaConformant
TantalumJiujiang Janny New Material Co., Ltd.*ChinaConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaConformant
TantalumJiujiang Tanbre Co., Ltd.ChinaConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaConformant
TantalumKEMET Blue MetalsMexicoConformant
TantalumKEMET Blue PowderUnited StatesConformant
TantalumLSM Brasil S.A.BrazilConformant
TantalumMetallurgical Products India Pvt., Ltd.IndiaConformant
TantalumMineracao Taboca S.A.BrazilConformant
TantalumMitsui Mining and Smelting Co., Ltd.JapanConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaConformant
TantalumNPM Silmet AS*EstoniaConformant
TantalumPRG DooelNorth MacedoniaConformant
TantalumResind Industria e Comercio Ltda.BrazilConformant
TantalumSolikamsk Magnesium Works OAORussiaConformant
TantalumTaki Chemical Co., Ltd.JapanConformant
TantalumTelex MetalsUnited StatesConformant
TantalumUlba Metallurgical Plant JSCKazakhstanConformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaConformant
TinAlphaUnited StatesConformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaConformant
TinChina Tin Group Co., Ltd.ChinaConformant
TinCV Ayi Jaya*IndonesiaConformant
TinCV Dua Sekawan*IndonesiaConformant
TinCV Gita Pesona*IndonesiaConformant
TinCV United Smelting*IndonesiaConformant
TinCV Venus Inti Perkasa*IndonesiaConformant
TinEM VintoBoliviaConformant
TinFenix MetalsPolandConformant
TinGejiu Fengming Metallurgy Chemical PlantChinaConformant
TinGejiu Jinye Mineral Company*ChinaNon Conformant
TinGejiu Kai Meng Industry and Trade LLCChinaConformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaConformant



MetalSmelter or Refinery NameLocationStatus
TinGuanyang Guida Nonferrous Metal Smelting PlantChinaConformant
TinHuiChang Hill Tin Industry Co., Ltd.ChinaConformant
TinHuichang Jinshunda Tin Co., Ltd.ChinaConformant
TinJiangxi New Nanshan Technology Ltd.ChinaConformant
TinMagnu's Minerais Metais e Ligas Ltda.BrazilConformant
TinMalaysia Smelting Corporation (MSC)MalaysiaConformant
TinMelt Metais e Ligas S.A.BrazilConformant
TinMetallic Resources, Inc.United StatesConformant
TinMetallo Belgium N.V.BelgiumConformant
TinMetallo Spain S.L.U.SpainConformant
TinMineracao Taboca S.A.BrazilConformant
TinMinsurPeruConformant
TinModeltech Sdn Bhd*MalaysiaNon Conformant
TinOperaciones Metalurgicas S.A.BoliviaConformant
TinPT Aries Kencana Sejahtera*IndonesiaConformant
TinPT Artha Cipta LanggengIndonesiaConformant
TinPT ATD Makmur Mandiri Jaya*IndonesiaConformant
TinPT Babel Inti Perkasa*IndonesiaConformant
TinPT Bangka Prima Tin*IndonesiaConformant
TinPT Bangka Serumpun*IndonesiaConformant
TinPT Bangka Tin Industry*IndonesiaConformant
TinPT Belitung Industri Sejahtera*IndonesiaConformant
TinPT Bukit Timah*IndonesiaConformant
TinPT DS Jaya Abadi*IndonesiaConformant
TinPT Inti Stania Prima*IndonesiaConformant
TinPT Karimun Mining*IndonesiaConformant
TinPT Kijang Jaya Mandiri*IndonesiaConformant
TinPT Lautan Harmonis Sejahtera*IndonesiaConformant
TinPT Menara Cipta Mulia*IndonesiaConformant
TinPT Mitra Stania PrimaIndonesiaConformant
TinPT Panca Mega Persada*IndonesiaConformant
TinPT Premium Tin Indonesia*IndonesiaConformant
TinPT Prima Timah Utama*IndonesiaConformant
TinPT Rajehan Ariq*IndonesiaConformant
TinPT Refined Bangka TinIndonesiaConformant
TinPT Sariwiguna Binasentosa*IndonesiaConformant
TinPT Stanindo Inti Perkasa*IndonesiaConformant
TinPT Sukses Inti Makmur*IndonesiaConformant
TinPT Sumber Jaya Indah*IndonesiaConformant
TinPT Timah Tbk KundurIndonesiaConformant
TinPT Timah Tbk MentokIndonesiaConformant



MetalSmelter or Refinery NameLocationStatus
TinPT Tinindo Inter Nusa*IndonesiaConformant
TinPT Tommy Utama*IndonesiaConformant
TinResind Industria e Comercio Ltda.BrazilConformant
TinRui Da HungTaiwanConformant
TinSoft Metais Ltda.BrazilConformant
TinThai Nguyen Mining and Metallurgy Co., Ltd.VietnamConformant
TinThaisarcoThailandConformant
TinTin Technology & RefiningUnited StatesConformant
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaConformant
TinYunnan Tin Company LimitedChinaConformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.*ChinaConformant
TungstenA.L.M.T. Corp.JapanConformant
TungstenACL Metais EireliBrazilConformant
TungstenAsia Tungsten Products Vietnam Ltd.VietnamConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.ChinaConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaConformant
TungstenFujian Jinxin Tungsten Co., Ltd.ChinaConformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaConformant
TungstenGlobal Tungsten & Powders Corp.United StatesConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaConformant
TungstenH.C. Starck Tungsten GmbHGermanyConformant
TungstenHunan Chenzhou Mining Co., Ltd.ChinaConformant
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiChinaConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.ChinaConformant
TungstenHydrometallurg, JSCRussiaConformant
TungstenJapan New Metals Co., Ltd.JapanConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaConformant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaConformant
TungstenKennametal FallonUnited StatesConformant
TungstenKennametal HuntsvilleUnited StatesConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaConformant
TungstenMasan Tungsten Chemical LLC (MTC)VietnamConformant
TungstenMoliren Ltd.RussiaConformant
TungstenNiagara Refining LLCUnited StatesConformant



MetalSmelter or Refinery NameLocationStatus
TungstenSouth-East Nonferrous Metal Company Limited of Hengyang City*ChinaNon Conformant
TungstenTejing (Vietnam) Tungsten Co., Ltd.VietnamConformant
TungstenUnecha Refractory metals plantRussiaConformant
TungstenWolfram Bergbau und Hutten AGAustriaConformant
TungstenWoltech Korea Co., Ltd.South KoreaConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaConformant
TungstenXiamen Tungsten Co., Ltd.ChinaConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.ChinaConformant
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.ChinaConformant




Appendix B
Aggregated Countries of Origin List

This table sets forth an aggregated list of countries of origin for 3TG metals that may be in our products based on information available from RMI on countries of origin for smelters or refiners that have been validated as Conformant with the RMAP. Due to confidential business information concerns, RMI provides this country of origin information on an aggregated basis. This table reflects information available from RMI as of December 31, 2019. This table does not include country of origin information for any smelters or refiners that have been validated as Conformant solely through the RJC, of which there were nine smelters or refiners as of December 31, 2019.

ArgentinaGuyanaPanama
ArmeniaHondurasPapua New Guinea
AustraliaHong KongPeru
AustriaHungaryPhilippines
AzerbaijanIcelandPoland
BahamasIndiaPortugal
BarbadosIndonesiaPuerto Rico
BelarusIranRomania
BelgiumIrelandRussia
BeninIsraelRwanda
BoliviaItalySan Marino
BoliviaIvory CoastSaudi Arabia
Bosnia and HerzegovinaJapanSenegal
BotswanaJordanSerbia
BrazilKazakhstan Sierra Leone
BulgariaKenyaSingapore
Burkina FasoSouth KoreaSlovakia
BurundiKosovoSlovenia
CambodiaKuwaitSolomon Islands
CameroonKyrgyzstanSomalia
CanadaLaosSouth Africa
Cayman IslandsLatviaSpain
ChileLebanonSuriname
ChinaLiberiaSwaziland
ColombiaLibyaSweden
Democratic Republic of the CongoLiechtensteinSwitzerland
CroatiaLithuaniaTaiwan
Curacao (Dutch Antilles)LuxembourgTajikistan
CyprusMacauTanzania
Czech RepublicMadagascarThailand
DenmarkMalaysiaTogo
Dominican RepublicMaliTrinidad and Tobago



EcuadorMaltaTunisia
EgyptMauritaniaTurkey
El SalvadorMauritiusUganda
EritreaMexicoUkraine
EstoniaMongoliaUnited Arab Emirates
EthiopiaMoroccoUnited Kingdom
FijiMozambiqueUnited States
FinlandMyanmarUruguay
FranceNamibiaUzbekistan
GabonNetherlandsVatican City
Gambia, TheNew CaledoniaVenezuela
GeorgiaNew ZealandVietnam
GermanyNicaraguaYemen
GhanaNigerZambia
GreeceNigeriaZimbabwe
GuatemalaNorway
GuineaPakistan