SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Specialized Disclosure Report
|MICRON TECHNOLOGY, INC.|
|(Exact name of registrant as specified in its charter)|
|(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
|(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.
The Conflict Minerals Report for the calendar year ended December 31, 2019 is filed as Exhibit 1.01 hereto.
Section 2 - Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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, 2020||By:||/s/ David A. Zinsner|
|Name:||David A. Zinsner|
|Title:||Senior Vice President and Chief Financial Officer|
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/.
1 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.
2 Unless otherwise noted, any designation of years refers to calendar years.
3 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.
4 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.
5 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.
6 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.
7 The term “Conformant” means that smelters or refiners are verified as Conformant with the RMI’s RMAP or an equivalent third-party auditing program.
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.
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.
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
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.
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 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 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.
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
•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.
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.
|Metal||Smelter or Refinery Name||Location||Status|
|Gold||Advanced Chemical Company||United States||Conformant|
|Gold||Al Etihad Gold Refinery DMCC*||United Arab Emirates||Non Conformant|
|Gold||Allgemeine Gold-und Silberscheideanstalt A.G.||Germany||Conformant|
|Gold||Almalyk Mining and Metallurgical Complex (AMMC)||Uzbekistan||Conformant|
|Gold||AngloGold Ashanti Corrego do Sitio Mineracao||Brazil||Conformant|
|Gold||Asahi Pretec Corp.||Japan||Conformant|
|Gold||Asahi Refining Canada Ltd.||Canada||Conformant|
|Gold||Asahi Refining USA Inc.||United States||Conformant|
|Gold||AU Traders and Refiners||South Africa||Conformant|
|Gold||Bangko Sentral ng Pilipinas (Central Bank of the Philippines)||Philippines||Conformant|
|Gold||C. Hafner GmbH + Co. KG||Germany||Conformant|
|Gold||CCR Refinery - Glencore Canada Corporation||Canada||Conformant|
|Gold||Cendres + Metaux S.A.||Switzerland||Conformant|
|Gold||Eco-System Recycling Co., Ltd. East Plant||Japan||Conformant|
|Gold||Emirates Gold DMCC||United Arab Emirates||Conformant|
|Gold||Gold Refinery of Zijin Mining Group Co., Ltd.||China||Conformant|
|Gold||Heimerle + Meule GmbH||Germany||Conformant|
|Gold||Heraeus Metals Hong Kong Ltd.||China||Conformant|
|Gold||Heraeus Precious Metals GmbH & Co. KG||Germany||Conformant|
|Metal||Smelter or Refinery Name||Location||Status|
|Gold||Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.||China||Conformant|
|Gold||Ishifuku Metal Industry Co., Ltd.||Japan||Conformant|
|Gold||Istanbul Gold Refinery||Turkey||Conformant|
|Gold||Jiangxi Copper Co., Ltd.||China||Conformant|
|Gold||JX Nippon Mining & Metals Co., Ltd.||Japan||Conformant|
|Gold||Kennecott Utah Copper LLC||United States||Conformant|
|Gold||KGHM Polska Miedz Spolka Akcyjna||Poland||Conformant|
|Gold||Kojima Chemicals Co., Ltd.||Japan||Conformant|
|Gold||Korea Zinc Co., Ltd.||South Korea||Conformant|
|Gold||LS-NIKKO Copper Inc.||South Korea||Conformant|
|Gold||LT Metal Ltd.||South Korea||Conformant|
|Gold||Matsuda Sangyo Co., Ltd.||Japan||Conformant|
|Gold||Metalor Technologies (Hong Kong) Ltd.||China||Conformant|
|Gold||Metalor Technologies (Singapore) Pte., Ltd.||Singapore||Conformant|
|Gold||Metalor Technologies (Suzhou) Ltd.||China||Conformant|
|Gold||Metalor Technologies S.A.||Switzerland||Conformant|
|Gold||Metalor USA Refining Corporation||United States||Conformant|
|Gold||Metalurgica Met-Mex Penoles S.A. De C.V.||Mexico||Conformant|
|Gold||Mitsubishi Materials Corporation||Japan||Conformant|
|Gold||Mitsui Mining and Smelting Co., Ltd.||Japan||Conformant|
|Gold||MMTC-PAMP India Pvt., Ltd.||India||Conformant|
|Gold||Moscow Special Alloys Processing Plant||Russia||Conformant|
|Gold||Nadir Metal Rafineri San. Ve Tic. A.S.||Turkey||Conformant|
|Gold||Nihon Material Co., Ltd.||Japan||Conformant|
|Gold||Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH||Austria||Conformant|
|Gold||OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)||Russia||Conformant|
|Gold||OJSC Novosibirsk Refinery||Russia||Conformant|
|Gold||Planta Recuperadora de Metales SpA||Chile||Conformant|
|Gold||Prioksky Plant of Non-Ferrous Metals||Russia||Conformant|
|Gold||PT Aneka Tambang (Persero) Tbk||Indonesia||Conformant|
|Gold||PX Precinox S.A.||Switzerland||Conformant|
|Gold||Rand Refinery (Pty) Ltd.||South Africa||Conformant|
|Metal||Smelter or Refinery Name||Location||Status|
|Gold||REMONDIS PMR B.V.||Netherlands||Conformant|
|Gold||Royal Canadian Mint||Canada||Conformant|
|Gold||Samduck Precious Metals||South Korea||Conformant|
|Gold||SAXONIA Edelmetalle GmbH||Germany||Conformant|
|Gold||SEMPSA Joyeria Plateria S.A.||Spain||Conformant|
|Gold||Shandong Zhaojin Gold & Silver Refinery Co., Ltd.||China||Conformant|
|Gold||Sichuan Tianze Precious Metals Co., Ltd.||China||Conformant|
|Gold||Singway Technology Co., Ltd.||Taiwan||Conformant|
|Gold||SOE Shyolkovsky Factory of Secondary Precious Metals||Russia||Conformant|
|Gold||Solar Applied Materials Technology Corp.||Taiwan||Conformant|
|Gold||Sumitomo Metal Mining Co., Ltd.||Japan||Conformant|
|Gold||Tanaka Kikinzoku Kogyo K.K.||Japan||Conformant|
|Gold||The Refinery of Shandong Gold Mining Co., Ltd.||China||Conformant|
|Gold||Tokuriki Honten Co., Ltd.||Japan||Conformant|
|Gold||Umicore Brasil Ltda.||Brazil||Conformant|
|Gold||Umicore Precious Metals Thailand||Thailand||Conformant|
|Gold||Umicore S.A. Business Unit Precious Metals Refining||Belgium||Conformant|
|Gold||United Precious Metal Refining, Inc.||United States||Conformant|
|Gold||Western Australian Mint (T/a The Perth Mint)||Australia||Conformant|
|Gold||WIELAND Edelmetalle GmbH||Germany||Conformant|
|Gold||Yamakin Co., Ltd.||Japan||Conformant|
|Gold||Zhongyuan Gold Smelter of Zhongjin Gold Corporation||China||Conformant|
|Tantalum||Changsha South Tantalum Niobium Co., Ltd.||China||Conformant|
|Tantalum||D Block Metals, LLC||United States||Conformant|
|Tantalum||Exotech Inc.||United States||Conformant|
|Tantalum||F&X Electro-Materials Ltd.||China||Conformant|
|Tantalum||FIR Metals & Resource Ltd.||China||Conformant|
|Tantalum||Global Advanced Metals Aizu||Japan||Conformant|
|Tantalum||Global Advanced Metals Boyertown||United States||Conformant|
|Tantalum||Guangdong Rising Rare Metals-EO Materials Ltd.*||China||Conformant|
|Tantalum||Guangdong Zhiyuan New Material Co., Ltd.||China||Conformant|
|Tantalum||H.C. Starck Co., Ltd.||Thailand||Conformant|
|Tantalum||H.C. Starck Hermsdorf GmbH||Germany||Conformant|
|Tantalum||H.C. Starck Inc.||United States||Conformant|
|Tantalum||H.C. Starck Ltd.||Japan||Conformant|
|Tantalum||H.C. Starck Smelting GmbH & Co. KG||Germany||Conformant|
|Tantalum||H.C. Starck Tantalum and Niobium GmbH||Germany||Conformant|
|Metal||Smelter or Refinery Name||Location||Status|
|Tantalum||Hengyang King Xing Lifeng New Materials Co., Ltd.||China||Conformant|
|Tantalum||Jiangxi Dinghai Tantalum & Niobium Co., Ltd.||China||Conformant|
|Tantalum||Jiangxi Tuohong New Raw Material||China||Conformant|
|Tantalum||Jiujiang Janny New Material Co., Ltd.*||China||Conformant|
|Tantalum||JiuJiang JinXin Nonferrous Metals Co., Ltd.||China||Conformant|
|Tantalum||Jiujiang Tanbre Co., Ltd.||China||Conformant|
|Tantalum||Jiujiang Zhongao Tantalum & Niobium Co., Ltd.||China||Conformant|
|Tantalum||KEMET Blue Metals||Mexico||Conformant|
|Tantalum||KEMET Blue Powder||United States||Conformant|
|Tantalum||LSM Brasil S.A.||Brazil||Conformant|
|Tantalum||Metallurgical Products India Pvt., Ltd.||India||Conformant|
|Tantalum||Mineracao Taboca S.A.||Brazil||Conformant|
|Tantalum||Mitsui Mining and Smelting Co., Ltd.||Japan||Conformant|
|Tantalum||Ningxia Orient Tantalum Industry Co., Ltd.||China||Conformant|
|Tantalum||NPM Silmet AS*||Estonia||Conformant|
|Tantalum||PRG Dooel||North Macedonia||Conformant|
|Tantalum||Resind Industria e Comercio Ltda.||Brazil||Conformant|
|Tantalum||Solikamsk Magnesium Works OAO||Russia||Conformant|
|Tantalum||Taki Chemical Co., Ltd.||Japan||Conformant|
|Tantalum||Telex Metals||United States||Conformant|
|Tantalum||Ulba Metallurgical Plant JSC||Kazakhstan||Conformant|
|Tantalum||XinXing HaoRong Electronic Material Co., Ltd.||China||Conformant|
|Tantalum||Yanling Jincheng Tantalum & Niobium Co., Ltd.||China||Conformant|
|Tin||Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.||China||Conformant|
|Tin||Chifeng Dajingzi Tin Industry Co., Ltd.||China||Conformant|
|Tin||China Tin Group Co., Ltd.||China||Conformant|
|Tin||CV Ayi Jaya*||Indonesia||Conformant|
|Tin||CV Dua Sekawan*||Indonesia||Conformant|
|Tin||CV Gita Pesona*||Indonesia||Conformant|
|Tin||CV United Smelting*||Indonesia||Conformant|
|Tin||CV Venus Inti Perkasa*||Indonesia||Conformant|
|Tin||Gejiu Fengming Metallurgy Chemical Plant||China||Conformant|
|Tin||Gejiu Jinye Mineral Company*||China||Non Conformant|
|Tin||Gejiu Kai Meng Industry and Trade LLC||China||Conformant|
|Tin||Gejiu Non-Ferrous Metal Processing Co., Ltd.||China||Conformant|
|Tin||Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.||China||Conformant|
|Tin||Gejiu Zili Mining And Metallurgy Co., Ltd.||China||Conformant|
|Tin||Guangdong Hanhe Non-Ferrous Metal Co., Ltd.||China||Conformant|
|Metal||Smelter or Refinery Name||Location||Status|
|Tin||Guanyang Guida Nonferrous Metal Smelting Plant||China||Conformant|
|Tin||HuiChang Hill Tin Industry Co., Ltd.||China||Conformant|
|Tin||Huichang Jinshunda Tin Co., Ltd.||China||Conformant|
|Tin||Jiangxi New Nanshan Technology Ltd.||China||Conformant|
|Tin||Magnu's Minerais Metais e Ligas Ltda.||Brazil||Conformant|
|Tin||Malaysia Smelting Corporation (MSC)||Malaysia||Conformant|
|Tin||Melt Metais e Ligas S.A.||Brazil||Conformant|
|Tin||Metallic Resources, Inc.||United States||Conformant|
|Tin||Metallo Belgium N.V.||Belgium||Conformant|
|Tin||Metallo Spain S.L.U.||Spain||Conformant|
|Tin||Mineracao Taboca S.A.||Brazil||Conformant|
|Tin||Modeltech Sdn Bhd*||Malaysia||Non Conformant|
|Tin||Operaciones Metalurgicas S.A.||Bolivia||Conformant|
|Tin||PT Aries Kencana Sejahtera*||Indonesia||Conformant|
|Tin||PT Artha Cipta Langgeng||Indonesia||Conformant|
|Tin||PT ATD Makmur Mandiri Jaya*||Indonesia||Conformant|
|Tin||PT Babel Inti Perkasa*||Indonesia||Conformant|
|Tin||PT Bangka Prima Tin*||Indonesia||Conformant|
|Tin||PT Bangka Serumpun*||Indonesia||Conformant|
|Tin||PT Bangka Tin Industry*||Indonesia||Conformant|
|Tin||PT Belitung Industri Sejahtera*||Indonesia||Conformant|
|Tin||PT Bukit Timah*||Indonesia||Conformant|
|Tin||PT DS Jaya Abadi*||Indonesia||Conformant|
|Tin||PT Inti Stania Prima*||Indonesia||Conformant|
|Tin||PT Karimun Mining*||Indonesia||Conformant|
|Tin||PT Kijang Jaya Mandiri*||Indonesia||Conformant|
|Tin||PT Lautan Harmonis Sejahtera*||Indonesia||Conformant|
|Tin||PT Menara Cipta Mulia*||Indonesia||Conformant|
|Tin||PT Mitra Stania Prima||Indonesia||Conformant|
|Tin||PT Panca Mega Persada*||Indonesia||Conformant|
|Tin||PT Premium Tin Indonesia*||Indonesia||Conformant|
|Tin||PT Prima Timah Utama*||Indonesia||Conformant|
|Tin||PT Rajehan Ariq*||Indonesia||Conformant|
|Tin||PT Refined Bangka Tin||Indonesia||Conformant|
|Tin||PT Sariwiguna Binasentosa*||Indonesia||Conformant|
|Tin||PT Stanindo Inti Perkasa*||Indonesia||Conformant|
|Tin||PT Sukses Inti Makmur*||Indonesia||Conformant|
|Tin||PT Sumber Jaya Indah*||Indonesia||Conformant|
|Tin||PT Timah Tbk Kundur||Indonesia||Conformant|
|Tin||PT Timah Tbk Mentok||Indonesia||Conformant|
|Metal||Smelter or Refinery Name||Location||Status|
|Tin||PT Tinindo Inter Nusa*||Indonesia||Conformant|
|Tin||PT Tommy Utama*||Indonesia||Conformant|
|Tin||Resind Industria e Comercio Ltda.||Brazil||Conformant|
|Tin||Rui Da Hung||Taiwan||Conformant|
|Tin||Soft Metais Ltda.||Brazil||Conformant|
|Tin||Thai Nguyen Mining and Metallurgy Co., Ltd.||Vietnam||Conformant|
|Tin||Tin Technology & Refining||United States||Conformant|
|Tin||White Solder Metalurgia e Mineracao Ltda.||Brazil||Conformant|
|Tin||Yunnan Chengfeng Non-ferrous Metals Co., Ltd.||China||Conformant|
|Tin||Yunnan Tin Company Limited||China||Conformant|
|Tin||Yunnan Yunfan Non-ferrous Metals Co., Ltd.*||China||Conformant|
|Tungsten||ACL Metais Eireli||Brazil||Conformant|
|Tungsten||Asia Tungsten Products Vietnam Ltd.||Vietnam||Conformant|
|Tungsten||Chenzhou Diamond Tungsten Products Co., Ltd.||China||Conformant|
|Tungsten||Chongyi Zhangyuan Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Fujian Jinxin Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Ganzhou Haichuang Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Ganzhou Huaxing Tungsten Products Co., Ltd.||China||Conformant|
|Tungsten||Ganzhou Jiangwu Ferrotungsten Co., Ltd.||China||Conformant|
|Tungsten||Ganzhou Seadragon W & Mo Co., Ltd.||China||Conformant|
|Tungsten||Global Tungsten & Powders Corp.||United States||Conformant|
|Tungsten||Guangdong Xianglu Tungsten Co., Ltd.||China||Conformant|
|Tungsten||H.C. Starck Tungsten GmbH||Germany||Conformant|
|Tungsten||Hunan Chenzhou Mining Co., Ltd.||China||Conformant|
|Tungsten||Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji||China||Conformant|
|Tungsten||Hunan Chunchang Nonferrous Metals Co., Ltd.||China||Conformant|
|Tungsten||Japan New Metals Co., Ltd.||Japan||Conformant|
|Tungsten||Jiangwu H.C. Starck Tungsten Products Co., Ltd.||China||Conformant|
|Tungsten||Jiangxi Gan Bei Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.||China||Conformant|
|Tungsten||Jiangxi Xinsheng Tungsten Industry Co., Ltd.||China||Conformant|
|Tungsten||Jiangxi Yaosheng Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Kennametal Fallon||United States||Conformant|
|Tungsten||Kennametal Huntsville||United States||Conformant|
|Tungsten||Malipo Haiyu Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Masan Tungsten Chemical LLC (MTC)||Vietnam||Conformant|
|Tungsten||Niagara Refining LLC||United States||Conformant|
|Metal||Smelter or Refinery Name||Location||Status|
|Tungsten||South-East Nonferrous Metal Company Limited of Hengyang City*||China||Non Conformant|
|Tungsten||Tejing (Vietnam) Tungsten Co., Ltd.||Vietnam||Conformant|
|Tungsten||Unecha Refractory metals plant||Russia||Conformant|
|Tungsten||Wolfram Bergbau und Hutten AG||Austria||Conformant|
|Tungsten||Woltech Korea Co., Ltd.||South Korea||Conformant|
|Tungsten||Xiamen Tungsten (H.C.) Co., Ltd.||China||Conformant|
|Tungsten||Xiamen Tungsten Co., Ltd.||China||Conformant|
|Tungsten||Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.||China||Conformant|
|Tungsten||Xinhai Rendan Shaoguan Tungsten Co., Ltd.||China||Conformant|
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.
|Armenia||Honduras||Papua New Guinea|
|Bolivia||Ivory Coast||Saudi Arabia|
|Bosnia and Herzegovina||Japan||Senegal|
|Brazil||Kazakhstan ||Sierra Leone|
|Burkina Faso||South Korea||Slovakia|
|Democratic Republic of the Congo||Liechtenstein||Switzerland|
|Curacao (Dutch Antilles)||Luxembourg||Tajikistan|
|Dominican Republic||Mali||Trinidad and Tobago|
|Estonia||Mongolia||United Arab Emirates|
|Fiji||Mozambique||United States |
|Gambia, The||New Caledonia||Venezuela|