UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
HP Inc.
(Exact name of the registrant as specified in its charter)
DELAWARE
 
1-4423
 
94-1081436
(State or other jurisdiction of incorporation or organization)
 
(Commission File Number)
 
(IRS Employer Identification No.)
 
 
 
 
 
1501 PAGE MILL ROAD, PALO ALTO, CA
 
94304
(Address of principal executive offices)
 
(Zip Code)
Ruairidh Ross
Global Head of Strategic Legal Matters and Assistant Secretary
(650) 857-1501
(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:
x Rule 13p-1 under the Securities 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
HP Inc. (“HP”) is a leading global provider of personal computing and other access devices, imaging and printing products, and related technologies, solutions and services. HP sells to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. Unless otherwise specified or unless the context otherwise requires, references to “HP,” “we,” “us” or “our” refer to HP Inc. and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD.
We have a long-standing commitment to sustainability. As part of our commitment, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HP’s Supply Chain Social and Environmental Responsibility Policy. In 2011, we added to this policy a section on conflict minerals. We engage in ongoing supplier outreach and communications regarding the substance of our conflict minerals policy, our expectations of suppliers with respect to conflict minerals, and our objective of responsible mineral sourcing. The policy is available on our website (which is not incorporated by reference herein) at http://h20195.www2.hp.com/V2/GetDocument.aspx?docname=c04797682.
Conflict Minerals Disclosure
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any conflict minerals in our 2019 products originated in the Democratic Republic of Congo or adjoining countries (the “Covered Countries”), or were conflict minerals from recycled or scrap sources. To make this determination, downstream companies like HP must obtain and review sourcing information on the entities reported to provide conflict minerals necessary to functionality or production (“necessary conflict minerals”) contained in our products in the form of gold and the derivatives tin, tantalum, and tungsten (collectively, “3TG”). We asked our direct suppliers (who in turn asked their suppliers) to provide us with relevant information and to report to us the entities that were providing necessary conflict minerals to them or their suppliers; this includes visits to supplier sites by HP staff to review HP expectations. HP social and environmental responsibility requirements for suppliers, which include conflict minerals due diligence and reporting obligations, are incorporated into HP’s contracts with direct suppliers.
Our RCOI included:
surveying our direct suppliers to identify suppliers of materials, parts, components or products containing necessary conflict minerals (“3TG Direct Suppliers”);
requiring that 3TG Direct Suppliers use the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (the “Template”) to obtain and provide to us information from their supply chains regarding relevant entities and the origin of necessary conflict minerals sourced by these entities;
conducting follow-up with 3TG Direct Suppliers with analysis of their submissions compared to our criteria, specifying deficiencies to be corrected in their responses, if necessary, to clarify, update or complete information reported to us so that it meets our expectations;
providing training and education to support 3TG Direct Suppliers in completing the Template;
obtaining acceptable responses from 3TG Direct Suppliers, estimated to represent 98% of our 2019 spend with such suppliers;
reviewing any information on countries of origin or recycled and scrap sourcing available through our membership in the Responsible Minerals Initiative (member ID: HPQQ) for reported entities; and
engaging an external expert consultant to review other publicly available information and to contact reported entities to assist us in determining whether or not reported entities may have sourced from the Covered Countries or may source only conflict minerals from recycled or scrap sources.

We compared all entities reported to us by our 3TG Direct Suppliers against the Responsible Minerals Initiative list
of smelters, refiners, recyclers or scrap processors of conflict minerals in order to identify the 295 entities providing necessary conflict minerals that were reported to be in our supply chain (collectively, the “3TG facilities”). Of the 295 3TG facilities, we reasonably believe that 62 exclusively provided conflict minerals from recycled or scrap sources and 133 did not source conflict minerals from the Covered Countries, leaving 100 facilities for due diligence.





For 2019, we determined with respect to our products containing necessary conflict minerals that we know or have reason to believe that some of the necessary conflict minerals from those 100 3TG facilities originated or may have originated in the Covered Countries and may not be conflict minerals from recycled or scrap sources. Accordingly, we conducted due diligence on the source and chain of custody of necessary conflict minerals from the 100 3TG facilities and have prepared the Conflict Minerals Report attached hereto as Exhibit 1.01.
Attachment A to the Conflict Minerals Report includes the countries from which the 295 supplier-reported 3TG facilities may have sourced necessary conflict minerals.
A copy of the Conflict Minerals Report filed for the calendar year ended December 31, 2019 is publicly
available electronically at http://www8.hp.com/us/en/pdf/sustainability/conflictminerals.pdf.
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 Form SD.







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 duly authorized undersigned.
 
 
HP INC.
 
 
 
May 29, 2020
By:
/s/ KIM M. RIVERA
 
Name:
Kim M. Rivera
 
Title:
President, Strategy and Business Management and Chief Legal Officer, General Counsel and Secretary



Exhibit


EXHIBIT 1.01
CONFLICT MINERALS REPORT OF HP INC.
PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
HP Inc. (“HP”) presents this Conflict Minerals Report for the reporting period of January 1, 2019 to December 31, 2019 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission.
HP is a leading global provider of personal computing and other access devices, imaging and printing products, and related technologies, solutions and services. HP sells to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health, and education sectors. Unless otherwise specified or unless the context otherwise requires, references to “HP,” “we,” “us” or “our” refer to HP Inc. and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD.
Overview of our Conflict Minerals Program
As part of our long-standing commitment to sustainability, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HP’s Supply Chain Social and Environmental Responsibility Policy. In 2011, we added to this policy a section on conflict minerals. We engage in ongoing supplier outreach and communications regarding the substance of our conflict minerals policy, our expectations of suppliers with respect to conflict minerals, and our objective of responsible mineral sourcing. The policy is available on our website (which is not incorporated by reference herein) at
http://h20195.www2.hp.com/v2/GetDocument.aspx?docname=c04797682.
HP has been recognized as an industry leader in the conflict minerals domain since 2008. HP collaboratively works with other businesses, nongovernmental organizations, government agencies, and our extensive network of direct suppliers to advance the use of responsibly sourced minerals, including from the Democratic Republic of the Congo (“DRC”) and adjoining countries (collectively, the “Covered Countries”). Our work began in 2008, when we helped establish the working group that was the precursor to the Responsible Minerals Initiative (“RMI”), and we have been instrumental since then in developing and advancing the Responsible Minerals Initiative programs and tools such as the Responsible Minerals Assurance Process (“RMAP”) and the Conflict Minerals Reporting Template (the “Template”). We contributed to the development of the Organisation for Economic Co-operation and Development (“OECD”) due diligence guidance and were a founding member of the Public Private Alliance for Responsible Mineral Trade as well as the Responsible Sourcing Network Multi-Stakeholder Group. We are a member of the European Partnership for Responsible Minerals. We were one of the first three companies to fund the Initial Audit Fund to offset part of the smelter audit cost. We also supported the initial piloting of the iTSCi traceability scheme for tin, and were a member of the Sustainable Trade Initiative (IDH) Indonesian Tin Working Group. We have visited DRC mines and have participated in critical in-region conflict free sourcing projects including Solutions for Hope, Kemet Partnership for Social and Economic Stability, and the former Conflict Free Tin Initiative. For each year since 2014, we have been able to report that all tantalum smelters reported to be in our supply chain were compliant with RMAP. For more information on our Responsible Minerals Program, we refer you to our annual Sustainable Impact Report, available on our website (which is not incorporated by reference herein) -
https://h20195.www2.hp.com/v2/GetDocument.aspx?docname=c06040843.

HP Products
Conflict minerals in the form of gold and the mineral derivatives tin, tantalum, and tungsten (collectively, “3TG”) are necessary to the functionality or production (“necessary conflict minerals”) of certain products. The products that we manufactured or contracted to manufacture during 2019 were:





Personal Systems Products. Consumer and commercial personal computers, workstations, thin clients, commercial tablets and mobility devices, retail point-of-sale systems, displays and other related accessories.
Printing Products. Consumer and commercial printer hardware (including 3D printing hardware), supplies, media, solutions and services, as well as scanning and imaging devices.

Design of Our Due Diligence Measures
We designed our due diligence measures to conform with applicable portions of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition, OECD 2016) and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures took into account our individual facts and circumstances, our downstream position in the minerals supply chain, the OECD recommendations for downstream actors that have no direct relationships to smelters or refiners1 and the use of independent assessment programs to provide information about smelters or refiners.
Consistent with the OECD Guidance, the design of our due diligence has the following features:
1.Establishment of strong internal company management systems, including a conflict minerals policy; a Conflict Minerals Program team with senior management support; a Supply Chain Transparency System; engagement with 3TG Direct Suppliers2 to communicate and reinforce HP expectations with respect to necessary conflict minerals; and a company level grievance mechanism that is available internally and externally to report concerns, including those related to conflict minerals.
2.Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Conflict Minerals Program team in systematically surveying, collecting, and analyzing information relating to 3TG facilities’3 use of necessary conflict minerals in the supply chain for our products.
3.Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on the due diligence practices of 3TG facilities, formulation of a risk management plan, and reporting to senior management.
4.Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership in the Responsible Minerals Initiative, the industry initiative that conducts audits and assessments of facilities’ due diligence activities.
5.Annual reporting through this Conflict Minerals Report, supplemented with additional information about our Responsible Minerals Program in our annual Sustainable Impact Report, available on our website (which is not incorporated by reference herein) - http://h20195.www2.hp.com/v2/GetDocument.aspx?docname=c06040843.

Description of Due Diligence Measures Performed
We undertook due diligence on the source and chain of custody of necessary conflict minerals from the relevant 3TG facilities (having excluded as a result of our reasonable country of origin inquiry, or “RCOI”, those 3TG facilities that we reasonably believe source conflict minerals exclusively from recycled or scrap sources or from outside of the Covered Countries) and reviewed the results with senior supply chain management, including our Chief Supply Chain Officer.
As part of our due diligence measures:
we compared the relevant 3TG facilities to the facilities that are listed by RMI as either compliant or in process4 with RMAP, which assesses facilities' systems and processes for traceability of ore and demonstration of conflict-free sourcing;
we engaged facilities when sourcing was unknown (directly or through a third party) to provide conflict minerals education, collect information on necessary conflict minerals such as country of origin, or encourage participation in RMAP;
if any 3TG Direct Supplier reported to us a facility for which we had information that triggered one of our potential risk indicators, we then requested the supplier investigate whether or not that facility





contributed 3TG to HP products, and if the supplier reported that it did, we asked that the supplier remove the facility from our supply chain;
if we obtained information that indicated there was a potential risk associated with a particular facility, we sought information from industry sources, news and media, stakeholders, and other relevant sources to support our decisions and actions;
we reviewed upstream incident review reporting produced by RMI that focuses on moderate and major mine-level incidents to determine whether there were incidents associated with facilities’ sourcing that might be linked, directly or indirectly, to supporting armed groups;
we supported the RMAP (member ID: HPQQ) through membership and participation in the RMI; and
we asked 3TG Direct Suppliers to encourage the facilities in their supply chain to participate in the RMAP.
Results
We set forth below the results of our due diligence as well as our overall progress toward DRC conflict free products. First, we summarize the outcome of due diligence focused on the relevant 3TG facilities (i.e., the facilities that we did not reasonably believe were sourcing conflict minerals exclusively from recycled or scrap sources or from outside the Covered Countries). We then provide a year-over-year view of all of the supplier-reported 3TG facilities and the status of due diligence. Finally, we provide a snapshot of our overall progress toward DRC conflict free products resulting from our RCOI and due diligence efforts including a chart that highlights our progress by each 3TG metal as well as our total progress toward DRC conflict free products. In 2019, 86% of all 3TG facilities reported to us are compliant, in process to become compliant, and/or are reasonably believed to provide only conflict minerals from recycled or scrap sources or to source conflict minerals from outside the Covered Countries.
Due Diligence Results for Relevant 3TG Facilities
We began our inquiry by focusing on the 295 supplier-reported 3TG facilities. After conducting a RCOI on these 3TG facilities, we reasonably believe 62 of these 3TG facilities exclusively provided conflict minerals from recycled or scrap sources, and 133 sourced conflict minerals from outside of the Covered Countries. Attachment A to this Conflict Minerals Report includes the countries from which the 295 3TG facilities may have sourced necessary conflict minerals.
The remaining 100 3TG facilities underwent further due diligence on the source and chain of custody of conflict minerals as detailed in Chart 1 and below.
__________________
1 The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HP; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
2 3TG Direct Suppliers are HP’s direct suppliers of materials, parts, components or products containing necessary conflict minerals.
3 3TG facilities are those entities reported by our 3TG Direct Suppliers that are also identified by RMI to be smelters, refiners, recyclers or scrap processors of conflict minerals.
4 Throughout this Conflict Minerals Report, “compliant” refers to facilities that are listed by RMI, as of March 31, 2020 (the “2020 Cut-Off Date”), as conformant to RMAP assessment protocols (including certification or accreditation by similar independent assessment programs cross-recognized by RMAP such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme), and “in process” refers to facilities that are listed by RMI (as of the 2020 Cut-Off Date) as in the process of becoming conformant to RMAP.






Based on further due diligence on the 100 relevant 3TG facilities, as of March 31, 2020 (the “2020 Cut-Off Date”):
60 facilities were listed by RMI as compliant or in process to become compliant with the RMAP assessment protocols.
The remaining 40 facilities are not participating and we have limited information about their sourcing and operations. Further, we have not been able to determine if these facilities are processing necessary conflict minerals contained in our products.
HP’s 3TG Direct Suppliers have reported to us more than 93% of the facilities in the world (as recognized by RMI). We doubt all of these facilities are contributing to the production of HP products. However, the over-reporting of facilities is a function of being several supply chain actors removed from the facilities and sub-tier suppliers refusing to provide customer-specific Templates to our suppliers. Accordingly, our due diligence has continued to be difficult and partially inconclusive.
Status of all Supplier-Reported 3TG Facilities
We also analyze our data set for information on the status of supplier-reported 3TG facilities and evaluate our overall progress by calculating how many of these facilities are listed as participating in or successfully completing an independent assessment program. Our suppliers reported a total of 295 3TG facilities in 2019, of which 237 are compliant with, or in process to become compliant with, an independent assessment program. Of the remaining 3TG facilities that are not participating, we have reason to believe that 18 facilities are sourcing from





outside the Covered Countries (CC) or are exclusively providing conflict minerals from recycled or scrap sources, leaving only the 40 3TG facilities with unknown status discussed above.
Attachment B to this Conflict Minerals Report sets forth the name and status of the 295 supplier-reported 3TG
facilities. Chart 2 illustrates a year-over-year comparison of all supplier-reported 3TG facilities.
Overall Progress toward DRC Conflict Free
Based on the RCOI we performed with respect to the 295 3TG facilities our suppliers reported to us and the additional due diligence on relevant 3TG facilities, 86% are RMAP compliant or in process to become compliant, provide only conflict minerals from recycled or scrap sources, and/or are facilities that we reasonably believe source conflict minerals from outside of the Covered Countries. About 14% (40 facilities) have sourcing that is unknown and are not participating in an independent assessment program.
Chart 3, below, further expands on our results by providing for each metal the number and percentage (as of the 2020 Cut-off Date) of all supplier-reported 3TG facilities that were either RMAP compliant or in process to become compliant, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries. All of the tantalum smelters reported to be in our supply chain are again compliant with the RMAP assessment protocols.







Chart 3: Overall Progress toward DRC Conflict Free by Metal

 
Total
Progress toward DRC
Conflict Free5
Percentage
Tantalum Facilities
39
39
100%
Tin Facilities
55
48
87%
Tungsten Facilities
47
45
96%
Gold Facilities
154
123
80%
Total
295
255
86%

Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity
As a downstream actor, we rely upon independent assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for downstream actors, our efforts to facilitate upstream mine or location of origin determinations were focused on supporting independent assessment programs such as the RMAP.
To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by independent assessment programs, we:
surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the Template (which included questions about the mine or location of origin) and required those suppliers to make similar efforts to survey their supply chains using the Template;
reviewed the information we obtained on 3TG facilities, and any mine or location of origin information if it was provided; and
assessed any information on countries of origin available through our membership in the Responsible Minerals Initiative for 3TG facilities (as part of the RMAP assessment protocols, the independent auditor makes an examination of the countries of origin as well as the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to RMI members).

Steps to Further Mitigate Risk and Improve Due Diligence in 2020
We plan to continue the following steps to further mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group:
engage with 3TG Direct Suppliers to update information provided to us, including visits to supplier sites;
repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the RMAP; and
support the development of the Responsible Minerals Initiative’s RMAP, including outreach efforts to encourage participation in the process.








________________________
5 This column includes the number of 3TG facilities that (as of the 2020 Cut-Off Date) were either RMAP compliant or in process to become compliant, and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries.





Attachment A
Countries of Origin
Based on information available from the Responsible Minerals Initiative as of the 2020 Cut-Off Date and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals from supplier-reported 3TG facilities may include the following countries.
Covered Countries
Outside Covered Countries
Burundi
Argentina
Kazakhstan
Spain
Democratic Republic of the Congo
Australia
Kenya
Suriname
Rwanda
Azerbaijan
Kyrgyzstan
Swaziland
Tanzania
Benin
Laos
Sweden
Uganda
Bolivia
Liberia
Taiwan
Zambia
Botswana
Madagascar
Tajikistan
 
Brazil
Malaysia
Thailand
 
Bulgaria
Mali
Togo
 
Burkina Faso
Mauritania
Turkey
 
Canada
Mexico
Uganda
 
Chile
Mongolia
United Kingdom
 
China
Morocco
United States of America
 
Colombia
Mozambique
Uruguay
 
Cuba
Myanmar
Uzbekistan
 
Cyprus
Namibia
Venezuela
 
Dominican Republic
Netherlands
Vietnam
 
Ecuador
New Zealand
Zimbabwe
 
Egypt
Nicaragua
 
 
Eritrea
Niger
 
 
Ethiopia
Nigeria
 
 
Fiji
Papua New Guinea
 
 
Finland
Peru
 
 
France
Philippines
 
 
French Guiana
Poland
 
 
Georgia
Portugal
 
 
Germany
Puerto Rico
 
 
Ghana
Russia
 
 
Guatemala
Russian Federation
 
 
Guinea
Saudi Arabia
 
 
Guyana
Senegal
 
 
Honduras
Serbia
 
 
India
Sierra Leone
 
 
Indonesia
Slovakia
 
 
Iran 6
Solomon Islands
 
 
Ivory Coast
Somaliland
 
 
Japan
South Africa
 

_____________________________________ 
6 Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person.






Attachment B
3TG Facility List
This 3TG Facility List sets forth the name, location and status of all of the 295 3TG facilities our suppliers reported to us. It is the result of our review of data from several sources, including information reported to us by 3TG Direct Suppliers, obtained through supplemental engagement with certain 3TG facilities, and from the Responsible Minerals Initiative. In many cases, facility information was provided to us for the entire supply chain of 3TG Direct Suppliers, and did not identify with specificity those 3TG facilities believed to contribute necessary conflict minerals to an HP product.
Metal
Facility Name7
Facility Location8
Status9
Gold
8853 S.p.A.*
ITALY
Compliant
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Not participating
Gold
Advanced Chemical Company*
UNITED STATES OF AMERICA
Compliant
Gold
African Gold Refinery
UGANDA
Not participating
Gold
Aida Chemical Industries Co., Ltd.*
JAPAN
Compliant
Gold
Al Etihad Gold Refinery DMCC*
UNITED ARAB EMIRATES
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
GERMANY
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)*
UZBEKISTAN
Compliant
Gold
AngloGold Ashanti Corrego do Sitio Mineracao*
BRAZIL
Compliant
Gold
Argor-Heraeus S.A.*
SWITZERLAND
Compliant
Gold
Asahi Pretec Corp.*
JAPAN
Compliant
Gold
Asahi Refining Canada Ltd.*
CANADA
Compliant
Gold
Asahi Refining USA Inc.*
UNITED STATES OF AMERICA
Compliant
Gold
Asaka Riken Co., Ltd.*
JAPAN
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not participating
Gold
AU Traders and Refiners*
SOUTH AFRICA
Compliant
Gold
Aurubis AG*
GERMANY
Compliant
Gold
Bangalore Refinery*
INDIA
Compliant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
PHILIPPINES
Compliant
Gold
Boliden AB*
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG*
GERMANY
Compliant
Gold
Caridad
MEXICO
Not participating
Gold
CCR Refinery - Glencore Canada Corporation*
CANADA
Compliant
Gold
Cendres + Metaux S.A.*
SWITZERLAND
Compliant
Gold
CGR Metalloys Pvt Ltd.
INDIA
Not participating
Gold
Chimet S.p.A.*
ITALY
Compliant
Gold
Chugai Mining*
JAPAN
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.*
CHINA
Not participating
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not participating
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Not participating
Gold
DODUCO Contacts and Refining GmbH*
GERMANY
Compliant
Gold
Dowa*
JAPAN
Compliant
Gold
DS PRETECH Co., Ltd.*
KOREA, REPUBLIC OF
Compliant
____________________
7 Entities that have been reported to us by our 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by RMI (as of the 2020 Cut-Off Date) to be smelters, refiners, recyclers or scrap processors of conflict minerals (“3TG facilities”). The facility names are listed as they appear on the RMI Smelter Database. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler or scrap processor) that is providing different types of minerals or metals.
8 The facility locations are listed as they appear for each of the 3TG facilities in the RMI Smelter Database.
9 Compliant refers to 3TG facilities that are listed by RMI (as of the 2020 Cut-Off Date) as (a) conformant with RMAP protocols or (b) certified or accredited by a similar independent assessment program cross-recognized by RMAP such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme. In Process refers to 3TG facilities that are listed by RMI (as of the 2020 Cut-Off Date) as currently in the process of becoming RMAP conformant. Not participating refers to 3TG facilities that are not engaged in an independent assessment program, including the RMAP.





Metal
Facility Name7
Facility Location8
Status9
Gold
DSC (Do Sung Corporation)*
KOREA, REPUBLIC OF
Compliant
Gold
Eco-System Recycling Co., Ltd. East Plant*
JAPAN
Compliant
Gold
Eco-System Recycling Co., Ltd. North Plant*
JAPAN
Compliant
Gold
Eco-System Recycling Co., Ltd. West Plant*
JAPAN
Compliant
Gold
Emirates Gold DMCC*
UNITED ARAB EMIRATES
Compliant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Not participating
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
Not participating
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Not participating
Gold
Geib Refining Corporation*
UNITED STATES OF AMERICA
Compliant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.*
CHINA
Compliant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM*
CHINA
Not participating
Gold
Guangdong Jinding Gold Limited*
CHINA
Not participating
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not participating
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not participating
Gold
Heimerle + Meule GmbH*
GERMANY
Compliant
Gold
Heraeus Metals Hong Kong Ltd.*
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG*
GERMANY
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not participating
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Not participating
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Not participating
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.*
CHINA
Compliant
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Not participating
Gold
Ishifuku Metal Industry Co., Ltd.*
JAPAN
Compliant
Gold
Istanbul Gold Refinery*
TURKEY
Compliant
Gold
Italpreziosi*
ITALY
Compliant
Gold
Japan Mint*
JAPAN
Compliant
Gold
Jiangxi Copper Co., Ltd.*
CHINA
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Not participating
Gold
JSC Uralelectromed*
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.*
JAPAN
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Not participating
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not participating
Gold
Kazzinc*
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC*
UNITED STATES OF AMERICA
Compliant
Gold
KGHM Polska Miedz Spolka Akcyjna*
POLAND
Compliant
Gold
Kojima Chemicals Co., Ltd.*
JAPAN
Compliant
Gold
Korea Zinc Co., Ltd.*
KOREA, REPUBLIC OF
Compliant
Gold
Kyrgyzaltyn JSC*
KYRGYZSTAN
Compliant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Not participating
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not participating
Gold
Lingbao Gold Co., Ltd.
CHINA
Not participating
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not participating
Gold
L'Orfebre S.A.*
ANDORRA
Compliant
Gold
LS-NIKKO Copper Inc.*
KOREA, REPUBLIC OF
Compliant
Gold
LT Metal Ltd.*
KOREA, REPUBLIC OF
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not participating
Gold
Marsam Metals*
BRAZIL
Compliant
Gold
Materion*
UNITED STATES OF AMERICA
Compliant
Gold
Matsuda Sangyo Co., Ltd.*
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.*
CHINA
Compliant
Gold
Metalor Technologies (Singapore) Pte., Ltd.*
SINGAPORE
Compliant





Metal
Facility Name7
Facility Location8
Status9
Gold
Metalor Technologies (Suzhou) Ltd.*
CHINA
Compliant
Gold
Metalor Technologies S.A.*
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation*
UNITED STATES OF AMERICA
Compliant
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.*
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation*
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
Compliant
Gold
MMTC-PAMP India Pvt., Ltd.*
INDIA
Compliant
Gold
Modeltech Sdn Bhd
MALAYSIA
Not participating
Gold
Morris and Watson
NEW ZEALAND
Not participating
Gold
Moscow Special Alloys Processing Plant*
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.*
TURKEY
Compliant
Gold
Navoi Mining and Metallurgical Combinat*
UZBEKISTAN
Not participating
Gold
NH Recytech Company*
KOREA, REPUBLIC OF
Not participating
Gold
Nihon Material Co., Ltd.*
JAPAN
Compliant
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH*
AUSTRIA
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd.*
JAPAN
Compliant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*
RUSSIAN FEDERATION
Compliant
Gold
OJSC Novosibirsk Refinery*
RUSSIAN FEDERATION
Compliant
Gold
PAMP S.A.*
SWITZERLAND
Compliant
Gold
Pease & Curren
UNITED STATES OF AMERICA
Not participating
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not participating
Gold
Planta Recuperadora de Metales SpA*
CHILE
Compliant
Gold
Prioksky Plant of Non-Ferrous Metals*
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk*
INDONESIA
Compliant
Gold
PX Precinox S.A.*
SWITZERLAND
Compliant
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Not participating
Gold
Rand Refinery (Pty) Ltd.*
SOUTH AFRICA
Compliant
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Not participating
Gold
REMONDIS PMR B.V.*
NETHERLANDS
Compliant
Gold
Royal Canadian Mint*
CANADA
Compliant
Gold
SAAMP*
FRANCE
Compliant
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Not participating
Gold
Safimet S.p.A*
ITALY
Compliant
Gold
SAFINA A.S.
CZECH REPUBLIC
In process
Gold
Sai Refinery
INDIA
Not participating
Gold
Samduck Precious Metals*
KOREA, REPUBLIC OF
Compliant
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Not participating
Gold
SAXONIA Edelmetalle GmbH*
GERMANY
Compliant
Gold
SEMPSA Joyeria Plateria S.A.*
SPAIN
Compliant
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Not participating
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not participating
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
CHINA
Compliant
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
CHINA
Compliant
Gold
Singway Technology Co., Ltd.*
TAIWAN, PROVINCE OF CHINA
Compliant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.*
TAIWAN, PROVINCE OF CHINA
Compliant
Gold
Sovereign Metals
INDIA
Not participating
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Not participating
Gold
Sudan Gold Refinery
SUDAN
Not participating





Metal
Facility Name7
Facility Location8
Status9
Gold
Sumitomo Metal Mining Co., Ltd.*
JAPAN
Compliant
Gold
SungEel HiMetal Co., Ltd.*
KOREA, REPUBLIC OF
Compliant
Gold
T.C.A S.p.A*
ITALY
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.*
JAPAN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.*
CHINA
Compliant
Gold
Tokuriki Honten Co., Ltd.*
JAPAN
Compliant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not participating
Gold
Tony Goetz NV
BELGIUM
Not participating
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not participating
Gold
Torecom*
KOREA, REPUBLIC OF
Compliant
Gold
Umicore Brasil Ltda.*
BRAZIL
Compliant
Gold
Umicore Precious Metals Thailand*
THAILAND
Compliant
Gold
Umicore S.A. Business Unit Precious Metals Refining*
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.*
UNITED STATES OF AMERICA
Compliant
Gold
Valcambi S.A.*
SWITZERLAND
Compliant
Gold
Western Australian Mint (T/a The Perth Mint)*
AUSTRALIA
Compliant
Gold
WIELAND Edelmetalle GmbH*
GERMANY
Compliant
Gold
Yamakin Co., Ltd.*
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.*
JAPAN
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not participating
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
CHINA
Compliant
Tantalum
Asaka Riken Co., Ltd.*
JAPAN
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
CHINA
Compliant
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
In process
Tantalum
D Block Metals, LLC*
UNITED STATES OF AMERICA
Compliant
Tantalum
Exotech Inc.*
UNITED STATES OF AMERICA
Compliant
Tantalum
F&X Electro-Materials Ltd.*
CHINA
Compliant
Tantalum
FIR Metals & Resource Ltd.*
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu*
JAPAN
Compliant
Tantalum
Global Advanced Metals Boyertown*
UNITED STATES OF AMERICA
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.*
THAILAND
Compliant
Tantalum
H.C. Starck Hermsdorf GmbH*
GERMANY
Compliant
Tantalum
H.C. Starck Inc.*
UNITED STATES OF AMERICA
Compliant
Tantalum
H.C. Starck Ltd.*
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG*
GERMANY
Compliant
Tantalum
H.C. Starck Tantalum and Niobium GmbH*
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
CHINA
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material*
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
CHINA
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.*
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
CHINA
Compliant
Tantalum
KEMET Blue Metals*
MEXICO
Compliant
Tantalum
KEMET Blue Powder*
UNITED STATES OF AMERICA
Compliant
Tantalum
LSM Brasil S.A.*
BRAZIL
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.*
INDIA
Compliant
Tantalum
Mineracao Taboca S.A.*
BRAZIL
Compliant
Tantalum
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
CHINA
Compliant
Tantalum
NPM Silmet AS*
ESTONIA
Compliant
Tantalum
PRG Dooel*
NORTH MACEDONIA
Compliant





Metal
Facility Name7
Facility Location8
Status9
Tantalum
QuantumClean*
UNITED STATES OF AMERICA
Compliant
Tantalum
Resind Industria e Comercio Ltda.*
BRAZIL
Compliant
Tantalum
Solikamsk Magnesium Works OAO*
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemical Co., Ltd.*
JAPAN
Compliant
Tantalum
Telex Metals*
UNITED STATES OF AMERICA
Compliant
Tantalum
Ulba Metallurgical Plant JSC*
KAZAKHSTAN
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.*
CHINA
Compliant
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.*
CHINA
Compliant
Tin
Alpha*
UNITED STATES OF AMERICA
Compliant
Tin
An Vinh Joint Stock Mineral Processing Company*
VIET NAM
Not participating
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
CHINA
Compliant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.*
CHINA
Compliant
Tin
China Tin Group Co., Ltd.*
CHINA
Compliant
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.*
CHINA
Not participating
Tin
Dowa*
JAPAN
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company*
VIET NAM
Not participating
Tin
EM Vinto*
BOLIVIA
Compliant
Tin
Estanho de Rondonia S.A.
BRAZIL
Not participating
Tin
Fenix Metals*
POLAND
Compliant
Tin
Gejiu Kai Meng Industry and Trade LLC*
CHINA
Compliant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
CHINA
Compliant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*
CHINA
Compliant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.*
CHINA
Compliant
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.*
CHINA
Compliant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
CHINA
Compliant
Tin
HuiChang Hill Tin Industry Co., Ltd.*
CHINA
Compliant
Tin
Huichang Jinshunda Tin Co., Ltd.*
CHINA
Compliant
Tin
Jiangxi New Nanshan Technology Ltd.*
CHINA
Compliant
Tin
Ma'anshan Weitai Tin Co., Ltd.*
CHINA
Compliant
Tin
Magnu's Minerais Metais e Ligas Ltda.*
BRAZIL
Compliant
Tin
Malaysia Smelting Corporation (MSC)*
MALAYSIA
Compliant
Tin
Melt Metais e Ligas S.A.*
BRAZIL
Compliant
Tin
Metallic Resources, Inc.*
UNITED STATES OF AMERICA
Compliant
Tin
Metallo Belgium N.V.*
BELGIUM
Compliant
Tin
Metallo Spain S.L.U.*
SPAIN
Compliant
Tin
Mineracao Taboca S.A.*
BRAZIL
Compliant
Tin
Minsur*
PERU
Compliant
Tin
Mitsubishi Materials Corporation*
JAPAN
Compliant
Tin
Modeltech Sdn Bhd*
MALAYSIA
Not participating
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not participating
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.*
PHILIPPINES
Compliant
Tin
Operaciones Metalurgicas S.A.*
BOLIVIA
Compliant
Tin
Pongpipat Company Limited
MYANMAR
Not participating
Tin
Precious Minerals and Smelting Limited
INDIA
In process
Tin
PT Artha Cipta Langgeng*
INDONESIA
Compliant
Tin
PT ATD Makmur Mandiri Jaya*
INDONESIA
Compliant
Tin
PT Mitra Stania Prima*
INDONESIA
Compliant
Tin
PT Refined Bangka Tin*
INDONESIA
Compliant
Tin
PT Timah Tbk Kundur*
INDONESIA
Compliant
Tin
PT Timah Tbk Mentok*
INDONESIA
Compliant





Metal
Facility Name7
Facility Location8
Status9
Tin
Resind Industria e Comercio Ltda.*
BRAZIL
Compliant
Tin
Rui Da Hung*
TAIWAN, PROVINCE OF CHINA
Compliant
Tin
Soft Metais Ltda.*
BRAZIL
Compliant
Tin
Super Ligas
BRAZIL
Not participating
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.*
VIET NAM
Compliant
Tin
Thaisarco*
THAILAND
Compliant
Tin
Tin Technology & Refining*
UNITED STATES OF AMERICA
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not participating
Tin
White Solder Metalurgia e Mineracao Ltda.*
BRAZIL
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
CHINA
Compliant
Tin
Yunnan Tin Company Limited*
CHINA
Compliant
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.*
CHINA
Compliant
Tungsten
A.L.M.T. Corp.*
JAPAN
Compliant
Tungsten
ACL Metais Eireli*
BRAZIL
Compliant
Tungsten
Asia Tungsten Products Vietnam Ltd.*
VIET NAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not participating
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Compliant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
CHINA
Compliant
Tungsten
Global Tungsten & Powders Corp.*
UNITED STATES OF AMERICA
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co. KG*
GERMANY
Compliant
Tungsten
H.C. Starck Tungsten GmbH*
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
CHINA
Compliant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.*
CHINA
Compliant
Tungsten
Hydrometallurg, JSC*
RUSSIAN FEDERATION
Compliant
Tungsten
Japan New Metals Co., Ltd.*
JAPAN
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
CHINA
Compliant
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not participating
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*
CHINA
Compliant
Tungsten
Jiangxi Xianglu Tungsten Co., Ltd.
CHINA
In process
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.*
CHINA
Compliant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
In process
Tungsten
Kennametal Fallon*
UNITED STATES OF AMERICA
Compliant
Tungsten
Kennametal Huntsville*
UNITED STATES OF AMERICA
Compliant
Tungsten
KGETS Co., Ltd.*
KOREA, REPUBLIC OF
Compliant
Tungsten
Lianyou Metals Co., Ltd.*
TAIWAN, PROVINCE OF CHINA
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
Masan Tungsten Chemical LLC (MTC)*
VIET NAM
Compliant
Tungsten
Moliren Ltd.*
RUSSIAN FEDERATION
Compliant
Tungsten
Niagara Refining LLC*
UNITED STATES OF AMERICA
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
PHILIPPINES
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
VIET NAM
Compliant





Metal
Facility Name7
Facility Location8
Status9
Tungsten
Unecha Refractory metals plant*
RUSSIAN FEDERATION
Compliant
Tungsten
Wolfram Bergbau und Hutten AG*
AUSTRIA
Compliant
Tungsten
Woltech Korea Co., Ltd.*
KOREA, REPUBLIC OF
Compliant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
CHINA
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.*
CHINA
Compliant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
CHINA
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
CHINA
Compliant
____________________
*
These 3TG facilities were reported for the supply chain of HP’s personal systems products.