UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
Specialized Disclosure Report
 
RALPH LAUREN CORPORATION
(Exact name of registrant as specified in its charter)
 
Delaware
001-13057
13-2622036
(State or other jurisdiction
of incorporation)
(Commission File Number)
(I.R.S. Employer
Identification No.)
     
650 Madison Avenue, New York, NY 10022
(Address of principal executive offices, including zip code)

Jane Hamilton Nielsen
Chief Operating Officer and Chief Financial Officer
(212) 318-7000
(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 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

Ralph Lauren Corporation (the “Company”) designs, markets, and distributes premium lifestyle products including apparel, footwear, accessories, home furnishings and other licensed product categories. The Company does not directly manufacture products but rather contracts for the manufacture of products. This disclosure relates to the following product categories (the “Covered Products”): apparel, footwear, accessories, and home furnishings. The Covered Products include products: (a) that were manufactured by certain third parties that affixed the Company’s brand, marks, logo or label to a generic product; and (b) for which we exerted sufficient influence over the manufacture of the products such that we could be considered to have contracted for their manufacture. The Covered Products do not include licensed product categories.

Unless the context indicates otherwise, the terms “Company,” “we,” “us” and “our” refer to Ralph Lauren Corporation and its consolidated subsidiaries.

Conflict Minerals Disclosure

This Specialized Disclosure Form (“Form SD”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (collectively with the Form SD, the “Conflict Minerals Rule”), for the period from January 1, 2019 to December 31, 2019 (the “Reporting Period”). We contract to manufacture certain products in which columbite-tantalite (coltan), cassiterite, gold, and wolframite, or their derivatives, tantalum, tin and tungsten (collectively, the “3TGs”), may be necessary to the functionality or production of those products.

The Company conducted a reasonable country of origin inquiry (“RCOI”) to ascertain whether any 3TGs contained in our products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”) as defined in Rule 13p-1 of the Securities Exchange Act of 1934, as amended. The Conflict Minerals Report describes our RCOI and additional due diligence efforts to determine the source and chain of custody of the 3TGs that may be necessary to the functionality or production of our Covered Products.

Item 1.02. Conflict Minerals Report

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at http://investor.ralphlauren.com.

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 SD


SIGNATURES

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.
 
RALPH LAUREN CORPORATION
 
       
       
Date:   May 29, 2020
By:
/s/ Jane Hamilton Nielsen  
  Name:  Jane Hamilton Nielsen  
  Title: 
Chief Operating Officer and Chief Financial Officer
 
       

 

EXHIBIT 1.01
 

RALPH LAUREN CORPORATION
Conflict Minerals Report
For the Year Ended December 31, 2019
This Conflict Minerals Report of Ralph Lauren Corporation (the “Company”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”), for the reporting period January 1, 2019 to December 31, 2019 (the “Reporting Period”). Unless the context indicates otherwise, the terms “Company,” “we,” “us” and “our” refer to Ralph Lauren Corporation and its consolidated subsidiaries.
The Conflict Minerals Rule imposes certain reporting obligations on public companies whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined by the Conflict Minerals Rule as: (a) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives,  which are limited to tin, tantalum, tungsten, and gold (“3TG”); or (b) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo ("DRC") or any adjoining country that shares an internationally recognized border with the DRC (the Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola) (collectively referred to as the “Covered Countries”).
The Company determined that we are subject to the requirements of the Conflict Minerals Rule because we contract to manufacture certain products in which one or more of the 3TGs may be necessary to the functionality or production of those products. As a result of this determination, the Company conducted a reasonable country of origin inquiry (“RCOI”) to ascertain whether any of the 3TGs in its products originated from the Covered Countries or from recycled or scrap sources. Based on the results of the RCOI and in accordance with the Conflict Minerals Rule, the Company then performed due diligence on the source and chain of custody of the 3TGs.
Section 1. Company Overview
The Company designs, markets, and distributes premium lifestyle products including apparel, footwear, accessories, home furnishings and other licensed product categories. We do not directly manufacture products but rather we contract for the manufacture of our products. This report relates to the following product categories (the “Covered Products”): apparel, footwear, accessories, and home furnishings. The Covered Products include products: (a) that were manufactured by certain third parties that affixed the Company’s brand, marks, logo or label to a generic product; and (b) for which we exerted sufficient influence over the manufacture of the products such that we could be considered to have contracted for their manufacture. The Covered Products do not include licensed product categories.
We have a global network of suppliers, vendors, and factories (the “Supply Chain Participants”) and there are, generally, multiple tiers between the 3TG sources and our direct Supply Chain Participants. Since we do not directly manufacture products but rather contract for the manufacture of the Covered Products, we must rely on our Supply Chain Participants to provide information regarding the products they supply to us and the origin of any 3TGs that are necessary to the functionality of those products. Due to the depth of our supply chain, we are far removed from the sources of ore from which 3TGs are produced and the smelters/refiners that process those ores. The efforts undertaken to identify the countries of origin of those ores reflect the Company’s circumstances and position in the supply chain as a “downstream” company with no direct influence on smelters or refiners. Since we do not have a direct relationship with smelters
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and refiners of 3TGs, we do not conduct or commission independent third party-audits of the smelters and refiners from which our independent Supply Chain Participants source 3TGs. We rely upon industry initiatives, such as the Responsible Minerals Initiative (“RMI”) founded by the Responsible Business Alliance (“RBA”) for independent third-party audit information.
We are opposed to human rights abuses such as those occurring in the Covered Countries, and are committed to the principles of ethical business practices, including the responsible sourcing of 3TGs. We expect that our Supply Chain Participants share this commitment and require that they cooperate with us in the compliance of the Conflict Minerals Rule.
Our expectations with respect to sourcing 3TGs reflect our continuing commitment to: identify product manufactured for us that contain 3TGs; engage with our Supply Chain Participants to identify the origin of those 3TGs; and deliver products to our consumers that are manufactured in a responsible and ethical manner. As we enter into new contractual arrangements with our Supply Chain Participants, or our contracts renew, we include provisions requiring them to represent that they do not source 3TGs from non-certified mines in the Covered Countries, and that they will identify, document and disclose to us, the source origins of any 3TGs utilized in their supply chain.
Section 2. Reasonable Country of Origin Inquiry (“RCOI”)
Due to the complexity of our supply chain and the breadth of our product offerings, we developed a risk-based approach that focused on Supply Chain Participants who were: (a) direct finished goods vendors, and (b) suppliers of raw materials and components that we believed were likely to supply us with products containing any of the 3TGs (such as hardware or metal components suppliers). As a result of our review, we determined that during the Reporting Period, we contracted to manufacture certain Covered Products containing 3TGs which are necessary to the functionality or production of those products. Based on this determination, we then conducted an RCOI to ascertain whether any 3TGs in the Covered Products originated in the Covered Countries.
To determine the origin of the 3TGs in the Covered Products, we retained an independent third-party service provider (the “Service Provider”), to assist us in reviewing our supply chain. Utilizing the Service Provider’s web-based software as a service tool, the Company requested its Supply Chain Participants to complete a survey (the “Conflict Minerals Survey”). The Conflict Minerals Survey was designed using the RMI’s Conflict Minerals Reporting Template (“CMRT”).  The Service Provider’s system allowed suppliers to complete and upload the CMRT directly into the system, and it provided the users with the ability to assess and manage information, as well as track and manage communications with suppliers within the system. In certain limited instances, Supply Chain Participants were also contacted directly via email communication. The Conflict Minerals Survey was accompanied by an introductory message reiterating, to our Supply Chain Participants, our commitment to the responsible sourcing of 3TGs, and our expectations that our Supply Chain Participants share this commitment and cooperate with our compliance efforts.
The use of the CMRT allowed for some elimination of “out of scope” suppliers. The CMRT also allowed us to collect the following information from each of our Supply Chain Participants:

i.
the types of raw materials, product components or Covered Products such Supply Chain Participant provided to the Company during the Reporting Period;


ii.
information regarding the source or origin of any 3TGs, including the names and locations of smelters and refiners or source of 3TGs supplied to the Company;


iii.
whether any 3TGs supplied to the Company came from recycled or scrap sources; and

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iv.
other additional information related to such Supply Chain Participant’s sourcing and compliance activities.

Our Supply Chain Participants were required to submit completed CMRTs through the Service Provider’s system. In addition to communicating with the Supply Chain Participants via the Service Provider’s platform, the escalation process for non-responsive Supply Chain Participants also included at least three additional follow-up emails, telephone calls and direct communications, as necessary.
The Service Provider’s software tool provided the ability to conduct automated data validation to review each completed CMRT for completeness, reasonableness, and consistency of answers. Upon receipt, all submitted forms were reviewed and classified as either “valid” or “invalid.”  All Supply Chain Participants who submitted incomplete or inconsistent answers were classified as “invalid” and were contacted for clarification on specific responses or to request the resubmission of a valid CMRT.  Additionally, the Service Provider’s platform provides Supply Chain Participants access to education and training resources to guide Supply Chain Participants  on navigating through the CMRT, and best practices for corrective action methods and ways to improve their own internal programs. All communications were monitored and tracked in the Service Provider’s Conflict Minerals portal for future reporting and transparency.
Based on the results of the RCOI and in accordance with the Conflict Minerals Rule, the Company then performed due diligence on the source and chain of custody of the 3TGs.
Section 3. Due Diligence Measures
Design
We based our due diligence measures, in all material respects, on the framework set forth in 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: Third Edition, including the supplements on tin, tantalum, tungsten and gold (“OECD Guidance”). The OECD Guidance was written for both upstream and downstream companies in the supply chain. Since the Company is a “downstream” company, with no direct relationship or influence on smelters or refiners of 3TGs, our due diligence practices were tailored accordingly. This year, we have also considered the requirements of the European Union Conflicts Minerals Rule with respect to due diligence efforts.
Step 1: Establish Strong Company Management Systems
The Company has developed management systems regarding the Conflict Minerals Rule. These systems include the following elements:


Internal Team: The Company has established an internal team who is responsible for managing the due diligence process to comply with the Conflict Minerals Rule. This team includes representatives from the following departments at the Company: (i) Global Human Rights Compliance; (ii) Global Manufacturing and Sourcing; (iii) Global Quality Assurance & Testing; and (iv) Legal. As previously noted, the Company also utilizes a Service Provider, to complement our internal Conflict Minerals team. The Service Provider assists with collecting and evaluating supply chain information regarding 3TGs, communicating with Supply Chain Participants, and developing and implementing due diligence measures. The Company leverages the Services Provider’s dedicated multi-lingual program specialists who are trained in conflict minerals compliance and the intricacies of the CMRT and conflict minerals reporting;

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Control Systems: The Company has established a control system which documents its due diligence activities, including findings and communications, within our supply chain. Utilizing the Service Provider’s web-based system, we communicated the Company’s expectations regarding compliance with the Conflict Minerals Rule, to our Supply Chain Participants, and followed-up with our Supply Chain Participants via e-mail and telephone conversations. All these activities are documented and retained in the Service Provider’s database;

Supplier Engagement: As we enter into new or renew our existing contractual arrangements with our Supply Chain Participants, we include provisions requiring them to represent that they do not source 3TGs from non-certified mines in the Covered Countries, and that they will identify, document and disclose to us, the source origins of any 3TGs utilized in their supply chain. The Company provided each of its Supply Chain Participants with a CMRT, using the Service Provider’s web-based tool. The Service Provider reviewed each survey and conducted due diligence by following-up on each Supply Chain Participant’s responses in their Conflict Minerals Survey, as applicable. To further strengthen communication and engagement with Supply Chain Participants, we have also utilized the Service Provider’s learning management systems, and provided all Supply Chain Participants with access to training material and courses which focus on responsible sourcing. For non-English speaking suppliers, Supply Chain Participants are provided access to the Service Provider’s multilingual help desk support and other multilingual resources to provide guidance and educational opportunities related to properly filing the CMRT ;

Grievance Mechanism: The Company has implemented a mechanism that provides for confidential reporting of suspected violations or concerns through the Company’s RL Hotline, a reporting service that is maintained by an independent third party. Violations or grievances at the industry level may also be reported to the RMI directly, via the http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.; and

Maintain Records: The Company has implemented a document retention policy through the Service Provider’s system which will retain Conflict Minerals-related documents, including the Supply Chain Participants’ responses to Conflict Minerals Surveys and sources identified, for a period of five (5) years. The Service Provider’s database can be audited by internal or external parties.

Step 2: Supply Chain Risk Identification and Assessment
Areas of risks are identified in the Service Provider’s system based on criteria established for the Supply Chain Participants’ responses. These risks are addressed by the Service Provider and members of the Company’s internal Conflict Minerals team by contacting the Supply Chain Participant, gathering additional pertinent data (as necessary) and performing an assessment of such Supply Chain Participant’s Conflict Minerals status.
As previously noted, our Supply Chain Participants consist of a global network of suppliers, vendors, and factories.  As such, completed CMRTs from each of our Supply Chain Participants were comprehensive and, in most cases, included all  facilities in such participant’s network, not just the particular facility that produced the Company’s Covered Products. As a result, because of
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the nature of our Supply Chain Participants’ global network of factories and facilities, this report may include more facilities than those that actually processed the 3TGs present in the Company’s Covered Products.

To the extent that specific smelters or refiners of 3TGs were identified by our Supply Chain Participants, the Service Provider compared the responses from the completed CMRTs with the list of known processing facilities maintained by the RMI. The RMI list includes active participants in the RMI Responsible Minerals Assurance Process (“RMAP”) Gold Standard, as well as the London Bullion Market Association Responsible Gold Audit Program and the Responsible Jewellery Council Chain of Custody Certification Program. Each identified facility was compared to the list of smelters and refiners maintained by RMI to ensure that facilities met the recognized definition of a 3TG processing facility. If a Supply Chain Participant indicated that the facility was certified as “Conflict-Free,” the Service Provider confirmed that the name of such facility was listed by RMI and has undergone a successful audit against a standard in conformance with the OECD Guidance, such as the RMAP.

Once a facility was found to meet the RMI definition of a 3TG smelter or refiner, such facility was assessed for risk, based on the presence of red flag indicators listed in the OECD Guidance, such as:


Geographic proximity to conflict-affected and high-risk areas, including the DRC and Covered Countries;


RMAP audit status;


Credible evidence of unethical or sourcing of Conflict Minerals;


Known mineral source country of origin; and


Peer Assessments conducted by credible third-party sources.

Additionally, the Supply Chain Participants were evaluated on whether they had implemented a program that incorporated the responsible sourcing due diligence measures, including conflict minerals practices and policies, as recommended by the OECD. Assessing whether a Supply Chain Participant’s program meets the OECD Guidance assists us in identifying risk in our supply chain and in making key risk mitigation decisions as our Conflict Minerals compliance program evolves.

Step 3: Design and Implement a Strategy to Respond to Risks
The Company’s risk management plan to respond to any situations which might arise involving Conflict Minerals includes carrying out the due diligence described in this Report, understanding the products impacted by any supplied materials identified as containing 3TGs, understanding the extent of the Company’s reliance on such materials, undertaking additional due diligence and risk mitigation to respond to identified risks, and communicating to our Supply Chain Participants that any 3TGs should be sourced responsibly where possible.
Feedback on CMRT submissions are provided directly to Supply Chain Participants, and multilingual educational resources regarding corrective action methods and improvements to supplier programs and processes are available at no expense on the Service Provider’s platform. In accordance with OECD Guidance, risk mitigation will depend on the Supply Chain Participant’s specific program, including such participant’s due diligence measures, and corrective actions.
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Step 4: Independent Third Party Private Sector Audit
We are not required to obtain an independent private sector audit (“IPSA”). If an IPSA is required in the future, we will outline the results of any required audit. We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMI RMAP Audit Program, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.  The Service Provider also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices.
Step 5: Report on Supply Chain Due Diligence
With the preparation and release of this Report, we have published a report of our due diligence measures with respect to the sourcing of 3TGs. A copy of this report is available at http://investor.ralphlauren.com. We have also publicly filed our Form SD and Conflict Minerals Report with the Securities and Exchange Commission (the “SEC”).
Section 4. Due Diligence Findings
Based on the survey responses received from our Supply Chain Participants, we believe that gold and tin are, or may be, necessary to the functionality or production of: (1) products that our Company contracts to be manufactured, including, but not limited to apparel, and metal components such as zippers, trims, rivets, buttons, and buckles, and (2) accessories, such as, watches and fine jewelry.
As previously noted, the Company does not have a direct relationship with smelters or refiners of 3TGs, and as a result, we must rely on our suppliers to provide us with smelter, refiner and country of origin data.
Based on our RCOI, we believe that the facilities that were used by our Supply Chain Participants to process the 3TGs that may be contained in our Covered Products included, but may not be limited to, the smelters and refiners listed in the chart attached hereto as Schedule A. As previously noted, many of the CMRTs collected were provided at the Supply Chain Participant’s company or division level and therefore may include more facilities than those that actually processed the 3TGs present in the Company’s Covered Products.
Using the smelter and refiner information provided by our Supply Chain Participants, we determined that no high risk facilities were declared by our Supply Chain Participants based on the criteria explained above. Based on the responses received, a total of 221  smelters and refiners were identified that appear on the list maintained by the RMI and were  identified as conformant with the RMAP.
Section 5. Steps to be Taken to Mitigate Risk
We intend to take the following steps to improve our due diligence measures and/or endeavor to mitigate risks:


i.
continue to communicate with our Supply Chain Participants regarding our expectations and requirements for compliance;


ii.
continue to refine the RCOI process and procedures in an effort to increase the Conflict Minerals Survey response rate and improve the content of our Supply Chain Participants’ responses to the Conflict Minerals Survey;

6



iii.
continue to monitor information regarding global traceability of raw materials in our products and continue to assess the use and source of 3TGs in our supply chain;


iv.
continue to raise awareness of our Supply Chain Participants  by directing them to information and training resources regarding responsible sourcing of 3TGs;

v.
continue to identify additional available resources to evaluate risks, including: comprehensive smelter and refinery databases with detailed listings and audit status, credible media reports relating to 3TG sourcing, and open source regulatory databases for comparing facilities against government watch and denied parties lists;

vi.
continue to monitor global legislative and regulatory developments and industry trends related to responsible sourcing focusing on human rights due diligence, transparency and risk mitigation; and
  vii.
continue to participate in industry-based efforts, such as the working group on Conflict Minerals organized by the American Apparel & Footwear Association, and relevant trade associations, such as the National Retail Federation and the United States Fashion Industry Association, to encourage further improvement and reliability in 3TG traceability programs, encourage responsible sourcing of 3TGs and to define and implement best practices.
SPECIAL NOTE REGARDING FORWARD LOOKING STATEMENTS
Certain statements in this report or incorporated by reference into report, in future filings by us with the SEC, in our press releases, and in oral statements made from time to time by us or on our behalf constitute “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements are based on current expectations and are indicated by words or phrases such as “anticipate,”, “outlook”, “estimate,” “expect,” “project,” “believe,” “envision,” “can”, “will” ,” and similar words or phrases. These forward-looking statements involve known and unknown risks, uncertainties, and other factors which may cause actual results, performance, or achievements to be materially different from the future results, performance, or achievements expressed in or implied by such forward-looking statements. We undertake no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events, or otherwise.

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Schedule A

METAL
SMELTER OR REFINER NAME
COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Gold
8853 S.p.A.
Italy
CID002763
Gold
Advanced Chemical Company
United States
CID000015
Gold
Aida Chemical Industries Co., Ltd.
Japan
CID000019
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
CID000041
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Brazil
CID000058
Gold
Argor-Heraeus S.A.
Switzerland
CID000077
Gold
Asahi Pretec Corp.
Japan
CID000082
Gold
Asahi Refining Canada Ltd.
Canada
CID000924
Gold
Asahi Refining USA Inc.
United States
CID000920
Gold
Asaka Riken Co., Ltd.
Japan
CID000090
Gold
AU Traders and Refiners
South Africa
CID002850
Gold
Aurubis AG
Germany
CID000113
Gold
Bangalore Refinery
India
CID002863
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
CID000128
Gold
Boliden AB
Sweden
CID000157
Gold
C. Hafner GmbH + Co. KG
Germany
CID000176
Gold
CCR Refinery - Glencore Canada Corporation
Canada
CID000185
Gold
Cendres + Metaux S.A.
Switzerland
CID000189
Gold
Chimet S.p.A.
Italy
CID000233
Gold
DODUCO Contacts and Refining GmbH
Germany
CID000362
Gold
Dowa
Japan
CID000401
Gold
DS PRETECH Co., Ltd.
Korea, Republic
CID003195
Gold
DSC (Do Sung Corporation)
Korea, Republic
CID000359
Gold
Eco-System Recycling Co., Ltd. East Plant
Japan
CID000425
Gold
Emirates Gold DMCC
United Arab Emirates
CID002561
Gold
Geib Refining Corporation
United States
CID002459

8


METAL SMELTER OR REFINER NAME
COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
China
CID002243
Gold
Heimerle + Meule GmbH
Germany
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
China
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
CID000711
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
CID000807
Gold
Istanbul Gold Refinery
Turkey
CID000814
Gold
Italpreziosi
Italy
CID002765
Gold
Japan Mint
Japan
CID000823
Gold
Jiangxi Copper Co., Ltd.
China
CID000855
Gold
JSC Uralelectromed
Russian Federation
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
CID000937
Gold
Kazzinc
Kazakhstan
CID000957
Gold
Kennecott Utah Copper LLC
United States
CID000969
Gold
KGHM Polska Miedz Spolka Akcyjna
Poland
CID002511
Gold
Kojima Chemicals Co., Ltd.
Japan
CID000981
Gold
Korea Zinc Co., Ltd.
Korea, Republic
CID002605
Gold
Kyrgyzaltyn JSC
Kyrgyzstan
CID001029
Gold
L'Orfebre S.A.
Andorra
CID002762
Gold
LS-NIKKO Copper Inc.
Korea, Republic
CID001078
Gold
LT Metal Ltd.
Korea, Republic
CID000689
Gold
Marsam Metals
Brazil
CID002606
Gold
Materion
United States
CID001113
Gold
Matsuda Sangyo Co., Ltd.
Japan
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
China
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
China
CID001147
Gold
Metalor Technologies S.A.
Switzerland
CID001153
Gold
Metalor USA Refining Corporation
United States
CID001157
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Mexico
CID001161
Gold
Mitsubishi Materials Corporation
Japan
CID001188

9

METAL SMELTER OR REFINER NAME COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
India
CID002509
Gold
Moscow Special Alloys Processing Plant
Russian Federation
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Turkey
CID001220
Gold
Nihon Material Co., Ltd.
Japan
CID001259
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Austria
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Russian Federation
CID001326
Gold
OJSC Novosibirsk Refinery
Russian Federation
CID000493
Gold
PAMP S.A.
Switzerland
CID001352
Gold
Planta Recuperadora de Metales SpA
Chile
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
Russian Federation
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
CID001397
Gold
PX Precinox S.A.
Switzerland
CID001498
Gold
Rand Refinery (Pty) Ltd.
South Africa
CID001512
Gold
REMONDIS PMR B.V.
Netherlands
CID002582
Gold
Royal Canadian Mint
Canada
CID001534
Gold
SAAMP
France
CID002761
Gold
Safimet S.p.A
Italy
CID002973
Gold
SAXONIA Edelmetalle GmbH
Germany
CID002777
Gold
SEMPSA Joyeria Plateria S.A.
Spain
CID001585
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
CID001622
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
CID001736
Gold
Singway Technology Co., Ltd.
Taiwan, Province Of China
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Russian Federation
CID001756
Gold
Solar Applied Materials Technology Corp.
Taiwan, Province Of China
CID001761
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
CID001798

10

METAL
SMELTER OR REFINER NAME COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Gold
SungEel HiMetal Co., Ltd.
Korea, Republic
CID002918
Gold
T.C.A S.p.A
Italy
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
CID001875
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
China
CID001916
Gold
Tokuriki Honten Co., Ltd.
Japan
CID001938
Gold
Torecom
Korea, Republic
CID001955
Gold
Umicore Brasil Ltda.
Brazil
CID001977
Gold
Umicore Precious Metals Thailand
Thailand
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
CID001980
Gold
United Precious Metal Refining, Inc.
United States
CID001993
Gold
Valcambi S.A.
Switzerland
CID002003
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
CID002030
Gold
WIELAND Edelmetalle GmbH
Germany
CID002778
Gold
Yamakin Co., Ltd.
Japan
CID002100
Gold
Yokohama Metal Co., Ltd.
Japan
CID002129
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
CID002224
Tantalum
Asaka Riken Co., Ltd.
Japan
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
CID000211
Tantalum
D Block Metals, LLC
United States
CID002504
Tantalum
Exotech Inc.
United States
CID000456
Tantalum
F&X Electro-Materials Ltd.
China
CID000460
Tantalum
FIR Metals & Resource Ltd.
China
CID002505
Tantalum
Global Advanced Metals Aizu
Japan
CID002558
Tantalum
Global Advanced Metals Boyertown
United States
CID002557
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
China
CID000616
Tantalum
H.C. Starck Co., Ltd.
Thailand
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
CID002547
Tantalum
H.C. Starck Inc.
United States
CID002548
Tantalum
H.C. Starck Ltd.
Japan
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Germany
CID002550

11

METAL SMELTER OR REFINER NAME COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Germany
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
CID002492
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
CID002512
Tantalum
Jiangxi Tuohong New Raw Material
China
CID002842
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
China
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
CID002506
Tantalum
KEMET Blue Metals
Mexico
CID002539
Tantalum
LSM Brasil S.A.
Brazil
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
India
CID001163
Tantalum
Mineracao Taboca S.A.
Brazil
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
CID001277
Tantalum
PRG Dooel
North Macedonia, Republic Of
CID002847
Tantalum
QuantumClean
United States
CID001508
Tantalum
Resind Industria e Comercio Ltda.
Brazil
CID002707
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation
CID001769
Tantalum
Taki Chemical Co., Ltd.
Japan
CID001869
Tantalum
Telex Metals
United States
CID001891
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
China
CID002508
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
China
CID001522
Tin
Alpha
United States
CID000292
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
CID000228
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
China
CID003190
Tin
China Tin Group Co., Ltd.
China
CID001070

12

METAL
SMELTER OR REFINER NAME
COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Tin
Dowa
Japan
CID000402
Tin
EM Vinto
Bolivia (Plurinational State Of)
CID000438
Tin
Fenix Metals
Poland
CID000468
Tin
Gejiu Kai Meng Industry and Trade LLC
China
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
China
CID001908
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
CID000555
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
China
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
China
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
China
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
China
CID000760
Tin
Jiangxi New Nanshan Technology Ltd.
China
CID001231
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
CID002468
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
CID001105
Tin
Melt Metais e Ligas S.A.
Brazil
CID002500
Tin
Metallic Resources, Inc.
United States
CID001142
Tin
Metallo Belgium N.V.
Belgium
CID002773
Tin
Metallo Spain S.L.U.
Spain
CID002774
Tin
Mineracao Taboca S.A.
Brazil
CID001173
Tin
Minsur
Peru
CID001182
Tin
Mitsubishi Materials Corporation
Japan
CID001191
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
CID002517
Tin
Operaciones Metalurgicas S.A.
Bolivia (Plurinational State Of)
CID001337
Tin
PT Artha Cipta Langgeng
Indonesia
CID001399
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
CID002503
Tin
PT Menara Cipta Mulia
Indonesia
CID002835
Tin
PT Mitra Stania Prima
Indonesia
CID001453

13

METAL
SMELTER OR REFINER NAME COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Tin
PT Refined Bangka Tin
Indonesia
CID001460
Tin
PT Timah Tbk Kundur
Indonesia
CID001477
Tin
PT Timah Tbk Mentok
Indonesia
CID001482
Tin
Resind Industria e Comercio Ltda.
Brazil
CID002706
Tin
Rui Da Hung
Taiwan, Province Of China
CID001539
Tin
Soft Metais Ltda.
Brazil
CID001758
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
Vietnam
CID002834
Tin
Thaisarco
Thailand
CID001898
Tin
Tin Technology & Refining
United States
CID003325
Tin
White Solder Metalurgia e Mineracao Ltda.
Brazil
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
CID002158
Tin
Yunnan Tin Company Limited
China
CID002180
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
China
CID003397
Tungsten
A.L.M.T. Corp.
Japan
CID000004
Tungsten
ACL Metais Eireli
Brazil
CID002833
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
CID002513
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
CID000258
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
China
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
China
CID002645
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
CID002494
Tungsten
Global Tungsten & Powders Corp.
United States
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Germany
CID002542
Tungsten
H.C. Starck Tungsten GmbH
Germany
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
China
CID002579

14

METAL
SMELTER OR REFINER NAME
COUNTRY
SMELTER OR
REFINER
IDENTIFICATION
NUMBER
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
CID000769
Tungsten
Hydrometallurg, JSC
Russian Federation
CID002649
Tungsten
Japan New Metals Co., Ltd.
Japan
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
CID002551
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
CID002321
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
CID002317
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
CID002316
Tungsten
Kennametal Fallon
United States
CID000966
Tungsten
Kennametal Huntsville
United States
CID000105
Tungsten
KGETS Co., Ltd.
Korea, Republic
CID003388
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
CID002319
Tungsten
Masan Tungsten Chemical LLC (MTC)
Vietnam
CID002543
Tungsten
Moliren Ltd.
Russian Federation
CID002845
Tungsten
Niagara Refining LLC
United States
CID002589
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Philippines
CID002827
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Vietnam
CID001889
Tungsten
Unecha Refractory metals plant
Russian Federation
CID002724
Tungsten
Wolfram Bergbau und Hutten AG
Austria
CID002044
Tungsten
Woltech Korea Co., Ltd.
Korea, Republic
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
China
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
China
CID002095

15