Arcimoto Inc.
05/31/2023 | Press release | Distributed by Public on 05/31/2023 12:44
Specialized Disclosure Report - Form SD
Exhibit 1.01
Arcimoto Conflict Minerals Report
2022
Arcimoto, Inc. ('Arcimoto') presents this Conflict Minerals Report for the year ended 31 December 2022 in accordance with Rule 13p-1 (the 'Rule') under the U.S. Securities Exchange Act of 1934 (the 'Exchange Act').
The Rule applies to companies required to file reports with the U.S. Securities and Exchange Commission ('SEC') under Section 13(a) or 15(d) of the Exchange Act if any of the products they manufacture or contract to manufacture contain conflict minerals necessary to the functionality or production of the product ('in-scope products').
As defined by the content requirements of SEC Form SD, 'conflict minerals' include columbite-tantalite ('coltan'), cassiterite, wolframite and/or gold or their derivatives, which are limited to tantalum, tin, and tungsten (each a '3TG metal'). Please refer to the requirements of SEC Form SD for definitions of many of the terms used in this report, including 'Covered Countries' (Democratic Republic of Congo ('DRC') or an adjoining country).
COMPANY OVERVIEW
Arcimoto, Inc. is a start-up electric vehicle company based in Eugene, Oregon, with a mission to catalyze the shift to a sustainable transportation system. We believe this shift will happen only when we move away from oversized, overpriced, polluting vehicles to right-sized, ultra-efficient electric vehicles. Arcimoto designs and manufactures a technically advanced 3-wheel electric vehicle platform. This platform can be used as the foundation for many types of vehicles. Our product offerings built on this platform include general purpose two seat enclosed vehicles, roadsters, delivery vehicles, flatbeds, and rapid responders. We manufactured 336 vehicles in 2022.
We recently introduced the Mean Lean Machine e-bike. The development of this advanced leaning three wheeled e-bike platform started in 2020. Development of this platform is currently on hold however.
With the mission to deliver sustainable, right-sized transportation, Arcimoto is committed to developing and maintaining an ethical, and responsible supply-chain for the parts and materials in its vehicles. This is our third year performing supplier surveys for our Conflict Minerals Reports. Since many of our suppliers for innovative electric vehicle components are also startups, we have sought to introduce them to the importance of conflict minerals reporting. Arcimoto is proud to present its third Conflict Minerals Report for the 2022 fiscal year.
APPLICABILITY
Our products contain numerous components that may contain one or more 3TG metals. For example, tin is often used as a soldering material for electronic components, gold and tantalum are typically used in electronic components such as connectors or capacitors, and tungsten is added to increase the strength of gear teeth, bearings, and cages.
We conducted reasonable due diligence regarding the source and chain of custody of the conflict minerals in our products. Based on our efforts, we have reason to believe that some of the conflict minerals present in our supply chain may have originated in the Democratic Republic of the Congo ("DRC") or adjoining countries (collectively the "Covered Countries"). We are unable to determine with assurance the origin of all conflict minerals in our products at this time. For these reasons, we are required under the Rule to submit this Conflict Minerals Report (CMR) as an exhibit to Arcimoto's Form SD.
REASONABLE COUNTRY OF ORIGIN INQUIRY
In accordance with the Rule, we carried out a Reasonable Country of Origin Inquiry ('RCOI') and due diligence process to determine the origin of the 3TG metals used in our in-scope products.
The smelters and refiners ('Smelters') that produce 3TG metals and the mines from which the minerals are originally sourced are many steps away from Arcimoto in the supply chain. Therefore, we rely on our suppliers to provide information to support our due diligence efforts. In undertaking our RCOI, we conducted a targeted survey of our strategic direct material suppliers, utilizing the Responsible Minerals Initiative ("RMI") Conflict Minerals Reporting Template ("CMRT") version 6.22. We reviewed the collected CMRTs to identify suppliers' respective risk levels, determine country of origin and/or sourcing from recycled or scrap sources, and determine if due diligence is required.
As a start-up company that does not yet need material in large volumes that warrant or necessitate supplier relationships with larger, sophisticated OEM suppliers, we often work with small and specialty suppliers, many of whom were not aware of conflict minerals requirements before our RCOI. As this is Arcimoto's third filing and with numerous start-up suppliers, information provided by many of our direct suppliers is incomplete, and a number of our suppliers were unable to confirm the country-of-origin information for 3TG metals in their products.
RCOI Conclusion
Based on data collected from our suppliers for the year ended 31 December 2022, we have reason to believe that some 3TG metals contained in our products may originate from Covered Countries. As such, we have conducted due diligence as described below.
RESPONSIBLE MINERAL SOURCING
3TG metals come from many different Smelters in a complex and often opaque supply chain. Minerals are extracted from mines. Smelters then procure those minerals and process them into useable metals. These metals are then incorporated into components that go into the electric vehicles we produce.
We conduct due diligence to support our commitment to deliver sustainable transportation. We strive to source the materials that are used in our vehicles responsibly and to comply with all relevant disclosure regulations. Our objective is to ensure that none of the products or components we buy contain 3TG metals that have helped to fund conflict or contribute to serious human rights abuses as defined 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) ('OECD Due Diligence Guidance').
Our process has been designed to comply with the Rule and interpretive guidance and to conform with the internationally recognized framework set out in the OECD Due Diligence Guidance.
DUE DILIGENCE DESIGN
Our due diligence process follows the five-step framework set out in the OECD Due Diligence Guidance. As we are just now ramping up our company's manufacturing process, we are also at the beginning stages of designing, implementing, and improving our due diligence process.
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Step 1: Establish strong company management systems
For Reporting Year 2022, Arcimoto has maintained the following company management systems regarding conflict minerals:
| ● | Conflict Minerals Policy. Arcimoto has developed and the Board has adopted a policy related to the sourcing of Conflict Minerals. The Policy has been posted at https://www.arcimoto.com/corporate-governance. |
| ● | Control Systems. Arcimoto is implementing a process into our quality systems responsible for assessing components and products for 3TG. |
| ● | Supplier Engagement. As we ramp up production, Arcimoto is changing the way in which we source components. Due to the relatively small quantities of parts, we have purchased to date, we have been required to source components through the "Aftermarket Divisions" of our suppliers, which typically do not fall under conflict mineral reporting requirements, and therefore, have little familiarity with them. As we increase production, we will be able to purchase parts and materials through the "OEM Divisions" of our suppliers, which are more accustomed to conflict mineral issues and reporting requirements. We will strive to enter into OEM agreements only with suppliers that commit to responsible sourcing and contractually agree to provide Arcimoto with an updated CMRT each year. |
| ● | Maintain Records. Arcimoto uses our cloud storage system to retain relevant documents. All conflict minerals supplier responses and forms are uploaded into these information systems for easy reference. These records will be kept in accordance with our document retention policies for at least 5 years. |
Step 2: Identify and assess risks in the supply chain
For direct suppliers indicating that they provide materials with tin, tantalum, tungsten, and gold, we initiate our RCOI process which includes: a request for a completed CMRT; follow-up and escalation for non-responsive suppliers; review of the CMRTs we receive; and determination if further actions are needed based on the supplier's response. We conduct an iterative verification process on each supplier's CMRT that we receive to uncover inconsistencies or risk in the supplier's response.
We also actively worked with our suppliers to identify other entities in our supply chain that are further upstream than our direct suppliers. For reporting year 2022, we conducted this survey process with 27 of our direct material suppliers. We rely on these suppliers to provide us with information about the source of conflict minerals contained in the components supplied to us. Of note, our suppliers are reliant upon information provided to them by their suppliers, just as we are reliant on information supplied by our suppliers.
We work together with a specialist consultancy service provider, Responsible Trade LLC, to assist in tracking data, assessing risks, and preparing our reporting.
We have established a process to identify in-scope suppliers (as outlined in the Applicability section above).
Our direct suppliers are expected to extend a similar identification process to their own suppliers and cascade them down the supply chain until the origin of 3TG metals contained in the products supplied to us (either directly or indirectly) can be identified.
To the extent possible, we require our identified in-scope suppliers to report on their progress through the RMI CMRT, which we ask them to complete on an annual basis. The CMRT is designed to identify the Smelters from which any 3TG metals are sourced for each in-scope product we procure from them.
We engage with in-scope suppliers to raise awareness of our processes and requirements. We share best practice advice on how to complete the CMRT and provide a dedicated point of contact at Arcimoto to respond to suppliers' questions regarding Conflict Minerals reporting. As we begin to incorporate Conflict Mineral contract clauses into supplier contracts, we will help our suppliers understand how to meet these requirements.
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Step 3: Design and implement a strategy to respond to identified risks
Our strategy to respond to identified risks includes a range of measures that form part of our due diligence process.
We review supplier responses to the CMRT and follow up with suppliers to request clarification or more complete responses where necessary. If risks are identified, we engage with suppliers and request their commitment to corrective actions to manage these risks, including a commitment to improve data quality.
We have established a communication and escalation process to notify and engage, if required, our senior materials management where any potentially significant risks are identified.
When our in-scope suppliers identify Smelters within our supply chain that are RMAP (Responsible Minerals Assurance Process) Non-Conformant, we will ask them to encourage these Smelters to participate in the RMAP process. If our suppliers will not do so, we will begin considering alternate sourcing arrangements.
Step 4: Carry out independent third-party audits of Smelter due diligence practices
We do not have direct relationships with Smelters with respect to 3TG. We do not directly purchase raw minerals, ores, or 3TG metals. We are many steps removed from the mines and Smelters that supply the minerals, ores, and 3TG metals contained in our products.
We do not perform or direct Smelter audits of companies within our supply chain, but like many other companies, we rely upon the Responsible Minerals Initiative (RMI) RMAP for meeting Step 4. Please see Annex 1 for a list of Smelters, their conformance status and Country-of-Origin information.
Step 5: Report annually on supply chain due diligence
In accordance with the Rule and the OECD Due Diligence Guidance, this report is publicly available on our website.
DUE DILIGENCE RESULTS
We surveyed our 27 in-scope suppliers regarding their source and custody of 3TGs using the RMI's CMRT. We received responses from 30%. These suppliers did not provide product-level responses to the RCOI, but rather reported in aggregate by company. As such, we do not know how many of the Smelters reported by these suppliers relate specifically to our supply chain. We rely on our direct suppliers to gather information about Smelters in our supply chain because we do not directly purchase raw minerals, ores, or 3TG metals.
These suppliers have reported to us 98% of RMI-recognized Smelters in the world. However, we do not believe that all of these facilities are contributing to the production of Arcimoto vehicles. The potential over-reporting of Smelters is a function of our products containing components several steps removed from the 3TG processing facilities and of intermediate suppliers failing to provide customer- or product-specific CMRTs to our direct suppliers.
Efforts to Determine Mine or Location of Origin
We requested that our suppliers complete the CMRT, which includes the completion of all necessary Smelter identification information. This information will enable the validation of these Smelters as well as the tracing of the 3TGs to their location of origin. We have determined that seeking this information regarding Smelters in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
Responses from our suppliers confirmed that there remain significant challenges in finding information about the country of origin of 3TG metals and the Smelters from which 3TG metals were sourced, as this information is often unavailable, incomplete, or potentially erroneous. We will continue engaging with suppliers to improve the completeness and quality of information they provide to us.
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CONTINUOUS IMPROVEMENT EFFORTS TO MITIGATE RISK
We are taking a range of steps to enhance the due diligence process and further mitigate any risk that Conflict Minerals used in the company's products may benefit armed groups.
We are in the process of implementing legal and contractual mechanisms to obligate our suppliers to comply with relevant regulations.
Arcimoto aims to ensure minerals used in our supply chain do not fund conflict or contribute to gross human rights abuses. At the same time, Arcimoto desires to continue supporting local economies in Conflict-Affected and High-Risk Areas, including the Covered Countries, by allowing the use of materials from those areas that have been processed by Smelters verified by third-party assurance programs, such as the RMI RMAP.
Arcimoto will continue to improve our conflict minerals program by:
| ● | Including Conflict Minerals clauses in supplier contracts and requiring suppliers to conduct due diligence to identify the origin of 3TG metals in purchased components or products, and to ensure that the 3TG elements do not originate from a source that finances or benefits armed groups, directly or indirectly. |
| ● | Encouraging suppliers to implement a Conflict Minerals policy and report their source and custody of conflict minerals or improve their existing Responsible Minerals program. |
| ● | Improving the completeness and quality of information provided by suppliers, particularly in relation to the identification of Smelters and the country of origin of 3TG metals and in providing CMRT information on Smelters at the product level. |
| ● | Seeking our suppliers' commitment to implement further improvements in relation to due diligence processes, including asking them to reach out to RMAP non-conformant Smelters identified as being within our supply chain to either encourage them to undergo a RMAP audit or remove them from the supply chain. |
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Annex 1
LIST OF SUPPLIER-REPORTED SMELTERS
This table lists the Smelters identified through supplier CMRT responses for the year ended December 31, 2022, that were classified by the RMI as RMAP Conformant on January 3, 2023.
| Metal | Smelter CID | Smelter Name | Country | |||
| Gold | CID002763 | 8853 S.p.A. | ITALY | |||
| Gold | CID002920 | ABC Refinery Pty Ltd. | AUSTRALIA | |||
| Gold | CID000015 | Advanced Chemical Company | UNITED STATES OF AMERICA | |||
| Gold | CID003185 | African Gold Refinery | UGANDA | |||
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | JAPAN | |||
| Gold | CID002560 | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | |||
| Gold | CID002760 | Albino Mountinho Lda. | PORTUGAL | |||
| Gold | CID003500 | Alexy Metals | UNITED STATES OF AMERICA | |||
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | |||
| Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | |||
| Gold | CID000077 | Argor-Heraeus S.A. | SWITZERLAND | |||
| Gold | CID000082 | Asahi Pretec Corp. | JAPAN | |||
| Gold | CID000924 | Asahi Refining Canada Ltd. | CANADA | |||
| Gold | CID000920 | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | |||
| Gold | CID000090 | Asaka Riken Co., Ltd. | JAPAN | |||
| Gold | CID002850 | AU Traders and Refiners | SOUTH AFRICA | |||
| Gold | CID003461 | Augmont Enterprises Private Limited | INDIA | |||
| Gold | CID000113 | Aurubis AG | GERMANY | |||
| Gold | CID002863 | Bangalore Refinery | INDIA | |||
| Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | |||
| Gold | CID000157 | Boliden AB | SWEDEN | |||
| Gold | CID000176 | C. Hafner GmbH + Co. KG | GERMANY | |||
| Gold | CID003421 | C.I Metales Procesados Industriales SAS | COLOMBIA | |||
| Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | CANADA | |||
| Gold | CID000189 | Cendres + Metaux S.A. | SWITZERLAND | |||
| Gold | CID003382 | CGR Metalloys Pvt Ltd. | INDIA | |||
| Gold | CID000233 | Chimet S.p.A. | ITALY | |||
| Gold | CID000264 | Chugai Mining | JAPAN | |||
| Gold | CID002867 | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | |||
| Gold | CID003348 | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | |||
| Gold | CID003663 | Dongwu Gold Group | CHINA | |||
| Gold | CID000401 | Dowa | JAPAN | |||
| Gold | CID000359 | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | |||
| Gold | CID000425 | Eco-System Recycling Co., Ltd. East Plant | JAPAN | |||
| Gold | CID003487 | Emerald Jewel Industry India Limited (Unit 1) | INDIA | |||
| Gold | CID003488 | Emerald Jewel Industry India Limited (Unit 2) | INDIA | |||
| Gold | CID003489 | Emerald Jewel Industry India Limited (Unit 3) | INDIA | |||
| Gold | CID003490 | Emerald Jewel Industry India Limited (Unit 4) | INDIA | |||
| Gold | CID002515 | Fidelity Printers and Refiners Ltd. | ZIMBABWE | |||
| Gold | CID002584 | Fujairah Gold FZC | UNITED ARAB EMIRATES | |||
| Gold | CID002459 | Geib Refining Corporation | UNITED STATES OF AMERICA | |||
| Gold | CID002852 | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | |||
| Gold | CID003641 | Gold by Gold Colombia | COLOMBIA | |||
| Gold | CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
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| Metal | Smelter CID | Smelter Name | Country | |||
| Gold | CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | |||
| Gold | CID002312 | Guangdong Jinding Gold Limited | CHINA | |||
| Gold | CID000694 | Heimerle + Meule GmbH | GERMANY | |||
| Gold | CID000711 | Heraeus Germany GmbH Co. KG | GERMANY | |||
| Gold | CID000707 | Heraeus Metals Hong Kong Ltd. | CHINA | |||
| Gold | CID002587 | Industrial Refining Company | BELGIUM | |||
| Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | |||
| Gold | CID002763 | 8853 S.p.A. | ITALY | |||
| Gold | CID002920 | ABC Refinery Pty Ltd. | AUSTRALIA | |||
| Gold | CID000015 | Advanced Chemical Company | UNITED STATES OF AMERICA | |||
| Gold | CID003185 | African Gold Refinery | UGANDA | |||
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | JAPAN | |||
| Gold | CID002560 | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | |||
| Gold | CID002760 | Albino Mountinho Lda. | PORTUGAL | |||
| Gold | CID003500 | Alexy Metals | UNITED STATES OF AMERICA | |||
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | |||
| Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | |||
| Gold | CID000077 | Argor-Heraeus S.A. | SWITZERLAND | |||
| Gold | CID000082 | Asahi Pretec Corp. | JAPAN | |||
| Gold | CID000924 | Asahi Refining Canada Ltd. | CANADA | |||
| Gold | CID000920 | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | |||
| Gold | CID000090 | Asaka Riken Co., Ltd. | JAPAN | |||
| Gold | CID002850 | AU Traders and Refiners | SOUTH AFRICA | |||
| Gold | CID003461 | Augmont Enterprises Private Limited | INDIA | |||
| Gold | CID000113 | Aurubis AG | GERMANY | |||
| Gold | CID002863 | Bangalore Refinery | INDIA | |||
| Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | |||
| Gold | CID000157 | Boliden AB | SWEDEN | |||
| Gold | CID000176 | C. Hafner GmbH + Co. KG | GERMANY | |||
| Gold | CID003421 | C.I Metales Procesados Industriales SAS | COLOMBIA | |||
| Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | CANADA | |||
| Gold | CID000189 | Cendres + Metaux S.A. | SWITZERLAND | |||
| Gold | CID003382 | CGR Metalloys Pvt Ltd. | INDIA | |||
| Gold | CID000233 | Chimet S.p.A. | ITALY | |||
| Gold | CID000264 | Chugai Mining | JAPAN | |||
| Gold | CID002867 | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | |||
| Gold | CID003348 | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | |||
| Gold | CID003663 | Dongwu Gold Group | CHINA | |||
| Gold | CID000401 | Dowa | JAPAN | |||
| Gold | CID000359 | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | |||
| Gold | CID000425 | Eco-System Recycling Co., Ltd. East Plant | JAPAN | |||
| Gold | CID003487 | Emerald Jewel Industry India Limited (Unit 1) | INDIA | |||
| Gold | CID003488 | Emerald Jewel Industry India Limited (Unit 2) | INDIA | |||
| Gold | CID003489 | Emerald Jewel Industry India Limited (Unit 3) | INDIA | |||
| Gold | CID003490 | Emerald Jewel Industry India Limited (Unit 4) | INDIA | |||
| Gold | CID002515 | Fidelity Printers and Refiners Ltd. | ZIMBABWE | |||
| Gold | CID002584 | Fujairah Gold FZC | UNITED ARAB EMIRATES | |||
| Gold | CID002459 | Geib Refining Corporation | UNITED STATES OF AMERICA | |||
| Gold | CID002852 | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | |||
| Gold | CID003641 | Gold by Gold Colombia | COLOMBIA | |||
| Gold | CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | |||
| Gold | CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | |||
| Gold | CID002312 | Guangdong Jinding Gold Limited | CHINA | |||
| Gold | CID000694 | Heimerle + Meule GmbH | GERMANY | |||
| Gold | CID000711 | Heraeus Germany GmbH Co. KG | GERMANY | |||
| Gold | CID000707 | Heraeus Metals Hong Kong Ltd. | CHINA | |||
| Gold | CID002587 | Industrial Refining Company | BELGIUM | |||
| Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
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| Metal | Smelter CID | Smelter Name | Country | |||
| Gold | CID002562 | International Precious Metal Refiners | UNITED ARAB EMIRATES | |||
| Gold | CID000807 | Ishifuku Metal Industry Co., Ltd. | JAPAN | |||
| Gold | CID000814 | Istanbul Gold Refinery | TURKEY | |||
| Gold | CID002765 | Italpreziosi | ITALY | |||
| Gold | CID000823 | Japan Mint | JAPAN | |||
| Gold | CID000855 | Jiangxi Copper Co., Ltd. | CHINA | |||
| Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | JAPAN | |||
| Gold | CID003497 | K.A. Rasmussen | NORWAY | |||
| Gold | CID002563 | Kaloti Precious Metals | UNITED ARAB EMIRATES | |||
| Gold | CID000957 | Kazzinc | KAZAKHSTAN | |||
| Gold | CID000969 | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | |||
| Gold | CID002511 | KGHM Polska Miedz Spolka Akcyjna | POLAND | |||
| Gold | CID000981 | Kojima Chemicals Co., Ltd. | JAPAN | |||
| Gold | CID002605 | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | |||
| Gold | CID003463 | Kundan Care Products Ltd. | INDIA | |||
| Gold | CID002865 | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | |||
| Gold | CID002762 | L'Orfebre S.A. | ANDORRA | |||
| Gold | CID001078 | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | |||
| Gold | CID000689 | LT Metal Ltd. | KOREA, REPUBLIC OF | |||
| Gold | CID002606 | Marsam Metals | BRAZIL | |||
| Gold | CID001113 | Materion | UNITED STATES OF AMERICA | |||
| Gold | CID001119 | Matsuda Sangyo Co., Ltd. | JAPAN | |||
| Gold | CID003548 | MD Overseas | INDIA | |||
| Gold | CID003575 | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | |||
| Gold | CID003557 | Metallix Refining Inc. | UNITED STATES OF AMERICA | |||
| Gold | CID001149 | Metalor Technologies (Hong Kong) Ltd. | CHINA | |||
| Gold | CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | |||
| Gold | CID001147 | Metalor Technologies (Suzhou) Ltd. | CHINA | |||
| Gold | CID001153 | Metalor Technologies S.A. | SWITZERLAND | |||
| Gold | CID001157 | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | |||
| Gold | CID001161 | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | |||
| Gold | CID001188 | Mitsubishi Materials Corporation | JAPAN | |||
| Gold | CID001193 | Mitsui Mining and Smelting Co., Ltd. | JAPAN | |||
| Gold | CID001352 | MKS PAMP SA | SWITZERLAND | |||
| Gold | CID002509 | MMTC-PAMP India Pvt., Ltd. | INDIA | |||
| Gold | CID002282 | Morris and Watson | NEW ZEALAND | |||
| Gold | CID001220 | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | |||
| Gold | CID001236 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | |||
| Gold | CID001259 | Nihon Material Co., Ltd. | JAPAN | |||
| Gold | CID001325 | Ohura Precious Metal Industry Co., Ltd. | JAPAN | |||
| Gold | CID002919 | Planta Recuperadora de Metales SpA | CHILE | |||
| Gold | CID001397 | PT Aneka Tambang (Persero) Tbk | INDONESIA | |||
| Gold | CID001498 | PX Precinox S.A. | SWITZERLAND | |||
| Gold | CID003324 | QG Refining, LLC | UNITED STATES OF AMERICA | |||
| Gold | CID001512 | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | |||
| Gold | CID002582 | REMONDIS PMR B.V. | NETHERLANDS | |||
| Gold | CID001534 | Royal Canadian Mint | CANADA | |||
| Gold | CID002761 | SAAMP | FRANCE | |||
| Gold | CID001546 | Sabin Metal Corp. | UNITED STATES OF AMERICA | |||
| Gold | CID002973 | Safimet S.p.A | ITALY | |||
| Gold | CID002290 | SAFINA A.S. | CZECHIA | |||
| Gold | CID001555 | Samduck Precious Metals | KOREA, REPUBLIC OF | |||
| Gold | CID003529 | Sancus ZFS (L'Orfebre, SA) | COLOMBIA | |||
| Gold | CID003540 | Sellem Industries Ltd. | MAURITANIA |
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| Metal | Smelter CID | Smelter Name | Country | |||
| Gold | CID001585 | SEMPSA Joyeria Plateria S.A. | SPAIN | |||
| Gold | CID001916 | Shandong Gold Smelting Co., Ltd. | CHINA | |||
| Gold | CID002525 | Shandong Humon Smelting Co., Ltd. | CHINA | |||
| Gold | CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | |||
| Gold | CID002750 | Shenzhen CuiLu Gold Co., Ltd. | CHINA | |||
| Gold | CID002527 | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | |||
| Gold | CID002588 | Shirpur Gold Refinery Ltd. | INDIA | |||
| Gold | CID002516 | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | |||
| Gold | CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | |||
| Gold | CID001761 | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | |||
| Gold | CID003383 | Sovereign Metals | INDIA | |||
| Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | JAPAN | |||
| Gold | CID002918 | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | |||
| Gold | CID001810 | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | |||
| Gold | CID002580 | T.C.A S.p.A | ITALY | |||
| Gold | CID001875 | Tanaka Kikinzoku Kogyo K.K. | JAPAN | |||
| Gold | CID001938 | Tokuriki Honten Co., Ltd. | JAPAN | |||
| Gold | CID001947 | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | |||
| Gold | CID002615 | TOO Tau-Ken-Altyn | KAZAKHSTAN | |||
| Gold | CID002314 | Umicore Precious Metals Thailand | THAILAND | |||
| Gold | CID001980 | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | |||
| Gold | CID001993 | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | |||
| Gold | CID002003 | Valcambi S.A. | SWITZERLAND | |||
| Gold | CID003615 | WEEEREFINING | FRANCE | |||
| Gold | CID002030 | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | |||
| Gold | CID002129 | Yokohama Metal Co., Ltd. | JAPAN | |||
| Gold | CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
This table lists the Smelters identified through supplier CMRT responses for the year ended December 31, 2022, that were classified by the RMI on January 3 as Actively working toward achieving conformance with the RMAP audit protocols.
| Metal | Smelter CID | Smelter Name | Country | |||
| Gold | CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | |||
| Gold | CID002778 | WIELAND Edelmetalle GmbH | GERMANY | |||
| Tin | CID000309 | PT Aries Kencana Sejahtera | INDONESIA |
9
This table lists the Smelters identified through supplier CMRT responses for the year ended December 31, 2022, that were neither classified by the RMI on January 3, 2023, as being conformant with the RMAP audit protocols nor actively working toward achieving conformance with the RMAP audit protocols. These smelters are generally referred to as "Not Conformant" even though the RMI itself does not use this label.
| Metal | Smelter CID | Smelter Name | Country | |||
| Gold | CID002708 | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | |||
| Gold | CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | |||
| Gold | CID000180 | Caridad | MEXICO | |||
| Gold | CID000343 | Daye Non-Ferrous Metals Mining Ltd. | CHINA | |||
| Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | JAPAN | |||
| Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | JAPAN | |||
| Gold | CID003186 | Gold Coast Refinery | GHANA | |||
| Gold | CID000651 | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | |||
| Gold | CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | |||
| Gold | CID000767 | Hunan Chenzhou Mining Co., Ltd. | CHINA | |||
| Gold | CID000773 | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | |||
| Gold | CID000778 | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | |||
| Gold | CID002893 | JALAN & Company | INDIA | |||
| Gold | CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | |||
| Gold | CID000493 | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | |||
| Gold | CID000929 | JSC Uralelectromed | RUSSIAN FEDERATION | |||
| Gold | CID000956 | Kazakhmys Smelting LLC | KAZAKHSTAN | |||
| Gold | CID001029 | Kyrgyzaltyn JSC | KYRGYZSTAN | |||
| Gold | CID001032 | L'azurde Company For Jewelry | SAUDI ARABIA | |||
| Gold | CID001056 | Lingbao Gold Co., Ltd. | CHINA | |||
| Gold | CID001058 | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | |||
| Gold | CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | |||
| Gold | CID002857 | Modeltech Sdn Bhd | MALAYSIA | |||
| Gold | CID001204 | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | |||
| Gold | CID003189 | NH Recytech Company | KOREA, REPUBLIC OF | |||
| Gold | CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | |||
| Gold | CID002872 | Pease & Curren | UNITED STATES OF AMERICA | |||
| Gold | CID001362 | Penglai Penggang Gold Industry Co., Ltd. | CHINA | |||
| Gold | CID001386 | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | |||
| Gold | CID000522 | Refinery of Seemine Gold Co., Ltd. | CHINA | |||
| Gold | CID002853 | Sai Refinery | INDIA | |||
| Gold | CID001562 | Samwon Metals Corp. | KOREA, REPUBLIC OF | |||
| Gold | CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | |||
| Gold | CID001955 | Torecom | KOREA, REPUBLIC OF | |||
| Gold | CID003617 | Value Trading | BELGIUM | |||
| Gold | CID002100 | Yamakin Co., Ltd. | JAPAN | |||
| Gold | CID000197 | Yunnan Copper Industry Co., Ltd. | CHINA | |||
| Tantalum | CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | |||
| Tantalum | CID001508 | QuantumClean | UNITED STATES OF AMERICA | |||
| Tantalum | CID001969 | Ulba Metallurgical Plant JSC | KAZAKHSTAN | |||
| Tin | CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | |||
| Tin | CID000942 | Gejiu Kai Meng Industry and Trade LLC | CHINA | |||
| Tin | CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | |||
| Tin | CID002500 | Melt Metais e Ligas S.A. | BRAZIL | |||
| Tin | CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | |||
| Tin | CID001305 | Novosibirsk Tin Combine | RUSSIAN FEDERATION | |||
| Tin | CID003409 | Precious Minerals and Smelting Limited | INDIA | |||
| Tin | CID003449 | PT Mitra Sukses Globalindo | INDONESIA | |||
| Tin | CID001460 | PT Refined Bangka Tin | INDONESIA | |||
| Tin | CID002816 | PT Sukses Inti Makmur | INDONESIA | |||
| Tin | CID002478 | PT Tirus Putra Mandiri | INDONESIA | |||
| Tin | CID002756 | Super Ligas | BRAZIL |
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| Metal | Smelter CID | Smelter Name | Country | |||
| Tin | CID001898 | Thaisarco | THAILAND | |||
| Tin | CID002574 | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | |||
| Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | |||
| Tungsten | CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | |||
| Tungsten | CID000281 | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | |||
| Tungsten | CID003401 | Fujian Ganmin RareMetal Co., Ltd. | CHINA | |||
| Tungsten | CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | |||
| Tungsten | CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | |||
| Tungsten | CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | |||
| Tungsten | CID003408 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | |||
| Tungsten | CID002319 | Malipo Haiyu Tungsten Co., Ltd. | CHINA | |||
| Tungsten | CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | |||
| Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | CHINA | |||
| Gold | CID002561 | Emirates Gold DMCC | UNITED ARAB EMIRATES | |||
| Gold | CID003153 | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | |||
| Gold | CID002567 | Sudan Gold Refinery | SUDAN | |||
| Tantalum | CID002505 | FIR Metals & Resource Ltd. | CHINA | |||
| Tantalum | CID002549 | TANIOBIS Japan Co., Ltd. | JAPAN | |||
| Tin | CID002774 | Aurubis Berango | SPAIN | |||
| Tin | CID003831 | DS Myanmar | MYANMAR | |||
| Tin | CID001490 | PT Tinindo Inter Nusa | INDONESIA | |||
| Tin | CID002036 | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | |||
| Tungsten | CID002645 | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | |||
| Tungsten | CID003978 | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF |
COUNTRY OF ORIGIN INFORMATION
The following countries of origin were identified based on the Smelters reported in suppliers' CMRT responses for the year ended 31 December 2022 and may be the origin of the material in our products.
| Country | Country | Country | ||
| Argentina | Guatemala | Peru | ||
| Armenia | Guinea | Philippines | ||
| Australia | Guyana | Portugal | ||
| Austria | Honduras | Russian Federation | ||
| Azerbaijan | India | Rwanda | ||
| Benin | Indonesia | Saudi Arabia | ||
| Bolivia | Japan | Senegal | ||
| Botswana | Kazakhstan | Sierra Leone | ||
| Brazil | Kenya | Slovakia | ||
| Burkina Faso | Kyrgyzstan | South Africa | ||
| Burundi | Lao People's Democratic Republic | South Korea | ||
| Canada | Liberia | Spain | ||
| Chile | Malaysia | Sudan | ||
| China | Mali | Suriname | ||
| Colombia | Mauritania | Swaziland | ||
| Congo, Democratic Republic of the | Mexico | Sweden | ||
| Côte d'Ivoire | Mongolia | Tanzania | ||
| Dominican Republic | Morocco | Thailand | ||
| Ecuador | Mozambique | Turkey | ||
| Egypt | Myanmar | Uganda | ||
| Eritrea | Namibia | United Kingdom | ||
| Ethiopia | New Zealand | United States of America | ||
| Fiji | Nicaragua | Uzbekistan | ||
| Finland | Niger | Venezuela | ||
| France | Nigeria | Vietnam | ||
| French Guiana | Oman | Zambia | ||
| Germany | Panama | Zimbabwe | ||
| Ghana | Papua New Guinea |
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