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. |