Document

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 
FORM SD
Specialized Disclosure Report
 
 
Medtronic Public Limited Company
(Exact name of Registrant as Specified in its Charter)
 
 
 
Ireland 1-36820 98-1183488
(State or other jurisdiction
of incorporation)
 (Commission
File Number)
 (IRS Employer
Identification No.)
 
20 On Hatch, Lower Hatch Street
Dublin 2, Ireland
 n/a
(Address of principal executive offices) (Zip Code)
 
Karen Parkhill 763-514-4000
(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:
 
xRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
 
  



INFORMATION TO BE INCLUDED IN THE REPORT
 
Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of Medtronic Public Limited Company (the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2019 to December 31, 2019.

A copy of Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and details the due diligence measures undertaken during the reporting period by the Company on a consolidated basis. A copy of the Conflict Minerals Report is also publicly available through the Company’s website: www.medtronic.com (under the “Investors” caption and “SEC Filings” subcaption).

Item 1.02 Exhibit

The Company has filed, as an exhibit to this Form SD, the Conflict Minerals Report of the Company required by Item 1.01.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report:

Exhibit 1.01 - Conflict Minerals Report of the Company




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.
 
MEDTRONIC PUBLIC LIMITED COMPANY
Date: May 1, 2020By/s/ Karen L. Parkhill
Karen L. Parkhill
Executive Vice President and Chief Financial Officer




EXHIBIT INDEX
Medtronic Public Limited Company
Form SD
 
Exhibit No.  Description
  

Document

Exhibit 1.01

Medtronic Public Limited Company
Conflict Minerals Report
For the Year Ended December 31, 2019

Overview

This Conflict Minerals Report (this “Report”) of Medtronic Public Limited Company (“Medtronic,” the “Company,” “we,” “us,” and “our”) has been prepared by us on a consolidated basis for the reporting period from January 1, 2019 to December 31, 2019 (the “Reporting Period”) pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. Conflict minerals are defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten and gold (often referred to as 3TG) for the purposes of this assessment. The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

If a registrant knows or has reason to believe that any of the conflict minerals necessary to the functionality or production of their products may have originated in the Covered Countries, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.

Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk about the sourcing of our conflict minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities) or these plans may not be effective. In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in the Company’s most recently submitted Quarterly or Annual Reports. Except as required by law, we disclaim any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.

Company Summary

Medtronic, headquartered in Dublin, Ireland, is among the world's largest medical technology, services, and solutions companies - alleviating pain, restoring health, and extending life for millions of people around the world. Medtronic was founded in 1949 and today serves hospitals, physicians, clinicians, and patients in more than 150 countries worldwide. Medtronic remains committed to a mission written by its founder in 1960 that directs Medtronic “to contribute to human welfare by the application of biomedical engineering in the research, design, manufacture, and sale of products to alleviate pain, restore health, and extend life.”

Medtronic’s business groups and products for the Reporting Period included:

The Cardiac and Vascular Group (“CVG”) is composed of the Cardiac Rhythm & Heart Failure (“CRHF”), Coronary & Structural Heart, and Aortic, Peripheral & Venous divisions. CVG's products include pacemakers, insertable and external cardiac monitors, cardiac resynchronization therapy devices, implantable cardioverter defibrillators, leads and delivery systems, ventricular assist systems, ablation products, electrophysiology catheters, products for the treatment of atrial fibrillation, information systems for the management of patients with CRHF devices, products designed to reduce surgical site infections, coronary and peripheral stents and related delivery systems, balloons and related delivery systems, endovascular stent graft systems, heart valve replacement technologies, cardiac tissue ablation systems, and open heart and coronary bypass grafting surgical products. CVG also includes Care Management Services and Cath Lab Managed Services within the CRHF division.

The Minimally Invasive Therapies Group (“MITG”) is composed of the Surgical Innovations and Respiratory, Gastrointestinal, & Renal divisions. MITG’s products span the entire continuum of patient care from diagnosis to



recovery with a focus on diseases of the gastrointestinal tract, lungs, pelvic region, kidneys, obesity, and preventable complications. The products include those for advanced and general surgical care including surgical stapling devices, vessel sealing instruments, wound closure, electrosurgery products, hernia mechanical devices, mesh implants, advanced ablation, interventional lung, ventilators, capnography, airway products, sensors, dialysis, and monitors.

The Restorative Therapies Group (“RTG”) is composed of the Spine, Brain Therapies, Specialty Therapies and Pain Therapies divisions. RTG’s products focus on various areas of the spine, bone graft substitutes, biologic products, trauma, implantable neurostimulation therapies and drug delivery systems for the treatment of chronic pain, movement disorders, epilepsy, overactive bladder, urinary retention, fecal incontinence and gastroparesis, as well as products to treat conditions of the ear, nose, and throat, and systems that incorporate advanced energy surgical instruments. RTG also manufactures and sells image-guided surgery and intra-operative imaging systems, robotic guidance systems used in robot assisted spine procedures, and therapies to treat diseases of the vasculature in and around the brain, including coils, neurovascular stents and flow diversion products.

The Diabetes Group’s products include insulin pumps, continuous glucose monitoring systems, insulin pump consumables, and therapy management software.

This Report has been prepared by Company management.

Design of Conflict Minerals Program

The Company has designed its conflict minerals program, and the reasonable country of origin inquiry and due diligence measures contained therein, to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2013) and related supplements for gold, tin, tantalum and tungsten. Due to the depth of the Company’s supply chain, the Company is far removed from the sources of ore from which conflict minerals are produced and the smelters and refiners that process those ores, and the Company has limited influence over the behavior of these smelters and refiners. Moreover, because of the geographic diversity and ongoing changes in the Company’s supply chain, the Company often has significant difficulty identifying those suppliers who are further upstream from the Company’s direct suppliers. As a result, the Company’s program was specifically designed to relate to our position in the minerals supply chain as a "downstream" purchaser. Summarized below are the design components of the Company’s conflict minerals program as they relate to the five-step framework from the OECD Guidance:

Step 1. Establish and Maintain Strong Company Management Systems

Establish and maintain a policy for the sourcing of minerals from the Covered Countries, which is available at www.medtronic.com/us-en/about/corporate-social-responsibility/suppliers/value-chain.html.

Maintain continued membership in the Responsible Minerals Initiative (“RMI”), formerly known as the Conflict Free Sourcing Initiative (“CFSI”).

Establish a system of controls and transparency through the use of the Conflict Minerals Reporting Template (“CMRT”) as a standard survey tool to identify smelters and refiners.

Establish and maintain a cross-functional conflict minerals management structure composed of three teams:

Steering Committee comprised of the Chief Procurement Officer, VP Finance and Chief Accounting Officer, and VP Corporate Governance & Privacy, which was responsible for the overall program management of the conflict minerals compliance program, including strategy, governance structure, and oversight through the Supply Management Leadership Team;

Central Team comprised of the Director, Responsible Supply Management Program, a Supply Chain Project Analyst, and a legal representative, which was responsible for the overall conflict minerals program design and implementation, including data collection, applicability and supplier review, reasonable country of origin inquiry (“RCOI”), due diligence, audit readiness, and reporting, as well as day-to-day program management; and

Business Group Team comprised of members from each business group who were responsible for data collection, applicability and supplier review.




Update Steering Committee and the Company’s senior sourcing and supply chain leaders on the status of the conflict minerals program on a quarterly basis.

Develop and maintain a training document for employees that discusses the highlights of the Rule and the Company’s expectations of its suppliers to assist in complying with the Rule. Employees are trained through materials that are made available on the Company’s intranet site. Supplier training materials are available to all in-scope suppliers through a 3rd party Learning Management System (LMS).

Enable the Company to receive external inquiries and grievances from customers, employees or other interested parties via the Company’s confidential Voice Your Concern Line at www.VoiceYourConcernLine.com or the conflict minerals e-mail box (conflictminerals@medtronic.com).

Develop and add a clause to templates for new and renewed supply agreements and to standard purchase order terms and conditions that requires suppliers to provide information about the sourcing of conflict minerals and smelters or refiners and to conduct due diligence on the source and chain of custody for any conflict minerals used in their manufacturing processes.
Maintain records of the Company’s conflict minerals process for a minimum of five years, in accordance with the OECD Guidance.

Step 2. Identify and Assess Risks in the Supply Chain

Engage with affected suppliers by sending an email notifying them that the Company is subject to the Rule and that their cooperation in responding to a conflict minerals survey is requested.

Conduct a supply chain survey, based on the CMRT developed by the RMI, of direct suppliers that supply the Company with products or components that may contain necessary conflict minerals.

Receive and review responses from suppliers that were surveyed.

Assess the reasonableness of all responses claiming to not use conflict minerals in their manufacturing processes based on internal knowledge of supplies purchased.

Perform an automated red flag review of all supplier responses.

Communicate with suppliers on the required corrective actions and request additional information as necessary.

Step 3. Design and Implement a Strategy to Respond to Identified Risks

Implement a risk management plan that outlines the Company’s responses to identified risks.

Send reminder letters to each supplier who does not respond to the Company’s initial survey request in an attempt to receive a completed CMRT and work through Category and/or Commodity managers to personally follow up with non-responsive, high-spend suppliers.

Review supplier responses that claim to source conflict minerals from one or more of the Covered Countries.

Follow up with suppliers that do not provide a smelter or refiner list or indicate that they do not provide a complete smelter or refiner list to request additional smelter or refiner information.

Compare a list of unique smelters or refiners received from suppliers who respond that they source conflict minerals from the Covered Countries against conformant, active, and standard smelter or refiner lists per the RMAP for verification of existence and location of the smelters or refiners, as well as the location from which conflict minerals were sourced. Identify smelters or refiners on the RMAP conformant list. For all suppliers who provide unknown or non-RMAP conformant smelters or refiners, continue to work with the supplier to investigate the smelter or refiner and determine the location from which the conflict minerals originated.

Evaluate facilities listed on CMRTs submitted by suppliers against red flag indicators defined in the OECD Guidance: geographic proximity to the Covered Countries, RMAP audit status, and credible evidence of unethical or conflict



sourcing. If facilities meeting these criteria appear on CMRTs submitted by suppliers, the suppliers receive instructions to take risk mitigation actions.

Send communication to non-conformant smelters and refiners identified in the Company’s supply chain asking them to get audited and become conformant.

Send communication to direct suppliers who trigger due diligence by indicating sourcing from the Covered Countries reminding them of the Company’s conflict minerals policy and asking them to make every effort to source conflict minerals from the validated sources.

Step 4. Carry Out Independent Third-Party Audit of Smelter or Refiner’s Due Diligence Practices

The Company is a downstream consumer of necessary conflict minerals and many steps removed from smelters or refiners who provide minerals and ores. The Company does not perform or direct audits of smelters or refiners within its supply chain and relies on the RMAP and its partners to conduct smelter and refiner due diligence.

Step 5. Report Annually on Supply Chain Due Diligence

This Conflict Minerals Report is annually filed with the U.S. Securities and Exchange Commission. This Conflict Minerals Report is also available at www.medtronic.com (under the “Investors” caption and “SEC Filings” sub caption).

2019 Process

The Company determined that tin, tantalum, tungsten and gold, often referred to as 3TG, were necessary to the functionality of many of its products. In order to conform to the Rule, the Company then performed a risk-based assessment to determine if the necessary conflict minerals in the products the Company manufactured or contracted to manufacture directly or indirectly financed or benefitted armed groups in one or more of the Covered Countries. This risk-based assessment is discussed in further detail in the following sections.

Reasonable Country of Origin Inquiry

In accordance with the Rule, after the Company’s initial determination that conflict minerals were necessary to the functionality of many products, the Company conducted a reasonable country of origin inquiry (“RCOI”) to determine whether the Company had reason to believe that any of the conflict minerals necessary to the functionality or production of its products may have originated in the Covered Countries. The Company identified suppliers to survey by reviewing 2019 direct material purchases and applying applicability filters to segment suppliers that supply the Company with products or components that may contain necessary conflict minerals. After identifying the relevant suppliers, the Company then conducted a supply chain survey, based on the current version of the Conflict Minerals Reporting Template (“CMRT”) originally developed by the Conflict Free Sourcing Initiative (“CFSI”), of 288 direct suppliers that supply the Company with products or components that may contain necessary conflict minerals. The Company utilized a third-party web-based software platform and analysis system to conduct this supply chain survey. The suppliers surveyed represented all suppliers determined to be in-scope for 2019 based on the Company’s applicability filters, as mentioned above.

The Company received 251 responses from suppliers that were surveyed, representing an 87% response rate and 94% of all spend surveyed. The Company sent up to three reminder letters to each supplier who did not respond to the Company’s initial survey request in an attempt to receive a completed CMRT and worked through relationship managers to personally follow up with non-responsive, high-spend suppliers.

Of the 251 responses, 38 suppliers either claimed to source conflict minerals from one or more of the Covered Countries or provided information that caused the Company to reasonably believe that the supplier sourced conflict minerals from one or more of the Covered Countries. As a result, the Company has reason to believe that necessary conflict minerals in its products may have originated in the Covered Countries.

Red Flag Review

The Company performed an automated red flag review of all supplier responses. Each facility that met the RMI definition of a smelter or refiner of a 3TG mineral was assessed according to red flag indicators defined in the OECD Guidance. The three factors evaluated to determine the level of risk that each smelter poses to the supply chain are:




Geographic proximity to the Covered Countries;

RMAP audit status; and

Credible evidence of unethical or conflict sourcing.

Based on these criteria the following facilities have been identified with red-flag risks in their supply chain:

Tony Goetz NV - CID002587-Belgium

African Gold Refinery - CID003185-Uganda

Kaloti Precious Metals - CID002563-UAE

Fidelity Printers - CID002515-Zimbabwe

Sudan Refinery - CID002567-Sudan

As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Submissions that included any of the above facilities immediately produced a return email instructing the supplier to take their own risk mitigation actions and to escalate this matter up within the supplier in order to work to remove these red flag smelters or refiners from their supply chain.

Due Diligence Measures Performed

Following the Company’s RCOI, the Company performed the following measures to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in the Company’s products which the Company has reason to believe may have originated from the Covered Countries:

Reviewed supplier responses that claimed to source conflict minerals from one or more of the Covered Countries (38 out of 251 completed supplier responses) and compiled initial list of smelters and refiners provided by such suppliers.

Followed up with suppliers that claimed to source, or provided information that caused the Company to reasonably believe that the supplier sourced, conflict minerals from one or more of the Covered Countries but did not provide a smelter or refiner list or indicated that they did not provide a complete smelter or refiner list to request additional smelter or refiner information.

Compared a list of 509 potential unique smelters or refiners received from the above suppliers against conformant, active, and legitimate smelter or refiner lists per the RMAP for verification of existence and location of the smelters or refiners, as well as the location from which conflict minerals were sourced.

Identified 234 smelters or refiners on the RMAP conformant list and 7 smelters on the RMAP active list.

For all suppliers who provided non-RMAP conformant or non-RMAP active smelters or refiners (73 suppliers), the Company reached out to them and asked them to work with their smelters and encourage them to become RMAP conformant.

Results of Due Diligence Measures

As a downstream purchaser of products which contain conflict minerals, the Company’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. The Company’s due diligence processes are based on the necessity of seeking data from direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. The Company also relies, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information due to, among other reasons, gaps in supplier or smelter data, errors or omissions in information provided by suppliers or smelters, or misunderstandings by suppliers or smelters regarding the SEC requirements.

Per the Company’s supply chain survey, 38 of the Company’s suppliers claimed to source, or provided information that caused the Company to reasonably believe that the supplier sourced, conflict minerals from one or more of the Covered Countries.



These suppliers identified 509 potential smelter and refiner facilities that may process the necessary conflict minerals contained in the materials provided to the Company. Of those facilities:

234 are listed as “conformant” on the RMAP list, meaning that they are conformant with the RMAP assessment protocols;

7 are listed as “active” on the RMAP list, meaning that they have committed to undergo a RMAP audit or are participating in a cross-recognized certification program;

61 are included on the RMAP list, but are not listed as “conformant” or “active”; and

after comparing the remaining 207 names to the RMAP database, the Company was unable to determine that these were valid smelter names.

A listing of the known smelters and refiners identified by the Company’s suppliers is included in Annex I below. Not all of the included smelters and refiners may have processed the necessary conflict minerals contained in the Company’s products. In some cases, suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their respective suppliers, the decision of such suppliers to provide information on a company-wide level rather than a product-based level, or for other reasons. The smelters and refiners listed in Annex I may not be all of the smelters and refiners in the Company’s supply chain, since certain suppliers were unable to identify the smelters and refiners of some of the necessary conflict minerals content contained in our products and because not all suppliers responded to our inquiries.

The RMAP-conformant smelters disclosed that, in addition to sourcing from recycled or scrap sources, they have sourced materials from L1, L2 and L3 countries, as well as from the Democratic Republic of the Congo. L1 and L2 countries are, respectively, countries with known active ore production that are not identified as conflict regions or plausible countries of smuggling or export of conflict minerals and countries that are known or plausible countries for smuggling, export out of L3 countries, or transit of materials containing conflict minerals. The L3 countries consist of the Covered Countries. The smelters that are not listed as “conformant” on the RMAP list disclosed that, in addition to sourcing from recycled or scrap sources, they have sourced materials from China, Australia, Canada, Indonesia, Peru, Bolivia, the United States of America and the L1 countries; however, many smelters did not provide specific country of origin data, and, as a result, this list is likely incomplete. The smelters that are not listed as “conformant” on the RMAP list did not disclose any mines located in the Covered Countries.
Compared to the 2018 reporting year, the Company observed the following changes through the analysis of RCOI and source and chain of custody due diligence data for the 2019 reporting year:

Decrease in the number of suppliers reporting high risk smelters or refiners from 40 to 38.

Decrease in percentage of suppliers reporting high risk smelters or refiners from 18% to 15%.

Independent Private Sector Audit

The Company does not have sufficient information to determine whether its products are “DRC conflict free.” As such, an independent private sector audit is not required at this time.

Continuous Improvement

The Company took the following steps, among others, to mature its conflict minerals program, including its RCOI and due diligence measures, in accordance with OECD Guidance and to further mitigate the risk that the conflict minerals contained in its products finance or benefit armed groups in the Covered Countries:

Included VP Corporate Governance & Privacy in the Steering Committee.

Integrated conflict minerals program from Mazor Robotics Ltd., which the Company acquired on December 18, 2028.

Included a conflict minerals flow-down clause in new or renewed supplier agreement templates and in standard purchaser terms and conditions.

Continued to partner with a 3rd party software and service provider with extensive expertise in turn-key conflict minerals services.




Shared all due diligence results with the Steering Committee and Business Groups senior sourcing leadership who demonstrated awareness and concern, as well as responsiveness to the risks identified in the due diligence.

Engaged with suppliers by directing them to training resources to increase the response rate and improve the quality of the supplier survey responses.

Reached out to smelters and refiners within the Company’s supply chain who are not currently on the RMAP list and encouraged them to become conformant.

Reached out to suppliers who indicated that they source conflict minerals from the Covered Countries to reiterate the Company’s policy and ask them to apply every effort to use only conformant sources of conflict minerals.

Worked with non-responsive suppliers through follow-up letters and direct outreach by commodity managers to educate suppliers and facilitate responses.

Created a process to receive external inquiries and grievances from customers, employees or other interested parties.

Participated in multiple webinars and conferences.

Maintained membership in RMI since 2015, which provides the Company with the ability to participate in shaping industry policies regarding conflict minerals, a forum for engagement with stakeholder groups related to conflict minerals, and access to data regarding those facilities that are validated through the RMI.

The Company expects to take the following steps as part of continuous improvement:

Review and update, as necessary, the Company’s Conflict Minerals policy.

Work to further mature the Company’s conflict minerals program and build transparency over its supply chain in accordance with the OECD Guidance.

Continue to annually evaluate the Company’s suppliers in order to determine those suppliers that are in-scope and should be surveyed as part of the Company’s conflict minerals program.

Continue to drive our suppliers to obtain current, accurate, and complete information from their supply chain about their smelters and refiners of conflict minerals.

Further focus on the analysis of supplier responses and maturing the Company’s due diligence efforts and procedures for suppliers that report to source from one or more of the Covered Countries, specifically at the smelter or refiner and component level.

Increase the Company’s focus on conflict minerals compliance on high-risk and high-spend suppliers.

Annex I

Smelters and Refiners

Metal
Standard Smelter Name
Smelter Facility Location
RMI Audit Status
Gold8853 S.p.A.ITALYConformant
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICANon Conformant
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICAConformant
GoldAfrican Gold RefineryUGANDAOutreach Required
GoldAida Chemical Industries Co., Ltd.JAPANConformant
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESConformant
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANConformant



GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILConformant
GoldArgor-Heraeus S.A.SWITZERLANDConformant
GoldAsahi Pretec Corp.JAPANConformant
GoldAsahi Refining Canada Ltd.CANADAConformant
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICAConformant
GoldAsaka Riken Co., Ltd.JAPANConformant
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYDue Diligence Vetting Process
GoldAU Traders and RefinersSOUTH AFRICAConformant
GoldAurubis AGGERMANYConformant
GoldBangalore RefineryINDIAConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESConformant
GoldBoliden ABSWEDENConformant
GoldC. Hafner GmbH + Co. KGGERMANYConformant
GoldCaridadMEXICOCommunication Suspended - Not Interested
GoldCCR Refinery - Glencore Canada CorporationCANADAConformant
GoldCendres + Metaux S.A.SWITZERLANDConformant
GoldCGR Metalloys Pvt Ltd.INDIAOutreach Required
GoldChimet S.p.A.ITALYConformant
GoldChugai MiningJAPANConformant
GoldDaye Non-Ferrous Metals Mining Ltd.CHINAIn Communication
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYOutreach Required
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESIn Communication
GoldDODUCO Contacts and Refining GmbHGERMANYConformant
GoldDowaJAPANConformant
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OFConformant
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFConformant
GoldEco-System Recycling Co., Ltd. East PlantJAPANConformant
GoldEco-System Recycling Co., Ltd. North PlantJAPANConformant
GoldEco-System Recycling Co., Ltd. West PlantJAPANConformant
GoldEmirates Gold DMCCUNITED ARAB EMIRATESConformant
GoldFidelity Printers and Refiners Ltd.ZIMBABWEDue Diligence Vetting Process
GoldFujairah Gold FZCUNITED ARAB EMIRATESOutreach Required
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIAIn Communication
GoldGeib Refining CorporationUNITED STATES OF AMERICAConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINAConformant
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINAOutreach Required
GoldGuangdong Jinding Gold LimitedCHINAOutreach Required
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINAOutreach Required
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINAOutreach Required
GoldHeimerle + Meule GmbHGERMANYConformant
GoldHeraeus Metals Hong Kong Ltd.CHINAConformant



GoldHeraeus Precious Metals GmbH & Co. KGGERMANYConformant
GoldHunan Chenzhou Mining Co., Ltd.CHINAOutreach Required
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINAOutreach Required
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFCommunication Suspended - Not Interested
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINAConformant
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESOutreach Required
GoldIshifuku Metal Industry Co., Ltd.JAPANConformant
GoldIstanbul Gold RefineryTURKEYConformant
GoldItalpreziosiITALYConformant
GoldJapan MintJAPANConformant
GoldJiangxi Copper Co., Ltd.CHINAConformant
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONRMI Due Diligence Review - Unable to Proceed
GoldJSC UralelectromedRUSSIAN FEDERATIONConformant
GoldJX Nippon Mining & Metals Co., Ltd.JAPANConformant
GoldKaloti Precious MetalsUNITED ARAB EMIRATESRMI Due Diligence Review - Unable to Proceed
GoldKazakhmys Smelting LLCKAZAKHSTANIn Communication
GoldKazzincKAZAKHSTANConformant
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICAConformant
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDConformant
GoldKojima Chemicals Co., Ltd.JAPANConformant
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFConformant
GoldKyrgyzaltyn JSCKYRGYZSTANConformant
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONOutreach Required
GoldL'azurde Company For JewelrySAUDI ARABIARMI Due Diligence Review - Unable to Proceed
GoldLingbao Gold Co., Ltd.CHINAOutreach Required
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINAOutreach Required
GoldL'Orfebre S.A.ANDORRAConformant
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFConformant
GoldLT Metal Ltd.KOREA, REPUBLIC OFConformant
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINAOutreach Required
GoldMarsam MetalsBRAZILConformant
GoldMaterionUNITED STATES OF AMERICAConformant
GoldMatsuda Sangyo Co., Ltd.JAPANConformant
GoldMetalor Technologies (Hong Kong) Ltd.CHINAConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPOREConformant
GoldMetalor Technologies (Suzhou) Ltd.CHINAConformant
GoldMetalor Technologies S.A.SWITZERLANDConformant
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICAConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOConformant



GoldMitsubishi Materials CorporationJAPANConformant
GoldMitsui Mining and Smelting Co., Ltd.JAPANConformant
GoldMMTC-PAMP India Pvt., Ltd.INDIAConformant
GoldModeltech Sdn BhdMALAYSIANon Conformant
GoldMorris and WatsonNEW ZEALANDCommunication Suspended - Not Interested
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYConformant
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANOutreach Required
GoldNH Recytech CompanyKOREA, REPUBLIC OFNon Conformant
GoldNihon Material Co., Ltd.JAPANConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIAConformant
GoldOhura Precious Metal Industry Co., Ltd.JAPANConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONConformant
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONConformant
GoldPAMP S.A.SWITZERLANDConformant
GoldPease & CurrenUNITED STATES OF AMERICAOutreach Required
GoldPenglai Penggang Gold Industry Co., Ltd.CHINAOutreach Required
GoldPlanta Recuperadora de Metales SpACHILEConformant
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONConformant
GoldPT Aneka Tambang (Persero) TbkINDONESIAConformant
GoldPX Precinox S.A.SWITZERLANDConformant
GoldQG Refining, LLCUNITED STATES OF AMERICAOutreach Required
GoldRand Refinery (Pty) Ltd.SOUTH AFRICAConformant
GoldRefinery of Seemine Gold Co., Ltd.CHINAOutreach Required
GoldREMONDIS PMR B.V.NETHERLANDSConformant
GoldRoyal Canadian MintCANADAConformant
GoldSAAMPFRANCEConformant
GoldSabin Metal Corp.UNITED STATES OF AMERICAOutreach Required
GoldSafimet S.p.AITALYConformant
GoldSAFINA A.S.CZECH REPUBLICActive
GoldSai RefineryINDIAOutreach Required
GoldSamduck Precious MetalsKOREA, REPUBLIC OFConformant
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCommunication Suspended - Not Interested
GoldSAXONIA Edelmetalle GmbHGERMANYConformant
GoldSEMPSA Joyeria Plateria S.A.SPAINConformant
GoldShandong Humon Smelting Co., Ltd.CHINAOutreach Required
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINAOutreach Required
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINAConformant
GoldSichuan Tianze Precious Metals Co., Ltd.CHINAConformant



GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINAConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONConformant
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINAConformant
GoldSovereign MetalsINDIAOutreach Required
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIAOutreach Required
GoldSudan Gold RefinerySUDANOutreach Required
GoldSumitomo Metal Mining Co., Ltd.JAPANConformant
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFConformant
GoldT.C.A S.p.AITALYConformant
GoldTanaka Kikinzoku Kogyo K.K.JAPANConformant
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINAConformant
GoldTokuriki Honten Co., Ltd.JAPANConformant
GoldTongling Nonferrous Metals Group Co., Ltd.CHINAOutreach Required
GoldTony Goetz NVBELGIUMNon Conformant
GoldTOO Tau-Ken-AltynKAZAKHSTANConformant
GoldTorecomKOREA, REPUBLIC OFConformant
GoldUmicore Brasil Ltda.BRAZILConformant
GoldUmicore Precious Metals ThailandTHAILANDConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMConformant
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICAConformant
GoldValcambi S.A.SWITZERLANDConformant
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIAConformant
GoldWIELAND Edelmetalle GmbHGERMANYConformant
GoldYamakin Co., Ltd.JAPANConformant
GoldYokohama Metal Co., Ltd.JAPANConformant
GoldYunnan Copper Industry Co., Ltd.CHINAOutreach Required
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINAConformant
TantalumAsaka Riken Co., Ltd.JAPANConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINAConformant
TantalumCP Metals Inc.UNITED STATES OF AMERICAActive
TantalumD Block Metals, LLCUNITED STATES OF AMERICAConformant
TantalumExotech Inc.UNITED STATES OF AMERICAConformant
TantalumF&X Electro-Materials Ltd.CHINAConformant
TantalumFIR Metals & Resource Ltd.CHINAConformant
TantalumGlobal Advanced Metals AizuJAPANConformant
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICAConformant
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINAConformant
TantalumH.C. Starck Co., Ltd.THAILANDConformant



TantalumH.C. Starck Hermsdorf GmbHGERMANYConformant
TantalumH.C. Starck Inc.UNITED STATES OF AMERICAConformant
TantalumH.C. Starck Ltd.JAPANConformant
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYConformant
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYConformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINAConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumJiangxi Tuohong New Raw MaterialCHINAConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINAConformant
TantalumJiujiang Tanbre Co., Ltd.CHINAConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINAConformant
TantalumKEMET Blue MetalsMEXICOConformant
TantalumLSM Brasil S.A.BRAZILConformant
TantalumMetallurgical Products India Pvt., Ltd.INDIAConformant
TantalumMineracao Taboca S.A.BRAZILConformant
TantalumMitsui Mining and Smelting Co., Ltd.JAPANConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINAConformant
TantalumNPM Silmet ASESTONIAConformant
TantalumPRG DooelNORTH MACEDONIA, REPUBLIC OFConformant
TantalumQuantumCleanUNITED STATES OF AMERICAConformant
TantalumResind Industria e Comercio Ltda.BRAZILConformant
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONConformant
TantalumTaki Chemical Co., Ltd.JAPANConformant
TantalumTelex MetalsUNITED STATES OF AMERICAConformant
TantalumUlba Metallurgical Plant JSCKAZAKHSTANConformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINAConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINAConformant
TinAlphaUNITED STATES OF AMERICAConformant
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMOutreach Required
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINAConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINAConformant
TinChina Tin Group Co., Ltd.CHINAConformant
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINANon Conformant
TinDowaJAPANConformant
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMNon Conformant
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)Conformant
TinEstanho de Rondonia S.A.BRAZILIn Communication
TinFenix MetalsPOLANDConformant
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINAOutreach Required



TinGejiu Kai Meng Industry and Trade LLCCHINAConformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINAConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINAConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINAConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINAConformant
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINAConformant
TinHuiChang Hill Tin Industry Co., Ltd.CHINAConformant
TinHuichang Jinshunda Tin Co., Ltd.CHINAConformant
TinJiangxi New Nanshan Technology Ltd.CHINAConformant
TinLuna Smelter, Ltd.RWANDAConformant
TinMa'anshan Weitai Tin Co., Ltd.CHINAConformant
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILConformant
TinMalaysia Smelting Corporation (MSC)MALAYSIAConformant
TinMelt Metais e Ligas S.A.BRAZILConformant
TinMetallic Resources, Inc.UNITED STATES OF AMERICAConformant
TinMetallo Belgium N.V.BELGIUMConformant
TinMetallo Spain S.L.U.SPAINConformant
TinMineracao Taboca S.A.BRAZILConformant
TinMinsurPERUConformant
TinMitsubishi Materials CorporationJAPANConformant
TinModeltech Sdn BhdMALAYSIANon Conformant
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMOutreach Required
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDConformant
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESConformant
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)Conformant
TinPongpipat Company LimitedMYANMAROutreach Required
TinPrecious Minerals and Smelting LimitedINDIAActive
TinPT Artha Cipta LanggengINDONESIAConformant
TinPT ATD Makmur Mandiri JayaINDONESIAConformant
TinPT Menara Cipta MuliaINDONESIAConformant
TinPT Mitra Stania PrimaINDONESIAConformant
TinPT Refined Bangka TinINDONESIAConformant
TinPT Timah Tbk KundurINDONESIAConformant
TinPT Timah Tbk MentokINDONESIAConformant
TinResind Industria e Comercio Ltda.BRAZILConformant
TinRui Da HungTAIWAN, PROVINCE OF CHINAConformant
TinSoft Metais Ltda.BRAZILConformant
TinSuper LigasBRAZILOutreach Required
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMConformant
TinThaisarcoTHAILANDConformant
TinTin Technology & RefiningUNITED STATES OF AMERICAConformant



TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMOutreach Required
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINAConformant
TinYunnan Tin Company LimitedCHINAConformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINAConformant
TungstenA.L.M.T. Corp.JAPANConformant
TungstenACL Metais EireliBRAZILConformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILActive
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINAConformant
TungstenChina Molybdenum Co., Ltd.CHINAOutreach Required
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINAConformant
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINAOutreach Required
TungstenCP Metals Inc.UNITED STATES OF AMERICAActive
TungstenFujian Ganmin RareMetal Co., Ltd.CHINAConformant
TungstenFujian Jinxin Tungsten Co., Ltd.CHINAConformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINAConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINAConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINAConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINAConformant
TungstenGEM Co., Ltd.CHINAIn Communication
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICAConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINAConformant
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYConformant
TungstenH.C. Starck Tungsten GmbHGERMANYConformant
TungstenHunan Chenzhou Mining Co., Ltd.CHINAConformant
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINAConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINAConformant
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINAConformant
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONConformant
TungstenJapan New Metals Co., Ltd.JAPANConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINAConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINAConformant
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACommunication Suspended - Not Interested
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINAConformant
TungstenJiangxi Xianglu Tungsten Co., Ltd.CHINAActive
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINAConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINAConformant
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONActive
TungstenKennametal FallonUNITED STATES OF AMERICAConformant



TungstenKennametal HuntsvilleUNITED STATES OF AMERICAConformant
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFConformant
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINAConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINAConformant
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMConformant
TungstenMoliren Ltd.RUSSIAN FEDERATIONConformant
TungstenNiagara Refining LLCUNITED STATES OF AMERICAConformant
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONIn Communication
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESConformant
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIET NAMConformant
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONConformant
TungstenWolfram Bergbau und Hutten AGAUSTRIAConformant
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OFConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINAConformant
TungstenXiamen Tungsten Co., Ltd.CHINAConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINAConformant
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINAConformant