In 2019, we had a total of 19 direct suppliers of the components
described above. We received Templates that we deemed to be
complete, or acceptable representations as to country of origin,
from all of those suppliers. We deemed a Template to be complete if
it identified all of the smelters in a supplier’s supply chain. We
excluded RFID chips from our RCOI because our spending on RFID
chips is de minimis. Based on the Templates that we reviewed, we
identified 33 total smelters, including 26 tin smelters and seven
tungsten smelters, that provided conflict minerals that were
ultimately incorporated into our products.
We are a member of the Responsible Minerals Initiative (“RMI”), an
industry initiative that audits smelters’ and refiners’ due
diligence activities. We used the Reasonable Country of Origin
Inquiry report that we received as part of our RMI membership (the
“RMI RCOI Report”) to identify the country of origin for 30 of our
Based on the RMI RCOI Report, we identified five tin smelters and
one tungsten smelter that supplied conflict minerals to our
suppliers and that we had reason to believe may have sourced
conflict minerals directly or indirectly from the Democratic
Republic of the Congo or an adjoining country (collectively, the
“Covered Countries”). Based on the RMI RCOI Report, we also
determined that a portion of our conflict minerals did not
originate in the Covered Countries (23 smelters) or were solely
from recycled or scrap sources (one smelter).
With respect to the remaining three smelters, we reviewed
representations made by certain suppliers and smelters, reviewed
the smelters’ websites, if any, and conducted open-source internet
searches for any further information on our suppliers and the
smelters regarding the country of origin of the conflict minerals
they used. Based on those additional inquiries, we had no reason to
believe that our conflict minerals from those smelters may have
originated in the Covered Countries.
For information on the due diligence that we performed with respect
to the source and chain of custody of the conflict minerals sourced
from the smelters whose conflict minerals may have originated in
the Covered Countries, see the Conflict Minerals Report attached
hereto as Exhibit 1.01.
This Form SD and the related Conflict Minerals Report are available
on our Internet website at http://investor.goodyear.com/sec.cfm.
Please note, however, that information contained on our Internet
website is not incorporated by reference into this Form SD or
otherwise considered to be a part of this document.
The Conflict Minerals Report required by Item 1.01 is attached
hereto as Exhibit 1.01. See Item 2.01 below.
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