UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
TotalEnergies SE
(Exact name of registrant as specified in its
charter)
Republic of France
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001-10888
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98-0227345
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(State or other jurisdiction of
incorporation or organization)
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(Commission File
Number)
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(IRS Employer
Identification No.)
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2, place Jean Millier
La Défense 6
92400 Courbevoie
France
(Address of principal
executive offices) (Zip Code)
Jean-Pierre Sbraire
Chief Financial Officer
Tel: +33 (0)1 47 44 45 46
Fax: +33 (0)1 47 44 49 44
(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:
x Rule 13p-1
under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
TotalEnergies SE is providing on this Form SD disclosure in accordance
with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.
Section 1 – Conflict Minerals Disclosure
Item 1.01(b)
CONFLICT MINERALS DISCLOSURE
TotalEnergies SE (collectively with its consolidated subsidiaries,
“TotalEnergies” or the “Group”) is providing herein disclosure in accordance with Rule 13p-1 (the “Rule”)
under the Securities Exchange Act of 1934, as amended, which implements reporting and disclosure requirements related to certain minerals
(referred to as “conflict minerals” under the Rule) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection
Act of 2010, for the reporting period from January 1, 2020 to December 31, 2020 (the “Reporting Period”). For the
Reporting Period, “Conflict Minerals” are defined in the Rule as the following minerals (regardless of their geographic
origin): cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, limited to tin, tantalum and tungsten and
a “Covered Country” is defined in the Rule as the Democratic Republic of the Congo or an adjoining country.
This conflict minerals disclosure is also publicly available at TotalEnergies’
Sustainable Performance website: https://www.sustainable-performance.totalenergies.com/en/our-challenges/supply-chain.1
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I.
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Diligence and Reporting Process
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TotalEnergies has established a management system to implement a diligence
and reporting process concerning Conflict Minerals in accordance with the Rule. This process is coordinated at the Holding level with
designated division coordinators at the level of each of the business segments and operational entities (Exploration & Production,
Gas, Renewables & Power, Refining & Chemicals, Trading & Shipping, Marketing & Services and Total
Global Procurement) who contact the relevant parties (such as business managers and purchasing departments). These division coordinators
report the results of the diligence process to the Holding level.
For this Reporting Period, Saft Groupe S.A. (“Saft”), a
subsidiary in the Gas, Renewables & Power business segment, and Hutchinson S.A. (“Hutchinson”), a subsidiary in the
Refining & Chemicals business segment, identified products which each had manufactured, or contracted to have manufactured, that
contained Conflict Minerals, namely tin, tantalum, tungsten and/or gold (collectively, “3TG”), that were necessary to the
functionality or production of those products.
In addition, SunPower Corporation, a subsidiary in the Gas, Renewables &
Power business segment based in California (“SunPower”)2, is subject to the
Rule because it is an American company listed on NASDAQ. It publishes separately information concerning its use of Conflict Minerals
in certain of its products that it manufactured or contracted to manufacture (solar panels, balance of systems components). The text
of SunPower’s disclosure for this Reporting Period provided on its Form SD is included in Annex A to this document.
A. Saft
Saft is a leading manufacturer of batteries for the industrial infrastructure
and processes, transportation, civil and military electronics markets, energy storage, transportation and telecommunication markets. Saft
focused its diligence efforts on the suppliers of components and parts (the “Relevant Suppliers”), which were determined by
Saft to contain or potentially contain 3TG, i.e. electronics and electric components, and which were incorporated into products manufactured
by Saft (the “Relevant Products”).
With the assistance of a third party retained by it to assist with
supplier outreach and data validation of the responses received from suppliers (the “Service Provider”), Saft conducted in
good faith a reasonable country of origin inquiry (the “RCOI”) regarding the sourcing of the necessary Conflict Minerals,
designed to determine whether any of them had originated in a Covered Country or were from recycled or scrap sources. To complete the
RCOI, Saft and the Service Provider engaged the Relevant Suppliers using the Conflict Minerals Reporting Template (“CMRT”)
developed by the Responsible Minerals Initiative.
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1
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References
to website in this Form SD are provided for convenience only, and their contents are
not incorporated by reference into this Form SD nor deemed filed with the U.S. Securities
and Exchange Commission.
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2
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As
of December 31, 2020, the Group held 51.61% of the outstanding share capital of SunPower.
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The Revant Suppliers had the ability to share information at a level
at which they were most comfortable (i.e. company, product or user-defined) but they had to specify the declaration scope. A limited number
of the Relevant Suppliers replied by providing their company’s formal policy on Conflict Minerals. Both Saft and the Service Provider
followed up with suppliers who did not respond to the initial request. Saft does not make purchases of raw ore or refined 3TG minerals
directly from smelters or refiners. Saft’s supply chain includes many third parties between the original sources of the necessary
Conflict Minerals and the products manufactured by it. Saft does not have direct contractual relationships with smelters and refiners
and relies on its suppliers to provide information on the original sources of the necessary Conflict Minerals in the Relevant Products
and on information provided by the Service Provider and independent third-party audit programs.
Based on the Relevant Suppliers’ responses, Saft could identify
the potential use in their supply chain of smelters in a Covered Country. A substantial number of these smelters were in compliance with
the Responsible Minerals Assurance Process Initiative assessment protocol as set forth by the RMI, without independent verification by
Saft, and a small number of these smelters were identified as not conformant with this protocol, without independent verification by Saft.
Based on the information provided to Saft and on Saft’s own diligence efforts, it is not possible to conclusively determine whether
the necessary Conflict Mineral provided from this small number of smelters are found in a product manufactured by Saft during the Relevant
Period.
Saft’s contracts with its suppliers require them to source responsibly,
and Saft maintains an active dialogue with its suppliers on this topic. As a result, Saft does not have any reason to believe that the
necessary Conflict Minerals contained in the Relevant Products in the Reporting Period directly or indirectly financed or benefitted armed
groups in the Covered Countries.
B. Hutchinson
Hutchinson is a global leader in vibration control, fluid management
and sealing technologies. Hutchinson reached out to all of its suppliers and identified the products containing necessary Conflict Minerals
during the Reporting Period: automotive fluid transfer lines, anti-vibration and sealing systems, and aerospace industrial applications
(the “Hutchinson Relevant Products”), which are found in the following business activities of Hutchinson: precision sealing
systems, fluid management systems, body sealing systems, anti-vibration systems, aerospace, defense & industry, belt drive systems.
Hutchinson conducted in good faith a RCOI regarding the sourcing of
the necessary Conflict Minerals in the Hutchinson Relevant Products to determine whether any had originated in a Covered Country or were
from recycled or scrap sources. To complete the RCOI, Hutchinson surveyed its suppliers to collect information about the presence and
source of the necessary Conflict Minerals. Suppliers responded by submitting a CMRT or sending an email or letter to Hutchinson. Hutchinson
followed up with suppliers who did not respond to its initial request. Hutchinson relies on the information provided to it by its suppliers.
Based on the suppliers’ responses, it was determined that a substantial
percentage of Hutchinson’s suppliers in terms of annual turnover certified that the necessary Conflict Minerals supplied to it either
originated from recycled or scrap sources or did not originate from the Covered Countries. A small percentage of suppliers in terms of
annual turnover sourced necessary Conflict Minerals during the Reporting Period from one or more of the Covered Countries for the Hutchinson
Relevant Products. A review of these suppliers by Hutchinson revealed them to be reputable, and mainly included major suppliers of the
automotive and aerospace industries, including publicly listed companies. The small percentage of non- responsive suppliers for the Reporting
Period were mainly distributors and small suppliers in terms of annual turnover.
The origin of some of the necessary Conflict Minerals in the Hutchinson
Relevant Products could be traced to smelters that are compliant with the Responsible Minerals Assurance Process Initiative assessment
protocol as set forth by the RMI, without independent verification by Hutchinson.
Hutchinson’s standard agreement with its suppliers require them
to fill out the survey questions set forth under the CMRT and Hutchinson maintains an active dialogue with its suppliers on this topic.
Hutchinson does not have any reason to believe that their necessary Conflict Minerals contained in its products in the Reporting Period
directly or indirectly financed or benefitted armed groups in the Covered Countries.
TotalEnergies is committed to responsible economic and social development
in Africa.
TotalEnergies monitors responsible practices among its suppliers. In
its Code of Conduct, TotalEnergies states that it works with its suppliers to ensure the protection of the interests of both parties in
accordance with clear, fairly negotiated contract terms. This relationship is based on three cornerstones: dialogue, professionalism and
meeting commitments.
TotalEnergies expects its suppliers to:
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adhere to the Group’s Fundamental Principles of Purchasing (the “FPP”) and ensure compliance with those principles
in their activities;
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agree to be audited in accordance with those principles;
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remain attentive to the everyday working conditions of their
employees and their suppliers’ employees;
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ensure that their own suppliers and subcontractors adhere to
the FPP;
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refer to the Group Ethics Committee in case of doubt.
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The FPP, launched in 2010 and updated in January 2021, specify
the commitments that TotalEnergies expects of its suppliers in the following areas1:
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respect for human rights at work;
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health protection, safety and security;
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preservation of the environment;
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prevention of corruption and conflicts of interest and fraud;
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respect for competition law; and
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the promotion of economic and social development.
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A Group directive reaffirms the obligation to annex the FPP or endeavor
to transpose them in the contracts negotiated with suppliers of goods and services. The FPP are available for consultation by all suppliers
in both French and English on TotalEnergies’ Sustainable Performance website (refer to the URL provided above).
In addition, questionnaires focused on societal issues are used to
gather more in-depth information from suppliers about their approach to such topics, either during the supplier qualification process2
or as part of an audit. The Group has also set up a supplier assessment process to identify and prevent risks of severe
violations of human rights and fundamental freedoms, human health and safety. Supplier awareness-raising actions are also carried out
during meetings with suppliers, particularly the Suppliers Day event that brings the Group’s strategic suppliers together every
two years. During Suppliers Day in 2019, the Fundamental Principles of Purchasing and the Group’s new Code of Conduct were distributed
to all participants.
TotalEnergies is a member of the United Nations Global Compact platform
on Decent Work in Global Supply Chains since 2018, and, in this capacity, takes part in various workshops that aim to help the member
companies of the Global Compact to make progress in this area.
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1
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Saft
and SunPower have defined fundamental principles of purchasing specific to their activities.
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2
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Purchases
by the subsidiaries of Hutchinson, Saft and SunPower are subject to supplier qualification
processes specific to their organizations.
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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.
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TotalEnergies SE
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Date: June 1, 2021
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By:
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/s/ JEAN-PIERRE SBRAIRE
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Name: Jean-Pierre SBRAIRE
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Title: Chief Financial Officer
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Annex A
Conflict Minerals
Report
SunPower Corporation has included this
Conflict Minerals Report as an exhibit to its Form SD for 2020 as provided for in Rule 13p-1 under the Securities Exchange
Act of 1934, as amended (the “Exchange Act”1), and Form SD (collectively, the “Conflict Minerals Rule”).
The date of filing of this Conflict Minerals Report is May 25, 2021.
Unless the context indicates otherwise,
the term “SunPower” refers to SunPower Corporation and its consolidated subsidiaries, and “Service Provider”
refers to the third party retained by SunPower to assist with supplier outreach and data validation of the responses received from suppliers.
Some of the compliance activities described in this Conflict Minerals Report were performed by the Service Provider in coordination with
SunPower. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite
(coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the
minerals or derivative metals.
This Conflict Minerals Report can be
found on the SunPower website at: http://investors.sunpower.com/sec.cfm.
Forward-Looking Statements
This document contains forward-looking
statements within the meaning of Section 27A of the Securities Act of 1933, as amended (the “Securities Act”), and Section 21E
of the Exchange Act. In particular, statements contained in this document that are not historical facts, including, but not limited to,
statements concerning the additional steps that SunPower intends to take to mitigate the risk that its necessary 3TG benefit armed groups,
constitute forward-looking statements and are made under the safe harbor provisions of Section 27A of the Securities Act and Section 21E
of the Exchange Act.
Forward-looking statements are subject
to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking
statements. These risks and uncertainties may include, but are not limited to, (1) the continued implementation of satisfactory
traceability and other compliance measures by SunPower’s direct and indirect suppliers on a timely basis or at all, (2) whether
smelters and refiners and other market participants responsibly source 3TG, and (3) political, regulatory, and economic developments,
whether in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”),
the United States or elsewhere. SunPower cautions readers not to place undue reliance on any forward-looking statements, which only
1
Definitions provided in this Annex are exclusive to this section.
speak as of the date made. SunPower
undertakes no obligation to update any forward-looking statement to reflect events or circumstances after the date on which such statement
is made.
Overview; SunPower's Products and
Applicability of the Conflict Minerals Rule
SunPower
is a leading solar energy company that delivers complete solar solutions to customers primarily in the United States and Canada through
an array of hardware, software, and financing options, and "Smart Energy" solutions. Our Smart Energy initiative is designed
to add layers of intelligent control to homes, buildings, and grids—all personalized through easy-to-use customer interfaces. SunPower
products include solar panels and balance of systems components that can include inverters, combiner boxes, racking systems, mechanical
and motorized systems, and electrical tracking, monitoring and controller systems. Each of the product areas that SunPower manufactures
and contracts to manufacture contains 3TG necessary to the functionality or production of such products. However, 3TG content continues
to represent a small portion of the materials content of SunPower’s products.
For a further discussion of SunPower’s
products, see its Annual Report on Form 10-K for the fiscal year ended January 3, 2021. The information contained in the Form 10-K
is not incorporated by reference into this Conflict Minerals Report or SunPower's Form SD for 2020 and should not be considered
part of this Conflict Minerals Report or the Form SD.
SunPower is multiple levels removed
from the mining of minerals (3TG or otherwise). SunPower does not make purchases of raw ore or refined minerals directly from smelters
or refiners and makes no purchases in the Covered Countries. However, through the efforts described in this Conflict Minerals Report,
SunPower seeks to ensure its suppliers are sourcing responsibly.
SunPower does not seek to embargo sourcing
of 3TG from the Covered Countries and encourages its suppliers to continue to source 3TG responsibly from the region.
Reasonable Country of Origin Inquiry
To complete the “reasonable country
of origin inquiry” (the “RCOI”) required by the Conflict Minerals Rule, SunPower and its Service Provider engaged with
suppliers to collect information about the presence and source of 3TG used in products and components supplied to SunPower. For its RCOI,
to the extent applicable, SunPower utilized the same processes and procedures as for its due diligence, in particular Steps 1 and 2 of
the OECD Guidance (as defined below), which are discussed later in this Conflict Minerals Report. For 2020, SunPower surveyed 14 suppliers
as part of its RCOI.
The results of SunPower’s RCOI
are discussed under “Findings Concerning Smelters and Refiners and Country of Origin Information.”
Due Diligence Measures
Design Framework
SunPower utilizes due diligence measures
for 3TG that are intended to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation
and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,
including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”).
The OECD Guidance established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals
from conflict-affected and high-risk areas. Application of the framework constitutes a part of the program that SunPower has put in place
to help ensure that the 3TG contained in its products are responsibly sourced.
Diligence Program
In furtherance of SunPower’s 3TG
due diligence, it performed the due diligence measures discussed below for 2020.
Compliance Team
In support of its compliance efforts,
SunPower has a compliance team that is charged with overseeing, implementing and providing feedback on its 3TG compliance strategy. The
team consists of staff from SunPower’s operations groups, under executive leadership. The members of the team and selected other
internal personnel are expected to be familiar with the Conflict Minerals Rule, the OECD Guidance, SunPower’s compliance plan,
and the procedures for reviewing and validating supplier responses to SunPower’s inquiries. SunPower also utilized the Service
Provider and specialist outside counsel to assist with and/or to advise it on certain aspects of its compliance.
Conflict Minerals Policy; Training
Resources; Grievance Mechanism
SunPower
maintains a Conflict Minerals Policy. Under the Conflict Minerals Policy, SunPower suppliers are required to acknowledge SunPower’s
Supplier Sustainability Guidelines, which incorporates the Conflict Minerals Policy. Under the Conflict
Minerals Policy, SunPower reserves the right to request additional documentation from its suppliers regarding the source of any 3TG included
in their products. In addition, SunPower reserves the right to ask suppliers to maintain traceability data for a minimum of five years.
The Conflict Minerals Policy indicates
that SunPower will evaluate its relationships
with its suppliers on an ongoing basis to ensure continued compliance with the Conflict Minerals Policy.
The
Conflict Minerals Policy is communicated internally to SunPower’s supply chain employees and to suppliers. In addition, the Conflict
Minerals Policy is posted on SunPower’s website at https://us.sunpower.com/sites/default/files/media-library/compliance-briefs/cb-sunpower-conflict-minerals-policy.pdf.
In an effort to increase supplier awareness
about Conflict Minerals and related regulatory requirements, provide answers to frequently asked questions concerning 3TG mineral tracing,
and ultimately improve the accuracy and completeness of supplier responses, suppliers that were part of SunPower’s outreach received
access to the Service Provider’s online resources.
SunPower has a grievance mechanism for
reporting violations of its Conflict Minerals Policy. The grievance mechanism is available through the Conflict Minerals Policy. Violations
may be reported by calling SunPower’s Compliance and Ethics Helpline at 1-866-307-5679 within the United States, or at toll-free
numbers provided for additional countries/regions in SunPower’s Code of Business Conduct and Ethics available on its investor relations
website at investors.sunpower.com, or by going to SunPower’s reporting website at sunpower.alertline.com.
Data Collection; Records Storage
and Retention
For 2020, SunPower carried out due diligence
on parts selected by SunPower within the bills of materials of products that were contracted to be manufactured, based on supplier spend.
The contract manufacturers carried out due diligence for general use parts of products that were contracted to be manufactured, the results
of which were reflected in their Conflict Minerals Reporting Templates (collectively, the “CMRTs” and individually, a “CMRT”)
furnished to SunPower. SunPower’s outreach included 14 suppliers (the “Suppliers”) that (1) contracted to manufacture
products for SunPower which were determined by SunPower to contain or potentially contain 3TG which is necessary to the functionality
or production of the products, or (2) provided components, parts, or products which were determined by SunPower to contain or potentially
contain necessary 3TG, and which were incorporated into products contracted to be manufactured by SunPower.
SunPower sent the Suppliers a request
to submit a CMRT to gather information on the use of 3TG by the Suppliers, the source of the 3TG and the Suppliers’ related compliance
procedures. SunPower gave the Suppliers the ability to provide information at a level at which they could most readily assemble the information
(i.e., company, product, or user-defined), but required the Suppliers to declare the level of information provided. Following the initial
introductions to the
program and information request, up
to three reminder emails were sent to each non-responsive Supplier requesting survey completion. This outreach was managed by the Service
Provider on our behalf. Additional outreach also was conducted by SunPower’s staff on an as-needed basis to further emphasize the
importance of suppliers completing the CMRT.
The Service Provider reviewed CMRT responses
received from the Suppliers for incomplete responses, potential errors or inaccuracies, lack of consistency, and other flags. If any
“quality control” flags were raised, Suppliers were contacted to clarify the concern. If a smelter or refiner was not on
the CMRT Smelter Look-up tab list, the Service Provider (a) requested that the Supplier confirm that the listed entity was a smelter
or refiner, (b) consulted publicly-available information to attempt to determine whether the identified entity was a smelter or
refiner, or (c) attempted to contact the listed entity. If the smelter or refiner was not identified as Conformant (as later defined)
or the equivalent by the Responsible Minerals Initiative (the “RMI”), the London Bullion Market Association (the “LMBA”)
or the Responsible Jewellery Council (the “RJC”), SunPower or the Service Provider attempted to contact the smelter or refiner
to gain more information about its sourcing practices, including countries of origin and transfer, and due diligence procedures.
To the extent that no contact was made
with a smelter or refiner identified by a Supplier, SunPower or the Service Provider searched public information to attempt to determine
the mine or location of origin of the 3TG processed by the smelter or refiner and whether it obtains 3TG from sources that directly or
indirectly finance or benefit armed groups in a Covered Country.
SunPower has an electronic file for
the maintenance of business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting
decisions. SunPower stores all supplier CMRTs and documents evidence of identified supplier 3TG sourcing risk. As contemplated by the
OECD Guidance, SunPower will maintain these records for at least five years. The Service Provider also has been requested to maintain
records in its possession for at least five years.
3TG Risk Management
SunPower obtained information on 3TG
sourcing risk from the Service Provider. SunPower further used the CMRT responses to identify 3TG sourcing risk. Given SunPower’s
position in the 3TG supply chain, it believes that this is the most efficient means for identifying 3TG sourcing risk.
The quality and supply chain teams within
SunPower worked together to identify 3TG sourcing concerns and determine risk mitigation efforts. The quality team reported aggregated
risk
findings to and the contents of this
Conflict Minerals Report are shared with SunPower’s executive management.
SunPower determines on a case-by-case
basis the appropriate risk mitigation strategy for any identified risks. Potential outcomes under SunPower’s risk mitigation strategy
include continuing to work with the supplier while risks are addressed or reassessing the relationship with the supplier. Under SunPower’s
risk management framework, to the extent that risks require mitigation, SunPower monitors and tracks the performance of the risk mitigation
efforts and reports these efforts to appropriate senior oversight personnel.
Utilization of Independent Third-Party
Audits
To the extent that smelters or refiners
are identified, SunPower primarily utilizes information made available by the RMI concerning independent third-party audits and Conformant
status. SunPower also relies on audits performed by the LBMA and the RJC.
Report on Supply Chain Due Diligence
SunPower files a Form SD and a
Conflict Minerals Report with the Securities and Exchange Commission and makes these filings available on its investor relations website.
Findings Concerning Smelters and
Refiners and Country of Origin Information
For 2020, SunPower surveyed 14 suppliers
as part of due diligence around 3TG and received 14 CMRTs in response to its outreach. The CMRT declarations received identified 325
smelters and refiners that processed or may have processed 3TG contained in SunPower’s products. Of these 14 CMRT declarations,
10 were company-level, 2 were product-level, and 2 were at a level defined by the Supplier. Due to the number of Suppliers providing
company-level declarations, the list of processing facilities disclosed below may over-represent the number of 3TG processing facilities
in SunPower’s supply chain.
In brief, as indicated in the table
below:
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325 smelters and refiners were
identified by the Suppliers.
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234 smelters and refiners, or 72%,
were listed as Conformant by the RMI.
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8 smelters or refiners, or 2%,
were listed as Active.
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83 smelters or refiners, or 26%,
were listed on the CMRT Smelter Look-up tab only.
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In connection with SunPower’s
RCOI or due diligence, as applicable, the Suppliers identified to SunPower the facilities listed below as potentially having processed
the necessary 3TG contained in SunPower’s in-scope products in 2020 (table information is as of May 10, 2021; see the notes
following the table for additional information concerning the information presented in the table).
Metal
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Smelter
Name
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Country
Name
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Status
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Gold
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8853
S.p.A.
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Italy
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Conformant
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Gold
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Abington
Reldan Metals, LLC
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United
States
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On
Smelter Look-up Tab Only
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Gold
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Advanced
Chemical Company
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United
States
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Conformant
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Gold
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African
Gold Refinery
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Uganda
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On
Smelter Look-up Tab Only
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Gold
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Aida
Chemical Industries Co., Ltd.
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Japan
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Conformant
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Gold
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Al
Etihad Gold Refinery DMCC
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United
Arab Emirates
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Conformant
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Gold
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Allgemeine
Gold-und Silberscheideanstalt A.G.
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Germany
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Conformant
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Gold
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Almalyk
Mining and Metallurgical Complex (AMMC)
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Uzbekistan
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Conformant
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Gold
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AngloGold
Ashanti Corrego do Sitio Mineracao
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Brazil
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Conformant
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Gold
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Argor-Heraeus
S.A.
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Switzerland
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Conformant
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Gold
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Asahi
Pretec Corp.
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Japan
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Conformant
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Gold
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Asahi
Refining Canada Ltd.
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Canada
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Conformant
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Gold
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Asahi
Refining USA Inc.
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United
States
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Conformant
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Gold
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Asaka
Riken Co., Ltd.
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Japan
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Conformant
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Gold
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Atasay
Kuyumculuk Sanayi Ve Ticaret A.S.
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Turkey
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On
Smelter Look-up Tab Only
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Gold
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AU
Traders and Refiners
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South
Africa
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Conformant
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Gold
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Augmont
Enterprises Private Limited
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India
|
On
Smelter Look-up Tab Only
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Gold
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Aurubis
AG
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Germany
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Conformant
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Gold
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Bangalore
Refinery
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India
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Conformant
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Gold
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Bangko
Sentral ng Pilipinas (Central Bank of the Philippines)
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Philippines
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Conformant
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Gold
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Boliden
AB
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Sweden
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Conformant
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Gold
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C.
Hafner GmbH + Co. KG
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Germany
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Conformant
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Gold
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C.I
Metales Procesados Industriales SAS
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Colombia
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On
Smelter Look-up Tab Only
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Gold
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Caridad
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Mexico
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On
Smelter Look-up Tab Only
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Gold
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CCR
Refinery - Glencore Canada Corporation
|
Canada
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Conformant
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Gold
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Cendres
+ Metaux S.A.
|
Switzerland
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Conformant
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Gold
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CGR
Metalloys Pvt Ltd.
|
India
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On
Smelter Look-up Tab Only
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Gold
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Chimet
S.p.A.
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Italy
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Conformant
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Gold
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Chugai
Mining
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Japan
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Conformant
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Gold
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Daye
Non-Ferrous Metals Mining Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Degussa
Sonne / Mond Goldhandel GmbH
|
Germany
|
On
Smelter Look-up Tab Only
|
Gold
|
Dijllah
Gold Refinery FZC
|
United
Arab Emirates
|
On
Smelter Look-up Tab Only
|
Gold
|
DODUCO
Contacts and Refining GmbH
|
Germany
|
Conformant
|
Gold
|
Dowa
|
Japan
|
Conformant
|
Gold
|
DS
PRETECH Co., Ltd.
|
Korea
|
Conformant
|
Gold
|
DSC
(Do Sung Corporation)
|
Korea
|
Conformant
|
Gold
|
Eco-System
Recycling Co., Ltd. East Plant
|
Japan
|
Conformant
|
Gold
|
Eco-System
Recycling Co., Ltd. North Plant
|
Japan
|
Conformant
|
Gold
|
Eco-System
Recycling Co., Ltd. West Plant
|
Japan
|
Conformant
|
Gold
|
Elemetal
Refining, LLC
|
United
States
|
On
Smelter Look-up Tab Only
|
Gold
|
Emirates
Gold DMCC
|
United
Arab Emirates
|
Conformant
|
Gold
|
Fidelity
Printers and Refiners Ltd.
|
Zimbabwe
|
On
Smelter Look-up Tab Only
|
Gold
|
Fujairah
Gold FZC
|
United
Arab Emirates
|
On
Smelter Look-up Tab Only
|
Gold
|
GCC
Gujrat Gold Centre Pvt. Ltd.
|
India
|
On
Smelter Look-up Tab Only
|
Gold
|
Geib
Refining Corporation
|
United
States
|
Conformant
|
Gold
|
Gold
Refinery of Zijin Mining Group Co., Ltd.
|
China
|
Conformant
|
Gold
|
Great
Wall Precious Metals Co., Ltd. of CBPM
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Guangdong
Jinding Gold Limited
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Guoda
Safina High-Tech Environmental Refinery Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Hangzhou
Fuchunjiang Smelting Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Heimerle
+ Meule GmbH
|
Germany
|
Conformant
|
Gold
|
Heraeus
Metals Hong Kong Ltd.
|
China
|
Conformant
|
Gold
|
Heraeus
Precious Metals GmbH & Co. KG
|
Germany
|
On
Smelter Look-up Tab Only
|
Gold
|
Hunan
Chenzhou Mining Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Hunan
Guiyang yinxing Nonferrous Smelting Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
HwaSeong
CJ CO., LTD.
|
Korea
|
On
Smelter Look-up Tab Only
|
Gold
|
Inner
Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
|
China
|
Conformant
|
Gold
|
International
Precious Metal Refiners
|
United
Arab Emirates
|
Active
|
Gold
|
Ishifuku
Metal Industry Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Istanbul
Gold Refinery
|
Turkey
|
Conformant
|
Gold
|
Italpreziosi
|
Italy
|
Conformant
|
Gold
|
JALAN &
Company
|
India
|
On
Smelter Look-up Tab Only
|
Gold
|
Japan
Mint
|
Japan
|
Conformant
|
Gold
|
Jiangxi
Copper Co., Ltd.
|
China
|
Conformant
|
Gold
|
JSC
Ekaterinburg Non-Ferrous Metal Processing Plant
|
Russian
Federation
|
On
Smelter Look-up Tab Only
|
Gold
|
JSC
Uralelectromed
|
Russian
Federation
|
Conformant
|
Gold
|
JX
Nippon Mining & Metals Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Kaloti
Precious Metals
|
United
Arab Emirates
|
On
Smelter Look-up Tab Only
|
Gold
|
Kazakhmys
Smelting LLC
|
Kazakhstan
|
On
Smelter Look-up Tab Only
|
Gold
|
Kazzinc
|
Kazakhstan
|
Conformant
|
Gold
|
Kennecott
Utah Copper LLC
|
United
States
|
Conformant
|
Gold
|
KGHM
Polska Miedz Spolka Akcyjna
|
Poland
|
Conformant
|
Gold
|
Kojima
Chemicals Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Korea
Zinc Co., Ltd.
|
Korea
|
Conformant
|
Gold
|
Kundan
Care Products Ltd.
|
India
|
On
Smelter Look-up Tab Only
|
Gold
|
Kyrgyzaltyn
JSC
|
Kyrgyzstan
|
Conformant
|
Gold
|
Kyshtym
Copper-Electrolytic Plant ZAO
|
Russian
Federation
|
On
Smelter Look-up Tab Only
|
Gold
|
L'azurde
Company For Jewelry
|
Saudi
Arabia
|
On
Smelter Look-up Tab Only
|
Gold
|
L'Orfebre
S.A.
|
Andorra
|
Conformant
|
Gold
|
Lingbao
Gold Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Lingbao
Jinyuan Tonghui Refinery Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
LS-NIKKO
Copper Inc.
|
Korea
|
Conformant
|
Gold
|
LT
Metal Ltd.
|
Korea
|
Conformant
|
Gold
|
Luoyang
Zijin Yinhui Gold Refinery Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
|
|
|
|
Gold
|
Marsam
Metals
|
Brazil
|
Conformant
|
Gold
|
Materion
|
United
States
|
Conformant
|
Gold
|
Matsuda
Sangyo Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Metalor
Technologies (Hong Kong) Ltd.
|
China
|
Conformant
|
Gold
|
Metalor
Technologies (Singapore) Pte., Ltd.
|
Singapore
|
Conformant
|
Gold
|
Metalor
Technologies (Suzhou) Ltd.
|
China
|
Conformant
|
Gold
|
Metalor
Technologies S.A.
|
Switzerland
|
Conformant
|
Gold
|
Metalor
USA Refining Corporation
|
United
States
|
Conformant
|
Gold
|
Metalurgica
Met-Mex Penoles S.A. De C.V.
|
Mexico
|
Conformant
|
Gold
|
Mitsubishi
Materials Corporation
|
Japan
|
Conformant
|
Gold
|
Mitsui
Mining and Smelting Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
MMTC-PAMP
India Pvt., Ltd.
|
India
|
Conformant
|
Gold
|
Modeltech
Sdn Bhd
|
Malaysia
|
On
Smelter Look-up Tab Only
|
Gold
|
Morris
and Watson
|
New
Zealand
|
On
Smelter Look-up Tab Only
|
Gold
|
Morris
and Watson Gold Coast
|
Australia
|
On
Smelter Look-up Tab Only
|
Gold
|
Moscow
Special Alloys Processing Plant
|
Russian
Federation
|
Conformant
|
Gold
|
Nadir
Metal Rafineri San. Ve Tic. A.S.
|
Turkey
|
Conformant
|
Gold
|
Navoi
Mining and Metallurgical Combinat
|
Uzbekistan
|
On
Smelter Look-up Tab Only
|
Gold
|
NH
Recytech Company
|
Korea
|
On
Smelter Look-up Tab Only
|
Gold
|
Nihon
Material Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Ogussa
Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
Austria
|
Conformant
|
Gold
|
Ohura
Precious Metal Industry Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
OJSC
"The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
Russian
Federation
|
Conformant
|
Gold
|
OJSC
Novosibirsk Refinery
|
Russian
Federation
|
Conformant
|
Gold
|
PAMP
S.A.
|
Switzerland
|
Conformant
|
Gold
|
Pease &
Curren
|
United
States
|
On
Smelter Look-up Tab Only
|
Gold
|
Penglai
Penggang Gold Industry Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Planta
Recuperadora de Metales SpA
|
Chile
|
Conformant
|
Gold
|
Prioksky
Plant of Non-Ferrous Metals
|
Russian
Federation
|
Conformant
|
Gold
|
PT
Aneka Tambang (Persero) Tbk
|
Indonesia
|
Conformant
|
Gold
|
PX
Precinox S.A.
|
Switzerland
|
Conformant
|
Gold
|
QG
Refining, LLC
|
United
States
|
On
Smelter Look-up Tab Only
|
Gold
|
Rand
Refinery (Pty) Ltd.
|
South
Africa
|
Conformant
|
Gold
|
Refinery
of Seemine Gold Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
REMONDIS
PMR B.V.
|
Netherlands
|
Conformant
|
Gold
|
Republic
Metals Corporation
|
United
States
|
On
Smelter Look-up Tab Only
|
Gold
|
Royal
Canadian Mint
|
Canada
|
Conformant
|
Gold
|
SAAMP
|
France
|
Conformant
|
Gold
|
Sabin
Metal Corp.
|
United
States
|
On
Smelter Look-up Tab Only
|
Gold
|
Safimet
S.p.A
|
Italy
|
Conformant
|
Gold
|
SAFINA
A.S.
|
Czech
Republic
|
Conformant
|
Gold
|
Sai
Refinery
|
India
|
On
Smelter Look-up Tab Only
|
Gold
|
Samduck
Precious Metals
|
Korea
|
Conformant
|
Gold
|
SAMWON
METALS Corp.
|
Korea
|
On
Smelter Look-up Tab Only
|
Gold
|
SAXONIA
Edelmetalle GmbH
|
Germany
|
Conformant
|
Gold
|
Schone
Edelmetaal B.V.
|
Netherlands
|
On
Smelter Look-up Tab Only
|
Gold
|
SEMPSA
Joyeria Plateria S.A.
|
Spain
|
Conformant
|
Gold
|
Shandong
Humon Smelting Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Shandong
Tiancheng Biological Gold Industrial Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Shandong
Zhaojin Gold & Silver Refinery Co., Ltd.
|
China
|
Conformant
|
Gold
|
Shenzhen
Zhonghenglong Real Industry Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Shirpur
Gold Refinery Ltd.
|
India
|
On
Smelter Look-up Tab Only
|
Gold
|
Sichuan
Tianze Precious Metals Co., Ltd.
|
China
|
Conformant
|
Gold
|
Singway
Technology Co., Ltd.
|
Taiwan
|
Conformant
|
Gold
|
SOE
Shyolkovsky Factory of Secondary Precious Metals
|
Russian
Federation
|
Conformant
|
Gold
|
Solar
Applied Materials Technology Corp.
|
Taiwan
|
Conformant
|
Gold
|
Sovereign
Metals
|
India
|
On
Smelter Look-up Tab Only
|
Gold
|
State
Research Institute Center for Physical Sciences and Technology
|
Lithuania
|
On
Smelter Look-up Tab Only
|
Gold
|
Sudan
Gold Refinery
|
Sudan
|
On
Smelter Look-up Tab Only
|
Gold
|
Sumitomo
Metal Mining Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
SungEel
HiMetal Co., Ltd.
|
Korea
|
Conformant
|
Gold
|
T.C.A
S.p.A
|
Italy
|
Conformant
|
Gold
|
Tanaka
Kikinzoku Kogyo K.K.
|
Japan
|
Conformant
|
Gold
|
The
Refinery of Shandong Gold Mining Co., Ltd.
|
China
|
Conformant
|
Gold
|
Tokuriki
Honten Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Tongling
Nonferrous Metals Group Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Tony
Goetz NV
|
Belgium
|
On
Smelter Look-up Tab Only
|
Gold
|
TOO
Tau-Ken-Altyn
|
Kazakhstan
|
Conformant
|
Gold
|
Torecom
|
Korea
|
Conformant
|
Gold
|
Umicore
Brasil Ltda.
|
Brazil
|
On
Smelter Look-up Tab Only
|
Gold
|
Umicore
Precious Metals Thailand
|
Thailand
|
Conformant
|
Gold
|
Umicore
S.A. Business Unit Precious Metals Refining
|
Belgium
|
Conformant
|
Gold
|
United
Precious Metal Refining, Inc.
|
United
States
|
Conformant
|
Gold
|
Valcambi
S.A.
|
Switzerland
|
Conformant
|
Gold
|
Western
Australian Mint (T/a The Perth Mint)
|
Australia
|
Conformant
|
Gold
|
WIELAND
Edelmetalle GmbH
|
Germany
|
Conformant
|
Gold
|
Yamakin
Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Yokohama
Metal Co., Ltd.
|
Japan
|
Conformant
|
Gold
|
Yunnan
Copper Industry Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Yunnan
Gold Mining Group Co., Ltd. (YGMG)
|
China
|
On
Smelter Look-up Tab Only
|
Gold
|
Zhongyuan
Gold Smelter of Zhongjin Gold Corporation
|
China
|
Conformant
|
Tantalum
|
Asaka
Riken Co., Ltd.
|
Japan
|
Conformant
|
Tantalum
|
Changsha
South Tantalum Niobium Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
CP
Metals Inc.
|
United
States
|
On
Smelter Look-up Tab Only
|
Tantalum
|
D
Block Metals, LLC
|
United
States
|
Conformant
|
Tantalum
|
Exotech
Inc.
|
United
States
|
Conformant
|
Tantalum
|
F&X
Electro-Materials Ltd.
|
China
|
Conformant
|
Tantalum
|
FIR
Metals & Resource Ltd.
|
China
|
Conformant
|
Tantalum
|
Global
Advanced Metals Aizu
|
Japan
|
Conformant
|
Tantalum
|
Global
Advanced Metals Boyertown
|
United
States
|
Conformant
|
Tantalum
|
Guangdong
Rising Rare Metals-EO Materials Ltd.
|
China
|
Conformant
|
Tantalum
|
Guangdong
Zhiyuan New Material Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tantalum
|
H.C.
Starck Hermsdorf GmbH
|
Germany
|
Conformant
|
Tantalum
|
H.C.
Starck Inc.
|
United
States
|
Conformant
|
Tantalum
|
Hengyang
King Xing Lifeng New Materials Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
Jiangxi
Dinghai Tantalum & Niobium Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
Jiangxi
Tuohong New Raw Material
|
China
|
Conformant
|
Tantalum
|
Jiujiang
Janny New Material Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tantalum
|
JiuJiang
JinXin Nonferrous Metals Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
Jiujiang
Tanbre Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
Jiujiang
Zhongao Tantalum & Niobium Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
KEMET
Blue Metals
|
Mexico
|
Conformant
|
Tantalum
|
Kemet
Blue Powder
|
United
States
|
On
Smelter Look-up Tab Only
|
Tantalum
|
LSM
Brasil S.A.
|
Brazil
|
Conformant
|
Tantalum
|
Metallurgical
Products India Pvt., Ltd.
|
India
|
Conformant
|
Tantalum
|
Mineracao
Taboca S.A.
|
Brazil
|
Conformant
|
Tantalum
|
Mitsui
Mining and Smelting Co., Ltd.
|
Japan
|
Conformant
|
Tantalum
|
Ningxia
Orient Tantalum Industry Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
NPM
Silmet AS
|
Estonia
|
Conformant
|
Tantalum
|
QuantumClean
|
United
States
|
Conformant
|
Tantalum
|
Resind
Industria e Comercio Ltda.
|
Brazil
|
Conformant
|
Tantalum
|
Solikamsk
Magnesium Works OAO
|
Russian
Federation
|
Conformant
|
Tantalum
|
Taki
Chemical Co., Ltd.
|
Japan
|
Conformant
|
Tantalum
|
TANIOBIS
Co., Ltd.
|
Thailand
|
Conformant
|
Tantalum
|
TANIOBIS
GmbH
|
Germany
|
Conformant
|
Tantalum
|
TANIOBIS
Japan Co., Ltd.
|
Japan
|
Conformant
|
Tantalum
|
TANIOBIS
Smelting GmbH & Co. KG
|
Germany
|
Conformant
|
Tantalum
|
Telex
Metals
|
United
States
|
Conformant
|
Tantalum
|
Ulba
Metallurgical Plant JSC
|
Kazakhstan
|
Conformant
|
Tantalum
|
XinXing
Haorong Electronic Material Co., Ltd.
|
China
|
Conformant
|
Tantalum
|
Yanling
Jincheng Tantalum & Niobium Co., Ltd.
|
China
|
Conformant
|
Tin
|
Alpha
|
United
States
|
Conformant
|
Tin
|
An
Vinh Joint Stock Mineral Processing Company
|
Vietnam
|
On
Smelter Look-up Tab Only
|
Tin
|
Chenzhou
Yunxiang Mining and Metallurgy Co., Ltd.
|
China
|
Conformant
|
Tin
|
Chifeng
Dajingzi Tin Industry Co., Ltd.
|
China
|
Conformant
|
Tin
|
China
Tin Group Co., Ltd.
|
China
|
Conformant
|
Tin
|
Dongguan
CiEXPO Environmental Engineering Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tin
|
Dowa
|
Japan
|
Conformant
|
Tin
|
Electro-Mechanical
Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
|
Vietnam
|
On
Smelter Look-up Tab Only
|
Tin
|
EM
Vinto
|
Bolivia
|
Conformant
|
Tin
|
Estanho
de Rondonia S.A.
|
Brazil
|
Active
|
Tin
|
Fenix
Metals
|
Poland
|
Conformant
|
Tin
|
Gejiu
City Fuxiang Industry and Trade Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tin
|
Gejiu
Kai Meng Industry and Trade LLC
|
China
|
Conformant
|
Tin
|
Gejiu
Non-Ferrous Metal Processing Co., Ltd.
|
China
|
Conformant
|
Tin
|
Gejiu
Yunxin Nonferrous Electrolysis Co., Ltd.
|
China
|
Conformant
|
Tin
|
Gejiu
Zili Mining And Metallurgy Co., Ltd.
|
China
|
Conformant
|
Tin
|
Guangdong
Hanhe Non-Ferrous Metal Co., Ltd.
|
China
|
Conformant
|
Tin
|
GUANGXI
HUA TIN GOLD MINUTE FEE, LTD.
|
China
|
On
Smelter Look-up Tab Only
|
Tin
|
Guanyang
Guida Nonferrous Metal Smelting Plant
|
China
|
Conformant
|
Tin
|
HuiChang
Hill Tin Industry Co., Ltd.
|
China
|
Conformant
|
Tin
|
Huichang
Jinshunda Tin Co., Ltd.
|
China
|
Conformant
|
Tin
|
Jiangxi
New Nanshan Technology Ltd.
|
China
|
Conformant
|
Tin
|
Luna
Smelter, Ltd.
|
Rwanda
|
Conformant
|
Tin
|
Ma'anshan
Weitai Tin Co., Ltd.
|
China
|
Conformant
|
Tin
|
Magnu's
Minerais Metais e Ligas Ltda.
|
Brazil
|
Conformant
|
Tin
|
Malaysia
Smelting Corporation (MSC)
|
Malaysia
|
Conformant
|
Tin
|
Metahub
Industries Sdn. Bhd.
|
Myanmar
|
On
Smelter Look-up Tab Only
|
Tin
|
Melt
Metais e Ligas S.A.
|
Brazil
|
Conformant
|
Tin
|
Metallic
Resources, Inc.
|
United
States
|
Conformant
|
Tin
|
Metallo
Belgium N.V.
|
Belgium
|
Conformant
|
Tin
|
Metallo
Spain S.L.U.
|
Spain
|
Conformant
|
Tin
|
Mineracao
Taboca S.A.
|
Brazil
|
Conformant
|
Tin
|
Minsur
|
Peru
|
Conformant
|
Tin
|
Mitsubishi
Materials Corporation
|
Japan
|
Conformant
|
Tin
|
Modeltech
Sdn Bhd
|
Malaysia
|
On
Smelter Look-up Tab Only
|
Tin
|
Nghe
Tinh Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
On
Smelter Look-up Tab Only
|
Tin
|
Novosibirsk
Processing Plant Ltd.
|
Russian
Federation
|
Active
|
Tin
|
O.M.
Manufacturing (Thailand) Co., Ltd.
|
Thailand
|
Conformant
|
Tin
|
O.M.
Manufacturing Philippines, Inc.
|
Philippines
|
Conformant
|
Tin
|
Operaciones
Metalurgicas S.A.
|
Bolivia
|
Conformant
|
Tin
|
Pongpipat
Company Limited
|
Myanmar
|
On
Smelter Look-up Tab Only
|
Tin
|
Precious
Minerals and Smelting Limited
|
India
|
On
Smelter Look-up Tab Only
|
Tin
|
PT
Artha Cipta Langgeng
|
Indonesia
|
Conformant
|
Tin
|
PT
ATD Makmur Mandiri Jaya
|
Indonesia
|
Conformant
|
Tin
|
PT
Babel Surya Alam Lestari
|
Indonesia
|
Conformant
|
Tin
|
PT
Bangka Serumpun
|
Indonesia
|
Conformant
|
Tin
|
PT
Menara Cipta Mulia
|
Indonesia
|
Conformant
|
Tin
|
PT
Mitra Stania Prima
|
Indonesia
|
Conformant
|
Tin
|
PT
Mitra Sukses Globalindo
|
Indonesia
|
On
Smelter Look-up Tab Only
|
Tin
|
PT
Premium Tin Indonesia
|
Indonesia
|
On
Smelter Look-up Tab Only
|
Tin
|
PT
Prima Timah Utama
|
Indonesia
|
Conformant
|
Tin
|
PT
Rajawali Rimba Perkasa
|
Indonesia
|
Conformant
|
Tin
|
PT
Rajehan Ariq
|
Indonesia
|
Conformant
|
Tin
|
PT
Refined Bangka Tin
|
Indonesia
|
Conformant
|
Tin
|
PT
Timah Tbk Kundur
|
Indonesia
|
Conformant
|
Tin
|
PT
Timah Tbk Mentok
|
Indonesia
|
Conformant
|
Tin
|
Resind
Industria e Comercio Ltda.
|
Brazil
|
Conformant
|
Tin
|
Rui
Da Hung
|
Taiwan
|
Conformant
|
Tin
|
Soft
Metais Ltda.
|
Brazil
|
Conformant
|
Tin
|
Super
Ligas
|
Brazil
|
Active
|
Tin
|
Thai
Nguyen Mining and Metallurgy Co., Ltd.
|
Vietnam
|
Conformant
|
Tin
|
Thaisarco
|
Thailand
|
Conformant
|
Tin
|
Tin
Technology & Refining
|
United
States
|
Conformant
|
Tin
|
Tuyen
Quang Non-Ferrous Metals Joint Stock Company
|
Vietnam
|
On
Smelter Look-up Tab Only
|
Tin
|
White
Solder Metalurgia e Mineracao Ltda.
|
Brazil
|
Conformant
|
Tin
|
Yunnan
Chengfeng Non-ferrous Metals Co., Ltd.
|
China
|
Conformant
|
Tin
|
Yunnan
Tin Company Limited
|
China
|
Conformant
|
Tin
|
Yunnan
Yunfan Non-ferrous Metals Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
A.L.M.T.
TUNGSTEN Corp.
|
Japan
|
Conformant
|
Tungsten
|
ACL
Metais Eireli
|
Brazil
|
Conformant
|
Tungsten
|
Albasteel
Industria e Comercio de Ligas Para Fundicao Ltd.
|
Brazil
|
Active
|
Tungsten
|
Asia
Tungsten Products Vietnam Ltd.
|
Vietnam
|
Conformant
|
Tungsten
|
Chenzhou
Diamond Tungsten Products Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
China
Molybdenum Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tungsten
|
Chongyi
Zhangyuan Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
CNMC
(Guangxi) PGMA Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tungsten
|
CP
Metals Inc.
|
United
States
|
On
Smelter Look-up Tab Only
|
Tungsten
|
Cronimet
Brasil Ltda
|
Brazil
|
Active
|
Tungsten
|
Fujian
Ganmin RareMetal Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Fujian
Jinxin Tungsten Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tungsten
|
Ganzhou
Haichuang Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Ganzhou
Huaxing Tungsten Products Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Ganzhou
Jiangwu Ferrotungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Ganzhou
Seadragon W & Mo Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
GEM
Co., Ltd.
|
United
States
|
On
Smelter Look-up Tab Only
|
Tungsten
|
Global
Tungsten & Powders Corp.
|
United
States
|
Conformant
|
Tungsten
|
Guangdong
Xianglu Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
H.C.
Starck Tungsten GmbH
|
Germany
|
Conformant
|
Tungsten
|
Hunan
Chenzhou Mining Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Hunan
Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
China
|
Conformant
|
Tungsten
|
Hunan
Chunchang Nonferrous Metals Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Hunan
Litian Tungsten Industry Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Hydrometallurg,
JSC
|
Russian
Federation
|
Conformant
|
Tungsten
|
Japan
New Metals Co., Ltd.
|
Japan
|
Conformant
|
Tungsten
|
Jiangwu
H.C. Starck Tungsten Products Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Jiangxi
Gan Bei Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Jiangxi
Minmetals Gao'an Non-ferrous Metals Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tungsten
|
Jiangxi
Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Jiangxi
Xianglu Tungsten Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
Tungsten
|
Jiangxi
Xinsheng Tungsten Industry Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Jiangxi
Yaosheng Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
JSC
"Kirovgrad Hard Alloys Plant"
|
Russian
Federation
|
Active
|
Tungsten
|
Kennametal
Fallon
|
United
States
|
Conformant
|
Tungsten
|
Kennametal
Huntsville
|
United
States
|
Conformant
|
Tungsten
|
KGETS
CO., LTD.
|
Korea
|
Conformant
|
Tungsten
|
Lianyou
Metals Co., Ltd.
|
Taiwan
|
Conformant
|
Tungsten
|
Malipo
Haiyu Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Masan
Tungsten Chemical LLC (MTC)
|
Vietnam
|
Conformant
|
Tungsten
|
Moliren
Ltd.
|
Russian
Federation
|
Conformant
|
Tungsten
|
Niagara
Refining LLC
|
United
States
|
Conformant
|
Tungsten
|
NPP
Tyazhmetprom LLC
|
Russian
Federation
|
Active
|
Tungsten
|
Philippine
Chuangxin Industrial Co., Inc.
|
Philippines
|
Conformant
|
Tungsten
|
South-East
Nonferrous Metal Company Limited of Hengyang City
|
China
|
Conformant
|
Tungsten
|
TANIOBIS
Smelting GmbH & Co. KG
|
Germany
|
Conformant
|
Tungsten
|
Tejing
(Vietnam) Tungsten Co., Ltd.
|
Vietnam
|
Conformant
|
Tungsten
|
Unecha
Refractory Metals Plant
|
Russian
Federation
|
Conformant
|
Tungsten
|
Wolfram
Bergbau und Hutten AG
|
Austria
|
Conformant
|
Tungsten
|
Woltech
Korea Co., Ltd.
|
Korea
|
Conformant
|
Tungsten
|
Xiamen
Tungsten (H.C.) Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Xiamen
Tungsten Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Xinfeng
Huarui Tungsten & Molybdenum New Material Co., Ltd.
|
China
|
Conformant
|
Tungsten
|
Xinhai
Rendan Shaoguan Tungsten Co., Ltd.
|
China
|
On
Smelter Look-up Tab Only
|
|
a)
|
“Conformant”
means that a smelter or refiner has successfully completed an assessment against the applicable
Responsible Minerals Assurance Process (“RMAP”) standard or an equivalent cross-recognized
assessment. Included smelters and refiners were not necessarily Conformant for all or part
of 2020 and may not continue to be Conformant for any future period.
|
|
b)
|
“Active”
means that a smelter or refiner has committed to undergo an RMAP assessment, completed the
relevant documents, and scheduled the on-site assessment. These may be in the pre-assessment,
assessment or corrective-action phases of the assessment.
|
|
c)
|
“On
Smelter Look-up Tab Only” means that a smelter or refiner is listed on the Smelter
Look-up tab list of the CMRT, but is not listed as “Conformant” or “Active.”
The RMI notes on its website that the operational impacts of COVID-19 have led to postponements
of some RMAP assessments. The RMI website also notes that, due to the eligibility criteria
for an RMAP assessment, smelters are sometimes removed from the Conformant list because they
are no longer operational and not because they are non-conformant to the standard.
|
|
d)
|
Smelter
or refiner status reflected in the table is based solely on information made publicly available
by the RMI, without independent verification by SunPower.
|
|
e)
|
Country
location is the location of the smelter or refiner and is based solely on information made
publicly available by the RMI, without independent verification by SunPower.
|
Country of Origin Information
SunPower has endeavored to determine
the mine or location of origin of the necessary 3TG contained in its in-scope products by requiring that the Suppliers provide it with
completed CMRTs and through the other measures described in this Conflict Minerals Report. Where a smelter or refiner has been identified
that is not Conformant, SunPower or the Service Provider also has reviewed public information, to the extent available, to try to determine
the mine or location of origin of the 3TG processed by the smelter or refiner.
The countries of origin of the newly-mined
3TG processed by smelters and refiners listed above may have included countries listed below (as well as possibly other countries).
Argentina
|
Egypt
|
Mali
|
Somaliland
|
Australia
|
Ethiopia
|
Mauritania
|
South
Africa
|
Austria
|
Eritrea
|
Mexico
|
Spain
|
Azerbaijan
|
France
|
Mongolia
|
Suriname
|
Benin
|
French
Guiana
|
Morocco
|
Swaziland
|
Bolivia
|
Georgia
|
Mozambique
|
Sweden
|
Botswana
|
Germany
|
Myanmar
|
Taiwan
|
Brazil
|
Ghana
|
Namibia
|
Tanzania*
|
Burkina
Faso
|
Guinea
|
Netherlands
|
Tajikistan
|
Burundi*
|
Guyana
|
Nicaragua
|
Thailand
|
Canada
|
Honduras
|
Niger
|
Turkey
|
Chile
|
India
|
Nigeria
|
Uganda*
|
China
|
Indonesia
|
Papua
New Guinea
|
United
Kingdom
|
Colombia
|
Ivory
Coast
|
Peru
|
United
States
|
Costa
Rica
|
Japan
|
Philippines
|
Uruguay
|
Cyprus
|
Kazakhstan
|
Portugal
|
Uzbekistan
|
Democratic
Republic of the Congo*
|
Laos
|
Russia
|
Vietnam
|
Madagascar
|
Rwanda*
|
Zimbabwe
|
Ecuador
|
Malaysia
|
Sierra
Leone
|
|
* Represents a Covered Country.
The 3TG processed by the identified
smelters and refiners also may have originated in whole or in part from recycled or scrap sources.
Due Diligence Improvement Measures
SunPower intends to further improve
its due diligence measures for 2021 in order to mitigate the risk that the necessary 3TG in its in-scope products benefit armed groups
by taking the following steps, among others:
|
·
|
Continue
to alert suppliers when SunPower obtains information that a 3TG smelter or refiner is believed
to be irresponsibly sourcing 3TG.
|
|
·
|
Request
that suppliers who have identified non-Conformant or high-risk smelters require their upstream
suppliers to find alternative sources of 3TG or require certification of the smelters and
refiners in their supply chains.
|
|
·
|
Review
our 3TG compliance program for potential additional enhancements, in particular ways to enhance
supplier engagement.
|
The foregoing steps are in addition
to the steps that SunPower took for 2020.
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