UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
___________________________________
FORM SD
SPECIALIZED DISCLOSURE REPORT
___________________________________
Arhaus, Inc.
(Exact name of the registrant as specified in its charter)
___________________________________
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Delaware (State or other jurisdiction of incorporation or organization) | | 001-41009 (Commission File Number) |
| | |
51 E. Hines Hill Road, Boston Heights, Ohio | | 44236 |
| (Address of Principal Executive Offices) | | (Zip Code) |
John Reed
Chief Executive Officer
(440) 439-7700
(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:
| | | | | |
☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Specialized Disclosure Report on Form SD of Arhaus, Inc. (the "Company") is filed pursuant to Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2023 to December 31, 2023 (the "reporting period").
The Company determined that during the reporting period, the Company contracted to manufacture products as to which conflict minerals are necessary to the functionality or production of such products. As a result, the Company has conducted a good faith reasonable country of origin inquiry to determine whether the necessary conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or came from recycled or scrap sources. A description of the Company's reasonable country of origin inquiry process, the result of the inquiry, and the determination reached as a result of this inquiry process is included in the Company's Conflict Minerals Report attached as Exhibit 1.01 to this Form SD.
A copy of the Conflict Minerals report filed for the calendar year ended December 31, 2023 is publically available electronically on the Investor Relations section of the Company's website at ir.arhaus.com, by clicking on “Financials” and then “SEC Filings.”
Item 1.02 Exhibits
The Conflict Minerals Report for the calendar year ended December 31, 2023 is filed as Exhibit 1.01 herewith.
Section 2 — Exhibits
Item 2.01 Exhibits
| | | | | | | | |
| Exhibit No. | | Description |
| | 2023 Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD |
SIGNATURE
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 undersigned hereunto duly authorized on this 29th day of May, 2024.
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| ARHAUS, INC. |
| |
By: | /s/ John Reed |
Name: | John Reed |
Title: | Chief Executive Officer |
Conflict Minerals Report
For Year Ended December 31, 2023
Introduction & Summary
Company Overview
This report has been prepared by the management of Arhaus, Inc. (herein referred to as the “Company,” “Arhaus,” “we,” “us,” or “our”). The information includes the activities of all of our wholly-owned subsidiaries.
Founded in 1986, the Company is a rapidly growing lifestyle brand and omni-channel retailer of premium home furnishings. We were founded on a simple idea: furniture should be responsibly sourced, lovingly made and built to last. Today, we partner with artisans around the world who share our vision, creating beautiful, premium and heirloom quality home furnishings that clients can use for generations.
Introduction
For the 2023 calendar year, Arhaus determined that tin, tungsten, tantalum, and/or gold (“3TGs”) were necessary to the functionality or production of its products that were manufactured or contracted to be manufactured. Therefore, Arhaus conducted a reasonable country of origin inquiry in good faith to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (“CAHRAs”), such as the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”).
Based on the country of origin data, Arhaus believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question to determine whether its products are “conflict free or responsibly sourced.”
The Company's due diligence measures were informed by the internationally recognized due diligence framework of the Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).
Conflict Minerals Program & Policy
The Company has engaged with its suppliers with respect to the use of conflict minerals. In our Standards for Suppliers/Code of Conduct, Arhaus adopted a conflict minerals policy articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals.
Description of Products
Our furniture product offerings are comprised of bedroom, dining room, living room and home office furnishings and include sofas, dining tables and chairs, accent chairs, console and coffee tables, beds, headboards, dressers, desks, bookcases and modular storage, among many more items. Our outdoor product offerings include outdoor dining tables, chairs, chaises and other furniture, lighting, textiles, décor, umbrellas and fire pits. Our lighting product offerings consist of a variety of distinct and artistic lighting fixtures, including chandeliers, pendants, table and floor lamps, and sconces. Our textile product offerings include handcrafted indoor and outdoor rugs, bed linens, and pillows and throws. Décor ranges from wall art to mirrors, vases to candles, and many other decorative accessories.
Reasonable Country of Origin Inquiry
To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Arhaus retained Assent Inc. (“Assent”), a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers who accounted for more than $1,000 of landed receipts to Arhaus in the calendar year 2023 (“in-scope suppliers”) to Assent for upload to the Assent Compliance Manager.
To trace materials, and demonstrate transparency procured by the supply chain, Arhaus utilized the Conflict Minerals Reporting Template (“CMRT”) Version 6.31 or higher to conduct a survey of all in-scope suppliers.
During the supplier survey, the Company contacted suppliers via the Assent Compliance Manager, a software-as-a-service platform provided by Assent that allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The Assent Compliance Manager provides functionality that meets the OECD Guidance process expectations and the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform for reporting and transparency.
As of April 3, 2024, there were 285 suppliers in scope of the conflict minerals program and 203 provided a completed CMRT. Arhaus’s total response rate for this reporting year was 71.23%.
Through reasonable due diligence practices, Arhaus was able to take advantage of a broader set of country-of-origin data to complement efforts in establishing transparency in the supply chain.
Due Diligence
Design of Due Diligence
Arhaus’s due diligence measures were informed by the framework in the OECD Guidance and the related supplements and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities. Due diligence requires the Company’s necessary
reliance on data provided by direct suppliers and third-party audit programs initiated by suppliers and/or smelters. There is a risk of incomplete or inaccurate data as the process cannot be fully owned by the Company. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, the Company believes risk gaps can be mitigated.
Due Diligence Performed
1) Establish Strong Company Management Systems
Internal Compliance Team
Arhaus established a cross-functional Conflict Minerals Compliance Team led by the Vice President of Corporate Responsibility. The Conflict Minerals Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.
The Company also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and developing and implementing additional due diligence steps that the Company plans to undertake with suppliers and/or respective stakeholders in regards to conflict minerals.
The Company leverages Assent’s Managed Services to support Arhaus’s conflict minerals program. The Company communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and CMRs, as well as Section 1502 of the Dodd-Frank Act.
Control Systems
As outlined in its Standards for Suppliers/Code of Conduct, the Company expects that our Suppliers be committed to responsible sourcing. We expect all Suppliers manufacturing our products to partner with us to conduct necessary due diligence and provide appropriate information in order to facilitate our compliance with the conflict minerals law. Arhaus’s Standards for Suppliers/Code of Conduct applies to, and is provided to, all direct suppliers. These Standards contain, among other things, our expectations regarding the collection and provision of relevant information, onsite monitoring and assessments, transparency and traceability. As a part of Arhaus’s commitment to continuous improvement in our supply chain, it reserves the right to take corrective action, up to and including termination of the relationship.
Supplier Engagement
Arhaus has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, Arhaus has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. Arhaus’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Suppliers are provided guidance in their native language, if needed.
The Company engages with buying agents and suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes a supplier risk identification process that may lead to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Additionally, the Company’s Standards for Suppliers/Code of Conduct is included as an exhibit in supplier contracts, outlining Arhaus’s expectation that suppliers will conduct the necessary due diligence and provide appropriate information in order to facilitate compliance with conflict minerals regulations.
The Company continues to place an emphasis on conflict minerals related supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.
The Company believes that the combination of the Standards for Suppliers/Code of Conduct and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.
Grievance Mechanisms
The Company established grievance mechanisms whereby suppliers can report violations of Arhaus policies, including conflict minerals. Suppliers and others outside of Arhaus may contact the Conflict Minerals Team to report grievances via a dedicated email address that is provided in communications with suppliers. Violations or grievances at the industry level can be reported to the RMI directly as well.
Maintain Records
The Company has adopted a policy to retain relevant documentation for a period of five years.
2) Identifying & Assessing Risk in the Supply Chain
Supplier Risk Evaluation
Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT. These risks are addressed by Assent staff and members of the Company’s internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”
Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Arhaus is unable to determine if all of the specified smelters/refiners were used for 3TGs in the products supplied to the Company.
Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) can identify problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that takes into account multiple conflict minerals factors.
Smelter/Refiners Risk Evaluation
Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s Smelter validation program compared listed facilities to the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2023 calendar year.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Arhaus does not have a direct relationship with smelters/refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict free or responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to conflict minerals.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
•Geographic proximity to Conflict-Affected and High-Risk Areas.
•Known mineral source country of origin.
•RMAP audit status.
•Credible evidence of unethical or conflict sourcing.
•Peer assessments conducted by credible third-party sources.
•Sanctions risks.
Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were provided with feedback instructing suppliers to take their own independent risk mitigation actions.
Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
3) Design & Implement A Strategy to Respond to Risks
Together with Assent, Arhaus developed processes to assess risks in the supply chain. As the conflict minerals program progresses, escalations will be sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.
Feedback on supplier CMRT submissions, including initial data validation and smelter due diligence, is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers are continuously non-responsive or are not committed to corrective action plans, the Company will assess if replacing that supplier is
feasible. The results of the program and risk assessment are shared with the relevant departments and the Arhaus Leadership Team to ensure transparency within the Company.
4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Arhaus does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters/refiners (industry recognized audit/assessment programs). As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters/refiners that agree to participate in the program.
5) Report Annually on Supply Chain Due Diligence
Arhaus has published the Form SD for the year ended December 31, 2023. This report is available on the Investor Relations section of the Company’s website at ir.arhaus.com. Information found on or accessed through the Company website is not considered part of this report and is not incorporated by reference herein. Arhaus has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission (“SEC”).
Due Diligence Results
Supply Chain Outreach Results
Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten, and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Arhaus for the 2023 reporting year.
Supply Chain Outreach Metrics
| | | | | | | | |
| Number of in-scope suppliers | | Response rate |
| 285 | | 71.23% |
|
Upstream Data Transparency
Appendix A includes all smelters/refiners that suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2023 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners which actually processed the 3TGs contained in the Company’s products.
Although the potential for over-reporting is understood, Arhaus has taken measures to validate all smelter/refiner data against validated audit programs and databases intended to verify the material types and mine sources of origin. From the gathered responses, 217 smelters that potentially posed a risk due to the presence of some red flag indicators were identified.
Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections.
| | | | | | | | |
| Status | | Number of identified smelters/refiners |
| RMAP Conformant | | 192 |
| RMAP Active | | 4 |
| Not Enrolled | | 4 |
| Non Conformant | | 17 |
Country of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country of origin data obtained via Assent’s supply chain database. As mentioned in the above section, it is understood that overreporting might occur which could result in Appendix B having more countries than those strictly relevant to the Company’s products.
Steps to Be Taken to Mitigate Risk
For RY 2024 Arhaus intends to take, or is evaluating, the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in the Company’s products could originate from Conflict-Affected and High-Risk Areas:
•Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:
◦Using a comprehensive smelter and refiner library with detailed status and notes for each entity.
◦Scanning for verifiable media sources on each smelter and refiner to flag risk issues.
◦Comparing the list of smelters/refiners against government watch and denied parties lists.
•Engage with suppliers more closely, and provide more information and training resources regarding responsible sourcing of 3TGs.
•Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
•Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.
•Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis.
Forward-Looking Statements
Certain statements contained herein, including statements under the heading "Steps to Be Taken to Mitigate Risks", are not based on historical fact and are “forward-looking statements” within the meaning of applicable securities laws.
Forward-looking statements can generally be identified by the use of forward-looking terminology, including, but not limited to, “may,” “could,” “seek,” “guidance,” “predict,” “potential,” “likely,” “believe,” “will,” “expect,” “anticipate,” “estimate,” “plan,” “intend,” “forecast,” or variations of these terms and similar expressions, or the negative of these terms or similar expressions. Past performance is not a guarantee of future results or returns and no representation or warranty is made regarding future performance. Such forward-looking statements involve known and unknown risks, uncertainties and other important factors beyond our control that could cause our actual results, performance or achievements to be materially different from the expected results, performance or achievements expressed or implied by such forward-looking statements. These risks and uncertainties include, but are not limited to: our ability to manage and maintain the growth rate of our business; our ability to obtain quality merchandise in sufficient quantities; disruption in our receiving and distribution system, including delays in the integration of our distribution centers and the possibility that we may not realize the anticipated benefits of multiple distribution centers; the possibility of cyberattacks and our ability to maintain adequate cybersecurity systems and procedures; loss, corruption and misappropriation of data and information relating to clients and employees; changes in and compliance with applicable data privacy rules and regulations; risks as a result of constraints in our supply chain; a failure of our vendors to meet our quality standards; declines in general economic conditions that affect consumer confidence and consumer spending that could adversely affect our revenue; our ability to anticipate changes in consumer preferences; risks related to maintaining and increasing showroom traffic and sales; our ability to compete in our market; our ability to adequately protect our intellectual property; compliance with applicable governmental regulations; effectively managing our eCommerce business and digital marketing efforts; our reliance on third-party transportation carriers and risks associated with increased freight and transportation costs; and compliance with SEC rules and regulations as a public reporting company. These factors should not be construed as exhaustive. Further information on potential factors that could affect the financial results of the Company and its forward-looking statements is included in the Company’s filings with the Securities and Exchange Commission. The Company assumes no obligation to update any forward-looking statement, except as may be required by law. These forward-looking statements speak only as of the date of this release. All forward-looking statements are qualified in their entirety by this cautionary statement.
Appendix A: Smelter List
Includes: mineral, smelter/refinery name, location
| | | | | | | | | | | | | | |
| Metal | Smelter Name | Smelter Facility Location | Smelter ID | RMAP Audit Status |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 | Conformant |
| Gold | Advanced Chemical Company | United States of America | CID000015 | Active |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 | Conformant |
| Gold | Agosi AG | Germany | CID000035 | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 | Conformant |
| Gold | Argor-Heraeus S.A. | Switzerland | CID000077 | Conformant |
| Gold | Asahi Pretec Corp. | Japan | CID000082 | Conformant |
| Gold | Asaka Riken Co., Ltd. | Japan | CID000090 | Conformant |
| Gold | Aurubis AG | Germany | CID000113 | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 | Conformant |
| Gold | Boliden AB | Sweden | CID000157 | Conformant |
| Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 | Conformant |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 | Conformant |
| Gold | Cendres + Metaux S.A. | Switzerland | CID000189 | Non Conformant |
| Gold | Chimet S.p.A. | Italy | CID000233 | Conformant |
| Gold | Chugai Mining | Japan | CID000264 | Conformant |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of | CID000359 | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 | Conformant |
| Gold | LT Metal Ltd. | Korea, Republic of | CID000689 | Conformant |
| Gold | Heimerle + Meule GmbH | Germany | CID000694 | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | Germany | CID000711 | Conformant |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 | Conformant |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 | Conformant |
| Gold | Istanbul Gold Refinery | Turkey | CID000814 | Conformant |
| Gold | Japan Mint | Japan | CID000823 | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | China | CID000855 | Conformant |
| Gold | Asahi Refining USA Inc. | United States of America | CID000920 | Conformant |
| Gold | Asahi Refining Canada Ltd. | Canada | CID000924 | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 | Conformant |
| Gold | Kazzinc | Kazakhstan | CID000957 | Conformant |
| | | | | | | | | | | | | | |
| Gold | Kennecott Utah Copper LLC | United States of America | CID000969 | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 | Conformant |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | CID001078 | Conformant |
| Gold | Materion | United States of America | CID001113 | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 | Conformant |
| Gold | Metalor Technologies S.A. | Switzerland | CID001153 | Conformant |
| Gold | Metalor USA Refining Corporation | United States of America | CID001157 | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 | Conformant |
| Gold | Nihon Material Co., Ltd. | Japan | CID001259 | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 | Conformant |
| Gold | MKS PAMP SA | Switzerland | CID001352 | Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 | Conformant |
| Gold | PX Precinox S.A. | Switzerland | CID001498 | Conformant |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 | Conformant |
| Gold | Royal Canadian Mint | Canada | CID001534 | Conformant |
| Gold | Samduck Precious Metals | Korea, Republic of | CID001555 | Non Conformant |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 | Conformant |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China | CID001761 | Conformant |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 | Conformant |
| Gold | Shandong Gold Smelting Co., Ltd. | China | CID001916 | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 | Conformant |
| Gold | Torecom | Korea, Republic of | CID001955 | Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 | Conformant |
| Gold | United Precious Metal Refining, Inc. | United States of America | CID001993 | Conformant |
| Gold | Valcambi S.A. | Switzerland | CID002003 | Conformant |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 | Conformant |
| Gold | Yamakin Co., Ltd. | Japan | CID002100 | Conformant |
| Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 | Conformant |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 | Conformant |
| | | | | | | | | | | | | | |
| Gold | Umicore Precious Metals Thailand | Thailand | CID002314 | Non Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 | Conformant |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province of China | CID002516 | Non Conformant |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 | Non Conformant |
| Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 | Non Conformant |
| Gold | T.C.A S.p.A | Italy | CID002580 | Conformant |
| Gold | REMONDIS PMR B.V. | Netherlands | CID002582 | Conformant |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 | Conformant |
| Gold | Marsam Metals | Brazil | CID002606 | Non Conformant |
| Gold | SAAMP | France | CID002761 | Non Conformant |
| Gold | L'Orfebre S.A. | Andorra | CID002762 | Conformant |
| Gold | 8853 S.p.A. | Italy | CID002763 | Non Conformant |
| Gold | Italpreziosi | Italy | CID002765 | Conformant |
| Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 | Conformant |
| Gold | Bangalore Refinery | India | CID002863 | Active |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of | CID002918 | Conformant |
| Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 | Conformant |
| Gold | Safimet S.p.A | Italy | CID002973 | Non Conformant |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | CID000291 | Active |
| Tantalum | F&X Electro-Materials Ltd. | China | CID000460 | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | CID000616 | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 | Conformant |
| Tantalum | AMG Brasil | Brazil | CID001076 | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 | Conformant |
| Tantalum | NPM Silmet AS | Estonia | CID001200 | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 | Conformant |
| Tantalum | QuantumClean | United States of America | CID001508 | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 | RMI Due Diligence Review - Unable to Proceed |
| Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 | Conformant |
| Tantalum | Telex Metals | United States of America | CID001891 | Conformant |
| | | | | | | | | | | | | | |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 | Conformant |
| Tantalum | D Block Metals, LLC | United States of America | CID002504 | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | CID002505 | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 | Conformant |
| Tantalum | KEMET de Mexico | Mexico | CID002539 | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | CID002544 | Conformant |
| Tantalum | TANIOBIS GmbH | Germany | CID002545 | Conformant |
| Tantalum | Materion Newton Inc. | United States of America | CID002548 | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | CID002549 | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002550 | Conformant |
| Tantalum | Global Advanced Metals Boyertown | United States of America | CID002557 | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | CID002558 | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 | Conformant |
| Tin | China Tin Group Co., Ltd. | China | CID001070 | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180 | Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 | Conformant |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 | Conformant |
| Tin | PT Timah Tbk Kundur | Indonesia | CID001477 | Conformant |
| Tin | PT Timah Tbk Mentok | Indonesia | CID001482 | Conformant |
| Tin | Thaisarco | Thailand | CID001898 | Conformant |
| Tin | Alpha | United States of America | CID000292 | Conformant |
| Tin | Dowa | Japan | CID000401 | Conformant |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 | Conformant |
| Tin | Estanho de Rondonia S.A. | Brazil | CID000448 | Conformant |
| Tin | Fenix Metals | Poland | CID000468 | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 | Conformant |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 | Non Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 | Conformant |
| Tin | Metallic Resources, Inc. | United States of America | CID001142 | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | CID001175 | Conformant |
| Tin | Minsur | Peru | CID001182 | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | CID001188 | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 | Conformant |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 | Conformant |
| | | | | | | | | | | | | | |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337 | Conformant |
| Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 | Conformant |
| Tin | PT Babel Inti Perkasa | Indonesia | CID001402 | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | CID001453 | Conformant |
| Tin | PT Prima Timah Utama | Indonesia | CID001458 | Conformant |
| Tin | PT Refined Bangka Tin | Indonesia | CID001460 | Conformant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463 | Conformant |
| Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 | Conformant |
| Tin | PT Tinindo Inter Nusa | Indonesia | CID001490 | Conformant |
| Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 | Non Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 | Conformant |
| Tin | CV Venus Inti Perkasa | Indonesia | CID002455 | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 | Conformant |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002707 | Conformant |
| Tin | Aurubis Beerse | Belgium | CID002773 | Conformant |
| Tin | Aurubis Berango | Spain | CID002774 | Conformant |
| Tin | PT Sukses Inti Makmur | Indonesia | CID002816 | Conformant |
| Tin | PT Menara Cipta Mulia | Indonesia | CID002835 | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | CID002844 | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 | Conformant |
| Tin | PT Bangka Serumpun | Indonesia | CID003205 | Conformant |
| Tin | Tin Technology & Refining | United States of America | CID003325 | Conformant |
| Tin | Luna Smelter, Ltd. | Rwanda | CID003387 | Conformant |
| Tin | CRM Synergies | Spain | CID003524 | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 | Conformant |
| Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309 | Conformant |
| Tin | PT Premium Tin Indonesia | Indonesia | CID000313 | Conformant |
| Tin | Dowa | Japan | CID000402 | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | CID001173 | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | CID001191 | Conformant |
| Tin | PT Bangka Tin Industry | Indonesia | CID001419 | Active |
| Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421 | Conformant |
| Tin | PT Bukit Timah | Indonesia | CID001428 | Conformant |
| Tin | PT Panca Mega Persada | Indonesia | CID001457 | Outreach Required |
| Tin | PT Tommy Utama | Indonesia | CID001493 | Conformant |
| Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 | Non Conformant |
| | | | | | | | | | | | | | |
| Tin | CV Ayi Jaya | Indonesia | CID002570 | Conformant |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 | Conformant |
| Tin | PT Bangka Prima Tin | Indonesia | CID002776 | Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | CID003379 | Non Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 | Conformant |
| Tungsten | A.L.M.T. Corp. | Japan | CID000004 | Conformant |
| Tungsten | Kennametal Huntsville | United States of America | CID000105 | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 | Conformant |
| Tungsten | Global Tungsten & Powders LLC | United States of America | CID000568 | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 | Conformant |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | CID000769 | Non Conformant |
| Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 | Conformant |
| Tungsten | Kennametal Fallon | United States of America | CID000966 | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 | Conformant |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | CID002502 | Conformant |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513 | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002542 | Conformant |
| Tungsten | Masan High-Tech Materials | Vietnam | CID002543 | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 | Conformant |
| Tungsten | Niagara Refining LLC | United States of America | CID002589 | Conformant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 | Non Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 | Conformant |
| | | | | | | | | | | | | | |
| Tungsten | ACL Metais Eireli | Brazil | CID002833 | Non Conformant |
| Tungsten | Moliren Ltd. | Russian Federation | CID002845 | RMI Due Diligence Review - Unable to Proceed |
Appendix B: Countries of Origin
Includes: list of countries that declared smelters are known to source from.
| | | | | | | | | | | |
| Albania | Eritrea | Lithuania | Singapore |
| Andorra | Estonia | Luxembourg | Slovakia |
| Angola | Ethiopia | Madagascar | South Africa |
| Argentina | Fiji | Malaysia | South Sudan |
| Armenia | Finland | Mali | Spain |
| Australia | France | Mauritania | Sudan |
| Austria | Georgia | Mexico | Suriname |
| Azerbaijan | Germany | Mongolia | Sweden |
| Belarus | Ghana | Morocco | Switzerland |
| Belgium | Guam | Mozambique | Taiwan |
| Benin | Guatemala | Myanmar | Tajikistan |
| Bolivia (Plurinational State of) | Guinea | Namibia | Tanzania |
| Botswana | Guyana | Netherlands | Thailand |
| Brazil | Honduras | New Zealand | Togo |
| Bulgaria | Hong Kong | Nicaragua | Turkey |
| Burkina Faso | Hungary | Niger | Uganda |
| Burundi | India | Nigeria | United Arab Emirates |
| Cambodia | Indonesia | Oman | United Kingdom |
| Canada | Ireland | Panama | United States of America |
| Central African Republic | Israel | Papua New Guinea | Uruguay |
| Chile | Italy | Peru | Uzbekistan |
| China | Ivory Coast | Philippines | Vietnam |
| Colombia | Japan | Poland | Zambia |
| Cyprus | Jersey | Portugal | |
| Democratic Republic of Congo | Kazakhstan | Russian Federation | |
| Djibouti | Kenya | Rwanda | |
| Dominican Republic | Korea | Saudi Arabia | |
| Ecuador | Kyrgyzstan | Senegal | |
| Egypt | Liberia | Serbia | |
| El Salvador | Liechtenstein | Sierra Leone | |
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