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   001-10888   98-0227345

(State or other jurisdiction of

incorporation or organization)

 

(Commission File 

Number)

 

(IRS Employer 

Identification No.)

 

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, 2021.
   
  Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for fiscal year ended _____________.

 

 

 

 

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”) 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, 2021 to December 31, 2021 (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’ website:

https://totalenergies.com/sustainability/creating-shared-value/supply-chain.1

 

I.            Diligence and Reporting Process

 

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 the following business segments and operational entities (Exploration & Production, Gas, Renewables & Power, Refining & Chemicals, Trading & Shipping, Marketing & Services and TotalEnergies 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, Hutchinson S.A. (“Hutchinson”), a subsidiary in the Refining & Chemicals business segment, and TotalEnergies Charging Services S.A.S. (“TECS”), a subsidiary in the Marketing & Services 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 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.

 

The Relevant Suppliers had the ability to share information at a level at which they were most comfortable (i.e., company,

 

 

1 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.

2 As of December 31, 2021, TotalEnergies held 50.83% of the outstanding share capital of SunPower.

 

 

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 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 and belt drive systems, aerospace and defense & industry.

 

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.

 

C. TECS’ purpose is to lead the electric mobility activity within TotalEnergies. From an operational perspective, TECS ensures the development, supply, and technical support of these services and solutions including hardware, software and professional services. TECS reached out to its suppliers of components that were determined to contain or potentially contain 3TG, i.e., electronics and electric components, and which were incorporated into products manufactured by TECS (the “TECS Relevant Products”).

 

TECS conducted in good faith a RCOI regarding the sourcing of the necessary Conflict Minerals in the TECS Relevant

 

 

Products to determine whether any had originated in a Covered Country or were from recycled or scrap sources. To complete the RCOI, TECS 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 corporate policy statement letter. TECS followed up with suppliers who did not respond to its initial request. TECS relies on the information provided to it by its suppliers. TECS does not make purchases of raw ore or refined 3TG minerals directly from smelters or refiners. Its supply chain includes many third parties between the original sources of the necessary Conflict Minerals and the products manufactured by it.

 

Based on the suppliers’ responses, it was determined that substantially all suppliers had a Conflict Minerals policy within their entity. The small number of suppliers that sourced necessary Conflict Minerals during the Reporting Period from one or more of the Covered Countries are considered to be reputable, including a publicly listed company. Most of its suppliers are distributors who depend on other suppliers, and who may not maintain conflict mineral information on products that pass through their business.

 

II.            Principles

 

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 adhere to the Fundamental Principles of Purchasing (the “FPP”) and ensure compliance with those principles in their activities, and in particular to

 

be attentive to the day-to-day working conditions of their employees and their suppliers’ employees;
ensure that their own suppliers and subcontractors adhere to the FPP;
agree to be audited in accordance with those principles;
refer to the Ethics Committee in case of doubt.

 

The FPP, launched in 2010 and updated in early 2022, specify the commitments that TotalEnergies expects of its suppliers in the following areas3:

 

respect human rights at work;
protect health, safety and security;
act in favor of climate;
preserve the environment;
prevent corruption and conflicts of interest and fraud;
respect competition law; and
promote economic and social development.

 

An internal directive reaffirms the obligation to annex the FPP or endeavor to transpose them in the selection process as well as in the contracts concluded with suppliers of goods and services. The FPP are available for consultation by all suppliers in both French and English on TotalEnergies’ corporate 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 process4 or as part of an audit. TotalEnergies 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 TotalEnergies’ strategic suppliers together every two years.

 

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.

 

 

3 Saft and SunPower have defined fundamental principles of purchasing specific to their activities.

4 Purchases by the subsidiaries of Hutchinson, Saft and SunPower are subject to supplier qualification processes specific to their organizations.

 

 

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.

 

  TotalEnergies SE

 

Date: May 31, 2022 By:   /s/ JEAN-PIERRE SBRAIRE
         Name:    Jean-Pierre SBRAIRE
         Title:     Chief Financial Officer

 

 

Annex A

 

Conflict Minerals Report

 

SunPower Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for 2021 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 27, 2022.

 

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 technology and energy services provider that offers fully integrated solar, storage and home energy 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 2, 2022. The information contained in the Form 10-K is not incorporated by reference into this Conflict Minerals Report or SunPower's Form SD for 2021 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 2021, SunPower surveyed 15 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 2021.

 

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 2021, 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 15 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 2021, SunPower surveyed 15 suppliers as part of its 3TG due diligence and received 15 CMRTs in response to its outreach. The CMRT declarations received identified 329 smelters and refiners that processed or may have processed 3TG contained in SunPower’s products. Of these 15 CMRT declarations, 12 were company-level, 3 were product-level, and 0 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:

 

329 smelters and refiners were identified by the Suppliers.

227 smelters and refiners, or 69%, were listed as Conformant by the RMI.

17 smelters or refiners, or 5%, were listed as Active.

85 smelters or refiners, or 26%, were listed on the CMRT Smelter Look-up tab only.

 

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 2021 (table information is as of May 11, 2022; see the notes following the table for additional information concerning the information presented in the table).

 

 

Metal Smelter Name Country Name Status
Gold 8853 S.p.A. Italy Conformant
Gold Abington Reldan Metals, LLC United States Active
Gold Advanced Chemical Company United States Conformant
Gold African Gold Refinery Uganda On Smelter Look-up Tab Only
Gold Aida Chemical Industries Co., Ltd. Japan Conformant
Gold Al Etihad Gold Refinery DMCC United Arab Emirates Conformant
Gold Alexy Metals United States Active
Gold Agosi AG Germany Conformant
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan Conformant
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil Conformant
Gold Argor-Heraeus S.A. Switzerland Conformant
Gold Asahi Pretec Corp. Japan Conformant
Gold Asahi Refining Canada Ltd. Canada Conformant
Gold Asahi Refining USA Inc. United States Conformant
Gold Asaka Riken Co., Ltd. Japan Conformant
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey On Smelter Look-up Tab Only
Gold AU Traders and Refiners South Africa On Smelter Look-up Tab Only
Gold Augmont Enterprises Private Limited India Active

 

 

 

 

Gold Aurubis AG Germany Conformant
Gold Bangalore Refinery India On Smelter Look-up Tab Only
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines Conformant
Gold Boliden AB Sweden Conformant
Gold C. Hafner GmbH + Co. KG Germany Conformant
Gold C.I Metales Procesados Industriales SAS Colombia Active
Gold Caridad Mexico On Smelter Look-up Tab Only
Gold CCR Refinery - Glencore Canada Corporation Canada Conformant
Gold Cendres + Metaux S.A. Switzerland Conformant
Gold CGR Metalloys Pvt Ltd. India On Smelter Look-up Tab Only
Gold Chimet S.p.A. Italy Conformant
Gold Chugai Mining Japan Conformant
Gold 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 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 Emerald Jewel Industry India Limited (Unit 1) India On Smelter Look-up Tab Only
Gold Emerald Jewel Industry India Limited (Uni 2) India On Smelter Look-up Tab Only
Gold Emerald Jewel Industry India Limited (Unit 3) India On Smelter Look-up Tab Only
Gold Emerald Jewel Industry India Limited (Unit 4) India 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 GGC Gujrat Gold Centre Pvt. Ltd. India Active
Gold Geib Refining Corporation United States Conformant
Gold Gold Coast Refinery Ghana On Smelter Look-up Tab Only

 

 

 

  

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 Conformant
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 On Smelter Look-up Tab Only
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 Uralelectromed Russian Federation On Smelter Look-up Tab Only
Gold JX Nippon Mining & Metals Co., Ltd. Japan Conformant
Gold K.A. Rasmussen Norway On Smelter Look-up Tab Only
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 On Smelter Look-up Tab Only
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 MD Overseas India On Smelter Look-up Tab Only
Gold Metal Concentrators SA (Pty) Ltd. South Africa Conformant
Gold Metallix Refining Inc. United States On Smelter Look-up Tab Only
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 Moscow Special Alloys Processing Plant Russian Federation On Smelter Look-up Tab Only
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey Conformant
Gold Navoi Mining and Metallurgical Combinat Uzbekistan Conformant
Gold NH Recytech Company Korea Conformant
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 On Smelter Look-up Tab Only

 

 

 

  

Gold OJSC Novosibirsk Refinery Russian Federation On Smelter Look-up Tab Only
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 On Smelter Look-up Tab Only
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 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 Sancus ZFS (L’Orfebre, SA) Colombia Active
Gold SAXONIA Edelmetalle GmbH Germany On Smelter Look-up Tab Only
Gold Sellem Industries Ltd. Mauritania 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 On Smelter Look-up Tab Only

 

 

 

 

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 Conformant
Gold TOO Tau-Ken-Altyn Kazakhstan Conformant
Gold Torecom Korea Conformant
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 Value Trading Belgium On Smelter Look-up Tab Only
Gold Weeerefining France Active
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 Zhongyuan Gold Smelter of Zhongjin Gold Corporation China Conformant
Tantalum Changsha South Tantalum Niobium Co., Ltd. China Conformant
Tantalum D Block Metals, LLC United States Conformant
Tantalum Exotech Inc. United States On Smelter Look-up Tab Only
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 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 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 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 On Smelter Look-up Tab Only
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  Ximei Resources (Guangdong) Limited China Conformant
Tantalum XinXing Haorong Electronic Material Co., Ltd. China Conformant
Tantalum Yancheng Jinye New Material Technology 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 CRM Fundicao De Me Metais E Comercio De Equipamentos Electronicos Do Brasil Ltda Brazil Active

 

 

 

 

Tin CRM Synergies Spain Conformant
Tin CV Venus Inti Perkasa Indonesia Active
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 Conformant
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil Conformant
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 On Smelter Look-up Tab Only
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 HuiChang Hill Tin Industry 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 Melt Metais e Ligas S.A. Brazil On Smelter Look-up Tab Only
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 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 Aries Kencana Sejahtera Indonesia Active
Tin PT Artha Cipta Langgeng Indonesia Conformant
Tin PT ATD Makmur Mandiri Jaya Indonesia Conformant
Tin PT Babel Inti Perkasa Indonesia Conformant
Tin PT Babel Surya Alam Lestari Indonesia Conformant
Tin PT Bangka Serumpun Indonesia Conformant
Tin PT Bukit Timah Indonesia Conformant
Tin PT Cipta Persada Mulia Indonesia Conformant
Tin PT Masbro Alam Stania Indonesia Active
Tin PT Menara Cipta Mulia Indonesia Conformant
Tin PT Mitra Stania Prima Indonesia Conformant
Tin PT Mitra Sukses Globalindo Indonesia Active
Tin PT Prima Timah Utama Indonesia Conformant
Tin PT Rajawali Rimba Perkasa Indonesia Conformant
Tin PT Refined Bangka Tin Indonesia Conformant
Tin PT Sariwiguna Binasentosa Indonesia Conformant
Tin PT Stanindo Inti Perkasa Indonesia Conformant
Tin PT Sukses Inti Makmur Indonesia Active

 

 

 

 

Tin PT Timah Nusantara Indonesia Active
Tin PT Timah Tbk Kundur Indonesia Conformant
Tin PT Timah Tbk Mentok Indonesia Conformant
Tin Tinindo Inter Nusa 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 VQB Mineral and Trading Group JSC 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 Tin Smelting Branch of Yunnan Tin Co., Ltd. China Conformant
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China On Smelter Look-up Tab Only
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 Artek LLC Russian Federation On Smelter Look-up Tab Only
Tungsten Asia Tungsten Products Vietnam Ltd. Vietnam Conformant
Tungsten China Molybdenum Co., Ltd. China Conformant
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China Conformant
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China On Smelter Look-up Tab Only
Tungsten Cronimet Brasil Ltda Brazil Conformant
Tungsten Fujian Ganmin RareMetal Co., Ltd. China Conformant
Tungsten Fujian Xinlu Tungsten China Conformant
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 Global Tungsten & Powders Corp. United States Conformant
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China Conformant

 

 

 

 

Tungsten H.C. Starck Tungsten GmbH Germany Conformant
Tungsten Hubei Green Tungsten Co., Ltd. China Conformant
Tungsten Hunan Chenzhou Mining Co., Ltd. China Conformant
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. China Conformant
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China Conformant
Tungsten Hydrometallurg, JSC Russian Federation On Smelter Look-up Tab Only
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 Xinsheng Tungsten Industry Co., Ltd. China Conformant
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China Conformant
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation On Smelter Look-up Tab Only
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 On Smelter Look-up Tab Only
Tungsten Niagara Refining LLC United States Conformant
Tungsten NPP Tyazhmetprom LLC Russian Federation Active
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines Conformant
Tungsten TANIOBIS Smelting GmbH & Co. KG Germany Conformant
Tungsten Unecha Refractory Metals Plant Russian Federation On Smelter Look-up Tab Only
Tungsten Wolfram Bergbau und Hutten AG Austria 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

 

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 2021 and may not continue to be Conformant for any future period.

 

b) “Active” means that a smelter or refiner is currently engaged in the RMAP but a conformance determination has yet to be made.

 

 

 

 

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).

 

Angola Finland Madagascar South Sudan
Argentina France Malaysia Spain
Armenia Germany Mali Suriname
Austria Ghana Mexico Sweden
Belgium Guinea Mongolia Switzerland
Bermuda Guyana Mozambique Taiwan
Bolivia Hong Kong Myanmar Tajikistan
Brazil Hungary Namibia Tanzania*
Burundi* India Netherlands Thailand
Cambodia Indonesia Niger Turkey
Canada Ireland Nigeria United Arab Emirates
Central African Republic Israel Papua New Guinea United Kingdom
Chile Italy Peru United States
China Ivory Coast Philippines Uzbekistan
Colombia Japan Poland Vietnam
Czech Republic Jersey Portugal Zambia*
Djibouti Kazakhstan Russian Federation Zimbabwe

 

 

 

 

Democratic Republic of the Congo* Kenya Rwanda*  
Ecuador Korea Sierra Leone  
Egypt Kyrgyzstan Singapore  
Estonia Laos Slovakia  
Ethiopia Luxembourg South Africa  

 

* 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 2022 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 2021.

 

 

 

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