UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
INTERNATIONAL BUSINESS MACHINES CORPORATION
(Exact name of registrant as specified in its charter)
| NEW YORK |
|
1-2360 |
|
13-0871985 |
(State or other jurisdiction of
incorporation or organization) |
|
(Commission File Number) |
|
(IRS Employer
Identification No.) |
|
ONE NEW ORCHARD ROAD
ARMONK, NEW YORK |
|
10504 |
| (Address of principal executive offices) |
|
(Zip Code) |
JANE EDWARDS
VICE PRESIDENT, ASSISTANT GENERAL COUNSEL AND SECRETARY
(914) 499-1900
(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, 2023.
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of International Business Machines Corporation (the
“Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the
reporting period January 1, 2023 to December 31, 2023.
A copy of the Company’s Conflict Minerals Report is provided
as Exhibit 1.01 to this Form SD and is publicly available at https://www.ibm.com/procurement/responsibleminerals.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD,
the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 — Exhibits
Item 2.01 Exhibit
The following exhibit is filed as part of this report.
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.
INTERNATIONAL BUSINESS MACHINES CORPORATION
| /s/ Ric Lewis |
|
May 24, 2024 |
| Name: |
Ric Lewis |
|
Date |
| Title: |
Senior Vice President, Infrastructure |
|
|
Exhibit 1.01
INTERNATIONAL
BUSINESS MACHINES CORPORATION
Conflict Minerals
Report
For the reporting
period from January 1, 2023 through December 31, 2023
This Conflict Minerals Report (Report)
of International Business Machines Corporation (IBM) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the
Rule) promulgated under the Securities Exchange Act of 1934, as amended, for the period from January 1, 2023, through December 31,
2023 (Reporting Period).
The Rule requires disclosure of
certain information when a company manufactures or contracts to manufacture products, and the minerals specified in the Rule are
necessary to the functionality or production of those products. The specified minerals are columbite-tantalite (coltan), cassiterite,
and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten, and gold (collectively, Conflict Minerals
or 3TG). As described in this Report, Conflict Minerals are necessary for the functionality or production of certain products that IBM
manufactures or contracts to manufacture.
Design of IBM’s Responsible
Minerals Program
IBM’s
Responsible Minerals Program, which includes IBM’s Conflict Minerals Initiative, and Cobalt and Mica Initiative, is run by full-time,
experienced supply chain professionals within IBM’s Global Procurement organization. This team
reports to IBM’s Vice President and Chief Procurement Officer, who has responsibility for IBM’s external supply base in support
of products listed in this report. IBM is highly committed to sourcing 3TG and other minerals responsibly. In support of its established
goals, IBM continued work to develop future platforms for mineral traceability due diligence, optimized Responsible Minerals supply
chain education and evolved practices through strong collaboration with companies, smelters and refiners, and industry groups.
Description of IBM’s Products
This Report relates to products: (i) for
which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted
to be manufactured, by IBM; and (iii) for which the manufacture was completed during the Reporting Period. IBM products include
the following categories that were manufactured or contracted to be manufactured by IBM in 2023:
IBM Hybrid Infrastructure: provides
clients with innovative infrastructure platforms to help meet the new requirements of hybrid multi-cloud and enterprise AI workloads
leveraging flexible and as-a-service consumption models. Hybrid Infrastructure includes zSystems and Distributed Infrastructure.
zSystems (also referred to as IBM Z):
the premier transaction processing platform with leading security, resilience and scale, highly optimized for mission-critical, high-volume
transaction workloads and enabled for enterprise AI and hybrid cloud. It includes zSystems and LinuxONE, with a range of high-performance
systems designed to address enterprise computing capacity, security and performance needs, z/OS, a security-rich, high-performance enterprise
operating system, as well as Linux and other operating systems.
Distributed
Infrastructure: includes Power, Storage, and IBM Cloud Infrastructure-as-a-Service (IaaS). Power consists of high-performance servers,
designed and engineered for data intensive and AI-enabled workloads and optimized for hybrid cloud and Linux. The Storage portfolio consists
of a broad range of storage hardware and software-defined offerings, including Z-attach and distributed flash, tape solutions, software-defined
storage controllers, data protection software and network-attach storage. IBM
Cloud IaaS is built on enterprise-grade hardware with leading security and compliance capabilities and offers
flexible computing options across architectures to meet client workload needs.
Reasonable Country of Origin Inquiry
IBM conducted a good faith reasonable
country of origin inquiry regarding 3TG. This inquiry was designed to determine whether any of the 3TG originated in the Democratic Republic
of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, or Angola
(collectively Covered Countries), and whether any of the Conflict Minerals may be from recycled or scrap sources.
IBM’s Conflict Minerals Due
Diligence Design
IBM’s due diligence measures for
3TG conforms in all applicable respects to the framework outlined in 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, including Annex II and the
related supplements pertaining to downstream companies (OECD Guidance).
IBM is not a direct purchaser of ore
or unrefined minerals; it is several tiers “downstream” from the smelters or refiners (SORs) of such minerals. SORs are at
a point in the supply chain where ore, concentrates, and/or scrap material are converted to metal. IBM, like many downstream companies,
does not have direct business relationships with SORs or visibility to the extraction and movement of 3TG between SORs and upstream entities.
This position increases the difficulty of determining the origin of the 3TG in IBM products and, as a result, IBM relies on established
industry processes and information provided by its in-scope direct suppliers.
Description of Due Diligence Measures
Performed
IBM upholds a high standard of due diligence
to meet legal requirements and internationally accepted standards, with the ultimate goal of establishing and maintaining a responsible
supply chain for 3TG. IBM aligns its Responsible Minerals Policy with the OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas (CAHRAs). As a member of the Responsible Minerals Initiative (RMI) our due diligence
process utilizes RMI resources including the Conflict Minerals Reporting Template (CMRT) and the Responsible Minerals Assurance Process
(RMAP), augmented by the London Bullion Market Association (LBMA), the Responsible Jewellery Council Chain of Custody Standard (RJC CoC),
and the Tungsten Industry – Conflict Minerals Council (TI-CMC). The RMAP, LBMA, RJC CoC, and TI-CMC use independent third-party
audits to identify SORs that have systems in place to ensure focus minerals are sourced responsibly. RMAP, LBMA, RJC CoC, and TI-CMC
are recognized by the industry as third-party validation schemes. Independently, IBM also conducts further due diligence on SORs
only processing 3TG recycled scrap as a part of our sustainability commitment.
Below is a description of the due diligence
measures performed by IBM for the Reporting Period, based on the OECD Guidance:
1. OECD Step 1: Establish strong
company management systems
| § | Positioned
the IBM Responsible Minerals team within IBM’s Global Procurement organization to orchestrate
the execution of IBM's 3TG Program. |
| § | The
IBM Responsible Minerals team reports through IBM’s Chief Procurement Officer and this
Report is reviewed by IBM’s Senior Vice President of Infrastructure. During the year,
we reported to IBM’s Global Procurement management on topics such as CMRT collection
efforts, in-scope supplier progress, SOR risk mitigation, and driving identified SORs toward
RMAP, LBMA, RJC CoC, or TI-CMC engagement. |
| § | Implemented
IBM’s Responsible Minerals Policy to include 3TG from the Covered Countries and CAHRAs.
This policy outlines IBM’s dedication to ethical and responsible minerals sourcing
due diligence consistent with the OECD Guidance. This policy also emphasizes IBM’s
expectations with its hardware suppliers for sourcing minerals ethically and responsibly.
Our policy is publicly available and can be found at https://www.ibm.com/procurement/responsibleminerals |
| § | Designated
members of the Responsible Minerals team engaged with in-scope suppliers, fostering collaboration,
providing invaluable support, and offering expert guidance to facilitate the realization
of the objectives outlined within IBM's Responsible Minerals program. |
| § | Utilized
a well-established communication portal for both internal and external stakeholders to report
concerns about 3TG, directing them to the independent Ombudsman Office of IBM for resolution
at: https://www.ibm.com/procurement/ombudsman-information |
| § | Included
Responsible Minerals requirements in standard contract templates: All IBM’s hardware
suppliers are required to sign a contract agreement to only source minerals responsibly,
in alignment with IBM’s Responsible Minerals Policy. |
2. OECD Step 2: Identify and assess
risks in the supply chain
| § | Requested
IBM’s in-scope suppliers to survey their upstream suppliers twice per year to identify
SORs and related 3TG information through the RMI CMRT. |
| § | Oversaw
the aggregation of supplier CMRTs and conducted comprehensive evaluations of the data contained
within, aligning with IBM's stringent validation criteria, and adhering to the guidelines
outlined by the OECD. |
| § | Utilized
curated data from RMI, supplemented by extensive research, to discern the potential provenance
of 3TG present in IBM products, particularly scrutinizing any trace of origin from the designated
Covered Countries and CAHRAs. |
| § | Validated
SORs status to confirm compliance with either RMAP, LBMA, RJC CoC, and/or TI-CMC standards. |
| § | In
situations when a nonconformant SOR was identified, the Responsible Minerals team collaborated
and supported firms across multiple layers of the supply chain to trace and transition from
use of the SOR. |
| § | Deployed
a third-party analytics tool to conduct a comprehensive evaluation of specific SORs for ownership
risk. |
3. OECD Step 3: Design and implement
a strategy to respond to identified risks
| § | IBM
requested suppliers to promptly transition away from SORs that had not been validated as
conformant or active by a recognized third-party assessment scheme. |
| § | Extended
Responsible Minerals support beyond first-tier suppliers. We continued one-on-one training
and joint outreach for new suppliers or personnel. |
| § | Participated
in the annual Responsible Minerals Initiative conference and forged strategic alliances with
industry peers across the supply chain spectrum and relevant industry consortiums, harnessing
efforts toward the establishment of an ethical and conscientious minerals-sourcing supply
chain. |
| § | Remained
at the vanguard of macro-level Conflict Minerals discourse and advancements by actively engaging
in the RMI, ensuring a comprehensive understanding of pertinent issues and evolving trends
in the field. |
| § | Implemented
a strategic shift away from non-participatory or non-compliant SORs, redirecting focus towards
those aligned with accredited schemes such as RMAP, LBMA, RJC, and/or TI-CMC, thereby ensuring
adherence to stringent regulatory standards and industry best practices. |
4. OECD Step 4: Carry out independent
third-party audit of smelter/refiner’s due diligence practices
| § | Contributed
to the advancement of RMI endeavors by actively engaging in collaborative RMI workgroups,
thereby fostering synergy and innovation in the pursuit of responsible mineral-sourcing practices. |
| § | Since
its inception, supported RMI’s RMAP accreditation of SORs engaged in Responsible Minerals
to build a global network of validated sources of material meeting the needs of IBM’s
Responsible Minerals Policy. With the backing of over 500 members in RMI, the network of
accredited SORs has grown considerably allowing for downstream companies to utilize greater
percentages of third-party verified 3TG. |
| § | Served
as the exclusive liaison for designated SORs lacking accredited status, collaborating closely
with RMI's smelter engagement teams to facilitate and advocate for their integration into
third-party validation schemes such as RMAP and others. |
| § | Participated
in teleconferences with SORs to discuss matters regarding RMAP, such as understanding the
dynamics of the SORs and downstream users of 3TG, SOR participation in the program, and retention
of SORs in the program. |
| § | Engaged
in collaborative partnerships with metal organizations to explore the prospective expansion
of third-party audit frameworks, fostering enhanced accountability and transparency within
the responsible minerals and smelting sector. |
| § | Delved
into and advocated for expanded cross-recognition audit initiatives within the RMAP, thereby
providing SORs with a broader array of audit program options compliant with both US and EU
regulatory frameworks. |
5. OECD Step 5: Report annually on
supply chain due diligence
| § | According
to the Rule, annually file Form SD and Exhibit 1.01 (Conflict Minerals Report). |
| § | Published
the 2022 Conflict Minerals Report on IBM’s Responsible Minerals website https://www.ibm.com/procurement/responsibleminerals |
| § | Incorporated
updates on the advancements made in Responsible Minerals management within IBM's annual Impact
Report, exemplifying our steadfast commitment to transparency and accountability in responsible
minerals and smelting practices. |
| § | Retained
records related to 3TG in conformance with IBM’s records retention policy. |
Reporting Period Determination and
Findings
Based on the information obtained through
the due diligence process described herein, IBM believes SORs that may be used to process the 3TG contained in IBM products are
listed in Appendix A. The list identifies SORs present at year-end 2023. Further, as listed in Appendix B, IBM has reasonably determined
the potential countries of origin of the 3TG in IBM products.
The following chart illustrates the
composition of 245 3TG SORs in IBM’s supply chain that (as of December 31) were conformant or actively participating in a
third-party scheme or were processing 100 percent recycled scrap.
IBM’s progress in this area since
2016 is illustrated below and reflects that, at year-end 2023, 100 percent of 3TG SORs reported in the IBM supply chain are pursuing
or are accredited as conformant to a recognized third-party validation scheme (or operating as refiners of 100 percent recycled 3TG).
This is the fifth consecutive year of IBM’s supply chain achieving this level of performance.
From 2016 onward, SORs that were active in a recognized third-party
validation scheme in addition to RMAP (LBMA, RJC, and/or TI-CMC) were added to the conformant category. In 2019 and beyond, IBM
included in the conformant category SORs that do not seek third-party validation but are determined to operate solely from recycled or
scrap sources – which the Rule designates as Conflict-Free.
IBM Requirement for Suppliers to
be Conflict-Free
During 2023, IBM continued its
initiative to have all in-scope direct suppliers achieve a conformant supply chain as defined by its Responsible Minerals Policy. In-scope
direct suppliers with CMRTs containing SORs that are not progressing toward, or have not already received conflict-free accreditation,
are required to transition those SORs from products provided to IBM. The IBM Responsible Minerals team and the Global Procurement organization
work with those suppliers to help them achieve this goal. Their progress is tracked and reported to IBM Global Procurement executives
monthly along with IBM’s progress toward attaining 100 percent conformant status. IBM has received CMRTs from 100 percent of our
in-scope suppliers, containing over 99.8 percent reporting of the extended supply chain.
IBM’s Next Steps to Mitigate
Conflict Minerals Risk
IBM
expects to take the following steps to enhance its due diligence measures and to continue mitigating the risk that the 3TG contained
in IBM products finance or benefit armed groups in the Covered Countries:
| § | Participating
in the RMI contributes to the continued development of collaborative tools and resources
for companies to assess their supply chains and avoid the inclusion of non-validated Conflict
Minerals 3TG in the extended supply chain. |
| § | Remain
aware of developments in 3TG due diligence processes by participation in the RMI and apply
that knowledge to IBM’s 3TG risk assessment and mitigation actions. |
| § | As
an ardent supporter of Environmental and Social stewardship, IBM continues to grow usage
of 3TG SORs processing 100 percent recycled scrap. |
| § | Work
with RMI members and IBM in-scope suppliers to gain SOR’s commitment for their continued
engagement with an RMAP assessment or another recognized validation scheme. |
| § | Pursue
resolution in 2024 for any identified SORs in IBM’s supply chain that are not validated
as conformant to one of the recognized assessment schemes. |
| § | Improve
in-scope direct suppliers’ CMRT upstream supplier completeness; provide collaboration
from IBM and other upstream suppliers to attain 100 percent upstream coverage. |
| § | Drive
in-scope direct suppliers to provide product-specific CMRTs versus company-level CMRTs, as
company-level CMRTs may include SORs not used in the supply chain for IBM products; use of
product-specific CMRTs by in-scope direct suppliers enables IBM to have a more precise list
of SORs used in IBM products. |
| § | Engage
IBM Hardware Development and Global Procurement on future products to ascertain the conformant
status of SORs to be used by the proposed in-scope direct suppliers. Eliminate the use of
nonconformant SORs before introducing the product to the marketplace. |
IBM’s Support of the RMI
As
outlined in the OECD Guidance, the internationally recognized standard on which IBM’s due diligence is based, IBM supports
an industry initiative that audits the due diligence activities of SORs. That industry initiative is the RMI’s RMAP. The potential
countries of origin found in Appendix B, and upon which IBM relied for certain statements in this
Report, were obtained through RMI and other accreditation source data. IBM is an active contributor to the RMI through our participation
in various working groups. IBM’s member ID is MIBM.
Appendix A
Smelters or Refiners
(SORs) that may be used to process 3TG contained in IBM Products.
SOR Status (as of December 31,
2023):
| § | “Conformant”
indicates the SOR has completed an assessment and is listed by the RMAP, LBMA Good Delivery
List, RJC Chain-of-Custody, or TI-CMC websites. |
| § | “Active”
indicates that the SOR is in the process of conformance assessment by one or more of the
recognized third-party validation schemes. |
| § | “Recycled
Scrap” indicates that the SOR has demonstrated conformance to criteria for a facility
processing only recycled or scrap materials and is currently not participating in one of
the noted validation schemes. |
| IBM
2023 Conflict Minerals Report - Appendix A |
| (SORs
for year-end 2023 with 3rd Party Assessment Status as of Dec 31, 2023) |
Legend
SOR Status: Conformant or Active (RMAP, LBMA, RJC, Ti-CMC),
or Recycled Scrap
(IBM)
|
| Metal |
Smelter
Name |
2023
Status |
| Tantalum |
AMG
Brasil |
Conformant
(RMAP) |
| Tantalum |
D
Block Metals, LLC |
Conformant
(RMAP) |
| Tantalum |
F&X
Electro-Materials Ltd. |
Conformant
(RMAP) |
| Tantalum |
FIR
Metals & Resource Ltd. |
Conformant
(RMAP) |
| Tantalum |
Global
Advanced Metals Aizu |
Conformant
(RMAP) |
| Tantalum |
Global
Advanced Metals Boyertown |
Conformant
(RMAP) |
| Tantalum |
Guangdong
Rising Rare Metals-EO Materials Ltd. |
Active
(RMAP) |
| Tantalum |
Hengyang
King Xing Lifeng New Materials Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Jiangxi
Dinghai Tantalum & Niobium Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Jiangxi
Tuohong New Raw Material |
Conformant
(RMAP) |
| Tantalum |
JiuJiang
JinXin Nonferrous Metals Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Jiujiang
Tanbre Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Jiujiang
Zhongao Tantalum & Niobium Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
KEMET
de Mexico |
Conformant
(RMAP) |
| Tantalum |
Materion
Newton Inc. |
Conformant
(RMAP) |
| Tantalum |
Metallurgical
Products India Pvt., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Mineracao
Taboca S.A. |
Conformant
(RMAP) |
| Tantalum |
Mitsui
Mining and Smelting Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Ningxia
Orient Tantalum Industry Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
NPM
Silmet AS |
Conformant
(RMAP) |
| Tantalum |
PowerX
Ltd. |
Conformant
(RMAP) |
| Tantalum |
QuantumClean |
Conformant
(RMAP) |
| Tantalum |
Resind
Industria e Comercio Ltda. |
Conformant
(RMAP) |
| Metal |
Smelter
Name |
2023
Status |
| Tantalum |
RFH
Yancheng Jinye New Material Technology Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Taki
Chemical Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
TANIOBIS
Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
TANIOBIS
GmbH |
Conformant
(RMAP) |
| Tantalum |
TANIOBIS
Japan Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
TANIOBIS
Smelting GmbH & Co. KG |
Conformant
(RMAP) |
| Tantalum |
Telex
Metals |
Conformant
(RMAP) |
| Tantalum |
Ulba
Metallurgical Plant JSC |
Conformant
(RMAP) |
| Tantalum |
Ximei
Resource (Guangdong) Limited |
Conformant
(RMAP) |
| Tantalum |
XinXing
HaoRong Electronic Material Co., Ltd. |
Conformant
(RMAP) |
| Tantalum |
Yanling
Jincheng Tantalum & Niobium Co., Ltd. |
Conformant
(RMAP) |
| Tin |
Alpha |
Conformant
(RMAP) |
| Tin |
Aurubis
Beerse |
Conformant
(RMAP) |
| Tin |
Aurubis
Berango |
Conformant
(RMAP) |
| Tin |
Chenzhou
Yunxiang Mining and Metallurgy Co., Ltd. |
Conformant
(RMAP) |
| Tin |
Chifeng
Dajingzi Tin Industry Co., Ltd. |
Conformant
(RMAP) |
| Tin |
China
Tin Group Co., Ltd. |
Conformant
(RMAP) |
| Tin |
CRM
Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Conformant
(RMAP) |
| Tin |
CRM
Synergies |
Conformant
(RMAP) |
| Tin |
CV
Ayi Jaya |
Conformant
(RMAP) |
| Tin |
CV
Venus Inti Perkasa |
Conformant
(RMAP) |
| Tin |
Dowa |
Conformant
(RMAP) |
| Tin |
DS
Myanmar |
Conformant
(RMAP) |
| Tin |
EM
Vinto |
Conformant
(RMAP) |
| Tin |
Estanho
de Rondonia S.A. |
Conformant
(RMAP) |
| Tin |
Fabrica
Auricchio Industria e Comercio Ltda. |
Conformant
(RMAP) |
| Tin |
Fenix
Metals |
Conformant
(RMAP) |
| Tin |
Gejiu
Non-Ferrous Metal
Processing Co., Ltd. |
Conformant
(RMAP) |
| Tin |
Guangdong
Hanhe Non-Ferrous
Metal Co., Ltd. |
Conformant
(RMAP) |
| Tin |
HuiChang
Hill Tin Industry Co., Ltd. |
Conformant
(RMAP) |
| Tin |
Jiangxi
New Nanshan Technology Ltd. |
Conformant
(RMAP) |
| Tin |
Luna
Smelter, Ltd. |
Conformant
(RMAP) |
| Tin |
Magnu's
Minerais Metais e Ligas Ltda. |
Conformant
(RMAP) |
| Tin |
Malaysia
Smelting Corporation (MSC) |
Conformant
(RMAP) |
| Tin |
Ma'anshan
Weitai Tin Co., Ltd. |
Active
(RMAP) |
| Tin |
Metallic
Resources, Inc. |
Conformant
(RMAP) |
| Tin |
Mineracao
Taboca S.A. |
Conformant
(RMAP) |
| Tin |
Minsur |
Conformant
(RMAP) |
| Tin |
Mining
Minerals Resources SARL |
Conformant
(RMAP) |
| Tin |
Mitsubishi
Materials Corporation |
Conformant
(RMAP) |
| Tin |
O.M.
Manufacturing (Thailand) Co., Ltd. |
Conformant
(RMAP) |
| Tin |
O.M.
Manufacturing Philippines, Inc. |
Conformant
(RMAP) |
| Metal |
Smelter
Name |
2023
Status |
| Tin |
Operaciones
Metalurgicas S.A. |
Conformant
(RMAP) |
| Tin |
Precious
Minerals and Smelting Limited |
Active
(RMAP) |
| Tin |
PT
Aries Kencana Sejahtera |
Conformant
(RMAP) |
| Tin |
PT
Artha Cipta Langgeng |
Conformant
(RMAP) |
| Tin |
PT
ATD Makmur Mandiri Jaya |
Conformant
(RMAP) |
| Tin |
PT
Babel Inti Perkasa |
Conformant
(RMAP) |
| Tin |
PT
Babel Surya Alam Lestari |
Conformant
(RMAP) |
| Tin |
PT
Bangka Prima Tin |
Conformant
(RMAP) |
| Tin |
PT
Bangka Serumpun |
Conformant
(RMAP) |
| Tin |
PT
Bangka Tin Industry |
Active
(RMAP) |
| Tin |
PT
Belitung Industri Sejahtera |
Active
(RMAP) |
| Tin |
PT
Bukit Timah |
Conformant
(RMAP) |
| Tin |
PT
Cipta Persada Mulia |
Conformant
(RMAP) |
| Tin |
PT
Menara Cipta Mulia |
Conformant
(RMAP) |
| Tin |
PT
Mitra Stania Prima |
Conformant
(RMAP) |
| Tin |
PT
Mitra Sukses Globalindo |
Conformant
(RMAP) |
| Tin |
PT
Premium Tin Indonesia |
Conformant
(RMAP) |
| Tin |
PT
Prima Timah Utama |
Conformant
(RMAP) |
| Tin |
PT
Putera Sarana Shakti (PT PSS) |
Conformant
(RMAP) |
| Tin |
PT
Rajawali Rimba Perkasa |
Conformant
(RMAP) |
| Tin |
PT
Rajehan Ariq |
Conformant
(RMAP) |
| Tin |
PT
Refined Bangka Tin |
Conformant
(RMAP) |
| Tin |
PT
Sariwiguna Binasentosa |
Conformant
(RMAP) |
| Tin |
PT
Stanindo Inti Perkasa |
Conformant
(RMAP) |
| Tin |
PT
Sukses Inti Makmur (SIM) |
Conformant
(RMAP) |
| Tin |
PT
Timah Tbk Kundur |
Conformant
(RMAP) |
| Tin |
PT
Timah Tbk Mentok |
Conformant
(RMAP) |
| Tin |
PT
Tinindo Inter Nusa |
Conformant
(RMAP) |
| Tin |
PT
Tommy Utama |
Conformant
(RMAP) |
| Tin |
Resind
Industria e Comercio Ltda. |
Conformant
(RMAP) |
| Tin |
Rui
Da Hung |
Conformant
(RMAP) |
| Tin |
Super
Ligas |
Conformant
(RMAP) |
| Tin |
Thaisarco |
Conformant
(RMAP) |
| Tin |
Tin
Smelting Branch of Yunnan Tin Co., Ltd. |
Conformant
(RMAP) |
| Tin |
Tin
Technology & Refining |
Conformant
(RMAP) |
| Tin |
White
Solder Metalurgia e Mineracao Ltda. |
Conformant
(RMAP) |
| Tin |
Yunnan
Chengfeng Non-ferrous Metals Co., Ltd. |
Conformant
(RMAP) |
| Tin |
Yunnan
Yunfan Non-ferrous Metals Co., Ltd. |
Conformant
(RMAP) |
| Tungsten |
A.L.M.T.
Corp. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Asia
Tungsten Products Vietnam Ltd. |
Conformant
(RMAP) |
| Tungsten |
China
Molybdenum Tungsten Co., Ltd. |
Conformant
(RMAP) |
| Tungsten |
Chongyi
Zhangyuan Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Cronimet
Brasil Ltda |
Conformant
(RMAP) |
| Tungsten |
Fujian
Xinlu Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Metal |
Smelter
Name |
2023
Status |
| Tungsten |
Ganzhou
Haichuang Tungsten Co., Ltd. |
Conformant
(RMAP) |
| Tungsten |
Ganzhou
Huaxing Tungsten Products Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Ganzhou
Jiangwu Ferrotungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Ganzhou
Seadragon W & Mo Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Global
Tungsten & Powders LLC. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Guangdong
Xianglu Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Hubei
Green Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Hunan
Chenzhou Mining Co., Ltd. |
Conformant
(RMAP) |
| Tungsten |
Hunan
Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Japan
New Metals Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Jiangwu
H.C. Starck Tungsten Products Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Jiangxi
Gan Bei Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Jiangxi
Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Jiangxi
Xinsheng Tungsten Industry Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Jiangxi
Yaosheng Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Kenee
Mining Corporation Vietnam |
Active
(RMAP) |
| Tungsten |
Kennametal
Fallon |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Kennametal
Huntsville |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Lianyou
Metals Co., Ltd. |
Conformant
(RMAP) |
| Tungsten |
Lianyou
Resources Co., Ltd. |
Active
(RMAP) |
| Tungsten |
Malipo
Haiyu Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Masan
High-Tech Materials |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Niagara
Refining LLC |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Philippine
Chuangxin Industrial Co., Inc. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Shinwon
Tungsten (Fujian Shanghang) Co., Ltd. |
Conformant
(RMAP) |
| Tungsten |
Taniobis
Smelting GmbH & Co. KG |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Tungsten
Vietnam Joint Stock Company |
Conformant
(RMAP) |
| Tungsten |
Wolfram
Bergbau und Hutten AG |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Xiamen
Tungsten (H.C.) Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Tungsten |
Xiamen
Tungsten Co., Ltd. |
Conformant
(RMAP, TI-CMC) |
| Gold |
8853
S.p.A. |
Conformant
(RJC) |
| Gold |
Abington
Reldan Metals, LLC |
Conformant
(RMAP) |
| Gold |
Advanced
Chemical Company |
Active
(RMAP) |
| Gold |
Agosi
AG |
Conformant
(LBMA, RMAP) |
| Gold |
Aida
Chemical Industries Co., Ltd. |
Conformant
(RMAP) |
| Gold |
Al
Etihad Gold Refinery DMCC |
Conformant
(RJC) |
| Gold |
Alexy
Metals |
Recycled
Scrap |
| Gold |
Almalyk
Mining and Metallurgical Complex (AMMC) |
Conformant
(LBMA, RMAP) |
| Gold |
AngloGold
Ashanti Corrego do Sitio Mineracao |
Conformant
(LBMA, RMAP) |
| Gold |
Argor-Heraeus
S.A. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Asahi
Pretec Corp. |
Conformant
(LBMA, RMAP) |
| Gold |
Asahi
Refining Canada Ltd. |
Conformant
(LBMA, RMAP) |
| Metal |
Smelter
Name |
2023
Status |
| Gold |
Asahi
Refining USA Inc. |
Conformant
(LBMA, RMAP) |
| Gold |
Asaka
Riken Co., Ltd. |
Conformant
(RMAP) |
| Gold |
Augmont
Enterprises Private Limited |
Conformant
(RJC) |
| Gold |
Aurubis
AG |
Conformant
(LBMA, RMAP) |
| Gold |
Bangalore
Refinery |
Active
(RMAP) |
| Gold |
Bangko
Sentral ng Pilipinas (Central Bank of the Philippines) |
Conformant
(LBMA, RMAP) |
| Gold |
Boliden
AB |
Conformant
(LBMA, RMAP) |
| Gold |
C.
Hafner GmbH + Co. KG |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
CCR
Refinery - Glencore Canada Corporation |
Conformant
(LBMA, RMAP) |
| Gold |
Cendres
+ Metaux S.A. |
Conformant
(RJC) |
| Gold |
Chimet
S.p.A. |
Conformant
(LBMA, RMAP) |
| Gold |
Chugai
Mining |
Conformant
(RMAP) |
| Gold |
Daye
Non-Ferrous Metals Mining Ltd. |
Conformant
(LBMA) |
| Gold |
Dowa |
Conformant
(RMAP) |
| Gold |
DSC
(Do Sung Corporation) |
Conformant
(RMAP) |
| Gold |
Eco-System
Recycling Co., Ltd. East Plant |
Conformant
(RMAP) |
| Gold |
Eco-System
Recycling Co., Ltd. North Plant |
Conformant
(RMAP) |
| Gold |
Eco-System
Recycling Co., Ltd. West Plant |
Conformant
(RMAP) |
| Gold |
Coimpa
Industrial LTDA |
Conformant
(RMAP) |
| Gold |
GG
Refinery Ltd. |
Active
(RMAP) |
| Gold |
GGC
Gujrat Gold Centre Pvt. Ltd. |
Active
(RMAP) |
| Gold |
Gold
by Gold Colombia |
Conformant
(RMAP) |
| Gold |
Gold
Refinery of Zijin Mining Group Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Great
Wall Precious Metals Co., Ltd. of CBPM |
Conformant
(LBMA) |
| Gold |
Heimerle
+ Meule GmbH |
Conformant
(LBMA, RMAP) |
| Gold |
Heraeus
Germany GmbH Co. KG |
Conformant
(LBMA, RMAP) |
| Gold |
Heraeus
Metals Hong Kong Ltd. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Inner
Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Ishifuku
Metal Industry Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Istanbul
Gold Refinery |
Conformant
(LBMA, RMAP) |
| Gold |
Italpreziosi |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Japan
Mint |
Conformant
(LBMA, RMAP) |
| Gold |
Jiangxi
Copper Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
JX
Nippon Mining & Metals Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Kazzinc |
Conformant
(LBMA, RMAP) |
| Gold |
Kennecott
Utah Copper LLC |
Conformant
(LBMA, RMAP) |
| Gold |
KGHM
Polska Miedz Spolka Akcyjna |
Conformant
(LBMA, RMAP) |
| Gold |
Kojima
Chemicals Co., Ltd. |
Conformant
(RMAP) |
| Gold |
Korea
Zinc Co., Ltd. |
Conformant
(RMAP) |
| Gold |
L'Orfebre
S.A. |
Conformant
(RMAP) |
| Gold |
LS
MnM Inc. |
Conformant
(LBMA, RMAP) |
| Gold |
LT
Metal Ltd. |
Conformant
(RMAP) |
| Gold |
Materion |
Conformant
(RMAP) |
| Metal |
Smelter
Name |
2023
Status |
| Gold |
Matsuda
Sangyo Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Metal
Concentrators SA (Pty) Ltd. |
Conformant
(RJC, RMAP) |
| Gold |
Metalor
Technologies (Hong Kong) Ltd. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Metalor
Technologies (Singapore) Pte., Ltd. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Metalor
Technologies (Suzhou) Ltd. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Metalor
Technologies S.A. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Metalor
USA Refining Corporation |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Metalurgica
Met-Mex Penoles S.A. De C.V. |
Conformant
(LBMA, RMAP) |
| Gold |
Mitsubishi
Materials Corporation |
Conformant
(LBMA, RMAP) |
| Gold |
Mitsui
Mining and Smelting Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
MKS
PAMP SA |
Conformant
(LBMA, RMAP) |
| Gold |
MMTC-PAMP
India Pvt., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Nadir
Metal Rafineri San. Ve Tic. A.S. |
Conformant
(LBMA, RMAP) |
| Gold |
Navoi
Mining and Metallurgical Combinat |
Conformant
(LBMA, RMAP) |
| Gold |
NH
Recytech Company |
Recycled
Scrap |
| Gold |
Nihon
Material Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Ogussa
Osterreichische Gold- und Silber-Scheideanstalt GmbH |
Conformant
(RJC, RMAP) |
| Gold |
Ohura
Precious Metal Industry Co., Ltd. |
Conformant
(RMAP) |
| Gold |
Planta
Recuperadora de Metales SpA |
Conformant
(RMAP) |
| Gold |
PT
Aneka Tambang (Persero) Tbk |
Conformant
(LBMA, RMAP) |
| Gold |
PX
Precinox S.A. |
Conformant
(LBMA, RMAP) |
| Gold |
Rand
Refinery (Pty) Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
REMONDIS
PMR B.V. |
Conformant
(LBMA, RMAP) |
| Gold |
Royal
Canadian Mint |
Conformant
(LBMA, RMAP) |
| Gold |
SAAMP |
Conformant
(RJC) |
| Gold |
Safimet
S.p.A |
Conformant
(RJC) |
| Gold |
SAFINA
A.S. |
Conformant
(RMAP) |
| Gold |
Samduck
Precious Metals |
Recycled
Scrap |
| Gold |
SEMPSA
Joyeria Plateria S.A. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
Shandong
Gold Smelting Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Shandong
Zhaojin Gold & Silver Refinery Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Sichuan
Tianze Precious Metals Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
Singway
Technology Co., Ltd. |
Recycled
Scrap |
| Gold |
Solar
Applied Materials Technology Corp. |
Conformant
(LBMA, RMAP) |
| Gold |
Sumitomo
Metal Mining Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
SungEel
HiMetal Co., Ltd. |
Conformant
(RMAP) |
| Gold |
T.C.A
S.p.A |
Conformant
(LBMA, RMAP) |
| Gold |
Tanaka
Kikinzoku Kogyo K.K. |
Conformant
(LBMA, RMAP) |
| Gold |
Tokuriki
Honten Co., Ltd. |
Conformant
(LBMA, RMAP) |
| Gold |
TOO
Tau-Ken-Altyn |
Conformant
(LBMA, RMAP) |
| Gold |
Torecom |
Conformant
(RMAP) |
| Gold |
Umicore
Precious Metals Thailand |
Recycled
Scrap |
| Gold |
Umicore
S.A. Business Unit Precious Metals Refining |
Conformant
(LBMA) |
| Metal |
Smelter
Name |
2023
Status |
| Gold |
United
Precious Metal Refining, Inc. |
Conformant
(RMAP) |
| Gold |
Valcambi
S.A. |
Conformant
(LBMA, RJC, RMAP) |
| Gold |
WEEEREFINING |
Conformant
(RMAP) |
| Gold |
Western
Australian Mint (T/a The Perth Mint) |
Conformant
(LBMA, RMAP) |
| Gold |
WIELAND
Edelmetalle GmbH |
Conformant
(RJC, RMAP) |
| Gold |
Yamakin
Co., Ltd. |
Conformant
(RMAP) |
| Gold |
Yokohama
Metal Co., Ltd. |
Conformant
(RMAP) |
| Gold |
Zhongyuan
Gold Smelter of Zhongjin Gold Corporation |
Conformant
(LBMA, RMAP) |
Appendix B
Reasonable Country
of Origin Inquiry for Conflict Minerals associated with the SORs listed in Appendix A
(Based on RMI, LBMA,
RJC, and TI-CMC accreditation source data)
| IBM
RCOI Data 2023 |
Country
of Origin
(Alphabetical List) -
From RMAP, LBMA,
RJC, Ti-CMC due
diligence |
Material
Origin |
Country
of Origin
(Alphabetical List) -
From RMAP, LBMA,
RJC, Ti-CMC due
diligence |
Material
Origin |
| Algeria |
Recycled
Scrap |
Brazil |
Mined
Ores & Recycled Scrap |
| Andorra |
Recycled
Scrap |
Bulgaria |
Recycled
Scrap |
| Antigua
and Barbuda |
Recycled
Scrap |
Burkina
Faso |
Mined
Ores & Recycled Scrap |
| Argentina |
Mined
Ores & Recycled Scrap |
Burundi |
Mined
Ores |
| Australia |
Mined
Ores & Recycled Scrap |
Cambodia |
Mined
Ores |
| Austria |
Mined
Ores & Recycled Scrap |
Cameroon |
Recycled
Scrap |
| Azerbaijan |
Mined
Ores |
Canada |
Mined
Ores & Recycled Scrap |
| Bahamas |
Recycled
Scrap |
Cayman
Islands |
Recycled
Scrap |
| Bangladesh |
Recycled
Scrap |
Chile |
Mined
Ores & Recycled Scrap |
| Barbados |
Recycled
Scrap |
China |
Mined
Ores & Recycled Scrap |
| Belarus |
Recycled
Scrap |
Chinese
Taipei (Taiwan) |
Recycled
Scrap |
| Belgium |
Recycled
Scrap |
Colombia |
Mined
Ores & Recycled Scrap |
| Benin |
Mined
Ores & Recycled Scrap |
Congo,
Democratic Republic of the |
Mined
Ores & Recycled Scrap |
| Bolivia
(Plurinational State of) |
Mined
Ores & Recycled Scrap |
Costa
Rica |
Recycled
Scrap |
| Bosnia
and Herzegovina |
Recycled
Scrap |
Côte
d'Ivoire (Ivory Coast) |
Mined
Ores & Recycled Scrap |
| Botswana |
Mined
Ores |
Croatia |
Recycled
Scrap |
| IBM
RCOI Data 2023 |
Country
of Origin
(Alphabetical List) -
From RMAP, LBMA,
RJC, Ti-CMC due
diligence |
Material
Origin |
Country
of Origin
(Alphabetical List) -
From RMAP, LBMA,
RJC, Ti-CMC due
diligence |
Material
Origin |
| Curacao |
Recycled
Scrap |
Kuwait |
Recycled
Scrap |
| Cyprus |
Recycled
Scrap |
Kyrgyzstan |
Mined
Ores & Recycled Scrap |
| Czech
Republic |
Recycled
Scrap |
Lao
People's Democratic Republic |
Mined
Ores |
| Denmark |
Recycled
Scrap |
Latvia |
Recycled
Scrap |
| Dominican
Republic |
Mined
Ores & Recycled Scrap |
Lebanon |
Recycled
Scrap |
| Ecuador |
Mined
Ores & Recycled Scrap |
Liberia |
Mined
Ores |
| Egypt |
Mined
Ores & Recycled Scrap |
Liechtenstein |
Recycled
Scrap |
| El
Salvador |
Recycled
Scrap |
Lithuania |
Recycled
Scrap |
| Estonia |
Recycled
Scrap |
Luxembourg |
Recycled
Scrap |
| Ethiopia |
Mined
Ores |
Macau |
Recycled
Scrap |
| Fiji |
Mined
Ores |
Madagascar |
Mined
Ores |
| Finland |
Mined
Ores & Recycled Scrap |
Malaysia |
Mined
Ores & Recycled Scrap |
| France
and French Guiana |
Mined
Ores & Recycled Scrap |
Mali |
Mined
Ores & Recycled Scrap |
| Georgia |
Mined
Ores & Recycled Scrap |
Malta |
Recycled
Scrap |
| Germany |
Recycled
Scrap |
Mauritania |
Mined
Ores |
| Ghana |
Mined
Ores & Recycled Scrap |
Mauritius |
Recycled
Scrap |
| Greece |
Recycled
Scrap |
Mexico |
Mined
Ores & Recycled Scrap |
| Grenada |
Recycled
Scrap |
Monaco |
Recycled
Scrap |
| Guatemala |
Mined
Ores & Recycled Scrap |
Mongolia |
Mined
Ores |
| Guinea |
Mined
Ores |
Morocco |
Mined
Ores & Recycled Scrap |
| Guyana |
Mined
Ores |
Mozambique |
Mined
Ores |
| Honduras |
Mined
Ores & Recycled Scrap |
Myanmar |
Mined
Ores |
| Hong
Kong |
Recycled
Scrap |
Namibia |
Mined
Ores & Recycled Scrap |
| Hungary |
Recycled
Scrap |
Netherlands |
Recycled
Scrap |
| Iceland |
Recycled
Scrap |
New
Zealand |
Mined
Ores & Recycled Scrap |
| India |
Recycled
Scrap |
Nicaragua |
Mined
Ores |
| Indonesia |
Mined
Ores & Recycled Scrap |
Republic
of the Niger |
Mined
Ores & Recycled Scrap |
| Ireland |
Recycled
Scrap |
Nigeria |
Mined
Ores & Recycled Scrap |
| Israel |
Recycled
Scrap |
Norway |
Recycled
Scrap |
| Italy |
Recycled
Scrap |
Oman |
Mined
Ores & Recycled Scrap |
| Jamaica |
Recycled
Scrap |
Pakistan |
Recycled
Scrap |
| Japan |
Mined
Ores & Recycled Scrap |
Panama |
Mined
Ores & Recycled Scrap |
| Jordan |
Recycled
Scrap |
Papua
New Guinea |
Mined
Ores |
| Kazakhstan |
Mined
Ores & Recycled Scrap |
Peru |
Mined
Ores & Recycled Scrap |
| Kenya |
Mined
Ores & Recycled Scrap |
Philippines |
Mined
Ores & Recycled Scrap |
| Korea,
Republic of |
Mined
Ores & Recycled Scrap |
Poland |
Recycled
Scrap |
| IBM
RCOI Data 2023 |
Country
of Origin
(Alphabetical List) -
From RMAP, LBMA,
RJC, Ti-CMC due
diligence |
Material
Origin |
Country
of Origin
(Alphabetical List) -
From RMAP, LBMA,
RJC, Ti-CMC due
diligence |
Material
Origin |
| Portugal |
Recycled
Scrap |
Sweden |
Mined
Ores & Recycled Scrap |
| Puerto
Rico |
Recycled
Scrap |
Switzerland |
Recycled
Scrap |
| Romania |
Recycled
Scrap |
Tajikistan |
Recycled
Scrap |
| Russian
Federation* |
Mined
Ores & Recycled Scrap |
Tanzania |
Mined
Ores & Recycled Scrap |
| Rwanda |
Mined
Ores |
Thailand |
Mined
Ores & Recycled Scrap |
| Saint
Kitts and Nevis |
Recycled
Scrap |
Trinidad
and Tobago |
Recycled
Scrap |
| Saudi
Arabia |
Mined
Ores & Recycled Scrap |
Tunisia |
Recycled
Scrap |
| Senegal |
Mined
Ores & Recycled Scrap |
Turkey |
Mined
Ores & Recycled Scrap |
| Serbia |
Mined
Ores & Recycled Scrap |
Turks
and Caicos |
Recycled
Scrap |
| Sierra
Leone |
Mined
Ores |
Uganda |
Mined
Ores |
| Singapore |
Recycled
Scrap |
Ukraine |
Recycled
Scrap |
| Sint
Maarten |
Recycled
Scrap |
United
Arab Emirates |
Recycled
Scrap |
| Slovakia |
Recycled
Scrap |
United
Kingdom of Great Britain and Northern Ireland |
Mined
Ores & Recycled Scrap |
| Slovenia |
Recycled
Scrap |
United
States of America |
Mined
Ores & Recycled Scrap |
| South
Africa |
Mined
Ores & Recycled Scrap |
Uruguay |
Recycled
Scrap |
| Spain |
Mined
Ores & Recycled Scrap |
Uzbekistan |
Mined
Ores & Recycled Scrap |
| St
Vincent and Grenadines |
Recycled
Scrap |
Vietnam |
Mined
Ores |
| Sudan |
Mined
Ores |
Zambia |
Mined
Ores |
| Suriname |
Mined
Ores |
Zimbabwe |
Mined
Ores |
RCOI: Reasonable
Country of Origin Inquiry. Data provided in aggregated fashion by the third parties noted.
* In 2022, IBM
carried out an orderly wind-down of its business in Russia. During 2023, RMI and other accreditation source data continued identifying
the Russian Federation as a country of origin for 3TG. IBM has no affirmative knowledge that minerals from this country are incorporated
into finished products furnished to IBM. To the extent that minerals from this country were used, they would have been substantially
transformed outside of the United States in a third country by a non-U.S. person before being incorporated into production of certain
products that IBM manufactures or contracts to manufacture.
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