UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
HASBRO, INC.
(Exact name of registrant as specified in its charter)
| Rhode Island | 1-6682 | 05-0155090 | ||||||||||||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) | ||||||||||||
1027 Newport Avenue, Pawtucket, Rhode Island | 02861 | ||||||||||
(Address of principal executive offices) | (Zip code) | ||||||||||
Deborah Thomas, Executive Vice President and Chief Financial Officer, (401) 431-8697 | |||||||||||
(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, 2020 to December 31, 2020.
Introduction:
Hasbro, Inc. (“Hasbro,” the “Company,” “we,” “us,” or “our”) (NASDAQ: HAS) is a global play and entertainment company committed to Creating the World's Best Play and Entertainment Experiences. From toys, games and consumer products to television, movies, digital gaming, live action, music, and virtual reality experiences, Hasbro connects to global audiences by bringing to life great innovations, stories and brands across established and inventive platforms. Hasbro’s iconic brands include NERF, MAGIC: THE GATHERING, MY LITTLE PONY, TRANSFORMERS, PLAY-DOH, MONOPOLY, BABY ALIVE, POWER RANGERS, PEPPA PIG and PJ MASKS, as well as premier partner brands. Through its global entertainment studio, eOne, Hasbro is building its brands globally through great storytelling and content on all screens.
Hasbro is committed to making the world a better place for all children, fans and families through corporate social responsibility and philanthropy. Hasbro ranked among the 2020 100 Best Corporate Citizens by 3BL Media, has been named one of the World’s Most Ethical Companies® by Ethisphere Institute for the past ten years, and one of America’s Most JUST Companies for the past four years.
Our commitment to CSR reflects our desire to build a safer, more sustainable and inclusive company and world for all. We believe that through our deep commitment to Corporate Social Responsibility, we are bringing meaning and purpose to play. We are headquartered in Pawtucket, Rhode Island and, as of December 27, 2020, had approximately 6,800 employees worldwide, approximately 2,800 of whom are located in the United States.
At Hasbro, we believe that every day is a chance to do better. We strive to always act responsibly, and in doing so we find smarter ways of doing business. While our CSR commitments address many areas, we focus on four key priorities: environmental responsibility, product and content safety, human rights and ethical sourcing, and culture and human capital management, including diversity and inclusion. These commitments include working with our vendors to ensure that they operate responsibly and adopt best practices.
Some of Hasbro’s products include electronics and other components that contain tin, tungsten, tantalum and/or gold (referred to collectively hereafter as "Conflict Minerals" or "3TG"). Accordingly, we are subject to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act" or the "Act") and Rule 13p-1 under the Securities Exchange Act of 1934 (the "Conflict Minerals Rule"). eOne products were not in scope for the calendar year 2020 conflict minerals report due to the fact that intellectual property related to those products was licensed to third-parties who manufactured and sold the products. Beginning in 2021, certain eOne products will be produced by Hasbro’s supply chain organization.
Hasbro has a Conflict Minerals Policy that is communicated to all of our suppliers and which expresses our commitment to (i) sourcing components and materials from companies that share our values around human rights, ethics and corporate social responsibility, (ii) utilizing due diligence practices to identify 3TG and their sources in our supply chain and (iii) requiring that any 3TG included in our products are sourced from smelters and refiners (“Smelters”) that have been identified as conformant by the Responsible Minerals Assurance Process (RMAP) in order to mitigate the possibility that such 3TG are being used to support armed conflict in the Democratic Republic of the Congo and the adjoining countries (Covered Countries 1).
________________________
1 The Democratic Republic of Congo and its adjoining countries (Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Republic of Tanzania, Uganda and Zambia).
Our policy does not preclude suppliers from sourcing certified conflict-free minerals from the DRC or the adjoining countries. To the extent that we identify non-conformance with our policy, we send corrective action letters to the contract manufacturers requiring them to: a) contact the identified Smelters and require that they participate in the conflict minerals audit program; and b) require the contract manufacturer to remove unaudited Smelters from their supply chain for Hasbro products if the contract manufacturer is unable to persuade the Smelter to undergo an RMAP audit. Hasbro's Conflicts Minerals Policy can be found at the following internet address https://csr.hasbro.com/en-us/news/policy?id=csr_conflict_minerals_policy.
Section 1 - Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
Hasbro has determined that during the 2020 calendar year, we contracted to manufacture certain products containing 3TG necessary to the functionality or production of these products.
We conducted a Reasonable Country of Origin Inquiry ("RCOI") to assess whether the necessary 3TG in our products originated from the Covered Countries.
During 2020, all of our products were manufactured in third-party vendor or owned facilities (referred to hereafter as “contract manufacturers”). The largest single concentration of our contract manufacturers are located in the People’s Republic of China. We also use contract manufacturers located in other countries, such as India, Vietnam and Mexico, and the United States. Over the past several years, we have continued to diversify our supply chain to reduce reliance on manufacturing facilities in China.
Under our RCOI methodology, Hasbro undertook an applicability assessment to identify the products containing 3TG and the relevant contract manufacturers of those products. To identify the applicable contract manufacturers, Hasbro filtered out contract manufacturers supplying Hasbro with products identified not to contain 3TG after a thorough review. Following the applicability assessment, Hasbro sent surveys to all of our contract manufacturers globally that were identified as producing products that could contain 3TG.
Utilizing the methodology above and based on the information provided by our business units and gathered from our sourcing and technology systems and records, we identified a total of 30 relevant contract manufacturers that are producing products that could contain 3TG. All 30 of these contract manufacturers were surveyed using a third-party technology platform that employs the Conflict Minerals Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI), an organization founded by members of the Responsible Business Alliance (RBA) and Global e-Sustainability Initiative (GeSI).
Many of Hasbro's contract manufacturers are not subject to the Dodd-Frank Act or the Conflict Minerals Rule adopted thereunder and initially were unfamiliar with the due diligence and reporting requirements. For several years now, Hasbro has conducted training with all of our contract manufacturers identified as using 3TG, to educate these manufacturers on the requirements of the Act related to conflict minerals and to help them understand the importance of conducting due diligence on the sourcing of the 3TG used in Hasbro products. We developed, produced and conducted a training program that provided a summary of the law related to conflict minerals, our obligations under the Act and the Conflict Minerals Rule, as well as the role of our contract manufacturers in assisting us to comply with the requirements of the Conflict Minerals Rule. Due to Covid-19 restrictions, in 2020, Hasbro conducted virtual training sessions with our contract manufacturers, as opposed to in-person sessions. The training materials and presentations were provided in the local language and were enhanced to clarify due diligence and legal reporting requirements. Hasbro maintains an e-mail box and gives contact information for specified point people
within Hasbro’s sourcing organization and manufacturers can also contact the third-party technology provider about the Conflict Minerals Rule or seek assistance in completing the Conflict Minerals survey using the CMRT.
Hasbro sent surveys to the 30 contract manufacturers that were identified as potentially producing products for us containing 3TG in 2020. Similar to previous years, we surveyed all contract manufacturers identified in our applicability assessment through a thorough product/vendor screening process.
Relevant contract manufacturers received a survey for products they supplied to us. Of the 30 contract manufacturers surveyed, 100% responded to the surveys.
In our survey results, 16 of our 30 contract manufacturers indicated potential sourcing of 3TG from the Covered Countries. The other 14 contract manufacturers indicated in their survey responses that they were either not sourcing any 3TG from the Covered Countries or the products supplied to Hasbro did not contain 3TG. Of the 16 contract manufacturers that identified potential sourcing of 3TG from the Covered Countries, each such contract manufacturer provided a list of Smelters from which they were sourcing 3TG. A complete list of Smelters reported by our contract manufacturers is attached as an exhibit to our Conflict Minerals Report.
As is discussed in the attached Conflicts Minerals Report, we are currently unable to determine the specific mine location or the country of origin for all of the 3TG used in our products. Based on our RCOI, we believe some of the 3TG used in our products originated in the Covered Countries. However, at this point we cannot make a determination about the source of all the 3TG in our products or components. Accordingly, we conducted due diligence on the source and chain of custody of the necessary conflict minerals we believe may be contained in our products as described in the Conflict Minerals Report included as Exhibit 1.01.
Item 1.02 Exhibit
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1"), this Specialized Disclosure Form ("Form SD") and the associated Conflict Minerals Report are posted to a publicly available Internet site at the following internet address: http://csr.hasbro.com/has20-conflict-minerals-report.php.
Section 2 - Exhibits
Signature
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
Hasbro, Inc.
(Registrant)
By: /s/ Deborah Thomas | May 24, 2021 | |||||||
Deborah Thomas | (Date) | |||||||
Executive Vice President and Chief Financial Officer (Signature and Title) | ||||||||
Exhibit 1.01 – Conflict Minerals Report (CMR)
Conflict Minerals Report of Hasbro, Inc.
Section 1: Introduction
This is the Conflict Minerals Report of Hasbro, Inc. (herein referred to as "Hasbro," the Company," "we," "us," or "our ") for calendar year 2020 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1"). Certain terms in this report are defined in Rule 13p-1 and Form SD and the reader is invited to refer to those sources for complete definitions of these terms.
Hasbro marketed products based on owned, controlled and licensed intellectual properties within our brand architecture under the following four brand categories during 2020, each of which may include products containing 3TG: (1) Franchise Brands; (2) Partner Brands; (3) Hasbro Gaming; and (4) Emerging Brands. Some examples of where 3TG can be found in our products are shown below. In all cases, those metals are inaccessible to the consumer because they are located within internal components. eOne products were not in scope for the calendar year 2020 conflict minerals report due to the fact that intellectual property related to those products was licensed to third-parties who manufactured and sold the products. Beginning in 2021, certain eOne products will be produced by Hasbro’s supply chain organization.
Franchise Brands: Franchise Brands are comprised of Hasbro’s most significant owned or controlled brands, which we believe can deliver significant revenues, profits and growth across the Hasbro brand blueprint over the long-term. Our seven Franchise Brands are MAGIC: THE GATHERING, NERF, PLAY-DOH, MONOPOLY, TRANSFORMERS, BABY ALIVE and MY LITTLE PONY. An example of 3TG used in Franchise Brands is the NERF Ultra One Motorized Blaster which contains tin in the solder and pins in the Printed Circuit Board Assembly. Gold is also found in the plating for the Printed Circuit Board Assembly.
Partner Brands: Partner Brands includes those brands we license from other parties for which we develop toy and game products. Significant Partner Brands include MARVEL, including SPIDER-MAN and THE AVENGERS, LUCASFILMS' STAR WARS, DISNEY PRINCESS and DISNEY FROZEN, DISNEY’S DESCENDANTS, BEYBLADE, DREAMWORKS’ TROLLS and SESAME STREET. Partner brands MARVEL, STAR WARS, DISNEY’S DESCENDANTS, DISNEY PRINCESS and DISNEY FROZEN are all owned by The Walt Disney Company (“Disney”).
Hasbro Gaming: Gaming includes the Company’s face-to-face, trading card and digital game experiences played as board, off-the-board, digital, card, electronic, trading card and role-playing games. Hasbro gaming includes brands such as DUNGEONS & DRAGONS, JENGA, THE GAME OF LIFE, OPERATION, SCRABBLE, TRIVIAL PURSUIT, TWISTER and many others. An example of 3TG used in Hasbro Gaming is the Operation Blitz which includes Tin in the electronic wire.
Emerging Brands: Emerging Brands includes those brands we own or control which have not yet grown to the significance of a franchise brand, many of which we believe could be potential franchise brands. We also launch new brands in this portfolio. Hasbro Emerging Brands include brands such as FURREAL FRIENDS, PEPPA PIG, POWER RANGERS, PLAYSKOOL, PJ MASKS, GI JOE, and LITTLEST PET SHOP. An example of 3TG used in Emerging Brands is the PLAYSKOOL Play Favorites Lullaby Gloworm Toy which includes Tin in the solder and plating in the Printed Circuit Board Assembly. Gold is found in the electronic wire and Tungsten in the Integrated Circuit in the Printed Circuit Board Assembly.
Section 2: Due diligence framework
Hasbro designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition ("OECD Framework").
Section 3: Due diligence measures undertaken
Hasbro's due diligence efforts for 2020 continued to include the following steps:
Establish company management systems:
•Communicated our conflict minerals policy to all contract manufacturers, ensuring they were made aware that Hasbro’s policy does not preclude them from sourcing conflict free minerals from the Covered Countries, but is intended to encourage responsible sourcing. To summarize our conflict minerals policy, Hasbro requires suppliers to fully respond to our information requests, provide a list of smelter or refiner (“Smelters”) names, source from conflict free Smelters as determined by a third-party audit program such as the Responsible Minerals Initiative (RMI), London Bullion Market Association, Responsible Jewellery Council or any other recognized equivalent, and to initiate contact with non-audited Smelters to persuade such Smelters to undergo a Responsible Minerals Assurance Process (“RMAP”) audit of their due diligence practices.
•Operated under our internal governance structure created in 2013, which is overseen by members of our senior management team and includes a cross functional conflict minerals steering committee and working group comprised of representatives from the Global Government and Regulatory Affairs, Corporate Social Responsibility, Global Sourcing, Legal, Finance and Internal Audit functions of Hasbro. The Senior Director, Global Ethical Sourcing oversees the program and its implementation.
•Provided surveyed contract manufacturers with training presentations that include an overview of the conflict minerals rule under the Dodd-Frank Act, as well as trainings on how to complete the survey. The communication and training specified that contract manufacturers should not ban sourcing 3TG from the Covered Countries in order to maintain support of socio-economic regional development, so long as the contract manufacturers are utilizing only conformant Smelters. In addition, Hasbro directly reviewed a sample of contract manufacturer conflict minerals policies to ensure that they included the minimum policy requirements and did not ban minerals from the Covered Countries.
•Engaged with contract manufacturers that Hasbro believed were most likely to supply products containing 3TG, informing them that Hasbro is subject to Section 1502 of the Dodd Frank Act and that their cooperation in responding to the survey is required.
•Conducted supply chain surveys using a third-party platform based on the RMI Conflict Minerals Reporting Template (CMRT). Surveys were sent to the 30 contract manufacturers of products identified during our applicability assessment as potentially containing 3TG.
•Engaged as necessary with unaudited Smelters by sending a letter requiring that they undergo the RMI audit process in order to demonstrate compliance with the Hasbro Conflict Minerals policy.
•Maintained our grievance mechanism to enable the reporting of grievances via the Hasbro Conflict Minerals email box.
•Maintained our policy of retaining conflict minerals program documentation for 5 years.
Identify and assess risks in the supply chain
•Contract manufacturers surveyed were asked to identify Smelters that process conflict minerals contained in our products, including country of origin of the 3TG, based on the RMI CMRT. Hasbro required vendors to provide information on Hasbro products only (“product-level declarations”).
•Every survey was entered into our third-party technology platform and then reviewed by the technology platform, a third-party consultant and, where deemed necessary, Hasbro personnel.
•Non-responsive contract manufacturers and survey responses that we believed to be incomplete or inconsistent were identified and resolved to achieve 100% complete/consistent responses.
•Reasons for follow-up with contract manufacturers included, but were not limited to, that the contract manufacturer did not provide a complete or accurate Smelter list, did not receive complete 3TG sourcing information from all of its relevant suppliers, the response was not specific to Hasbro products only, or inconsistencies were identified in the answers contract manufacturers provided within the survey.
•Smelters identified by contract manufacturers surveyed by Hasbro were compared against lists maintained by the technology platform provider, the current Smelter lists from the RMAP and our external consultant. This was done to confirm the validity of Smelters and the plausibility of the countries of origin.
•Reviewed contract manufacturers policies and procedures directly, in addition to conducting Responsible Business Alliance (RBA) audits, in order to ensure they meet minimum requirements.
•Conducted remote visits to a contract manufacturers and Smelters in order to learn more about effective implementation and challenges to responsible mineral use.
Design and implement a strategy to respond to identified risks
•Executive members of the steering committee met three times during the 2020 conflict minerals due diligence period to review the results of the applicability assessment, survey review and associated risks.
•Contract manufacturers that did not respond to Hasbro's initial survey request were sent escalation letters directing that they provide the information requested. In cases where additional follow-up was needed, emails were sent by the technology platform, by our third-party consultant and contact was made by Hasbro management.
•Contract manufacturers that provided survey responses identifying Smelters not on the RMI’s active or compliant Smelter lists were sent corrective action letters, as necessary, noting that Hasbro requires them to source 3TG from RMAP-compliant Smelters. In the corrective action letters, Hasbro requested that contract manufacturers that source from non-RMAP-compliant Smelters verify if the Smelters are in the Hasbro supply chain. If the Smelter was not in the supply chain, they were required to update their response and remove the Smelter from their list. If the Smelter was in the supply chain, contract manufacturers were instructed to contact the respective Smelters and require them to participate in a recognized conflict minerals audit program and provide documentation of this to Hasbro. If they were not able to obtain Smelter cooperation, the contract manufacturers were reminded of the Hasbro conflict minerals sourcing policy and requirement to remove the unaudited Smelter from their supply chain for Hasbro Products.
Carry out independent third-party audit of Smelter due diligence practices
Hasbro is a downstream consumer of 3TG and is many steps removed from Smelters that provide minerals and ores. Hasbro does not purchase raw minerals or ores and does not directly purchase 3TG. Therefore, Hasbro does not perform or direct audits of Smelters within the supply chain. Rather, as a member of the RMI we rely on and support the audits carried out by that organization. Those audits confirm that Smelters conform to the OECD Due Diligence Guidance for their own sourcing practices by reviewing the Smelter sourcing/conflict minerals policy and verifying implementation.
Report annually on supply chain due diligence
This report and the associated Form SD are available online at the following internet address: http://csr.hasbro.com/has20-conflict-minerals-report.php.
Section 4: Determination
Based on the due diligence described above for 2020, Hasbro was able to determine that some 3TG used by our contract manufacturers for Hasbro products originated in the Covered Countries and/or did not originate from recycled or scrap sources.
As a downstream consumer of 3TG, Hasbro must rely on its contract manufacturers to gather information about Smelters in the supply chain. Hasbro received responses from 100% of the contract manufacturers it surveyed (the survey included all 30 contract manufacturers identified as potentially incorporating 3TG into products supplied to Hasbro). The relevant contract manufacturers declared a total of 240 unique Smelter names as the source of 3TG in Hasbro products. Of the 240 declared Smelters, 237 (99%) were designated as conformant or active under the RMAP for 2020. However, we are unable to link specific Smelters to our applicable products. There were two tungsten smelters and one tin smelter that were non-conformant. Based on our third-party data collection system, the two tungsten smelters did not source from the Covered Countries and based on the RMI data, ceased operations during 2020. We were unable to determine the country of origin for the minerals processed by the one tin smelter that was non-conformant, and it has been removed from our supplier’s supply chain. As of the end of the reporting year all smelters identified as operational in our supply chain were RMAP conformant or active.
The results of our due diligence of the 3TG used in our in-scope products are noted below:
| 2021 Smelter | Tin | Tungsten | Tantalum | Gold | Total | ||||||||||||
| Total number of Smelters | 52 | 43 | 37 | 108 | 240 | ||||||||||||
| Number (%) of Smelters listed as conformant by RMI | 51 (98%) | 41 (95%) | 37 (100%) | 108 (100%) | 237 (99%) | ||||||||||||
| Number (%) of Smelters not sourcing from Covered Countries (RMI) | 48 (92%) | 13 (30%) | 26 (70%) | 41 (38%) | 128 (53%) | ||||||||||||
Number (%) of Smelters that are conformant or not sourcing from the Covered Countries | 51 (98%) | 43 (100%) | 37 (100%) | 108 (100%) | 239 (99.6%) | ||||||||||||
Status of Identified Smelters
Set forth in Annex 1 is a list of the unique Smelter names disclosed to us by contract manufacturers broken down by metal. Based on the information provided by Hasbro’s contract manufacturers, from the RMAP and other sources, Hasbro believes that the countries of origin of the 3TG contained in some of our products might include Covered Countries, and may not originate from recycled or scrap sources, but we are not able to make that determination at this time for all products or sources. The aggregated list of Countries of Origin based on input from RMI and their Country of Origin list and the Smelters reported to us by our contract manufacturers is set forth in Annex 2.
The Hasbro sourcing model is designed to provide Hasbro flexibility to move production of products among contract manufacturers based on contract manufacturer capacities and product demand. Consequently, there may be instances where the same Hasbro branded product is manufactured by multiple contract manufacturers, which increases the complexity in linking a product with specific Smelters.
Section 5: Independent audit
Hasbro has determined that for 2020 an independent private sector audit is not required.
Section 6: Continuous Improvement efforts to mitigate risk
Hasbro took the following steps to improve our program overall, the number and quality of responses in the 2020 compliance period and to mitigate risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:
•Hasbro’s Senior Director of Ethical Sourcing and Human Rights issued a response request letter to all contract manufacturers for the 2020 reporting year survey.
•Achieved a 100% response rate from all applicable contract manufacturers and resolved 100% of inconsistent responses from contract manufacturers.
•Engaged with the one contract manufacturer to bring the one identified non-conformant tin smelter into conformance with the RMAP process or have them removed from the supply chain. The contract manufacture has informed Hasbro that the smelter has been removed from the supply chain. (As mentioned above, the other 2 non-conformant smelters are now not operational).
•Continued to use contract terms and conditions for new contracts requiring contract manufacturers to respond to inquiries regarding 3TG in a timely manner, such as through incorporation of conflict minerals requirements into Hasbro’s Vendor Manual, which is incorporated into Hasbro’s Master Agreements with contract manufacturers.
•Rather than relying on contract manufacturers to provide country of origin information, we undertook our own efforts to identify countries of origin using our third-party technology provider. Our external consultant conducted a further plausibility review to ensure that the identified countries have known 3TG ore mining operations or proven mineral reserves.
•Continued to work with contract manufacturers to help them understand the importance of this initiative to Hasbro and to encourage their participation in the conflict minerals survey through trainings for relevant contract manufacturers. Due to Covid-19 circumstances, Hasbro conducted virtual training sessions for all global in-scope vendors, as opposed to in-person sessions. We believe this resulted in improvements in identifying Smelters applicable to Hasbro.
In the next compliance period, Hasbro intends to take the following steps to further improve the number and quality of contract manufacturer responses and continue to mitigate the risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:
•Continue to use contract terms and conditions for new contracts requiring contract manufacturers to respond to inquiries regarding conflict minerals in a timely manner.
•Continue engaging with contract manufacturers, with the objective of maintaining a 100% response rate from all applicable contract manufacturers and obtaining complete lists.
•Continue to work with contract manufacturers to identify to the extent possible the source of 3TG used in Hasbro's products.
•Continue to build capabilities with active and new contract manufacturers by helping them understand the importance of this initiative to Hasbro and to encourage their participation through contract manufacturer trainings.
•Continue to require that any 3TG included in our products be sourced from Smelters that are identified as conflict free through the RMAP or an audit program with which RMAP has a mutual recognition agreement.
•Continue working with our contract manufacturers to better understand how individual sources of 3TG may apply to our individual product categories.
•As a result of becoming a full RBA member in October 2016, Hasbro will continue to utilize an annual RBA Validated Audit Process (VAP) or Customer Managed Audit (CMA) audit for 100% of our contract manufacturers, which includes verifying that a manufacturer has a documented, effective and communicated conflict minerals policy and management program.
•Continue to emphasize that Hasbro’s policy does not preclude contract manufacturers from sourcing conflict free minerals from the DRC and adjoining countries and communicate this policy provision to contract manufacturers.
Certain statements in this Conflict Minerals Report contain "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements include expectations concerning the Company's future actions to engage contract manufacturers, to identify to the extent possible the source of 3TG in its products and to take other actions regarding its product sourcing. The Company's actual actions or results may differ materially from those expected or anticipated in the forward-looking statements due to both known and unknown risks and uncertainties including, but not limited to, decisions to make changes in the Company’s continual improvement efforts and delays or difficulties in engaging contract manufacturers and identifying the source of 3TG contained in the Company’s products.
ANNEX 1
Identified Smelters
(of the 240 identified Smelters, 237 were RMAP active or conformant for 2020)
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Gold | 8853 S.p.A. | CID002763 | Italy | Conformant | ||||||||||
| Gold | Advanced Chemical Company | CID000015 | United States | Conformant | ||||||||||
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | Japan | Conformant | ||||||||||
| Gold | Al Etihad Gold Refinery DMCC | CID002560 | United Arab Emirates | Conformant | ||||||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | Germany | Conformant | ||||||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | Uzbekistan | Conformant | ||||||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 | Brazil | Conformant | ||||||||||
| Gold | Argor-Heraeus S.A. | CID000077 | Switzerland | Conformant | ||||||||||
| Gold | Asahi Pretec Corp. | CID000082 | Japan | Conformant | ||||||||||
| Gold | Asahi Refining Canada Ltd. | CID000924 | Canada | Conformant | ||||||||||
| Gold | Asahi Refining USA Inc. | CID000920 | United States | Conformant | ||||||||||
| Gold | Asaka Riken Co., Ltd. | CID000090 | Japan | Conformant | ||||||||||
| Gold | AU Traders and Refiners | CID002850 | South Africa | Conformant | ||||||||||
| Gold | Aurubis AG | CID000113 | Germany | Conformant | ||||||||||
| Gold | Bangalore Refinery | CID002863 | India | Conformant | ||||||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | Philippines | Conformant | ||||||||||
| Gold | Boliden AB | CID000157 | Sweden | Conformant | ||||||||||
| Gold | C. Hafner GmbH + Co. KG | CID000176 | Germany | Conformant | ||||||||||
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | Canada | Conformant | ||||||||||
| Gold | Cendres + Metaux S.A. | CID000189 | Switzerland | Conformant | ||||||||||
| Gold | Chimet S.p.A. | CID000233 | Italy | Conformant | ||||||||||
| Gold | Chugai Mining | CID000264 | Japan | Conformant | ||||||||||
| Gold | DODUCO Contacts and Refining GmbH | CID000362 | Germany | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Gold | Dowa | CID000401 | Japan | Conformant | ||||||||||
| Gold | DS PRETECH Co., Ltd. | CID003195 | Korea, Republic of | Conformant | ||||||||||
| Gold | DSC (Do Sung Corporation) | CID000359 | Korea, Republic of | Conformant | ||||||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 | Japan | Conformant | ||||||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 | Japan | Conformant | ||||||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 | Japan | Conformant | ||||||||||
| Gold | Emirates Gold DMCC | CID002561 | United Arab Emirates | Conformant | ||||||||||
| Gold | Geib Refining Corporation | CID002459 | United States | Conformant | ||||||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 | China | Conformant | ||||||||||
| Gold | Heimerle + Meule GmbH | CID000694 | Germany | Conformant | ||||||||||
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 | China | Conformant | ||||||||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 | Germany | Active | ||||||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | China | Conformant | ||||||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | Japan | Conformant | ||||||||||
| Gold | Istanbul Gold Refinery | CID000814 | Turkey | Conformant | ||||||||||
| Gold | Italpreziosi | CID002765 | Italy | Conformant | ||||||||||
| Gold | Japan Mint | CID000823 | Japan | Conformant | ||||||||||
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | China | Conformant | ||||||||||
| Gold | JSC Uralelectromed | CID000929 | Russian Federation | Conformant | ||||||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | Japan | Conformant | ||||||||||
| Gold | Kazzinc | CID000957 | Kazakhstan | Conformant | ||||||||||
| Gold | Kennecott Utah Copper LLC | CID000969 | United States | Conformant | ||||||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 | Poland | Conformant | ||||||||||
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | Japan | Conformant | ||||||||||
| Gold | Korea Zinc Co., Ltd. | CID002605 | Korea, Republic of | Conformant | ||||||||||
| Gold | Kyrgyzaltyn JSC | CID001029 | Kyrgyzstan | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Gold | L'Orfebre S.A. | CID002762 | Andorra | Conformant | ||||||||||
| Gold | LS-NIKKO Copper Inc. | CID001078 | Korea, Republic of | Conformant | ||||||||||
| Gold | LT Metal Ltd. | CID000689 | Korea, Republic of | Conformant | ||||||||||
| Gold | Marsam Metals | CID002606 | Brazil | Conformant | ||||||||||
| Gold | Materion | CID001113 | United States | Conformant | ||||||||||
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | Japan | Conformant | ||||||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | China | Conformant | ||||||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | Singapore | Conformant | ||||||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | China | Conformant | ||||||||||
| Gold | Metalor Technologies S.A. | CID001153 | Switzerland | Conformant | ||||||||||
| Gold | Metalor USA Refining Corporation | CID001157 | United States | Conformant | ||||||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 | Mexico | Conformant | ||||||||||
| Gold | Mitsubishi Materials Corporation | CID001188 | Japan | Conformant | ||||||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | Japan | Conformant | ||||||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | India | Conformant | ||||||||||
| Gold | Moscow Special Alloys Processing Plant | CID001204 | Russian Federation | Conformant | ||||||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 | Turkey | Conformant | ||||||||||
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | Uzbekistan | Conformant | ||||||||||
| Gold | Nihon Material Co., Ltd. | CID001259 | Japan | Conformant | ||||||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | Austria | Conformant | ||||||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | Japan | Conformant | ||||||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | Russian Federation | Conformant | ||||||||||
| Gold | OJSC Novosibirsk Refinery | CID000493 | Russian Federation | Conformant | ||||||||||
| Gold | PAMP S.A. | CID001352 | Switzerland | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Gold | Planta Recuperadora de Metales SpA | CID002919 | Chile | Conformant | ||||||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | Russian Federation | Conformant | ||||||||||
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | Indonesia | Conformant | ||||||||||
| Gold | PX Precinox S.A. | CID001498 | Switzerland | Conformant | ||||||||||
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | South Africa | Conformant | ||||||||||
| Gold | REMONDIS PMR B.V. | CID002582 | Netherlands | Conformant | ||||||||||
| Gold | Royal Canadian Mint | CID001534 | Canada | Conformant | ||||||||||
| Gold | SAAMP | CID002761 | France | Conformant | ||||||||||
| Gold | Safimet S.p.A | CID002973 | Italy | Conformant | ||||||||||
| Gold | SAFINA A.S. | CID002290 | Czech Republic | Conformant | ||||||||||
| Gold | Samduck Precious Metals | CID001555 | Korea, Republic of | Conformant | ||||||||||
| Gold | SAXONIA Edelmetalle GmbH | CID002777 | Germany | Conformant | ||||||||||
| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 | Spain | Conformant | ||||||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | China | Conformant | ||||||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | China | Conformant | ||||||||||
| Gold | Singway Technology Co., Ltd. | CID002516 | Taiwan | Conformant | ||||||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | Russian Federation | Conformant | ||||||||||
| Gold | Solar Applied Materials Technology Corp. | CID001761 | Taiwan | Conformant | ||||||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | Japan | Conformant | ||||||||||
| Gold | SungEel HiMetal Co., Ltd. | CID002918 | Korea, Republic of | Conformant | ||||||||||
| Gold | T.C.A S.p.A | CID002580 | Italy | Conformant | ||||||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | Japan | Conformant | ||||||||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | China | Conformant | ||||||||||
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | Japan | Conformant | ||||||||||
| Gold | TOO Tau-Ken-Altyn | CID002615 | Kazakhstan | Conformant | ||||||||||
| Gold | Torecom | CID001955 | Korea, Republic of | Conformant | ||||||||||
| Gold | Umicore Precious Metals Thailand | CID002314 | Thailand | Conformant | ||||||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | Belgium | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Gold | United Precious Metal Refining, Inc. | CID001993 | United States | Conformant | ||||||||||
| Gold | Valcambi S.A. | CID002003 | Switzerland | Conformant | ||||||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 | Australia | Conformant | ||||||||||
| Gold | WIELAND Edelmetalle GmbH | CID002778 | Germany | Conformant | ||||||||||
| Gold | Yamakin Co., Ltd. | CID002100 | Japan | Conformant | ||||||||||
| Gold | Yokohama Metal Co., Ltd. | CID002129 | Japan | Conformant | ||||||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | China | Conformant | ||||||||||
| Tantalum | Asaka Riken Co., Ltd. | CID000092 | Japan | Conformant | ||||||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | China | Conformant | ||||||||||
| Tantalum | D Block Metals, LLC | CID002504 | United States | Conformant | ||||||||||
| Tantalum | Exotech Inc. | CID000456 | United States | Conformant | ||||||||||
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | China | Conformant | ||||||||||
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | China | Conformant | ||||||||||
| Tantalum | Global Advanced Metals Aizu | CID002558 | Japan | Conformant | ||||||||||
| Tantalum | Global Advanced Metals Boyertown | CID002557 | United States | Conformant | ||||||||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | China | Conformant | ||||||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 | Germany | Conformant | ||||||||||
| Tantalum | H.C. Starck Inc. | CID002548 | United States | Conformant | ||||||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | China | Conformant | ||||||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | China | Conformant | ||||||||||
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | China | Conformant | ||||||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | China | Conformant | ||||||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | China | Conformant | ||||||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | China | Conformant | ||||||||||
| Tantalum | KEMET Blue Metals | CID002539 | Mexico | Conformant | ||||||||||
| Tantalum | LSM Brasil S.A. | CID001076 | Brazil | Conformant | ||||||||||
| Tantalum | Meta Materials | CID002847 | Macedonia, The Former Yugoslav Republic Of | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | India | Conformant | ||||||||||
| Tantalum | Mineracao Taboca S.A. | CID001175 | Brazil | Conformant | ||||||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 | Japan | Conformant | ||||||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | China | Conformant | ||||||||||
| Tantalum | NPM Silmet AS | CID001200 | Estonia | Conformant | ||||||||||
| Tantalum | QuantumClean | CID001508 | United States | Conformant | ||||||||||
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 | Brazil | Conformant | ||||||||||
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | Russian Federation | Conformant | ||||||||||
| Tantalum | Taki Chemical Co., Ltd. | CID001869 | Japan | Conformant | ||||||||||
| Tantalum | TANIOBIS Co., Ltd. | CID002544 | Thailand | Conformant | ||||||||||
| Tantalum | TANIOBIS GmbH | CID002545 | Germany | Conformant | ||||||||||
| Tantalum | TANIOBIS Japan Co., Ltd. | CID002549 | Japan | Conformant | ||||||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | CID002550 | Germany | Conformant | ||||||||||
| Tantalum | Telex Metals | CID001891 | United States | Conformant | ||||||||||
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | Kazakhstan | Conformant | ||||||||||
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. | CID002508 | China | Conformant | ||||||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | China | Conformant | ||||||||||
| Tin | Alpha | CID000292 | United States | Conformant | ||||||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | China | Conformant | ||||||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 | China | Conformant | ||||||||||
| Tin | China Tin Group Co., Ltd. | CID001070 | China | Conformant | ||||||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd.* | CID003356 | China | Not Conformant | ||||||||||
| Tin | Dowa | CID000402 | Japan | Conformant | ||||||||||
| Tin | EM Vinto | CID000438 | Bolivia | Conformant | ||||||||||
| Tin | Fenix Metals | CID000468 | Poland | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | China | Conformant | ||||||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | China | Conformant | ||||||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | China | Conformant | ||||||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | China | Conformant | ||||||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 | China | Conformant | ||||||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | China | Conformant | ||||||||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 | China | Conformant | ||||||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 | China | Conformant | ||||||||||
| Tin | Luna Smelter, Ltd. | CID003387 | Rwanda | Conformant | ||||||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 | China | Conformant | ||||||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | Brazil | Conformant | ||||||||||
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | Malaysia | Conformant | ||||||||||
| Tin | Melt Metais e Ligas S.A. | CID002500 | Brazil | Conformant | ||||||||||
| Tin | Metallic Resources, Inc. | CID001142 | United States | Conformant | ||||||||||
| Tin | Metallo Belgium N.V. | CID002773 | Belgium | Conformant | ||||||||||
| Tin | Metallo Spain S.L.U. | CID002774 | Spain | Conformant | ||||||||||
| Tin | Mineracao Taboca S.A. | CID001173 | Brazil | Conformant | ||||||||||
| Tin | Minsur | CID001182 | Peru | Conformant | ||||||||||
| Tin | Mitsubishi Materials Corporation | CID001191 | Japan | Conformant | ||||||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | Thailand | Conformant | ||||||||||
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | Philippines | Conformant | ||||||||||
| Tin | Operaciones Metalurgicas S.A. | CID001337 | Bolivia | Conformant | ||||||||||
| Tin | PT Artha Cipta Langgeng | CID001399 | Indonesia | Conformant | ||||||||||
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | Indonesia | Conformant | ||||||||||
| Tin | PT Babel Surya Alam Lestari | CID001406 | Indonesia | Conformant | ||||||||||
| Tin | PT Bangka Serumpun | CID003205 | Indonesia | Conformant | ||||||||||
| Tin | PT Menara Cipta Mulia | CID002835 | Indonesia | Conformant | ||||||||||
| Tin | PT Mitra Stania Prima | CID001453 | Indonesia | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Tin | PT Prima Timah Utama | CID001458 | Indonesia | Conformant | ||||||||||
| Tin | PT Rajawali Rimba Perkasa | CID003381 | Indonesia | Conformant | ||||||||||
| Tin | PT Rajehan Ariq | CID002593 | Indonesia | Conformant | ||||||||||
| Tin | PT Refined Bangka Tin | CID001460 | Indonesia | Conformant | ||||||||||
| Tin | PT Timah Tbk Kundur | CID001477 | Indonesia | Conformant | ||||||||||
| Tin | PT Timah Tbk Mentok | CID001482 | Indonesia | Conformant | ||||||||||
| Tin | Resind Industria e Comercio Ltda. | CID002706 | Brazil | Conformant | ||||||||||
| Tin | Rui Da Hung | CID001539 | Taiwan | Conformant | ||||||||||
| Tin | Soft Metais Ltda. | CID001758 | Brazil | Conformant | ||||||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | CID002834 | Viet Nam | Conformant | ||||||||||
| Tin | Thaisarco | CID001898 | Thailand | Conformant | ||||||||||
| Tin | Tin Technology & Refining | CID003325 | United States | Conformant | ||||||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 | Brazil | Conformant | ||||||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | China | Conformant | ||||||||||
| Tin | Yunnan Tin Company Limited | CID002180 | China | Conformant | ||||||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | China | Conformant | ||||||||||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 | Japan | Conformant | ||||||||||
| Tungsten | ACL Metais Eireli | CID002833 | Brazil | Conformant | ||||||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | Viet Nam | Conformant | ||||||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | China | Conformant | ||||||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | China | Conformant | ||||||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CID003401 | China | Conformant | ||||||||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd.** | CID000499 | China | Not Conformant | ||||||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 | China | Conformant | ||||||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | China | Conformant | ||||||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | China | Conformant | ||||||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | China | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Tungsten | Global Tungsten & Powders Corp. | CID000568 | United States | Conformant | ||||||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | China | Conformant | ||||||||||
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 | Germany | Conformant | ||||||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | China | Conformant | ||||||||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 | China | Conformant | ||||||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | China | Conformant | ||||||||||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CID003182 | China | Conformant | ||||||||||
| Tungsten | Hydrometallurg, JSC | CID002649 | Russian Federation | Conformant | ||||||||||
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | Japan | Conformant | ||||||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | China | Conformant | ||||||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | China | Conformant | ||||||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | China | Conformant | ||||||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | China | Conformant | ||||||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | China | Conformant | ||||||||||
| Tungsten | Kennametal Fallon | CID000966 | United States | Conformant | ||||||||||
| Tungsten | Kennametal Huntsville | CID000105 | United States | Conformant | ||||||||||
| Tungsten | KGETS CO., LTD. | CID003388 | Korea, Republic of | Conformant | ||||||||||
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 | Taiwan | Conformant | ||||||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | China | Conformant | ||||||||||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | CID002543 | Viet Nam | Conformant | ||||||||||
| Tungsten | Moliren Ltd. | CID002845 | Russian Federation | Conformant | ||||||||||
| Tungsten | Niagara Refining LLC | CID002589 | United States | Conformant | ||||||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | Philippines | Conformant | ||||||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | CID002542 | Germany | Conformant | ||||||||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | Viet Nam | Conformant | ||||||||||
| Metal | Official Smelter Name | RMI Smelter ID | Smelter Country | Conformance Status | ||||||||||
| Tungsten | Unecha Refractory Metals Plant | CID002724 | Russian Federation | Conformant | ||||||||||
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 | Austria | Conformant | ||||||||||
| Tungsten | Woltech Korea Co., Ltd. | CID002843 | Korea, Republic of | Conformant | ||||||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | China | Conformant | ||||||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | China | Conformant | ||||||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 | China | Conformant | ||||||||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.** | CID002095 | China | Not Conformant | ||||||||||
* Smelter removed from Hasbro Supply Chain.
** Smelter is no longer operational.
ANNEX 2
Countries of Origin of 3TG
| Country of Origin | ||||||||
| Argentina - G | Ghana - G | Philippines - G | ||||||
| Australia - 3TG | Guatemala - G | Portugal – Sn, W | ||||||
| Austria - W | Guinea - G | Puerto Rico - G | ||||||
| Azerbaijan - G | Guyana - G | Russian Federation – 3TG | ||||||
| Benin - G | Honduras - G | Rwanda – 3TG | ||||||
| Bolivia - 3TG | India - Ta | Saudi Arabia -G | ||||||
| Botswana - G | Indonesia – G, SN | Senegal - G | ||||||
| Brazil - 3TG | Ivory Coast - G | Serbia - G | ||||||
| Burkina Faso - G | Japan - G | Sierra Leone - G, Ta | ||||||
| Burundi - 3T | Kazakhstan - G,W | Slovakia - G | ||||||
| Canada - G | Kenya - G | Solomon Islands - G | ||||||
| Chile - G | Laos -G, Sn | South Africa - G | ||||||
| China – 3TG | Liberia - G | Spain - 3TG | ||||||
| Colombia -3TG | Madagascar - Ta | Suriname - G | ||||||
| Congo, Democratic Republic of the – 3TG | Malaysia – 3TG | Sweden - G | ||||||
| Costa Rica - G | Mali - G | Taiwan – Sn | ||||||
| Cuba - G | Mauritania - G | Tajikistan - G | ||||||
| Cyprus - G | Mexico - G, W | Tanzania - G | ||||||
| Dominican Republic - G | Mongolia – G, Sn, W | Thailand – 3T | ||||||
| Ecuador - G | Morocco - G | Turkey - G | ||||||
| Egypt - G | Mozambique - G, Ta | Uganda – 3TG | ||||||
| Eritrea - G | Myanmar (Burma) – Sn, W | United Kingdom – G, Sn, W | ||||||
| Ethiopia - G, Ta | Namibia -G, Ta | Uruguay - G | ||||||
| Fiji - G | New Zealand -G | USA – G, Sn, W | ||||||
| Finland - G | Nicaragua - G | Uzbekistan - W | ||||||
| France - Ta | Niger - G | Venezuela - Sn | ||||||
| French Guiana - G | Nigeria – 3T | Vietnam – Sn, W | ||||||
| Georgia - G | Papua New Guinea - G | Zambia - G | ||||||
| Germany - Ta | Peru – G, Sn, W | Zimbabwe – G, Ta, W | ||||||
| Key: | 3TG = Tantalum, Tin, Tungsten and Gold; 3T= Tantalum, Tin and Tungsten | ||||
| G = Gold; Ta= Tantalum; Sn= Tin; W=Tungsten | |||||