Document

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 1-668205-0155090
  (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.

[__] Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ______.









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 and making the world a better place for all children, fans and families. Hasbro delivers immersive brand experiences for global audiences through consumer products, including toys and games; gaming, led by the team at Wizards of the Coast, an award-winning developer of tabletop and digital games; and entertainment through Entertainment One (“eOne”), our independent studio.

Our iconic brands include MAGIC: THE GATHERING, NERF, PLAY-DOH, TRANSFORMERS, PEPPA PIG, MONOPOLY, MY LITTLE PONY, BABY ALIVE, DUNGEONS & DRAGONS, PJ MASKS and POWER RANGERS, as well as premier partner brands. For the past decade, we have been consistently recognized for our corporate citizenship, including being named one of the 100 Best Corporate Citizens by 3BL Media and one of the World’s Most Ethical Companies by Ethisphere Institute.

At Hasbro, we believe strong Environmental, Social and Governance (ESG) performance drives long-term value creation for all our stakeholders. Our ESG priorities include climate and sustainability, human rights and ethical sourcing, human capital management and culture, including Diversity, Equity & Inclusion (“DE&I”), and product and content safety.

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"). During fiscal year 2021, Hasbro began producing certain eOne toy products through Hasbro’s supply chain organization and accordingly, such products were included in the due diligence process and reporting this year. Other eOne product categories remain licensed to third-parties who manufactured and, therefore, sold the products and were not in scope of this year’s reporting.

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 Countries1 ).

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.

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).



Section 1 – Conflict Minerals Disclosures

Item 1.01 Conflict Minerals Disclosure and Report

Hasbro has determined that during the 2021 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 2021, all of our products were manufactured in third-party vendor or owned facilities (referred to hereafter as “contract manufacturers”). Many 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 27 relevant contract manufacturers that are producing products that could contain 3TG. All 27 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).

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 our products. We have developed, produced and conducted a training program that provides 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 2021, 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. Manufacturers can contact Hasbro via email to Hasbro’s designated sourcing organization and may 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 27 contract manufacturers that were identified as potentially producing products for us containing 3TG in 2021. 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 27 contract manufacturers surveyed, 100% responded to the surveys.




In our survey results, 5 of our 27 contract manufacturers indicated potential sourcing of 3TG from the Covered Countries. The other 22 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 5 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.

1 of the 27 contract manufacturers submitted incomplete data and as part of our due diligence process, we are engaging with this supplier to assist with completion of the data set.

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/has21-conflict-minerals-report.

Section 2 – Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable

Section 3 – Exhibits

Item 3.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.



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 25, 2022
Deborah Thomas
(Date)
Executive Vice President and Chief Financial Officer
(Signature and Title)

Document

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 2021 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 2021, 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. During fiscal year 2021, Hasbro began producing certain eOne toy products through Hasbro’s supply chain organization and accordingly, such products were included in the due diligence process and reporting this year. Other eOne product categories remain licensed to third-parties who manufactured and, therefore, sold the products and were not in scope of this year’s reporting.

Franchise Brands: In 2021, Franchise Brands were comprised of Hasbro’s flagship 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, TRANSFORMERS, MONOPOLY, BABY ALIVE and MY LITTLE PONY. An example of 3TG used in Franchise Brands is the NERF Mega Mastodon 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: In 2021, Partner Brands included those brands we licensed from other parties for which we developed toy and game products. Significant Partner Brands included MARVEL, including SPIDER-MAN and THE AVENGERS, LUCASFILMS' STAR WARS, DISNEY PRINCESS and DISNEY FROZEN, DISNEY’S DESCENDANTS, BEYBLADE 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: In 2021, Gaming included 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, DUEL MASTERS, JENGA, OPERATION, CONNECT 4, CLUE, THE GAME OF LIFE, TWISTER, TRIVIAL PURSUIT and many others. An example of 3TG used in Hasbro Gaming is the Operation Pet Scan which includes Tin in the electronic wire.

Emerging Brands: In 2021, Emerging Brands included 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. In 2021, Hasbro Emerging Brands included brands such as PEPPA PIG, FURREAL FRIENDS, PJ MASKS, POWER RANGERS, GI JOE, SUPER SOAKER, POTATO HEAD, PLAYSKOOL 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
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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 2021 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 established 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, ESG, Global Sourcing, Legal, Finance and Internal Audit functions of Hasbro. The Vice President of Global Sustainability and Human Rights 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 27 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.
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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. We worked with the non-responsive suppliers and have received responses from all of them. We are continuing to engage with one supplier to complete the data.

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 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 2021 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.
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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/has21-conflict-minerals-report.

Section 4: Determination
Based on the due diligence described above for 2021, 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 27 contract manufacturers identified as potentially incorporating 3TG into products supplied to Hasbro). The relevant contract manufacturers declared a total of 212 unique Smelter names as the source of 3TG in Hasbro products. Of the 212 declared Smelters, 98% were designated as conformant or active under the RMAP for 2021. However, we are unable to link specific Smelters to our applicable products. 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 SmelterTinTungstenTantalumGoldTotal
Total number of Smelters512826107212
Number (%) of Smelters listed as conformant by RMI49 (96%)28 (100%)26 (100%)105 (98%)208 (98%)
Number (%) of Smelters not sourcing from Covered Countries (RMI)48 (94%)3 (11%)14 (54%)14 (13%)79 (37%)
Number (%) of Smelters that are conformant or not sourcing from the Covered Countries
51 (100%)28 (100%)26 (100%)107 (100%)212 (100%)

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Status of Identified Smelters
https://cdn.kscope.io/89ca77c27fd532ecb12843409e2f615c-picture2a.jpg

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 2021 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 2021 compliance period and to mitigate risk that 3TG used in Hasbro products may finance or benefit armed groups in the Covered Countries:

Achieved a 100% response rate from all applicable contract manufacturers. Engaged with the five contract manufacturers to bring the four identified non-conformant Smelters into conformance with the RMAP process or have them removed from the supply chain. The contract manufacturers have informed Hasbro that the Smelters have been removed from the supply chain.

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
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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.
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ANNEX 1


 Identified Smelters
(Of the 212 identified Smelters, 208 were RMAP active or conformant for 2021)

MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
Gold8853 S.p.A.CID002763ItalyConformant
GoldAdvanced Chemical CompanyCID000015United StatesConformant
GoldAida Chemical Industries Co., Ltd.CID000019JapanConformant
GoldAl Etihad Gold Refinery DMCCCID002560United Arab EmiratesConformant
GoldAllgemeine Gold-und Silberscheideanstalt A.G.CID000035GermanyConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)CID000041UzbekistanConformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoCID000058BrazilConformant
GoldArgor-Heraeus S.A.CID000077SwitzerlandConformant
GoldAsahi Pretec Corp.CID000082JapanConformant
GoldAsahi Refining Canada Ltd.CID000924CanadaConformant
GoldAsahi Refining USA Inc.CID000920United StatesConformant
GoldAsaka Riken Co., Ltd.CID000090JapanConformant
GoldAurubis AGCID000113GermanyConformant
GoldBangalore RefineryCID002863IndiaConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)CID000128PhilippinesConformant
GoldBoliden ABCID000157SwedenConformant
GoldC. Hafner GmbH + Co. KGCID000176GermanyConformant
GoldCCR Refinery - Glencore Canada CorporationCID000185CanadaConformant
GoldCendres + Metaux S.A.CID000189SwitzerlandConformant
GoldChimet S.p.A.CID000233ItalyConformant
GoldChugai MiningCID000264JapanConformant
GoldDODUCO Contacts and Refining GmbHCID000362GermanyConformant
GoldDowaCID000401JapanConformant
GoldDSC (Do Sung Corporation)CID000359Korea, Republic ofConformant
GoldEco-System Recycling Co., Ltd. East PlantCID000425JapanConformant
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MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
GoldEco-System Recycling Co., Ltd. North PlantCID003424JapanConformant
GoldEco-System Recycling Co., Ltd. West PlantCID003425JapanConformant
GoldEmirates Gold DMCCCID002561United Arab EmiratesConformant
GoldGeib Refining CorporationCID002459United StatesConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.CID002243ChinaConformant
GoldHeimerle + Meule GmbHCID000694GermanyConformant
GoldHeraeus Metals Hong Kong Ltd.CID000707ChinaConformant
GoldHeraeus Precious Metals GmbH & Co. KGCID000711GermanyConformant
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CID000801ChinaConformant
GoldIshifuku Metal Industry Co., Ltd.CID000807JapanConformant
GoldIstanbul Gold RefineryCID000814TurkeyConformant
GoldItalpreziosiCID002765ItalyConformant
GoldJapan MintCID000823JapanConformant
GoldJiangxi Copper Co., Ltd.CID000855ChinaConformant
GoldJSC UralelectromedCID000929Russian FederationConformant
GoldJX Nippon Mining & Metals Co., Ltd.CID000937JapanConformant
GoldKazzincCID000957KazakhstanConformant
GoldKennecott Utah Copper LLCCID000969United StatesConformant
GoldKGHM Polska Miedz Spolka AkcyjnaCID002511PolandConformant
GoldKojima Chemicals Co., Ltd.CID000981JapanConformant
GoldKorea Zinc Co., Ltd.CID002605Korea, Republic ofConformant
GoldL'Orfebre S.A.CID002762AndorraConformant
GoldLS-NIKKO Copper Inc.CID001078Korea, Republic ofConformant
GoldLT Metal Ltd.CID000689Korea, Republic ofConformant
GoldMarsam MetalsCID002606BrazilConformant
GoldMaterionCID001113United StatesConformant
GoldMatsuda Sangyo Co., Ltd.CID001119JapanConformant
GoldMetalor Technologies (Hong Kong) Ltd.CID001149ChinaConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.CID001152SingaporeConformant
GoldMetalor Technologies (Suzhou) Ltd.CID001147ChinaConformant
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MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
GoldMetalor Technologies S.A.CID001153SwitzerlandConformant
GoldMetalor USA Refining CorporationCID001157United StatesConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.CID001161MexicoConformant
GoldMitsubishi Materials CorporationCID001188JapanConformant
GoldMitsui Mining and Smelting Co., Ltd.CID001193JapanConformant
GoldMMTC-PAMP India Pvt., Ltd.CID002509IndiaConformant
GoldMoscow Special Alloys Processing PlantCID001204Russian FederationConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.CID001220TurkeyConformant
GoldNavoi Mining and Metallurgical CombinatCID001236UzbekistanConformant
GoldNihon Material Co., Ltd.CID001259JapanConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHCID002779AustriaConformant
GoldOhura Precious Metal Industry Co., Ltd.CID001325JapanConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)CID001326Russian FederationConformant
GoldOJSC Novosibirsk RefineryCID000493Russian FederationConformant
GoldPAMP S.A.CID001352SwitzerlandConformant
GoldPlanta Recuperadora de Metales SpACID002919ChileConformant
GoldPrioksky Plant of Non-Ferrous MetalsCID001386Russian FederationConformant
GoldPT Aneka Tambang (Persero) TbkCID001397IndonesiaConformant
GoldPX Precinox S.A.CID001498SwitzerlandConformant
GoldRand Refinery (Pty) Ltd.CID001512South AfricaConformant
GoldREMONDIS PMR B.V.CID002582NetherlandsConformant
GoldRoyal Canadian MintCID001534CanadaConformant
GoldSAAMPCID002761FranceConformant
GoldSafimet S.p.ACID002973ItalyConformant
GoldSAFINA A.S.CID002290Czech RepublicConformant
GoldSamduck Precious MetalsCID001555Korea, Republic ofConformant
GoldSEMPSA Joyeria Plateria S.A.CID001585SpainConformant
GoldShandong Gold Smelting Co., Ltd.CID001916ChinaConformant
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CID001622ChinaConformant
GoldSichuan Tianze Precious Metals Co., Ltd.CID001736ChinaConformant
9



MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
GoldSingway Technology Co., Ltd.CID002516TaiwanConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsCID001756Russian FederationConformant
GoldSolar Applied Materials Technology Corp.CID001761TaiwanConformant
GoldSumitomo Metal Mining Co., Ltd.CID001798JapanConformant
GoldSungEel HiMetal Co., Ltd.CID002918Korea, Republic ofConformant
GoldT.C.A S.p.ACID002580ItalyConformant
GoldTanaka Kikinzoku Kogyo K.K.CID001875JapanConformant
GoldTokuriki Honten Co., Ltd.CID001938JapanConformant
GoldTOO Tau-Ken-AltynCID002615KazakhstanConformant
GoldTorecomCID001955Korea, Republic ofConformant
GoldUmicore Precious Metals ThailandCID002314ThailandConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningCID001980BelgiumConformant
GoldUnited Precious Metal Refining, Inc.CID001993United StatesConformant
GoldValcambi S.A.CID002003SwitzerlandConformant
GoldWestern Australian Mint (T/a The Perth Mint)CID002030AustraliaConformant
GoldWIELAND Edelmetalle GmbHCID002778GermanyConformant
GoldYamakin Co., Ltd.CID002100JapanConformant
GoldYokohama Metal Co., Ltd.CID002129JapanConformant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCID002224ChinaConformant
GoldSAXONIA Edelmetalle GmbHCID002777GermanyActive
GoldAU Traders and RefinersCID002850South AfricaNot Conformant
GoldKyrgyzaltyn JSC*CID001029KyrgyzstanNot Conformant
TantalumChangsha South Tantalum Niobium Co., Ltd.CID000211ChinaConformant
TantalumD Block Metals, LLCCID002504United StatesConformant
TantalumF&X Electro-Materials Ltd.CID000460ChinaConformant
TantalumFIR Metals & Resource Ltd.CID002505ChinaConformant
TantalumGlobal Advanced Metals AizuCID002558JapanConformant
TantalumGlobal Advanced Metals BoyertownCID002557United StatesConformant
TantalumH.C. Starck Hermsdorf GmbHCID002547GermanyConformant
10



MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
TantalumH.C. Starck Inc.CID002548United StatesConformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CID002492ChinaConformant
TantalumJiangxi Tuohong New Raw MaterialCID002842ChinaConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CID000914ChinaConformant
TantalumJiujiang Tanbre Co., Ltd.CID000917ChinaConformant
TantalumMetallurgical Products India Pvt., Ltd.CID001163IndiaConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.CID001277ChinaConformant
TantalumNPM Silmet ASCID001200EstoniaConformant
TantalumSolikamsk Magnesium Works OAOCID001769Russian FederationConformant
TantalumTaki Chemical Co., Ltd.CID001869JapanConformant
TantalumTANIOBIS Co., Ltd.CID002544ThailandConformant
TantalumTANIOBIS GmbHCID002545GermanyConformant
TantalumTANIOBIS Japan Co., Ltd.CID002549JapanConformant
TantalumTANIOBIS Smelting GmbH & Co. KGCID002550GermanyConformant
TantalumTelex MetalsCID001891United StatesConformant
TantalumUlba Metallurgical Plant JSCCID001969KazakhstanConformant
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCID000616ChinaConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CID001522ChinaConformant
TantalumExotech Inc.CID000456United StatesActive
TinAlphaCID000292United StatesConformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CID000228ChinaConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.CID003190ChinaConformant
TinChina Tin Group Co., Ltd.CID001070ChinaConformant
TinDowaCID000402JapanConformant
TinEM VintoCID000438BoliviaConformant
TinFenix MetalsCID000468PolandConformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CID000538ChinaConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CID001908ChinaConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.CID000555ChinaConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CID003116ChinaConformant
11



MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
TinHuiChang Hill Tin Industry Co., Ltd.CID002844ChinaConformant
TinJiangxi New Nanshan Technology Ltd.CID001231ChinaConformant
TinLuna Smelter, Ltd.CID003387RwandaConformant
TinMa'anshan Weitai Tin Co., Ltd.CID003379ChinaConformant
TinMagnu's Minerais Metais e Ligas Ltda.CID002468BrazilConformant
TinMalaysia Smelting Corporation (MSC)CID001105MalaysiaConformant
TinMetallic Resources, Inc.CID001142United StatesConformant
TinMetallo Belgium N.V.CID002773BelgiumConformant
TinMetallo Spain S.L.U.CID002774SpainConformant
TinMineracao Taboca S.A.CID001173BrazilConformant
TinMinsurCID001182PeruConformant
TinMitsubishi Materials CorporationCID001191JapanConformant
TinO.M. Manufacturing (Thailand) Co., Ltd.CID001314ThailandConformant
TinO.M. Manufacturing Philippines, Inc.CID002517PhilippinesConformant
TinOperaciones Metalurgicas S.A.CID001337BoliviaConformant
TinPT Artha Cipta LanggengCID001399IndonesiaConformant
TinPT ATD Makmur Mandiri JayaCID002503IndonesiaConformant
TinPT Babel Surya Alam LestariCID001406IndonesiaConformant
TinPT Bangka SerumpunCID003205IndonesiaConformant
TinPT Menara Cipta MuliaCID002835IndonesiaConformant
TinPT Mitra Stania PrimaCID001453IndonesiaConformant
TinPT Prima Timah UtamaCID001458IndonesiaConformant
TinPT Rajawali Rimba PerkasaCID003381IndonesiaConformant
TinPT Refined Bangka TinCID001460IndonesiaConformant
TinPT Stanindo Inti PerkasaCID001468IndonesiaConformant
TinPT Timah Tbk KundurCID001477IndonesiaConformant
TinPT Timah Tbk MentokCID001482IndonesiaConformant
TinPT Tinindo Inter NusaCID001490IndonesiaConformant
TinResind Industria e Comercio Ltda.CID002706BrazilConformant
TinRui Da HungCID001539TaiwanConformant
TinSoft Metais Ltda.CID001758BrazilConformant
TinThai Nguyen Mining and Metallurgy Co., Ltd.CID002834Viet NamConformant
TinThaisarcoCID001898ThailandConformant
TinTin Technology & RefiningCID003325United StatesConformant
12



MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
TinWhite Solder Metalurgia e Mineracao Ltda.CID002036BrazilConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CID002158ChinaConformant
TinYunnan Tin Company LimitedCID002180ChinaConformant
TinMelt Metais e Ligas S.A.CID002500BrazilActive
TinGejiu Kai Meng Industry and Trade LLCCID000942ChinaNot Conformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CID003397ChinaNot Conformant
TungstenA.L.M.T. TUNGSTEN Corp.CID000004JapanConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CID002513ChinaConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CID000258ChinaConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CID000875ChinaConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CID002315ChinaConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.CID002494ChinaConformant
TungstenGlobal Tungsten & Powders Corp.CID000568United StatesConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.CID000218ChinaConformant
TungstenH.C. Starck Tungsten GmbHCID002541GermanyConformant
TungstenHunan Chenzhou Mining Co., Ltd.CID000766ChinaConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CID000769ChinaConformant
TungstenHydrometallurg, JSCCID002649Russian FederationConformant
TungstenJapan New Metals Co., Ltd.CID000825JapanConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CID002551ChinaConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CID002321ChinaConformant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CID002318ChinaConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CID002317ChinaConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CID002316ChinaConformant
TungstenKennametal FallonCID000966United StatesConformant
TungstenKennametal HuntsvilleCID000105United StatesConformant
TungstenKGETS CO., LTD.CID003388Korea, Republic ofConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.CID002319ChinaConformant
13



MetalOfficial Smelter NameRMI Smelter IDSmelter CountryConformance Status
TungstenMasan High-Tech MaterialsCID002543Viet NamConformant
TungstenNiagara Refining LLCCID002589United StatesConformant
TungstenTANIOBIS Smelting GmbH & Co. KGCID002542GermanyConformant
TungstenWolfram Bergbau und Hutten AGCID002044AustriaConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.CID002320ChinaConformant
TungstenXiamen Tungsten Co., Ltd.CID002082ChinaConformant
*As of May 4th, this refiner is now conformant.


14



ANNEX 2

Countries of Origin of 3TG

Country of Origin
Argentina GGuinea GPeru G, Sn, W
Armenia GGuyana GPhilippines G, W
Australia 3TGHonduras GPortugal Sn, W
Austria WIndia TaRussian Federation 3TG
Azerbaijan GIndonesia G, SnRwanda* 3TG
Benin GIvory Coast GSaudi Arabia G
Bolivia 3TGJapan GSenegal G
Botswana GKazakhstan GSierra Leone G, Ta
Brazil 3TGKenya GSlovakia G
Burkina Faso GKyrgyzstan WSouth Africa G
Burundi* 3TLaos G, SnSouth Korea G, Sn
Canada GLiberia GSpain 3TG
Chile GMadagascar TaSudan G
China 3TGMalaysia 3TSuriname G
Colombia 3TGMali GSwaziland G
Congo, Democratic Republic of the* 3TGMauritania GSweden G
Cuba GMexico GTaiwan Sn
Dominican Republic GMongolia GTanzania* G
Ecuador GMorocco GThailand 3TG
Egypt GMozambique Ta,Turkey G
Eritrea GMyanmar 3TUganda* 3TG
Ethiopia G, TaNamibia G,TaUnited Kingdom of Great Britain and Northern Ireland Sn, W
Fiji GNew Zealand GUnited States of America 3TG
Finland GNicaragua GUzbekistan G, W
France TaNiger GVenezuela Sn
French Guiana GNigeria 3TVietnam Sn, W
Germany G, Ta, SnOman GZambia* G
Ghana GPanama GZimbabwe Ta, W
Guatemala GPapua New Guinea G

Key:3TG = Tantalum, Tin, Tungsten and Gold; 3T= Tantalum, Tin and Tungsten
G = Gold; Ta= Tantalum; Sn= Tin; W=Tungsten
15