SD

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

Form SD

SPECIALIZED DISCLOSURE REPORT

 

 

RH

(Exact name of the registrant as specified in charter)

 

 

 

DELAWARE   001-35720   45-3052669

(State or other jurisdiction of

incorporation or organization)

 

(Commission

File Number)

 

(IRS Employer

Identification No.)

 

15 Koch Road, Suite K

Corte Madera, CA

  94925
(Address of principal executive offices)   (Zip code)

Jack Preston

(415) 924-1005

(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:

 

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.

 

 

 


Section 1 — Conflict Minerals Disclosure

 

Item 1.01

Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Specialized Disclosure Report on Form SD of RH (the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2018 to December 31, 2018 (the “reporting period”).

The Company determined that during the reporting period, RH contracted to manufacture products as to which conflict minerals are necessary to the functionality or production of such products. As a result, the Company has conducted a good faith reasonable country of origin inquiry to determine whether the necessary conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or came from recycled or scrap sources. A description of our reasonable country of origin inquiry process, the result of the inquiry, and the determination we reached as a result of this inquiry process is included in our Conflict Minerals Report attached as Exhibit 1.01 to this Form SD.

A copy of the Conflict Minerals Report filed for the calendar year ended December 31, 2017 is publicly available electronically on the Investor Relations section of the Company’s website at ir.rh.com, by clicking on “SEC Filings.”

 

Item 1.02

Exhibit

The Conflict Minerals Report for the calendar year ended December 31, 2018 is filed as Exhibit 1.01 hereto.

Section 2 — Exhibits

 

Item 2.01

Exhibits

 

Exhibit 1.01    RH Conflict Minerals Report, as required by Items 1.01 and 1.02 of Form SD.


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

  RH
Dated: May 31, 2019   By:  

/s/ Jack Preston

  Name:   Jack Preston
  Title:   Chief Financial Officer
EX-1.01

Exhibit 1.01

Conflict Minerals Report of RH in Accordance with Rule 13p-1 under the Securities and Exchange Act of 1934

I. Introduction

 

  1.

Overview of our Conflict Minerals Report

This Conflict Minerals Report of RH (the “Company,” “us,” “we”) is prepared in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2018 to December 31, 2018 (the “reporting period”). RH is inclusive of its wholly-owned subsidiary Restoration Hardware, Inc. and its subsidiaries, including, but not limited to, the subsidiary Waterworks Operating Co., LLC, operating under the name “Waterworks.” The information provided in this Conflict Minerals Report on behalf of RH is inclusive of Waterworks, its products and supply chain.

The Rule requires issuers that manufacture or contract to manufacture products that contain conflict minerals that are necessary to the functionality or production of those products to, among other things, disclose annually whether any of those conflict minerals originated in the Covered Countries and if so, to submit a report to the Securities and Exchange Commission (the “SEC”) that includes a description of the measures they took to exercise due diligence on the conflict minerals’ source and chain of custody. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are limited to tantalum, tin and tungsten (the “conflict minerals”). The “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

 

  2.

Overview of our Supply Chain, Verification Process and Conflict Minerals Policy

During the reporting period, RH did not own or operate any manufacturing facilities that manufacture products that contain conflict minerals that are necessary to the functionality or production of those products. Instead, RH contracted and had relationships with third-party suppliers who manufacture products for RH that contain conflict minerals that are necessary to the functionality or production of those products. These products that the Company “contracts to manufacture,” as such term is referred to by the Rule, are herein referred to as the “Subject Products.” The Subject Products are manufactured for the Company through such suppliers’ own factories or factories with which such suppliers have commercial relationships. The Company must therefore rely on its third-party suppliers to provide information regarding the existence of conflict minerals in the Subject Products and their origin.

The Company relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from the smelters or refiners who may provide those minerals to companies in our supply chain. The Company is many steps removed from the mining of conflict minerals. The Company does not purchase raw or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries. The statements herein are based on the activities performed to date, in good faith, by the Company and on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions in the information provided by suppliers or smelters, ongoing identification of smelters in our supply chain, and incomplete information from industry or other third-party sources, among other factors.

We maintain a Conflict Minerals Policy that is incorporated into our Vendor’s Operation Manual (the “Vendor Manual”), which our suppliers are able to access via a secure website.

II. Description of Products Covered by this Conflict Minerals Report

RH offers merchandise assortments across a growing number of categories, including furniture, lighting, textiles, bathware, décor, outdoor and garden, and children’s furnishings. The Subject Products included products sold by the Company in the following categories: furniture, bathware, plumbing fixtures, lighting fixtures, kitchen and bath hardware, décor, outdoor and garden, and children’s furnishings.

III. Reasonable Country of Origin Inquiry

In accordance with the Rule, we conducted in good faith a reasonable country of origin inquiry (the “RCOI”) that was reasonably designed to determine whether any of the necessary conflict minerals in the Subject Products originated in the Covered Countries or were from recycled or scrap sources.

 

1


To conduct our RCOI, we used a conflict minerals reporting template developed by the Responsible Minerals Initiative (“RMI”) (formerly Conflict Free Sourcing Initiative (“CFSI”)), an initiative founded by members of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI). We requested this information from our direct suppliers who manufacture our Subject Products.

Based on our RCOI, we have reason to believe that some of the necessary conflict minerals used in our Subject Products originated in the Covered Countries and may not have been from recycled or scrap sources. Accordingly, we conducted due diligence to determine the source and chain of custody of these conflict minerals.

IV. Due Diligence Process

We have designed our diligence efforts to generally conform to the Organization for Economic Cooperation and Development’s (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the “OECD Guidance”).

The OECD Guidance identifies five due diligence steps: (i) Establish Strong Company Management Systems; (ii) Identify and Assess Risks in the Supply Chain; (iii) Design and Implement a Strategy to Respond to Identified Risks; (iv) Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence; and (v) Report Annually on Supply Chain Due Diligence.

The due diligence steps that we executed included the following:

 

Step

  

OECD Guidance
Steps

  

Due diligence activities performed by RH

1   

Establish Strong

Company

Management

Systems

  

Maintain Conflict

Minerals Policy

      We maintained a Conflict Minerals Policy that is published online, in our Vendor Manual.
     

Maintained Conflict

Minerals

Compliance Team

      We maintained an internal conflict minerals team composed of a representative from the legal department and a representative from our vendor compliance team (the “Conflict Minerals Compliance Team”). The team was structured to ensure our annual conflict minerals due diligence was executed.
                 

Our Conflict Minerals Compliance Team periodically

reported on its due diligence activities to the legal department and the Vendor
Compliance and Product Compliance teams.

      Internal Engagement       We educated and continue educating relevant employees on our conflict minerals program and reporting obligations.
     

Supplier

Engagement

     

We provided our direct suppliers information on conflict

minerals and our disclosure requirements.

2   

Identify and

Assess Risks in

the Supply Chain

  

Identified

Products in Scope

      Our Conflict Minerals Compliance Team conducted a review of the products contracted to be manufactured during the reporting period to identify suppliers that manufacture product categories and Subject Products that may contain conflict minerals.

 

2


     

Inquired about

Due Diligence

Measures

Performed by

Direct Suppliers

      We used the responses from our direct suppliers to the RMI reporting template to review their due diligence activities, including whether they had adopted a conflict minerals policy, required their own suppliers to source from processing facilities validated by an independent audit firm, and implemented a review process that includes corrective action management.
                  As deemed appropriate by us, we followed up by email or phone with the
suppliers who did not respond to our request to complete the RMI reporting
template, or who submitted incomplete responses or responses that we
determined may have contained errors or inaccuracies.
                 

We employed a conflict minerals data management tool that tracks
communications sent to direct suppliers

and consolidates suppliers responses to the RMI template for analysis and
reporting.

     

Identified

Smelters

      We collected a list of smelters/processors that are in our supply chain by utilizing the RMI reporting template via a web-based platform. We determined if the processing facilities adhere to responsible sourcing practices by reconciling that list to the list of facilities designated by the RMI Responsible Minerals Assurance Program (“RMAP”) as RMAP Conformant Smelters & Refiners and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit. We have provided lists of smelters/processors that are reported in our supply chain in Appendix A.
3   

Design and

Implement a

Strategy to

Respond to

Identified Risks

  

Internal

Reporting System

     

Our Conflict Minerals Compliance Team periodically

reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams.

     

Maintained Conflict

Minerals Policy

      We maintained a Conflict Minerals Policy that is published online, in our Vendor Manual.
     

Verified Smelters

      As part of our risk mitigation process, we determined if the processing facilities identified in our supply chain adhere to responsible sourcing practices by reconciling the list of smelters collected from our direct suppliers to the list of smelter facilities that have been verified as complying with the RMAP and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit.
4   

Carry out

Independent

Third-Party

Audit of

Smelter/Refiner’s

Due Diligence

         We relied on the RMI’s published lists to verify the RMAP compliance status of smelters/processors that are reported in our supply chain.
5   

Report Annually

on Supply Chain

Due Diligence

        

This Conflict Minerals Report is filed with the SEC and

publicly available on our website at ir.rh.com, by clicking on “SEC Filings.”

 

3


V. Review of Due Diligence Results

 

  1.

Facilities Used to Process Conflict Minerals in Subject Products

Based on our due diligence process and the information received from our direct suppliers, we have identified, in Appendix A, facilities that may have been used to process conflict minerals used in the Subject Products.

 

  2.

Country of Origin of Conflict Minerals in Subject Products

Based on the information provided by our direct suppliers, we have reason to believe that some of the products RH sold during the reporting year contain necessary conflict minerals that originated from the Covered Countries. Eighteen of our direct suppliers indicated that products supplied to RH contained intentionally added conflict minerals necessary to the function and/or production of the product. Of these eighteen direct suppliers: nine indicated that the products they sold to RH contained necessary conflict minerals that did not originate in the Covered Countries; four indicated that the products they sold to RH contained necessary conflict minerals originating in the Covered Countries (and one such supplier is required to file an annual conflict minerals disclosure with the SEC); and five did not know the country of origin of the necessary conflict minerals in their products, including if conflict minerals in finished products originated in the Covered Countries. Four suppliers within this group also reported only using conflict minerals from 100% recycled or scrap sources. In addition, 9% of our direct suppliers did not respond to our survey. Accordingly, notwithstanding our due diligence efforts, we were unable to determine the origin of a portion of conflict minerals contained in certain of the Subject Products.

 

  3.

Efforts to Identify the Mine or Location of Origin of the Conflict Minerals

Our reasonable country-of-origin inquiry and due diligence process described above represent our efforts to identify the mine or location of origin for the conflict minerals contained in the Subject Products for this reporting period.

VI. Steps To Be Taken To Mitigate Risk

RH intends to continue to require our suppliers to comply with our Conflict Minerals Policy and to keep it posted online in our Vendor Manual for all suppliers to access. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of conflict minerals will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. We expect that our direct suppliers will comply with our Conflict Minerals Policy and (i) provide appropriate information and conduct necessary due diligence to facilitate our compliance with the Rule, (ii) implement and communicate to their relevant personnel and suppliers policies that are consistent with the Policy, (iii) put in place procedures and contractual provisions for the traceability of conflict minerals, working with their suppliers as applicable, (iv) use reasonable efforts to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and (v) adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with our Conflict Minerals Policy.

In addition to the due diligence steps that we took during the reporting period, which we intend to continue for 2019 as applicable, we intend to communicate to new suppliers our sourcing expectations, including by disseminating our Conflict Minerals Policy to them.

VII. Independent Private Sector Audit

Not required for the reporting period.

Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements within the meaning of the federal securities laws including statements related to our business, products and conflict mineral efforts, including steps we intend to take in the future to mitigate the risk that the conflict minerals used in the Subject Products benefit the armed groups on the Covered Countries, our ability to monitor the progress of our suppliers or that our suppliers would comply with our Conflict Mineral Policy and our requests for timely and accurate information, our suppliers’ ability to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and the effectiveness of any of our risk management strategies to identify risks in the supply chain consistent with our Conflict Minerals Policy. You can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. These

 

4


statements may include words such as “anticipate,” “estimate,” “expect,” “project,” “plan,” “intend,” “believe,” “may,” “will,” “should,” “likely” and other words and terms of similar meaning in connection with any discussion of the timing or nature of future events. We cannot assure you that future developments affecting us will be those that we have anticipated. Important risks and uncertainties that may cause these forward-looking statements to differ materially from our expectations include, among others: failure to carry out our plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers; lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities); internal and external resource constraints; political developments in the Covered Countries and regulatory developments in the United States, as well as those risks and uncertainties disclosed under the sections entitled “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in RH Form 10-K filed with the SEC on March 29, 2019, and similar disclosures in subsequent reports filed with the SEC, which are available on our investor relations website at ir.restorationhardware.com and on the SEC website at www.sec.gov. Any forward-looking statement made by us in this Conflict Minerals Report speaks only as of the date on which we make it. We undertake no obligation to publicly update any forward-looking statement, whether as a result of new information, future developments or otherwise, except as may be required by any applicable securities laws.

 

5


Appendix A

Processing Facilities

Table 1. RMAP-conformant processing facilities as listed by RMI as of May 21, 2019

Processing facilities and their locations reported in our supply chain that are reported by RMI as conformant with the RMAP.

 

Mineral        Facility ID    Processing Facility Name    Country

Tin

  

CID001105

   Malaysia Smelting Corporation (MSC)   

Malaysia

Tin

  

CID001182

   Minsur   

Peru

Tin

  

CID001399

   PT Artha Cipta Langgeng   

Indonesia

Tin

  

CID001458

   PT Prima Timah Utama   

Indonesia

Tin

  

CID001477

   PT Tambang Timah Kundur   

Indonesia

Tin

  

CID001482

   PT Timah Mentok(Persero), Tbk   

Indonesia

Tin

  

CID001490

   PT Tinindo Inter Nusa   

Indonesia

Tin

  

CID002158

   Yunnan Chengfeng Non-Ferrous Metals Co.   

China

Tin

  

CID002180

   Yunnan Tin Company, Ltd.—   

China

Tin

  

CID000292

   Alpha   

United States

Tin

  

CID002703

   An Vinh Joint Stock Mineral Processing Company   

Vietnam

Tin

  

CID000228

   Chenzhou Yunxiang Mining and Metallurgy   

China

Tin

  

CID003190

   Chifeng Dajingzi Tin Industry Co.   

China

Tin

  

CID001070

   China Tin Group Co., Ltd.   

China

Tin

  

CID002570

   CV Ayi Jaya   

Indonesia

Tin

  

CID002592

   CV Dua Sekawan   

Indonesia

Tin

  

CID000306

   CV Gita Pesona   

Indonesia

Tin

  

CID002593

   CV Tiga Sekawan   

Indonesia

Tin

  

CID000315

   CV United Smelting   

Indonesia

Tin

  

CID002455

   CV Venus Inti Perkasa   

Indonesia

Tin

  

CID000402

   Dowa   

Japan

Tin

  

CID002572

   Electro-Mechanical Facility of the Cap Bang Minerals   

Vietnam

Tin

  

CID000438

   EM Vinto   

Bolivia

Tin

  

CID000448

   Estanho de Rondonia S.A.   

Brazil

Tin

  

CID000468

   Fenix Metals   

Poland

Tin

  

CID002848

   Gejiu Fengming Metallurgy Chemical Plant   

China

Tin

  

CID000942

   Gejiu Kai Meng Industry and Trade LLC   

China

Tin

  

CID000538

   Gejiu Non Ferrous Metal Processing Co. Ltd   

China

Tin

  

CID001908

   Gejiu Yunxin Nonferrous Electrolysis   

China

Tin

  

CID000555

   Gejiu Zi-Li Mining and Metallurgy Co   

China

Tin

  

CID003116

   Guangdong Hanhe Non-Ferrous Metal Co.   

China

Tin

  

CID002849

   Guanyang Guida Nonferrous Metal Smelting Plant   

China

Tin

  

CID002844

   HuiChang Hill Tin Industry Co., Ltd.   

China

Tin

  

CID000760

   HuiChang Jinshunda Tin Co.   

China

Tin

  

CID000244

   Jiangxi Ketai Advanced Material Co., Ltd.   

China

Tin

  

CID001231

   Jiangxi Nanshan   

China

Tin

  

CID002468

   Magnu’s Minerais Metais e Ligas LTDA   

Brazil

Tin

  

CID001105

   Malaysia Smelting Corporation (MSC)   

Malaysia

 

6


Tin

  

CID002500

  

Melt Metais e Ligas LTDA

  

Brazil

Tin

  

CID001142

  

Metallic Resources, Inc.

  

United States

Tin

  

CID002774

  

Metallo- S.L.U.

  

Spain

Tin

  

CID002773

  

Metallo-Chimique N.V.

  

Belgium

Tin

  

CID001173

  

Mineracao Taboca S.A.

  

Brazil

Tin

  

CID001182

  

Minsur

  

Peru

Tin

  

CID001191

  

Mistubishi Materials Corporation

  

Japan

Tin

  

CID002858

  

Modeltech Sdn Bhd

  

Malaysia

Tin

  

CID002573

  

Nghe Tinh Non-Ferrous Metals Joint Stock Company

  

Vietnam

Tin

  

CID001314

  

O.M. Manufacturing (Thailand) Co., Ltd.

  

Thailand

Tin

  

CID002517

  

O.M. Manufacturing Philippines, Inc.

  

Phillipines

Tin

  

CID001337

  

OMSA

  

Bolivia

Tin

  

CID003208

  

Pongpipat Company Limited

  

Myanmar

Tin

  

CID000309

  

PT Aries Kencana Sejahtera

  

Indonesia

Tin

  

CID001399

  

PT Artha Cipta Langgeng

  

Indonesia

Tin

  

CID002503

  

PT ATD Makmur Mandiri Jaya

  

Indonesia

Tin

  

CID001402

  

PT Babel Inti Perkasa

  

Indonesia

Tin

  

CID002776

  

PT Bangka Prima Tin

  

Indonesia

Tin

  

CID003205

  

PT Bangka Serumpun

  

Indonesia

Tin

  

CID001419

  

PT Bangka Tin Industry

  

Indonesia

Tin

  

CID001421

  

PT Belitung Industri Sejahtera

  

Indonesia

Tin

  

CID001428

  

PT Bukit Timah

  

Indonesia

Tin

  

CID001434

  

PT DS Jaya Abadi

  

Indonesia

Tin

  

CID002530

  

PT Inti Stania Prima

  

Indonesia

Tin

  

CID001448

  

PT Karimun Mining

  

Indonesia

Tin

  

CID002829

  

PT Kijang Jaya Mandiri

  

Indonesia

Tin

  

CID002870

  

PT Lautan Harmonis Sejahtera

  

Indonesia

Tin

  

CID002835

  

PT Menara Cipta Mulia

  

Indonesia

Tin

  

CID001453

  

PT Mitra Stania Prima

  

Indonesia

Tin

  

CID001457

  

PT Panca Mega Persada

  

Indonesia

Tin

  

CID000313

  

PT Premium Tin

  

Indonesia

Tin

  

CID001458

  

PT Prima Timah Utama

  

Indonesia

Tin

  

CID001460

  

PT REFINED BANGKA TIN

  

Indonesia

Tin

  

CID001463

  

PT Sariwiguna Binasentosa

  

Indonesia

Tin

  

CID001468

  

PT Stanindo Inti Perkasa

  

Indonesia

Tin

  

CID002816

  

PT Sukses Inti Makmur

  

Indonesia

Tin

  

CID001471

  

PT Sumber Jaya Indah

  

Indonesia

Tin

  

CID001477

  

PT Tambang Timah Kundur

  

Indonesia

Tin

  

CID001482

  

PT Timah Mentok(Persero), Tbk

  

Indonesia

Tin

  

CID001490

  

PT Tinindo Inter Nusa—Indonesia

  

Indonesia

Tin

  

CID001493

  

PT Tommy Utama

  

Indonesia

Tin

  

CID002706

  

Resind Industria e ComÈrcio Ltda.

  

Brazil

Tin

  

CID001539

  

Rui Da Hung

  

Taiwan

Tin

  

CID001758

  

Soft Metais, Ltda.

  

Brazil

Tin

  

CID002756

  

Super Ligas

  

Brazil

 

7


Tin

  

CID001898    

  

Thaisarco

  

Thailand

Tin

  

CID002574

  

Tuyen Quang Non-Ferrous Metals Joint Stock Company

  

Vietnam

Tin

  

CID002036

  

White Solder Metalurgia e MineraÁo Ltda.

  

Brazil

Tin

  

CID002158

  

Yunnan Chengfeng Non-Ferrous Metals Co.

  

China

Tin

  

CID002180

  

Yunnan Tin Company, Ltd.

  

China

Tantalum    

  

CID000092

  

Asaka Riken Co., Ltd.

  

Japan

Tantalum

  

CID000211

  

Changsha South Tantalum Niobium Co., Ltd.

  

China

Tantalum

  

CID002504

  

D Block Metals, LLC

  

United States    

Gold

  

CID000077

  

Argor-Heraeus S.A.

  

Switzerland

Gold

  

CID001622

  

Shangdong Zhaojin Gold & Silver Refinery Co., Ltd

  

China

Gold

  

CID001153

  

Metalor Technologies S.A.

  

Switzerland

Gold

  

CID000015

  

Advanced Chemical Company

  

United States

Gold

  

CID000707

  

Heraeus Metals Hong Kong Ltd.

  

Hong Kong

Gold

  

CID002224

  

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

  

China

Gold

  

CID001149

  

Metalor Technologies (Hong Kong) Ltd.

  

Hong Kong

Gold

  

CID000019

  

Aida Chemical Industries Co., Ltd.

  

Japan

Gold

  

CID001119

  

Matsuda Sangyo Co., Ltd.

  

Singapore

Tungsten

  

CID000004

  

A.L.M.T. Corp.

  

Japan

Tungsten

  

CID002494

  

Ganzhou Seadragon W & Mo Co., Ltd.

  

China

Tungsten

  

CID002833

  

ACL Metais Eireli

  

Brazil

Tungsten

  

CID000769

  

Hunan Chunchang Nonferrous Metals Co., Ltd.

  

China

Tungsten

  

CID002513

  

Chenzhou Diamond Tungsten Products Co., Ltd.

  

China

Tungsten

  

CID002082

  

Xiamen Tungsten Co., Ltd.

  

China

Tungsten

  

CID000499

  

Fujian Jinxin Tungsten Co.,Ltd.

  

China

Table 2. RMAP-participating processing facilities as listed by RMI as of May 21, 2019

We did not identify any facilities in our supply chain that are reported by RMI to have agreed to participate in the RMAP but have not yet completed the program.

Table 3. RMAP-non-participating processing facilities as of May 21, 2019

Processing facilities and their locations reported in our supply chain that are not reported as either compliant with or participating in the RMAP.

 

Mineral    

  

Facility ID

  

Processing Facility Name

  

Country

Tin

  

N/A

  

Dongguan Best Alloys co.,ltd

  

China

Tin

  

N/A

  

American tin and solder

  

United States

Gold

  

N/A

  

Abington Reldan Metals, LLC

  

United States

 

8