I. | Overview |
II. | Reasonable Country of Origin Inquiry Information |
III. | Due Diligence Program Design and Execution |
1. | OECD Guidance Step One: “Establish strong company management systems” | |
a. | We have a cross-functional working group charged with managing our 3TG compliance strategy, that ultimately reports to the Chief Legal Officer. The following functional areas were represented on the working group: external reporting; legal; and procurement. We also appointed representatives from each business unit with potentially in-scope products. Selected internal personnel were educated on the Conflict Minerals Rule and our compliance plan. We also used specialist outside counsel to assist us with certain aspects of our compliance efforts. | |
b. | Arconic’s procurement function maintains a standard operating procedure (“SOP”) governing purchases of 3TG and materials or products containing 3TG. The SOP defines the processes that our procurement function uses to source 3TG and materials or products containing 3TG and to support the annual disclosure of country of origin information for those minerals. The SOP provides that we will only purchase 3TG or materials or products containing 3TG from suppliers that can provide acceptable certification that the minerals did not originate from sources that directly or indirectly financed or benefitted armed groups in the Covered Countries. | |
c. | We used the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”) to identify SORs in our supply chain. We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, in a structured computerized database, for at least five years. | |
d. | We have a grievance mechanism for employees, suppliers and other interested parties to report violations of our 3TG program compliance requirements. The URL is https://www.arconic.com/global/en/who-we-are/integrity-line.asp | |
2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” | |
a. | We determined which of our products were in-scope or potentially in-scope for purposes of our compliance with the Conflict Minerals Rule through product specifications, bills of material, supplier inquiries, elemental composition limits, spectrographic analysis of the product composition and other information known to us. | |
b. | We requested by email that the suppliers we determined to potentially be in-scope for purposes of our compliance with the Conflict Minerals Rule (the “Suppliers”) provide us with information, through the completion of a CMRT, concerning the usage and source of 3TG in their products, as well as information concerning the Suppliers’ related compliance measures. We followed up multiple times, if required, by email with the Suppliers that did not respond to the request within the specified time frame. For 2019, our outreach included 73 Suppliers and our overall Supplier response rate was 67%. | |
c. | SOR information also was reviewed against the lists of Conformant and Active (as defined herein), or the equivalent, SORs published by the RMI. For 2019, the Suppliers identified 77 SORs as having processed the necessary 3TG contained in our in-scope products. Out of the 77 identified SORS, 67 SORs (or 87%) were listed as Conformant, 1 SOR (or 1%) was listed as Active, and 9 SORs (or 12%) were on the Smelter Look-Up Tab List Only (as defined herein). | |
3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” | |
a. | Our 3TG compliance team reported its findings to our Chief Legal Officer. | |
b. | Under our risk mitigation strategy, we take such risk mitigation efforts as we deem to be appropriate based on the findings of our supply chain risk assessment. Our risk mitigation efforts are determined by the particular facts and circumstances and risks identified. | |
c. | To mitigate the risk that our necessary 3TG finance or benefit armed groups, for 2020, we also intend to engage in the additional measures discussed under “Additional Risk Mitigation Efforts” below. | |
4. | OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” | |
5. | OECD Guidance Step 5: “Report on supply chain due diligence” | |
IV. | Product, Smelter and Refiner and Country of Origin Information |
V. | Additional Risk Mitigation Efforts |
1. | Continue to encourage Suppliers that provided company level or user defined information for 2019 to provide product level information for 2020. | |
2 | Request Suppliers that provided incomplete responses or that did not provide responses for 2019 to provide requested information for 2020. | |
3. | Monitor the continuing development and progress of traceability measures at Suppliers that indicated for 2019 that the source of 3TG was unknown. | |
4. | Communicate to new in-scope suppliers our sourcing expectations through the conflict minerals clause in our standard terms and conditions. | |
Metal | Smelter Name | Smelter Country | Status |
Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | On Smelter Look-up Tab List Only |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
Tin | CV Ayi Jaya | INDONESIA | Conformant |
Tin | CV Dua Sekawan | INDONESIA | Conformant |
Tin | CV United Smelting | INDONESIA | Conformant |
Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | On Smelter Look-up Tab List Only |
Tin | Dowa | JAPAN | Conformant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | On Smelter Look-up Tab List Only |
Tin | EM Vinto | BOLIVIA | Conformant |
Tin | Estanho de Rondonia S.A. | BRAZIL | On Smelter Look-up Tab List Only |
Tin | Fenix Metals | POLAND | Conformant |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tin | Minsur | PERU | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
Tin | Modeltech Sdn Bhd | MALAYSIA | On Smelter Look-up Tab List Only |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | On Smelter Look-up Tab List Only |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA | Conformant |
Tin | Pongpipat Company Limited | MYANMAR | On Smelter Look-up Tab List Only |
Tin | Precious Minerals and Smelting Limited | INDIA | Active |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
Tin | PT Bangka Serumpun | INDONESIA | Conformant |
Tin | PT Bukit Timah | INDONESIA | Conformant |
Tin | PT DS Jaya Abadi | INDONESIA | Conformant |
Tin | PT Inti Stania Prima | INDONESIA | Conformant |
Tin | PT Karimun Mining | INDONESIA | Conformant |
Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
Tin | PT Panca Mega Persada | INDONESIA | Conformant |
Tin | PT Prima Timah Utama | INDONESIA | Conformant |
Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
Tin | PT Tommy Utama | INDONESIA | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tin | Rui Da Hung | TAIWAN | Conformant |
Tin | Soft Metais Ltda. | BRAZIL | Conformant |
Tin | Super Ligas | BRAZIL | On Smelter Look-up Tab List Only |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM | Conformant |
Tin | Thaisarco | THAILAND | Conformant |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM | On Smelter Look-up Tab List Only |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
Tin | Yunnan Tin Company Limited | CHINA | Conformant |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
a. | The SORs reflected above may not include all of the SORs in Arconic’s supply chain, since some Suppliers did not identify all of their SORs and because not all Suppliers responded to Arconic’s inquiries. | |
b. | The table only includes entities that were listed as SORs on the Smelter Look-up tab list of the CMRT. | |
c. | “Conformant” means that a SOR has successfully completed an assessment against the applicable Responsible Minerals Assurance Process (the “RMAP”) standard or an equivalent cross-recognized assessment. Included SORs were not necessarily Conformant for all or part of 2019 and may not continue to be Conformant for any future period. | |
d. | “Active” means that the SOR has committed to undergo an RMAP assessment, completed the relevant documents and scheduled the on-site assessment. These may be in the pre-assessment, assessment, or corrective-action phases of the assessment. | |
e. | “On Smelter Look-up Tab List Only” means that a SOR is listed on the Smelter Look-up tab list of the CMRT, but is not listed as Conformant or Active. | |
f. | SOR status and location reflected in the table is based solely on information made publicly available by the RMI, without independent verification by Arconic. | |
Angola* | Estonia | Luxembourg | Singapore |
Argentina | Ethiopia | Madagascar | Slovakia |
Australia | France | Malaysia | South Africa |
Austria | Germany | Mexico | South Sudan* |
Belgium | Guyana | Mongolia | Spain |
Bolivia | Hong Kong | Morocco | Suriname |
Brazil | Hungary | Mozambique | Sweden |
Burundi* | India | Myanmar | Switzerland |
Cambodia | Indonesia | Namibia | Taiwan |
Canada | Ireland | Netherlands | Tanzania* |
Central African Republic* | Israel | Nigeria | Thailand |
Chile | Ivory Coast | Papua New Guinea | Turkey |
China | Japan | Peru | Uganda* |
Colombia | Jersey | Philippines | United Kingdom |
Czech Republic | Kazakhstan | Poland | United States |
Djibouti | Kenya | Portugal | Uzbekistan |
Democratic Republic of the Congo* | Korea | Russia | Vietnam |
Ecuador | Kyrgyzstan | Rwanda* | Zambia* |
Egypt | Laos | Sierra Leone | Zimbabwe |