UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
| The Children’s Place, Inc. |
| (Exact name of the registrant as specified in its charter) |
| Delaware | 0-23071 | 31-1241495 | ||
| (State of other jurisdiction of | (Commission | (IRS Employer | ||
| incorporation or organization) | File Number) | Identification No.) |
| 500 Plaza Drive, Secaucus NJ | 07094 | |
| (Address of principal executive offices) | (Zip code) |
| Bradley Cost, Senior Vice President, General Counsel and Secretary | (201) 453-7496 |
| (Name and telephone number, including area code, of the | |
| person to contact in connection with this report.) | |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Specialized Disclosure Form (“Form SD”) of The Children’s Place, Inc., together with the associated Conflict Minerals Report (Exhibit 1.01), is filed pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 through December 31, 2020.
A copy of this Form SD and the Conflict Minerals Report is publicly available at http://corporate.childrensplace.com in the “Corporate Overview” section under the “Investor Relations” tab and in the section entitled “Financial Info – SEC Filings.”
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 - Exhibit
Item 2.01 Exhibit
The following exhibit is filed as part of this report.
Exhibit 1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.
| 2 |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
THE CHILDREN’S PLACE, INC.
(Registrant)
| By: | /s/ Bradley P. Cost | May 28, 2021 | |
| (Signature and Title)* | (Date) | ||
| Name: | Bradley P. Cost | ||
| Title: | Senior Vice President, General Counsel and Secretary |
*Print name and title of the registrant’s signing executive officer under his or her signature.
| 3 |
Exhibit 1.01 Conflict Minerals Report
THE CHILDREN’S PLACE, INC.
Conflict Minerals Report
For the Year Ended December 31, 2020
SPECIAL NOTE REGARDING FORWARD LOOKING STATEMENTS
This Conflict Minerals Report contains or may contain forward-looking statements made pursuant to the safe harbor provisions of the Private Securities Litigation Reform Act of 1995, including but not limited to statements relating to the Company’s strategic initiatives and adjusted net income per diluted share. Forward-looking statements typically are identified by use of terms such as “may,” “will,” “should,” “plan,” “project,” “expect,” “anticipate,” “estimate” and similar words, although some forward-looking statements are expressed differently. These forward-looking statements are based upon the Company’s current expectations and assumptions and are subject to various risks and uncertainties that could cause actual results and performance to differ materially. Some of these risks and uncertainties are described in the Company’s filings with the Securities and Exchange Commission, including in the “Risk Factors” section of its annual report on Form 10-K for the fiscal year ended January 30, 2021. Included among the risks and uncertainties that could cause actual results and performance to differ materially are the risk that the Company will be unsuccessful in gauging fashion trends and changing consumer preferences, the risks resulting from the highly competitive nature of the Company’s business and its dependence on consumer spending patterns, which may be affected by changes in economic conditions, the risks related to the COVID-19 pandemic, including the impact of the COVID-19 pandemic on our business or the economy in general (including decreased customer traffic, schools adopting remote and hybrid learning models, closures of businesses and other activities causing decreased demand for our products and negative impacts on our customers’ spending patterns due to decreased income or actual or perceived wealth, and the impact of the CARES Act and other legislation related to the COVID-19 pandemic, and any changes to the CARES Act or such other legislation), the risk that the Company’s strategic initiatives to increase sales and margin are delayed or do not result in anticipated improvements, the risk of delays, interruptions and disruptions in the Company’s global supply chain, including resulting from COVID-19 or other disease outbreaks, or foreign sources of supply in less developed countries, more politically unstable countries, or countries where vendors fail to comply with industry standards or ethical business practices, including the use of forced, indentured or child labor, the risk that the cost of raw materials or energy prices will increase beyond current expectations or that the Company is unable to offset cost increases through value engineering or price increases, various types of litigation, including class action litigations brought under consumer protection, employment, and privacy and information security laws and regulations, the imposition of regulations affecting the importation of foreign-produced merchandise, including duties and tariffs, and the uncertainty of weather patterns. Readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date they were made. The Company undertakes no obligation to release publicly any revisions to these forward-looking statements that may be made to reflect events or circumstances after the date hereof or to reflect the occurrence of unanticipated events.
| 1. | Introduction |
This Conflict Minerals Report has been prepared by The Children’s Place, Inc. and its subsidiaries (herein referred to as “The Children’s Place,” the “Company,” “we,” “us,” or “our”) pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 through December 31, 2020 (the “Reporting Period”).
The Children’s Place is the largest pure-play children’s specialty apparel retailer in North America. The Company designs, contracts to manufacture, sells at retail and wholesale, and licenses to sell fashionable, high-quality merchandise predominantly at value prices, primarily under the proprietary “The Children’s Place”, “Place”, “Baby Place”, and “Gymboree” brand names. As of May 1, 2021, the Company had 724 stores in the United States, Canada, and Puerto Rico, online stores at www.childrensplace.com and www.gymboree.com, and the Company’s eight international franchise partners had 213 international points of distribution in 19 countries.
1
The Rule requires companies to disclose their use of conflict minerals (as defined below) if those minerals are “necessary to the functionality or production of a product” manufactured or contracted to be manufactured by those companies. The conflict minerals covered by the Rule are tantalum, tin, gold, tungsten (“3TG”) or any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”).
The Company has determined that it contracts to manufacture certain products for which one or more of the 3TG metals are necessary to the functionality or production of those products. Accordingly, the Company conducted a reasonable country of origin inquiry (or “RCOI”) and due diligence as required by the Rule.
| 2. | Reasonable Country of Origin Inquiry |
The Company is far removed from the sources of ore from which minerals are produced, and the smelters or refineries (“SORs”) that process those ores. The efforts undertaken to identify the country(ies) of origin of those ores reflect the Company’s circumstances and position in the supply chain. The Company must rely on information obtained from direct suppliers, who in turn, must obtain information from upstream suppliers, on the origin of the 3TG used in the products manufactured for the Company. Such information may be inaccurate or incomplete.
The Company has a conflict minerals team (or “CMT”) that manages the implementation and progress of its RCOI and due diligence efforts. The team is composed of representatives from the Company’s legal and global sourcing departments, as well as a conflict minerals third-party service provider (the “CMT Service Provider”).
As part of the Company’s RCOI process, the Company developed a risk-based approach that focused on direct suppliers of finished products, as well as suppliers that are reasonably likely to supply components or trims containing one or more of the 3TG metals (together, the “In-Scope Suppliers”) which could have originated from the Covered Countries.
In-Scope Suppliers were asked to complete the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (the “CMRT”). Only CMRT’s version 4.0 or higher were accepted. The Company believes that the CMRT is generally regarded as the most common reporting tool for conflict minerals content and sourcing information worldwide, developed by several of the world’s leading consumer electronics brands. As such, the Company believes the process was reasonably designed and performed in good faith.
The CMRT includes questions regarding the presence and sourcing of 3TG used in the products supplied to the Company, the In-Scope Supplier’s conflict minerals policy, due diligence process, and information about its supply chain, including the names and locations of SORs.
The CMRT responses were evaluated for plausibility, consistency, and gaps. Based on the In-Scope Supplier’s response, additional follow-up was performed, as necessary.
The response rate among In-Scope Suppliers was 63%.
Of those responding In-Scope Suppliers, 3% reported one or more of the 3TG metals as necessary to the functionality or production of the products they manufactured for the Company. Further due diligence (as described below) was undertaken to ascertain the chain and custody of the identified 3TG metals.
| 3. | Due Diligence |
A. Design of Due Diligence
The Company’s due diligence measures were designed to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development (OECD) in the publication OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing (OECD Guidance) and related Supplements on Tin, Tantalum, and Tungsten and on Gold.
2
| B. | Due Diligence Performed |
The Company performed its due diligence as follows:
Step 1: Establish a Strong Company Management System
Policies and Procedures
The Company communicated its conflict minerals policy to all In-Scope Suppliers. In addition, the Company’s terms and conditions contain provisions regarding conflict minerals compliance. In-Scope Suppliers are required to comply with the conflict minerals policy and the terms and conditions.
Internal Team
As mentioned above, the Company has a conflict minerals team that manages the implementation and progress of its RCOI and due diligence efforts.
Control Systems
The Company has in place the following controls: (i) a company-wide business code of conduct that outlines expected behaviors for all Company associates, and (ii) a vendor code of conduct that outlines expected behavior and working conditions for vendors and suppliers.
Maintain Records
The Company has a records retention policy that provides that relevant materials must be preserved for appropriate periods.
Supplier Engagement
The Company utilized members of its global sourcing team and the CMT Service Provider to engage with In-Scope Suppliers on the exchange of supply chain and conflict minerals related information.
Step 2: Identify and Assess Risks in the Supply Chain
For those In-Scope Suppliers who identified the use of one or more 3TG metals in products supplied to the Company, further investigation was performed to determine the source and chain-of-custody of the 3TG, and specifically, whether the SOR of the 3TG is known or thought to be sourcing from the Covered Countries.
The following internationally accepted audit standards were relied on to determine which SORs are considered “DRC Conflict Free”: the Responsible Minerals Assurance Process (RMAP), the London Bullion Market Association Good Delivery Program (“LBMA”) and the Responsible Jewellery Council Chain-of-Custody Certification (“RJC”).
If the SOR is not certified by an internationally-recognized scheme, additional research (internet, industry and government associations) and outreach (email and telephone) with the SOR was performed to confirm the data provided in the CMRT and to gain more information about their sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SORs took to track the chain-of-custody on the source of its mineral ores.
Step 3: Design and Implement a Strategy to Respond to Risks
The CMT received regular updates on the RCOI and due diligence efforts. Findings were reported to senior management.
Where the Company determines an In-Scope Supplier is using conflict minerals in products manufactured for the Company, the Company will work with the In-Scope Supplier to ensure the minerals are sourced from registered conflict free smelters or the minerals are eliminated from use. During the Reporting Period, there were no instances that required the Company to implement risk mitigation efforts, temporarily suspend trade or disengage with a supplier for sourcing and using conflict minerals in products manufactured for the Company.
3
Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence at identified points in the supply chain
The Company does not have a direct relationship with SORs and therefore does not perform or direct audits of these entities.
Step 5: Reports on Supply Chain Due Diligence
This Conflict Minerals Report constitutes the Company’s annual report on its conflict minerals due diligence. The Report is available at http://corporate.childrensplace.com in the “Corporate Overview” section under the “Investor Relations” tab and in the section entitled “Financial Info – SEC Filings.”
C. Due Diligence Findings
Given the Company’s position in the supply chain and the CMRT responses from In-Scope Suppliers, the Company is unable to determine whether the 3TG present in its products originated in the Covered Countries or financed or benefited armed groups in those countries.
Product Description
The products at issue are children’s apparel, accessories and footwear.
Processing Facilities
Based on the CMRT responses from In-Scope Suppliers, the attached Appendix 1 lists the SORs that may have processed the 3TG used in products manufactured for the Company.
Country of Origin
The following is a list of the countries of origin of the 3TG processed by the SORs identified in the attached Appendix 1:
| · | Angola*, Argentina, Armenia, Australia, Austria; |
| · | Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi*; |
| · | Cambodia, Canada, Central African Republic*, Chile, China, Colombia, Congo (Brazzaville)*, Czech Republic; |
| · | Djibouti, DRC – Congo (Kinshasa)*; |
| · | Ecuador, Egypt, Estonia, Ethiopia; |
| · | Finland, France; |
| · | Germany, Ghana, Guinea, Guyana; |
| · | Hong Kong, Hungary; |
| · | India, Indonesia, Ireland, Israel, Italy, Ivory Coast; |
| · | Japan, Jersey; |
| · | Kazakhstan, Kenya*, Korea, Kyrgyzstan; |
| · | Laos, Luxembourg; |
| · | Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique*, Myanmar; |
| · | Namibia, Netherlands, Niger, Nigeria; |
| · | Papua New Guinea, Peru, Philippines, Poland, Portugal; |
| · | Russia, Rwanda*; |
| · | Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa*, South Sudan*, Spain, Suriname, Sweden, Switzerland; |
4
| · | Taiwan, Tajikistan, Tanzania*, Thailand, Turkey; |
| · | Uganda*, United Arab Emirates*, United Kingdom, United States, Uzbekistan; |
| · | Vietnam; and |
| · | Zambia*, Zimbabwe. |
*All smelters that are known to source 3TG from Angola, Burundi, Central African Republic, Congo (Brazzaville), Congo (Kinhasa), Kenya, Mozambique, Rwanda, South Africa, South Sudan, Tanzania, Uganda, United Arab Emirates and Zambia are certified conflict free by one or a combination of RMAP, LBMA, and RJC.
Independent Private Sector Audit
For the Reporting Period, the company is not required to obtain an independent private sector audit of the Conflict Minerals Report.
| 4. | Steps to Improve Due Diligence |
The Company continues to take the following steps to improve due diligence processes in place, namely:
| • | Continue engagement with In-Scope Suppliers and direct them to information and training resources in order to improve the content of the In-Scope Suppliers CMRT responses; |
| • | Continue to require In-Scope Suppliers not to use any conflict minerals in products manufactured for the Company; and |
| • | Work with In-Scope Suppliers, if found to be providing the Company with components or materials containing minerals from sources that support conflict in the Covered Countries, to establish an alternative source of minerals that does not support such conflict. |
5
Appendix 1 to Conflict Minerals Report
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Gold | 8853 S.p.A. | RMAP | YES |
| Gold | Advanced Chemical Company | RMAP | YES |
| Gold | Aida Chemical Industries Co., Ltd. | RMAP | YES |
| Gold | Al Etihad Gold Refinery DMCC | RMAP | YES |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | LBMA, RJC, RMAP | YES |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | LBMA, RMAP | YES |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | LBMA, RMAP | YES |
| Gold | Argor-Heraeus S.A. | LBMA, RMAP | YES |
| Gold | Asahi Pretec Corp. | LBMA, RMAP | YES |
| Gold | Asahi Refining Canada Ltd. | LBMA, RMAP | YES |
| Gold | Asahi Refining USA Inc. | LBMA, RMAP | YES |
| Gold | Asaka Riken Co., Ltd. | RMAP | YES |
| Gold | AU Traders and Refiners | RJC, RMAP | YES |
| Gold | Aurubis AG | LBMA, RMAP | YES |
| Gold | Bangalore Refinery | RMAP | YES |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | LBMA, RMAP | YES |
| Gold | Boliden AB | LBMA, RMAP | YES |
| Gold | C. Hafner GmbH + Co. KG | LBMA, RJC, RMAP | YES |
| Gold | CCR Refinery - Glencore Canada Corporation | LBMA, RMAP | YES |
| Gold | Cendres + Metaux S.A. | RMAP | YES |
| Gold | Chimet S.p.A. | LBMA, RMAP | YES |
| Gold | Chugai Mining | RMAP | YES |
| Gold | DODUCO Contacts and Refining GmbH | RMAP | YES |
| Gold | Dowa | RMAP | YES |
| Gold | DS PRETECH Co., Ltd. | RMAP | YES |
| Gold | DSC (Do Sung Corporation) | RMAP | YES |
| Gold | Eco-System Recycling Co., Ltd. East Plant | RMAP | YES |
| Gold | Emirates Gold DMCC | RMAP | YES |
| Gold | Geib Refining Corporation | RMAP | YES |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | LBMA, RMAP | YES |
| Gold | Heimerle + Meule GmbH | LBMA, RMAP | YES |
| Gold | Heraeus Metals Hong Kong Ltd. | LBMA, RJC, RMAP | YES |
| Gold | Heraeus Precious Metals GmbH & Co. KG | RMAP - Active | NO |
6
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | LBMA, RMAP | YES |
| Gold | Ishifuku Metal Industry Co., Ltd. | LBMA, RMAP | YES |
| Gold | Istanbul Gold Refinery | LBMA, RMAP | YES |
| Gold | Italpreziosi | RJC, RMAP | YES |
| Gold | Japan Mint | LBMA, RMAP | YES |
| Gold | Jiangxi Copper Co., Ltd. | LBMA, RMAP | YES |
| Gold | JSC Uralelectromed | LBMA, RMAP | YES |
| Gold | JX Nippon Mining & Metals Co., Ltd. | LBMA, RMAP | YES |
| Gold | Kazzinc | LBMA, RMAP | YES |
| Gold | Kennecott Utah Copper LLC | LBMA, RMAP | YES |
| Gold | KGHM Polska Miedz Spolka Akcyjna | RMAP | YES |
| Gold | Kojima Chemicals Co., Ltd. | RMAP | YES |
| Gold | Korea Zinc Co., Ltd. | RMAP | YES |
| Gold | Kyrgyzaltyn JSC | LBMA, RMAP | YES |
| Gold | L'Orfebre S.A. | RMAP | YES |
| Gold | LS-NIKKO Copper Inc. | LBMA, RMAP | YES |
| Gold | LT Metal Ltd. | RMAP | YES |
| Gold | Marsam Metals | RMAP | YES |
| Gold | Materion | RMAP | YES |
| Gold | Matsuda Sangyo Co., Ltd. | LBMA, RMAP | YES |
| Gold | Metalor Technologies (Hong Kong) Ltd. | LBMA, RJC, RMAP | YES |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | LBMA, RJC, RMAP | YES |
| Gold | Metalor Technologies (Suzhou) Ltd. | RJC, RMAP | YES |
| Gold | Metalor Technologies S.A. | LBMA, RJC, RMAP | YES |
| Gold | Metalor USA Refining Corporation | LBMA, RJC, RMAP | YES |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | LBMA, RMAP | YES |
| Gold | Mitsubishi Materials Corporation | LBMA, RMAP | YES |
| Gold | Mitsui Mining and Smelting Co., Ltd. | LBMA, RMAP | YES |
| Gold | MMTC-PAMP India Pvt., Ltd. | LBMA, RMAP | YES |
| Gold | Moscow Special Alloys Processing Plant | LBMA, RMAP | YES |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | LBMA, RMAP | YES |
| Gold | Nihon Material Co., Ltd. | LBMA, RMAP | YES |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | RJC, RMAP | YES |
| Gold | Ohura Precious Metal Industry Co., Ltd. | RMAP | YES |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | LBMA, RMAP | YES |
7
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Gold | OJSC Novosibirsk Refinery | LBMA, RMAP | YES |
| Gold | PAMP S.A. | LBMA, RMAP | YES |
| Gold | Planta Recuperadora de Metales SpA | RMAP | YES |
| Gold | Prioksky Plant of Non-Ferrous Metals | LBMA, RMAP | YES |
| Gold | PT Aneka Tambang (Persero) Tbk | LBMA, RMAP | YES |
| Gold | PX Precinox S.A. | LBMA, RMAP | YES |
| Gold | Rand Refinery (Pty) Ltd. | LBMA, RMAP | YES |
| Gold | REMONDIS PMR B.V. | RMAP | YES |
| Gold | Royal Canadian Mint | LBMA, RMAP | YES |
| Gold | SAAMP | RJC, RMAP | YES |
| Gold | Safimet S.p.A | RMAP | YES |
| Gold | Samduck Precious Metals | RMAP | YES |
| Gold | SAXONIA Edelmetalle GmbH | RMAP | YES |
| Gold | SEMPSA Joyeria Plateria S.A. | LBMA, RMAP | YES |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | LBMA, RMAP | YES |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | LBMA, RMAP | YES |
| Gold | Singway Technology Co., Ltd. | RMAP | YES |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | LBMA, RMAP | YES |
| Gold | Solar Applied Materials Technology Corp. | LBMA, RMAP | YES |
| Gold | Sumitomo Metal Mining Co., Ltd. | LBMA, RMAP | YES |
| Gold | SungEel HiMetal Co., Ltd. | RMAP | YES |
| Gold | T.C.A S.p.A | LBMA, RMAP | YES |
| Gold | Tanaka Kikinzoku Kogyo K.K. | LBMA, RMAP | YES |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | LBMA, RMAP | YES |
| Gold | Tokuriki Honten Co., Ltd. | LBMA, RMAP | YES |
| Gold | Torecom | RMAP | YES |
| Gold | Umicore Precious Metals Thailand | RJC, RMAP | YES |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | LBMA, RMAP | YES |
| Gold | United Precious Metal Refining, Inc. | RMAP | YES |
| Gold | Valcambi S.A. | LBMA, RJC, RMAP | YES |
| Gold | Western Australian Mint (T/a The Perth Mint) | LBMA, RMAP | YES |
| Gold | WIELAND Edelmetalle GmbH | RMAP | YES |
| Gold | Yamakin Co., Ltd. | RMAP | YES |
| Gold | Yokohama Metal Co., Ltd. | RMAP | YES |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | LBMA, RMAP | YES |
| Gold | Coimpa Industrial | In Progress | |
| Gold | Too Vague To Recognize | Non Processor | Non Processor |
8
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Tantalum | Asaka Riken Co., Ltd. | RMAP | YES |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | RMAP | YES |
| Tantalum | D Block Metals, LLC | RMAP | YES |
| Tantalum | Exotech Inc. | RMAP | YES |
| Tantalum | F&X Electro-Materials Ltd. | RMAP | YES |
| Tantalum | FIR Metals & Resource Ltd. | RMAP | YES |
| Tantalum | Global Advanced Metals Aizu | RMAP | YES |
| Tantalum | Global Advanced Metals Boyertown | RMAP | YES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | RMAP | YES |
| Tantalum | H.C. Starck Hermsdorf GmbH | RMAP | YES |
| Tantalum | H.C. Starck Inc. | RMAP | YES |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | RMAP | YES |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | RMAP | YES |
| Tantalum | Jiangxi Tuohong New Raw Material | RMAP | YES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | RMAP | YES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | RMAP | YES |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | RMAP | YES |
| Tantalum | KEMET Blue Metals | RMAP | YES |
| Tantalum | LSM Brasil S.A. | RMAP | YES |
| Tantalum | Meta Materials | RMAP | YES |
| Tantalum | Metallurgical Products India Pvt., Ltd. | RMAP | YES |
| Tantalum | Mineracao Taboca S.A. | RMAP | YES |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | RMAP | YES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | RMAP | YES |
| Tantalum | QuantumClean | RMAP | YES |
| Tantalum | Resind Industria e Comercio Ltda. | RMAP | YES |
| Tantalum | Solikamsk Magnesium Works OAO | RMAP | YES |
| Tantalum | Taki Chemical Co., Ltd. | RMAP | YES |
| Tantalum | TANIOBIS Co., Ltd. | RMAP | YES |
| Tantalum | TANIOBIS GmbH | RMAP | YES |
| Tantalum | TANIOBIS Japan Co., Ltd. | RMAP | YES |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | RMAP | YES |
| Tantalum | Telex Metals | RMAP | YES |
| Tantalum | Ulba Metallurgical Plant JSC | RMAP | YES |
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. | RMAP | YES |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | RMAP | YES |
| Tin | Alpha | RMAP | YES |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | RMAP | YES |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | RMAP | YES |
| Tin | China Tin Group Co., Ltd. | RMAP | YES |
9
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Tin | CV Ayi Jaya | RMAP - Active | NO |
| Tin | Dowa | RMAP | YES |
| Tin | EM Vinto | RMAP | YES |
| Tin | Fenix Metals | RMAP | YES |
| Tin | Gejiu Kai Meng Industry and Trade LLC | RMAP | YES |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | RMAP | YES |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | RMAP | YES |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | RMAP | YES |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | RMAP | YES |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | RMAP | YES |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | RMAP | YES |
| Tin | Huichang Jinshunda Tin Co., Ltd. | RMAP | YES |
| Tin | Jiangxi New Nanshan Technology Ltd. | RMAP | YES |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | RMAP | YES |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | RMAP | YES |
| Tin | Malaysia Smelting Corporation (MSC) | RMAP | YES |
| Tin | Melt Metais e Ligas S.A. | RMAP | YES |
| Tin | Metallic Resources, Inc. | RMAP | YES |
| Tin | Metallo Belgium N.V. | RMAP | YES |
| Tin | Metallo Spain S.L.U. | RMAP | YES |
| Tin | Mineracao Taboca S.A. | RMAP | YES |
| Tin | Minsur | RMAP | YES |
| Tin | Mitsubishi Materials Corporation | RMAP | YES |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | RMAP | YES |
| Tin | O.M. Manufacturing Philippines, Inc. | RMAP | YES |
| Tin | Operaciones Metalurgicas S.A. | RMAP | YES |
| Tin | PT Artha Cipta Langgeng | RMAP | YES |
| Tin | PT ATD Makmur Mandiri Jaya | RMAP | YES |
| Tin | PT Bangka Serumpun | RMAP | YES |
| Tin | PT Menara Cipta Mulia | RMAP | YES |
| Tin | PT Mitra Stania Prima | RMAP | YES |
| Tin | PT Prima Timah Utama | RMAP | YES |
| Tin | PT Refined Bangka Tin | RMAP | YES |
| Tin | PT Stanindo Inti Perkasa | RMAP | YES |
| Tin | PT Timah Tbk Kundur | RMAP | YES |
| Tin | PT Timah Tbk Mentok | RMAP | YES |
| Tin | Resind Industria e Comercio Ltda. | RMAP | YES |
| Tin | Rui Da Hung | RMAP | YES |
| Tin | Soft Metais Ltda. | RMAP | YES |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | RMAP | YES |
10
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Tin | Thaisarco | RMAP | YES |
| Tin | Tin Technology & Refining | RMAP | YES |
| Tin | White Solder Metalurgia e Mineracao Ltda. | RMAP | YES |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | RMAP | YES |
| Tin | Yunnan Tin Company Limited | RMAP | YES |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | RMAP | YES |
| Tin | CV United Smelting | Inactive | Inactive |
| Tin | PT DS Jaya Abadi | Inactive | Inactive |
| Tin | PT Inti Stania Prima | Inactive | Inactive |
| Tin | PT Sariwiguna Binasentosa | Inactive | Inactive |
| Tin | PT Sukses Inti Makmur | Inactive | Inactive |
| Tin | PT Tommy Utama | Inactive | Inactive |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | RMAP | YES |
| Tungsten | ACL Metais Eireli | RMAP | YES |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | RMAP | YES |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | RMAP | YES |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | NO | |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | RMAP | YES |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | RMAP | YES |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | RMAP | YES |
| Tungsten | Global Tungsten & Powders Corp. | RMAP | YES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | H.C. Starck Tungsten GmbH | RMAP | YES |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | RMAP | YES |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | RMAP | YES |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | RMAP | YES |
| Tungsten | Hydrometallurg, JSC | RMAP | YES |
| Tungsten | Japan New Metals Co., Ltd. | RMAP | YES |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | RMAP | YES |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | RMAP | YES |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | RMAP | YES |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Kennametal Fallon | RMAP | YES |
| Tungsten | Kennametal Huntsville | RMAP | YES |
| Tungsten | KGETS CO., LTD. | RMAP | YES |
11
| Metal | Official Smelter Name | Conflict-Free Certifications |
Certified Smelter |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | RMAP | YES |
| Tungsten | Moliren Ltd. | RMAP | YES |
| Tungsten | Niagara Refining LLC | RMAP | YES |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | RMAP | YES |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | RMAP | YES |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Unecha Refractory Metals Plant | RMAP | YES |
| Tungsten | Wolfram Bergbau und Hutten AG | RMAP | YES |
| Tungsten | Woltech Korea Co., Ltd. | RMAP | YES |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | RMAP | YES |
| Tungsten | Xiamen Tungsten Co., Ltd. | RMAP | YES |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | RMAP | YES |
12