UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
______
FORM SD
SPECIALIZED DISCLOSURE REPORT
Tapestry, Inc.
(Exact name of registrant as specified in its charter)
(Exact name of registrant as specified in its charter)
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Maryland
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1-16153
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52-2242751
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(State of
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(Commission File Number)
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(IRS Employer
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Incorporation)
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Identification No.)
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10 Hudson Yards, New York, NY 10001
(Address of principal executive offices) (Zip Code)
(Address of principal executive offices) (Zip Code)
Todd Kahn (212) 594-1850
(Name and telephone number, including area code, of the person to contact in connection with this report.)
(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
Tapestry, Inc. (“Tapestry”) has filed this Form SD as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, because,
during the calendar year ended December 31, 2018, Tapestry contracted to manufacture certain products that contained “conflict minerals” necessary to their functionality. Conflict minerals are defined by the Securities and Exchange Commission as
columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. Based on a reasonable country of origin inquiry, Tapestry performed additional due diligence and filed a Conflict
Minerals Report.
Information concerning necessary conflict minerals from recycled or scrap sources that may be contained in Tapestry’s in-scope products is
included in the Conflict Minerals Report and is incorporated in this Form SD by reference.
The Conflict Minerals Report, filed as Exhibit 1.01 hereto, is also publicly available at:
www.tapestry.com/investors/ under the Conflict Minerals Policy section. The information maintained or referenced on Tapestry’s or any
of its brands’ websites is not incorporated by reference into this Form SD or the Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.
Items 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
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.
TAPESTRY, INC.
By: /s/ Todd Kahn________________________________
May 31, 2019
Todd Kahn
President, Chief Administrative Officer, Chief Legal Officer & Secretary
President, Chief Administrative Officer, Chief Legal Officer & Secretary
Exhibit 1.01
Tapestry, Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2018
I. Introduction
This report has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the
“Conflict Minerals Rule”) for the reporting period from January 1 to December 31, 2018, and relates to the process undertaken for Tapestry, Inc. (“Tapestry” or the “Company”) products that were contracted to be manufactured during calendar 2018
and that contain gold, tantalum, tin and/or tungsten (collectively the “3TG minerals”) that is necessary to the functionality or production of the products.
II. Applicability of the Conflict minerals Rule to Tapestry
Tapestry, Inc. is a global house of
brands powered by optimism, innovation and inclusivity. Tapestry brands include Coach, kate spade new york and Stuart Weitzman. The
information maintained or referenced on Tapestry’s or any of its brands’ websites is not incorporated by reference into this Conflict Minerals Report or the Form SD, of which it is a part, and should not be considered part of this Conflict
Minerals Report or the Form SD.
Tapestry determined that it is subject to the requirements of the Conflict Minerals Rule because of the degree of influence that it exercises
over the design, materials, and components of some of its products that contain necessary 3TG minerals. None of Tapestry’s brands directly manufacture products but “contract to manufacture”, and are far removed from the sources of ore from which
these metals are produced and the smelters/refiners that process those ores. The efforts undertaken to identify the origin of those ores reflect Tapestry’s position in the supply chain.
The products covered by this Report include the following, although not all of Tapestry’s products in each of these categories are in-scope
for purposes of its compliance:
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●
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Fashion Accessories
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●
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Handbags
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●
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Jewelry
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●
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Footwear
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●
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Ready-to-Wear
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Tapestry’s in-scope products for 2018 contain tin, gold, tungsten and tantalum. However, each in-scope product did not contain all four of
the 3TG minerals.
For 2018, Tapestry identified 141 suppliers of potentially in-scope products.
III. Tapestry’s Conflict Minerals Policy; Compliance Overview
Tapestry adopted a policy for the supply chain of 3TG minerals (the “Conflict Minerals Policy”).
Consistent with its belief in the dignity of, and respect for, individuals, as demonstrated in its policies on labor practices, Tapestry is
concerned with the potential humanitarian abuses involved in the mining of these minerals and subsequent financing of armed conflict, and takes its obligations under the Conflict Minerals Rule seriously. As such, Tapestry strives to deliver
products to its consumers manufactured in an ethical way consistent with its humanitarian beliefs and to be compliant with the laws in the countries in which it operates.
Tapestry continues to strive towards a supply chain that contains 3TG minerals that are from sources that are Conformant (as defined later in
this Conflict Minerals Report). Tapestry does not ban procurement of 3TG minerals from the Democratic Republic of the Congo (the “DRC”) and adjoining countries, but seeks to source from responsible conflict-free sources in the region.
To enable its commitment to responsible 3TG minerals sourcing, Tapestry has adopted the following practices, in addition to the other
practices discussed in this Conflict Minerals Report:
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●
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Instituted an assessment of its supply chain to identify areas where there is a high probability of 3TG mineral use;
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●
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Collaborates with suppliers to confirm 3TG mineral usage and potential sources of these minerals;
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Works with its suppliers through the product development process to understand the likelihood of 3TG minerals being incorporated
into the design;
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●
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Requires the distribution of Tapestry’s Conflict Minerals Policy and the CMRT (as defined later in this Conflict Minerals Report) to
all new and current suppliers; and
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Expects its suppliers to adopt policies with respect to 3TG minerals consistent with Tapestry’s stance.
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Tapestry expects its suppliers to adhere to the following guidelines when procuring 3TG minerals for use in Tapestry products:
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Suppliers should have a policy with respect to the sourcing of 3TG minerals, specifically that they will make progress to switch to
certified conflict-free or Conformant sources.
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Suppliers should not take conflict-free or Conformant to mean that Tapestry does not source from the DRC or its adjoining countries.
Rather, suppliers should seek certified conflict-free or Conformant sources without excluding the DRC and its adjoining countries.
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●
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Suppliers should respond in full to any surveys or requests for documentation received from Tapestry.
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Suppliers’ processes and procedures relating to the traceability of the sources of 3TG minerals should conform to the Organisation
for Economic Co-Operation and Development Due Diligence Guidance for Responsible Sourcing of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”).
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In addition, Tapestry’s Supplier Code of Conduct states that any 3TGs used in the production of its products, and the applicable smelters,
must be disclosed to Tapestry during its annual 3TG survey. The Supplier Code of Conduct also states that Tapestry encourages its suppliers to look for conflict-free certified sources when sourcing 3TGs. Tapestry’s Supplier Code of Conduct is
available at www.tapestry.com/investors under Corporate Governance.
In order to achieve these objectives, Tapestry developed a process consistent with the OECD Guidance due diligence framework for 3TG minerals,
as further discussed below.
IV. Reasonable Country of Origin Inquiry Information
Following a risk assessment to scope where 3TG minerals may be found in its products, Tapestry conducted a “reasonable country of origin
inquiry” (“RCOI”) within the meaning of the Conflict Minerals Rule. The RCOI was undertaken on the products sourced directly by, and manufactured for, Tapestry in 2018. Tapestry and its brands do not directly manufacture products, but “contract
to manufacture” from its suppliers products that may contain 3TG minerals necessary to their functionality. Tapestry then identified the suppliers who supplied the materials. The survey was administered to those suppliers via a web-based portal
by a third-party service provider (the “Service Provider”), with manual and automated follow-up communications to improve survey response rate, and to complement Tapestry’s internal management process.
Based on its RCOI, Tapestry concluded that, of the 293 smelters and refiners (“SORs”) identified by suppliers, 241 sourced 3TG minerals
exclusively from outside of the DRC region and/or from recycled or scrap sources and 52 sourced in whole or in part from the DRC region. Tapestry’s conclusions concerning 3TG mineral origin are based on information provided by the Service
Provider derived from supplier responses and the Service Provider’s own analysis. Eighty-two percent of the identified SORs were listed as Conformant by the Responsible Minerals Initiative (the “RMI”), and the remainder were listed as Active or
Known (as defined later in this Conflict Minerals Report), in each case as of April 10, 2019. All SORs believed by the Service Provider to source at least in part from the DRC region are listed as Conformant. More detailed SOR and country of
origin information is provided under “Item VI. Identified Smelters and Refiners” and “Item VII. Country of Origin Information” below, respectively.
Tapestry and the Service Provider received survey responses from Tapestry’s suppliers, which were reviewed by both parties for plausibility,
consistency and gaps. Tapestry and the Service Provider requested suppliers to provide corrections and clarification where needed.
V. Due Diligence
Based on the results of Tapestry’s RCOI, Tapestry conducted due diligence for 2018. These due diligence efforts are discussed below.
Design of Due Diligence
Tapestry designed its due diligence measures to conform with the OECD Guidance (Third Edition), which includes the related supplements on tin,
tantalum, tungsten and gold. Specifically, due to its classification as a “downstream” company within the supply chain, Tapestry’s due diligence practices were tailored accordingly based upon the OECD Guidance.
Due Diligence Measures Performed
Based upon the OECD Guidance, Tapestry’s due diligence measures included the following elements. These are not all of the discrete elements
and tasks that are part of Tapestry’s compliance program.
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OECD Step One: “Establish strong company management systems”
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o
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Adopted the Conflict Minerals Policy, which is reviewed annually. Tapestry’s Conflict Minerals Policy was reviewed in April 2019,
and is available publicly at www.tapestry.com/investors under the Conflict Minerals Policy section..
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o
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Included the Conflict Minerals Policy in the Company’s Supplier Code of Conduct, which is available publicly.
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Assembled an internal team to support supply chain due diligence.
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o
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Designated a senior internal resource, the Senior Manager of Sustainability and Legal Compliance, to manage the program.
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Adopted a policy to keep records relating to conflict minerals due diligence for at least five years.
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Added conflict minerals-specific questions to our supplier onboarding process.
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OECD Step Two: “Identify and assess risk in the supply chain”
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o
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Sent requests to 141 suppliers to provide Tapestry with a completed Conflict Minerals Reporting Template (“CMRT”), which is the form
developed by the RMI. Both Tapestry and the Service Provider followed up by phone and email with the suppliers that did not provide a response within a specified time frame. 100% of the suppliers surveyed responded to Tapestry’s request
for information.
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o
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Utilized the CMRT version 5.10 for Tapestry’s 2018 survey outreach, and only versions of the CMRT 4.0 or later were accepted.
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o
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Tapestry and the Service Provider reviewed the responses received from suppliers. The Service Provider reviewed the responses for
plausibility, consistency and gaps, and then followed up via phone or email with suppliers that submitted a response that triggered quality control flags.
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o
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The Service Provider reviewed the lists of the suppliers’ identified SORs and compared those lists against the list of Conformant or
equivalent SORs published in connection with the RMI’s Responsible Minerals Assurance Process (“RMAP”), the London Bullion Market Association’s (“LBMA”) Good Delivery List and the Responsible Jewellery Council’s (“RJC”) Chain of Custody
Certification.
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o
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For those SORs identified by a supplier that were not listed as Conformant or the equivalent by an independent third-party, the
Service Provider attempted to contact the SOR to gain information about its sourcing practices, including origin and transfer, to determine the source and chain of custody of the 3TG minerals. Internet research also was performed to
determine whether there was any outside sources of information regarding the SORs sourcing practices.
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OECD Step Three: “Design and implement a strategy to respond to identified risks”
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o
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Suppliers were ranked based on a risk level assigned by the Service Provider. Tapestry reported its risk management findings to its
President, Chief Administrative Officer, Chief Legal Officer & Secretary. Tapestry reports the results of its analysis to the Company’s Board of Directors.
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OECD Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in
the supply chain”
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o
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In connection with Tapestry’s due diligence, the Service Provider, on Tapestry’s behalf, utilizes information made available by the
RMI, LBMA and RJC concerning independent third-party audits of smelters and refiners.
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OECD Step Five: “Report on supply chain due diligence”
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o
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Tapestry files a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission (“SEC”) and makes the filings
publicly available: https://tapestry.gcs-web.com/static-files/2ead14dd-b33c-4fb4-add6-7fd97d6859ea
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VI. Identified
Smelters and Refiners
Table 1 makes use of the terms “Conformant,” “Active” and “Known.” “Conformant” means that a SOR was listed as Conformant with the RMAP’s
assessment protocols, including those indicated as “Re-audit in progress.” Included SORs were not necessarily Conformant for all or part of 2018 and may not continue to be Conformant for any future period. “Active” is an RMAP designation that
means that the SOR is a participant in the RMAP and has committed to undergo an RMAP assessment. A SOR is listed as “Known” if it was not Conformant or Active but is listed on the CMRT Smelter Look-up tab. The status information reflected in
this table is current as of April 18, 2019.
Tapestry received data from its suppliers on a company-level basis, meaning that the suppliers reported 3TG minerals contained in all of their
products, not just those in the products that they sold to Tapestry. Accordingly, not all included SORs listed below may have processed the necessary 3TG minerals contained in Tapestry’s in-scope products. Furthermore, the SORs listed in the
table below may not be all of the SORs in Tapestry’s supply chain, since some suppliers indicated that they did not identify all of the SORs used to process the necessary 3TG minerals content in the products covered by their CMRTs.
Table 1: List of identified SORs
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Mineral
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Smelter or Refiner Name
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Status
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Gold
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Advanced Chemical Company
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Conformant
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Gold
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Aida Chemical Industries Co., Ltd.
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Conformant
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Gold
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Al Etihad Gold LLC
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Conformant
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Gold
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Allgemeine Gold-und Silberscheideanstalt A.G.
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Conformant
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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Conformant
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Gold
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AngloGold Ashanti Corrego do Sitio Mineracao
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Conformant
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Gold
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Argor-Heraeus SA
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Conformant
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Gold
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Asahi Pretec Corporation
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Conformant
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Gold
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Asahi Refining Canada Ltd.
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Conformant
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Gold
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Asahi Refining USA Inc.
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Conformant
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Gold
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Asaka Riken Co., Ltd.
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Conformant
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Gold
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AU Traders and Refiners
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Conformant
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Gold
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Aurubis AG
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Conformant
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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Conformant
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Gold
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Boliden AB
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Conformant
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Gold
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C. Hafner GmbH + Co. KG
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Conformant
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Gold
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CCR Refinery - Glencore Canada Corporation
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Conformant
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Gold
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Cendres + Metaux S.A.
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Conformant
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Gold
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Chimet S.p.A.
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Conformant
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Gold
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Daejin Indus Co., Ltd.
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Conformant
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Gold
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DODUCO Contacts and Refining GmbH
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Conformant
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Gold
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Dowa
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Conformant
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Gold
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DSC (Do Sung Corporation)
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Conformant
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Gold
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Eco-System Recycling Co., Ltd.
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Conformant
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Gold
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Emirates Gold DMCC
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Conformant
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Gold
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Geib Refining Corporation
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Conformant
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Gold
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Gold Refinery of Zijin Mining Group Co., Ltd
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Conformant
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Gold
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HeeSung Metal Ltd.
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Conformant
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Gold
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Heimerle + Meule GmbH
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Conformant
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Gold
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Heraeus Metals Hong Kong Ltd
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Conformant
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Gold
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Heraeus Precious Metals GmbH & Co. KG
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Conformant
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
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Conformant
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Gold
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Ishifuku Metal Industry Co., Ltd.
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Conformant
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Gold
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Istanbul Gold Refinery
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Conformant
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Gold
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Italpreziosi
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Conformant
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Gold
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Japan Mint
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Conformant
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Gold
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Jiangxi Copper Company Limited
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Conformant
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Gold
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant
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Conformant
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Gold
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JSC Uralelectromed
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Conformant
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Gold
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JX Nippon Mining & Metals Co., Ltd.
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Conformant
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Gold
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Kazzinc
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Conformant
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Gold
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Kennecott Utah Copper LLC
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Conformant
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Gold
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Kojima Chemicals Co., Ltd.
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Conformant
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Gold
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Korea Zinc Co., Ltd.
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Conformant
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Gold
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Kyrgyzaltyn JSC
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Conformant
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Gold
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L’Orfebre S.A.
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Conformant
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Gold
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LS-NIKKO Copper Inc.
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Conformant
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Gold
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Marsam Metals
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Conformant
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Gold
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Materion
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Conformant
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Gold
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Matsuda Sangyo Co., Ltd.
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Conformant
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Gold
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Metalor Technologies (Hong Kong) Ltd.
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Conformant
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Gold
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Metalor Technologies (Singapore) Pte., Ltd.
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Conformant
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Gold
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Metalor Technologies SA
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Conformant
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Gold
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Metalor USA Refining Corporation
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Conformant
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Gold
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METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
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Conformant
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Gold
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Mitsui Mining and Smelting Co., Ltd.
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Conformant
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Gold
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Mitsubishi Materials Corporation
|
Conformant
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Gold
|
MMTC-PAMP India Pvt., Ltd.
|
Conformant
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Gold
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Moscow Special Alloys Processing Plant
|
Conformant
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Gold
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Nadir Metal Rafineri San. Ve Tic. A.S.
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Conformant
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|
Gold
|
Nihon Material Co., Ltd.
|
Conformant
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Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
Conformant
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Gold
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Ohura Precious Metal Industry Co., Ltd.
|
Conformant
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|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
Conformant
|
|
Gold
|
OJSC Novosibirsk Refinery
|
Conformant
|
|
Gold
|
PAMP S.A.
|
Conformant
|
|
Gold
|
Planta Recuperadora de Metales SpA
|
Conformant
|
|
Gold
|
Prioksky Plant of Non-Ferrous Metals
|
Conformant
|
|
Gold
|
PT Aneka Tambang (Persero) Tbk
|
Conformant
|
|
Gold
|
PX Precinox S.A.
|
Conformant
|
|
Gold
|
Rand Refinery (Pty) Ltd.
|
Conformant
|
|
Gold
|
Redmondis PMR B.V.
|
Conformant
|
|
Gold
|
SAAMP
|
Conformant
|
|
Gold
|
Royal Canadian Mint
|
Conformant
|
|
Gold
|
Safimet S.p.A
|
Conformant
|
|
Gold
|
Samduck Precious Metals
|
Conformant
|
|
Gold
|
SAXONIA Edelmetalle GmbH
|
Conformant
|
|
Gold
|
Schone Edelmetaal B.V.
|
Conformant
|
|
Gold
|
SEMPSA Joyería Platería SA
|
Conformant
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
Conformant
|
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
Conformant
|
|
Gold
|
Singway Technology Co., Ltd.
|
Conformant
|
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
Conformant
|
|
Gold
|
Solar Applied Materials Technology Corp.
|
Conformant
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
Conformant
|
|
Gold
|
SungEel HiMetal Co., Ltd.
|
Conformant |
|
Gold
|
T.C.A S.p.A
|
Conformant
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
Conformant
|
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
Conformant
|
|
Gold
|
Tokuriki Honten Co., Ltd.
|
Conformant
|
|
Gold
|
Torecom
|
Conformant
|
|
Gold
|
Umicore Brasil Ltda.
|
Conformant
|
|
Gold
|
Umicore Precious Metals Thailand
|
Conformant
|
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
Conformant
|
|
Gold
|
United Precious Metal Refining, Inc.
|
Conformant
|
|
Gold
|
Valcambi S.A.
|
Conformant
|
|
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
Conformant
|
|
Gold
|
WIELAND Edelmetalle GmbH
|
Conformant
|
|
Gold
|
Yamakin Co., Ltd.
|
Conformant
|
|
Gold
|
Yokohama Metal Co., Ltd.
|
Conformant
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
Conformant
|
|
Gold
|
Chugai Mining
|
Active
|
|
Gold
|
KGHM Polska Miedz Spolka Akcyjna
|
Active
|
|
Gold
|
Abington Reldan Metals, LLC
|
Known
|
|
Gold
|
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
|
Known
|
|
Gold
|
Bangalore Refinery
|
Known
|
|
Gold
|
Caridad
|
Known
|
|
Gold
|
Daye Non-Ferrous Metals Mining Ltd.
|
Known
|
|
Gold
|
Degussa Sonne / Mond Goldhandel GmbH
|
Known
|
|
Gold
|
Fidelity Printers and Refiners Ltd.
|
Known
|
|
Gold
|
GCC Gujrat Gold Centre Pvt. Ltd
|
Known
|
|
Gold
|
Great Wall Precious Metals Co., Ltd. of CBPM
|
Known
|
|
Gold
|
Guangdong Jinding Gold Limited
|
Known
|
|
Gold
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
|
Known
|
|
Gold
|
Hangzhou Fuchunjiang Smelting Co., Ltd.
|
Known
|
|
Gold
|
Hunan Chenzhou Mining Co., Ltd.
|
Known
|
|
Gold
|
HwaSeong CJ CO., LTD.
|
Known
|
|
Gold
|
Kaloti Precious Metals
|
Known
|
|
Gold
|
Kazakhmys Smelting LLC
|
Known
|
|
Gold
|
Kyshtym Copper-Electrolytic Plant ZAO
|
Known
|
|
Gold
|
L'azurde Company For Jewelry
|
Known
|
|
Gold
|
Lingbao Gold Co., Ltd.
|
Known
|
|
Gold
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
|
Known
|
|
Gold
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
|
Known
|
|
Gold
|
Modeltech Sdn Bhd
|
Known
|
|
Gold
|
Morris and Watson
|
Known
|
|
Gold
|
Navoi Mining and Metallurgical Combinat
|
Known
|
|
Gold
|
Pease & Curren
|
Known
|
|
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
Known
|
|
Gold
|
Refinery of Seemine Gold Co., Ltd.
|
Known
|
|
Gold
|
Sabin Metal Corp.
|
Known
|
|
Gold
|
SAFINA A.S.
|
Known
|
|
Gold
|
Sai Refinery
|
Known
|
|
Gold
|
SAMWON METALS Corp.
|
Known
|
|
Gold
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
|
Known
|
|
Gold
|
State Research Institute Center for Physical Sciences and Technology
|
Known
|
|
Gold
|
Sudan Gold Refinery
|
Known
|
|
Gold
|
Tonling Nonferrous Metals Group Co., Ltd.
|
Known
|
|
Gold
|
Tony Goetz NV
|
Known
|
|
Gold
|
TOO Tau-Ken-Altyn
|
Known
|
|
Gold
|
Universal Precious Metals Refining Zambia
|
Known
|
|
Gold
|
Yunnan Copper Industry Co., Ltd.
|
Known
|
|
Tantalum
|
Asaka Riken Co., Ltd.
|
Conformant
|
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
Conformant
|
|
Tantalum
|
D Block Metals, Ltd.
|
Conformant
|
|
Tantalum
|
Exotech Inc.
|
Conformant
|
|
Tantalum
|
F&X Electro-Materials Ltd.
|
Conformant
|
|
Tantalum
|
FIR Metals & Resource Ltd.
|
Conformant
|
|
Tantalum
|
Global Advanced Metals Aizu
|
Conformant
|
|
Tantalum
|
Guangdong Rising Rare Metals-EO Materials Ltd.
|
Conformant
|
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.
|
Conformant
|
|
Tantalum
|
H.C. Starck Co., Ltd.
|
Conformant
|
|
Tantalum
|
H.C. Starck Hermsdorf GmbH
|
Conformant
|
|
Tantalum
|
H.C. Starck Inc.
|
Conformant
|
|
Tantalum
|
H.C. Starck Ltd.
|
Conformant
|
|
Tantalum
|
H.C. Starck Smelting GmbH & Co. KG
|
Conformant
|
|
Tantalum
|
H.C. Starck Tantalum and Niobium GmbH
|
Conformant
|
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
Conformant
|
|
Tantalum
|
Jiangxi Dinghai Tantalum & Niobum Co., Ltd.
|
Conformant
|
|
Tantalum
|
Jiangxi Tuohong New Raw Material
|
Conformant
|
|
Tantalum
|
JiuJiang Jenny New Material Co., Ltd.
|
Conformant
|
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
Conformant
|
|
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
Conformant
|
|
Tantalum
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
|
Conformant
|
|
Tantalum
|
KEMET Blue Metals
|
Conformant
|
|
Tantalum
|
Kemet Blue Powder
|
Conformant
|
|
Tantalum
|
LSM Brasil S.A.
|
Conformant
|
|
Tantalum
|
Metallurgical Products India Pvt., Ltd.
|
Conformant
|
|
Tantalum
|
Mineracao Taboca S.A.
|
Conformant
|
|
Tantalum
|
Mitsui Mining and Smelting Co., Ltd.
|
Conformant
|
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
Conformant
|
|
Tantalum
|
NPM Silmet AS
|
Conformant
|
|
Tantalum
|
Power Resources, Ltd.
|
Conformant
|
|
Tantalum
|
QuantumClean
|
Conformant
|
|
Tantalum
|
Resind Industria e Comercio Ltda.
|
Conformant
|
|
Tantalum
|
Solikamsk Magnesium Works OAO
|
Conformant
|
|
Tantalum
|
Taki Chemical Co., Ltd.
|
Conformant
|
|
Tantalum
|
Telex Metals
|
Conformant
|
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
Conformant
|
|
Tantalum
|
XinXing Haorong Electronic Material Co., Ltd.
|
Conformant
|
|
Tantalum
|
Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
Conformant
|
|
Tin
|
Alpha
|
Conformant
|
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
Conformant
|
|
Tin
|
Chifeng Dajingzi Tin Inudstry Co.,Ltd
|
Conformant
|
|
Tin
|
China Tin Group Co., Ltd.
|
Conformant
|
|
Tin
|
CV Ayi Jaya
|
Conformant
|
|
Tin
|
CV Dua Sekawan
|
Conformant
|
|
Tin
|
CV Gita Pesona
|
Conformant
|
|
Tin
|
CV United Smelting
|
Conformant
|
|
Tin
|
CV Venus Inti Perkasa
|
Conformant
|
|
Tin
|
Dowa
|
Conformant
|
|
Tin
|
EM Vinto
|
Conformant
|
|
Tin
|
Fenix Metals
|
Conformant
|
|
Tin
|
Gejiu Fengming Metallurgy Chemical Plant
|
Conformant
|
|
Tin
|
Gejiu Jinye Mineral Company
|
Conformant
|
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
Conformant
|
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
Conformant
|
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
Conformant
|
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd
|
Conformant
|
|
Tin
|
Guanyang Guida Nonferrous Metal Smelting Plant
|
Conformant
|
|
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
Conformant
|
|
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
Conformant
|
|
Tin
|
Magnu's Minerais Metais e Ligas Ltda.
|
Conformant
|
|
Tin
|
Malaysia Smelting Corporation (MSC)
|
Conformant
|
|
Tin
|
Melt Metais e Ligas S.A.
|
Conformant
|
|
Tin
|
Metallic Resources, Inc.
|
Conformant
|
|
Tin
|
Metallo Belgium N.V.
|
Conformant
|
|
Tin
|
Metallo Spain S.L.U.
|
Conformant
|
|
Tin
|
Mineração Taboca S.A.
|
Conformant
|
|
Tin
|
Minsur
|
Conformant
|
|
Tin
|
Mitsubishi Materials Corporation
|
Conformant
|
|
Tin
|
Modeltech Sdn Bhd
|
Conformant
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
Conformant
|
|
Tin
|
Operaciones Metalurgical S.A.
|
Conformant
|
|
Tin
|
PT Aries Kencana Sejahtera
|
Conformant
|
|
Tin
|
PT Artha Cipta Langgeng
|
Conformant
|
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
Conformant
|
|
Tin
|
PT Babel Inti Perkasa
|
Conformant
|
|
Tin
|
PT Bangka Prima Tin
|
Conformant
|
|
Tin
|
PT Bangka Serumpun
|
Conformant
|
|
Tin
|
PT Bangka Tin Industry
|
Conformant
|
|
Tin
|
PT Belitung Industri Sejahtera
|
Conformant
|
|
Tin
|
PT Bukit Timah
|
Conformant
|
|
Tin
|
PT DS Jaya Abadi
|
Conformant
|
|
Tin
|
PT Inti Stania Prima
|
Conformant
|
|
Tin
|
PT Karimun Mining
|
Conformant
|
|
Tin
|
PT Kijang Jaya Mandiri
|
Conformant
|
|
Tin
|
PT Menara Cipta Mulia
|
Conformant
|
|
Tin
|
PT Mitra Stania Prima
|
Conformant
|
|
Tin
|
PT Panca Mega Persada
|
Conformant
|
|
Tin
|
PT Premium Tin Indonesia
|
Conformant
|
|
Tin
|
PT Prima Timah Utama
|
Conformant
|
|
Tin
|
PT Rajehan Ariq
|
Conformant
|
|
Tin
|
PT Refined Bangka Tin
|
Conformant
|
|
Tin
|
PT Sariwiguna Binasentosa
|
Conformant
|
|
Tin
|
PT Stanindo Inti Perkasa
|
Conformant
|
|
Tin
|
PT Sukses Inti Makmur
|
Conformant
|
|
Tin
|
PT Sumber Jaya Indah
|
Conformant
|
|
Tin
|
PT Timah (Persero) Tbk Kundur
|
Conformant
|
|
Tin
|
PT Timah (Persero) Tbk Mentok
|
Conformant
|
|
Tin
|
PT Tinindo Inter Nusa
|
Conformant
|
|
Tin
|
PT Tommy Utama
|
Conformant
|
|
Tin
|
Resind Industria e Comercio Ltda.
|
Conformant
|
|
Tin
|
Rui Da Hung
|
Conformant
|
|
Tin
|
Soft Metais Ltda.
|
Conformant
|
|
Tin
|
Thaisarco
|
Conformant
|
|
Tin
|
White Solder Metalurgia e Mineração Ltda.
|
Conformant
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
Conformant
|
|
Tin
|
Yunnan Tin Group (Holding) Company Limited
|
Conformant
|
|
Tin
|
An Vinh Joint Stock Mineral Processing Company
|
Known
|
|
Tin
|
CNMC (Guangxi) PGMA Co., Ltd.
|
Known
|
|
Tin
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
|
Known
|
|
Tin
|
Estanho de Rondonia S.A.
|
Known
|
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
Known
|
|
Tin
|
Huichang Jinshunda Tin Co., Ltd.
|
Known
|
|
Tin
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company
|
Known
|
|
Tin
|
Super Ligas
|
Known
|
|
Tin
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company
|
Known
|
|
Tungsten
|
ACL Metais Eireli
|
Conformant
|
|
Tungsten
|
A.L.M.T. TUNGSTEN Corp.
|
Conformant
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
Conformant
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
Conformant
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Ganzhou Haichung Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
Conformant
|
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
Conformant
|
|
Tungsten
|
Global Tungsten & Powders Corp.
|
Conformant
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
H.C. Starck Smelting GmbH & Co. KG
|
Conformant
|
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
Conformant
|
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
Conformant
|
|
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
Conformant
|
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
Conformant
|
|
Tungsten
|
Hydrometallurg, JSC
|
Conformant
|
|
Tungsten
|
Japan New Metals Co., Ltd.
|
Conformant
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
Conformant
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
Conformant
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
Conformant
|
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Kennametal Fallon
|
Conformant
|
|
Tungsten
|
Kennametal Huntsville
|
Conformant
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Masa Tungsten Chemical LLC (MTC)
|
Conformant
|
|
Tungsten
|
Moliren Ltd.
|
Conformant
|
|
Tungsten
|
Niagara Refining LLC
|
Conformant
|
|
Tungsten
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
|
Conformant
|
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
Conformant
|
|
Tungsten
|
South-East Nonferrous Metal Company Limted of Hengyang City
|
Conformant
|
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Unecha Refractory Metals Plant
|
Conformant
|
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
Conformant
|
|
Tungsten
|
Woltech Korea Co., Ltd.
|
Conformant
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
Conformant
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
|
Conformant
|
|
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
Conformant
|
|
Tungsten
|
Hunan Litian Tungsten Industry Co., Ltd.
|
Known
|
|
Tunsten
|
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
|
Known
|
|
Tungsten
|
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
|
Known
|
VII. Country of Origin Information
The countries of origin of the Conformant SORs in the table above may have included the countries in the categories listed below. Country of
origin information has been provided to the Company by the Service Provider. The countries below are categorized by risk level, as indicated for each category.
L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of 3TG minerals from the DRC and its
adjoining countries: Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana,
Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Korea, Republic of, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Myanmar, Namibia,
Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Turkey,
United Kingdom, United States, Uzbekistan, Vietnam, and Zimbabwe.
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG minerals:
Kenya, Mozambique, South Africa and UAE (Gold only).
L3 - The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda,
United Republic of Tanzania and Zambia.
Some of the Conformant SORs also may have sourced in whole or in part from recycled or scrap sources.
Tapestry endeavored to determine the mine location of origin of the necessary 3TG minerals contained in its in-scope products by requesting
that the suppliers provide it with a completed CMRT and through the other procedures followed by Tapestry and its Service Provider that are described in this Conflict Minerals Report.
VIII. Steps to Improve Due Diligence
Tapestry intends to further improve upon its supply chain due diligence via the following measures:
|
●
|
Encourage new suppliers to partner with upstream suppliers to identify source of 3TG minerals;
|
|
●
|
Encourage suppliers that have not yet done so to adopt and communicate their own responsible sourcing policies relating to 3TG
minerals;
|
|
●
|
Continue to provide conflict minerals-specific in person training to our suppliers; and
|
|
●
|
Continue to distribute and provide training on our Supplier Code of Conduct to existing and new suppliers.
|
All of these steps are in addition to the steps that Tapestry took in respect of its 2018 compliance, which it intends to continue to take for
2019 to the extent applicable.
This document contains forward-looking statements based on management's current expectations. These statements can be identified by the use of
forward-looking terminology such as “may,” “will,” “should,” “expect,” “intend,” “become,” “future,” “continue,” “strive,” “seek” or comparable terms. Future results may differ materially from management's current expectations, based upon risks
and uncertainties such as (1) the continued implementation of satisfactory traceability and other compliance measures by Tapestry’s direct and indirect suppliers on a timely basis, (2) whether SORs and other market participants responsibly source
3TG minerals, (3) political and regulatory developments within the DRC region, the United States or elsewhere, and (4) changes in Tapestry’s supplier base, etc. Undue reliance should not be placed on these forward-looking statements, which speak
only as of the date of the filing of this document. Tapestry does not intend, and undertakes no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of the filing of this document to reflect
the occurrence of unanticipated events. Please refer to Tapestry’s latest Annual Report on Form 10-K for the fiscal year ended June 30, 2018 and its other filings with the SEC for a complete list of risks and other factors.