UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

 

Specialized Disclosure Report

KEURIG DR PEPPER INC.

(Exact name of registrant as specified in its charter)

 

Delaware			001-33829			98-0517725
(State or other jurisdiction of incorporation or organization)			(Commission File Number)			(I.R.S. Employer Identification Number)

53 South Avenue

Burlington, Massachusetts 01803

(781) 418-7000

(Address of registrant’s principal executive office) (Zip Code)

James L. Baldwin, Jr.

Chief Legal Officer and General Counsel

53 South Avenue

Burlington, Massachusetts 01803

(781) 418-7000

(Name and telephone number, including area code, of 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 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, 2019

 

 

---

Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

A copy of Keurig Dr Pepper Inc.’s ("KDP's") Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019 is provided as Exhibit 1.01 hereto and is publicly available at https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance and http://investors.keurigdrpepper.com/sec-filings.*

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report.

Exhibit No.			Description
1.01			Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019.

_____________________________

* The reference to KDP’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD nor the Conflicts Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.

---

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.

KEURIG DR PEPPER INC.

By:

/s/ James L. Baldwin

May 26, 2020

James L. Baldwin

(Date)

Chief Legal Officer, Corporate General Counsel and Secretary

---

Exhibit 1.01

Keurig Dr Pepper Inc.

Conflict Minerals Report

For the reporting period from January 1, 2019 to December 31, 2019

Introduction

Keurig Dr Pepper, Inc. (the “Company,” “KDP,” “we,” “us” or “our”) is committed to sourcing products, components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. To that end, we are committed to the ethical sourcing of minerals including tin, tantalum, tungsten and gold. There is concern that these “Conflict Minerals” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.

KDP has prepared this Conflict Minerals Report (this “Report”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2019 to December 31, 2019 (the “Reporting Period”).

This Report describes KDP’s due diligence process and compliance with the Rule’s requirements. The Rule requires disclosure of certain information when a reporting company manufactures, or contracts to manufacture, products which contain the minerals specified in the Rule, if those minerals are necessary to the functionality or production of such products. The specified minerals, which the Company collectively refers to in this Report as “3TG,” are gold, columbite-tantalite (coltan), cassiterite and wolframite and their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

Reporting Scope

As described in this Report, certain 3TG are necessary to the functionality or production of products that the Company contracted to manufacture, or manufactured, during the Reporting Period. These products are the Company’s Keurig brewers and milk frother products, as well as coffee brewer products manufactured and sold by Keurig Canada Inc., an indirect wholly-owned subsidiary of KDP (such in-scope products, collectively, the “Covered Products”). There are no additional products that KDP contracted to manufacture, or manufactured, during the Reporting Period which are considered in-scope products according to the Rule.

Our Approach

KDP uses components and materials containing 3TG in its Covered Products but does not purchase 3TG directly from mines, smelters, or refiners. Therefore, we must collaborate with suppliers, industry peers, and other stakeholders as described in this Report to conduct appropriate due diligence on our upstream supply chains.

KDP is a member of the Responsible Minerals Initiative (“RMI”), a multi-industry initiative addressing Conflict Minerals issues in the supply chain (unique member code KEUR). The RMI’s Conflict Minerals Reporting Template (“CMRT”) is a widely-used standard form to collect information from the supply chain, including the names of 3TG smelters or refiners (“SORs”). RMI also manages the Responsible Minerals Assurance Process (“RMAP”), which uses independent third-party audits to assess whether 3TG SORs have systems in place to source 3TG in conformance with the Organisation for Economic Co-

1

---

operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition (“OECD Guidance”)¹. We use the CMRT to survey our suppliers and identify SORs in our supply chain, and the RMAP to determine the country of origin and conformance status of minerals.

In accordance with the Rule, KDP has in good faith conducted a reasonable country of origin inquiry (“RCOI”) regarding 3TG. This country of origin inquiry was designed to determine whether any of the 3TG used in the Covered Products originated in the Covered Countries and whether any of such 3TG may be from recycled or scrap sources. The Company also performed due diligence on the source and chain of custody of such 3TG based on the OECD Guidance and as described in more detail below.

Reasonable Country of Origin Inquiry

In 2019, KDP identified its direct suppliers believed or known to have provided materials, components or products which may contain Conflict Minerals, as well as one indirect component supplier with whom KDP engages directly (such direct suppliers and indirect supplier, collectively, the “Suppliers”). KDP requested that each Supplier submit information to KDP using the CMRT.

The information submitted by KDP’s Suppliers in their CMRTs included information gathered by those Suppliers about the smelters and refiners identified in their own supply chains which KDP utilized to conduct further due diligence. As described in more detail below, KDP’s Responsible Sourcing team reviewed and analyzed each CMRT received.

KDP compared the list of SORs reported by Suppliers against the RMI’s Smelter Database² to first determine which of the reported entities are known to be true SORs of 3TG (“Eligible SORs”). The list of Eligible SORs that our Suppliers reported as being in their supply chains is set forth in Annex I. The list of countries from which KDP believes the 3TG in its Covered Products may have originated is set forth in Annex II. This information was obtained through KDP’s membership in the RMI, using the RCOI report dated March 27, 2020. Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP. Through our RCOI, we found that:

–Some 3TG is sourced through SORs that are not yet RMAP-Conformant and therefore we have not yet determined the country of origin of those minerals;

–Some 3TG is sourced from RMAP-Conformant SORs, including SORs that source responsibly from the Covered Countries; and

–Some 3TG also may have originated from recycled or scrap sources.

___________________

¹ OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition, 2016; https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf

² The RMI Smelter Database was exported and referenced as of our cutoff date of April 29, 2020:

http://www.responsiblemineralsinitiative.org/members/smelter-database/

2

---

In addition to the RMI RCOI data available to KDP, select Suppliers reported to KDP that they source from the Covered Countries in their CMRTs:

–Several Suppliers reported that they source from the Covered Countries and reported to KDP the names of the SORs found to source from the Covered Counties. KDP referenced the RMI Smelter Database and confirmed that the SOR names provided are RMAP Conformant.

–Two Suppliers provided SOR names that we confirmed have ceased operations or have been re-classified as non-smelters by the RMI.

–Five Suppliers reported that they source from the Covered Countries but did not provide the corresponding SOR names. In this case, KDP could not cross reference Smelter Database for SOR Conformance status.

Ultimately, KDP relies on the RMI RCOI data as the most accurate information for our RCOI.

The information obtained from our Suppliers indicated that there was reason to believe that a portion of 3TG used in the Covered Products may have originated in the Covered Countries and were not exclusively from recycled or scrap sources, triggering the due diligence steps described in the following sections.

Due Diligence

Design of Due Diligence

KDP designed its due diligence measures in accordance with the OECD Guidance.

The OECD Guidance utilizes a five-step process for due diligence:

Step 1: Establish Strong Company Management Systems

Step 2: Identify and Assess Risks in the Supply Chain

Step 3: Design and Implement a Strategy to Respond to Identified Risks

Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices

Step 5: Report Annually on Supply Chain Due Diligence

Below is a description of KDP’s due diligence measures performed for the Reporting Period.

Due Diligence Measures Performed

Step 1: Establish Strong Company Management Systems:

The Company has adopted a policy relating to 3TG incorporating the standards set forth in the OECD Guidance (the “Conflict Minerals Policy”). The Conflict Minerals Policy is available on KDP’s website at https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance.

KDP’s Conflict Minerals Policy states in part that KDP is committed to: (1) supporting the aims and objectives of the U.S. legislation on the disclosure of 3TG; (2) not knowingly procuring 3TG that originates from facilities in the Covered Countries that are not considered conflict free; and (3) ensuring compliance with the KDP Conflict Minerals Policy.

3

---

Members from the Company’s Supply Chain, Legal, and Sustainability Teams were involved in the due diligence process, which was led by the Company’s Responsible Sourcing Team. Members of our Executive Leadership Team were briefed on the Company’s due diligence procedures and results, and reviewed and approved this Report.

Requirements related to Conflict Minerals and related due diligence activities are generally included in our most significant supplier contracts relating to Covered Products.

KDP has established a system of controls and transparency to determine the SORs in its 3TG supply chain by creating a process to engage Suppliers. KDP uses a third party software platform to collect, store, analyze and aggregate Supplier data for reporting purposes. It is also used to send automated reminders to Suppliers throughout the due diligence process.

KDP provided Suppliers with links to the RMI e-learning academy and other resources. Throughout the due diligence process, KDP also engaged in ongoing communication and provided support to its Suppliers to facilitate the completion of their CMRTs.

Suppliers and employees are encouraged to report any ethical concerns or violations by any KDP employee or agent acting on behalf of the supplier or KDP. Concerns or violations may be reported in the following ways:

•Call: 800-349-4248 (U.S. & Canada) or 001-888-243-8076 (Mexico).

•Mail: Attn: General Counsel | Keurig Dr Pepper | 5301 Legacy Drive | Plano, TX 75024.

•Web: www.integrity-helpline.com/kdp.jsp

KDP retains Conflict Minerals documentation materials for five years after receipt.

Step 2: Identify and Assess Risks in the Supply Chain:

As described above, as part of its due diligence process KDP identified in scope Suppliers and requested that the Suppliers submit a completed CMRT.

Via our software platform, KDP then reviewed Suppliers’ completed CMRTs against a set of internally developed criteria for completeness and consistency. While 100% of Suppliers surveyed submitted a CMRT this year, there were several CMRTs that were incomplete or contained inconsistencies which we were unable to resolve with the supplier before our cutoff date of April 29, 2020 despite numerous follow up requests. We intend to work with these suppliers to improve their responses year over year.

For Suppliers that indicated in their responses that they or a supplier in their supply chain did use 3TG in their part(s) and/or product(s) during the Reporting Period and provided the applicable smelter or refiner information, the Company reconciled the reported SORs against the RMI Smelter Database, which contains RMAP SOR Conformance status. (Available to RMI members at http://www.responsiblemineralsinitiative.org/members/smelter-database/)

Step 3: Design and Implement a Strategy to Respond to Identified Risks:

Where SORs were reported that are not RMAP-Conformant or Active (engaged in the RMAP program but not yet audited), KDP sent a notice via the platform asking applicable Suppliers to either work with their supply-chain to request the smelter to participate in the RMAP audit program, and/or work to transition away from the smelter, depending on level of identified risk. There were also instances where inaccurate or outdated SOR information was reported to us, for example: smelters no longer in operation, or entities

4

---

that could not be identified as known SORs. In these cases, we sent a notification to Suppliers asking them to work with their supply chain to obtain accurate smelter information. Our smelter action requests specified that we expect to see continuous improvement year over year in the reported smelter information.

In addition to the above, we also review our Suppliers’ CMRTs for due diligence activities, such as whether they have their own Conflict Minerals Policy. See the Due Diligence Results section below where we report on the number of Suppliers who provided a policy that indicates a commitment to reasonably ensuring that only conflict-free materials and components are used in products/parts that are sold to KDP.

Further, several Suppliers indicated in their responses that they have not received complete information from their suppliers. When this happened, we requested that they work to improve their response rate.

Lastly, recognizing that the complexity of this issue requires a collaborative and cross-industry approach, we actively participate in the RMI’s China Smelter Engagement Team (the “China SET”). China SET’s purpose is to conduct coordinated outreach to SORs to encourage them to participate in RMAP or other equivalent third-party validation schemes. As a member of China SET, we work as the Single Point of Contact for three smelters to facilitate their engagement with RMI, including to communicate RMAP requirements to them, and to encourage them to maintain their status on the Conformant Smelter List.

Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices

As a member of the RMI, KDP leverages information from the independent third party audits of the SORs facilitated by initiatives such as the RMI’s RMAP and the London Bullion Market Association (LBMA), or Responsible Jewelry Council (RJC).

Step 5: Report Annually on Supply Chain Due Diligence:

As discussed above, KDP is reporting on supply chain due diligence by publishing a Conflict Minerals Report for the Reporting Period on KDP’s corporate website (https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance).

Due Diligence Results

Many of our Supplier responses represented their supply chain at a company level rather than being product specific. Therefore, the list of SORs contained in this Report may contain more SORs than those that actually process the conflict minerals contained in our products.

5

---

The total number of unique entities reported as SORs by the KDP supply base as a result of the 2019 survey was 361. Of these:

–296 have been confirmed as being Eligible SORs by the RMI

–61 were known to not be Eligible SORs, and

–4 reported entities’ status could not be confirmed as of our cutoff date of April 29, 2020. This is compared to 6 entities in the prior year.

Of the 296 Eligible SORs reported by KDP Suppliers (for detail by mineral, please refer to Figure 1, below):

–234, or 79% had been validated by the RMI RMAP program as Conformant to an RMI recognized audit protocol (RMAP, LBMA, or RJC), a 2% decrease from the prior year. This change is mainly attributed to a large number of previously operating Conformant Tin smelters which temporarily or permanently ceased operations during 2019 due to regulatory changes in Indonesia.

–9 were in process or communication with RMAP, but had not achieved Conformant status as of April 26, 2020.

–The remaining 53 have not been validated by the RMAP program as Conformant.

A list of all 296 of the Eligible SORs identified during the due diligence process is included in Annex I to this Report.

Figure 1: Conformance Status of Eligible SORs Reported by KDP Suppliers:

The 61 entities reported by our Suppliers that are not currently considered Eligible SORs fell into two categories:

–6 companies that had been reclassified by RMI due to better understanding of their business (group company or did not meet the definition of a smelter), and

–55 Eligible SORs that had either temporarily or permanently suspended operations.

As described above, we also requested Suppliers provide a policy that indicates a commitment to reasonably ensuring that only conflict free materials and components are used in products/parts sold to KDP. 58% of Suppliers provided a policy that meets this criterion, up from 40% in the prior year.

6

---

Future Due Diligence Improvements

KDP plans to continue to improve its due diligence measures by taking the following steps, among others:

–Continuing to engage with Suppliers to obtain current, accurate and complete information about our supply chain;

–Continuing to encourage Suppliers to improve their own due diligence processes including their own conflict minerals policy; and

–Continuing to encourage Suppliers to request non-Conformant smelters to participate in the RMAP audit program, and/or work to transition away from such SORs.

Determination

Based on the information obtained pursuant to the due diligence process described above, KDP believes that the SORs that may have been used to process the 3TG in KDP products include the SORs listed in Annex I below. The list of countries from which KDP believes the 3TG in their products may have originated, as well as any materials from recycled and scrap sources, is set forth in Annex II. The SOR information collected from our Suppliers continued to include a number of SORs that had not been audited and determined to be RMAP Conformant by the RMI, or any other recognized organization.

KDP has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with KDP’s Conflict Minerals Policy, may affect KDP’s future determinations.

7

---

Annex I

List of Smelters and Refiners

The table below represents a consolidated list of SORs (296 in total) identified by KDP’s Suppliers. The results are based on:

•Information provided by KDP’s Suppliers in their CMRTs; and

•The Conformance status indicated in the RMI Smelter Database as of April 29, 2020

“SOR Country” refers to the location of the SOR, not the source of minerals. Refer to Annex II for the list of countries from which 3TG may have originated.

SORs that have been validated by the RMAP program as Conformant:

Metal			SOR Name			SOR Country			SOR ID
Gold			8853 S.p.A.			ITALY			CID002763
Gold			Advanced Chemical Company			UNITED STATES OF AMERICA			CID000015
Gold			Aida Chemical Industries Co., Ltd.			JAPAN			CID000019
Gold			Al Etihad Gold Refinery DMCC			UNITED ARAB EMIRATES			CID002560
Gold			Allgemeine Gold-und Silberscheideanstalt A.G.			GERMANY			CID000035
Gold			Almalyk Mining and Metallurgical Complex (AMMC)			UZBEKISTAN			CID000041
Gold			AngloGold Ashanti Corrego do Sitio Mineracao			BRAZIL			CID000058
Gold			Argor-Heraeus S.A.			SWITZERLAND			CID000077
Gold			Asahi Pretec Corp.			JAPAN			CID000082
Gold			Asahi Refining Canada Ltd.			CANADA			CID000924
Gold			Asahi Refining USA Inc.			UNITED STATES OF AMERICA			CID000920
Gold			Asaka Riken Co., Ltd.			JAPAN			CID000090
Gold			AU Traders and Refiners			SOUTH AFRICA			CID002850
Gold			Aurubis AG			GERMANY			CID000113
Gold			Bangalore Refinery			INDIA			CID002863
Gold			Bangko Sentral ng Pilipinas (Central Bank of the Philippines)			PHILIPPINES			CID000128
Gold			Boliden AB			SWEDEN			CID000157
Gold			C. Hafner GmbH + Co. KG			GERMANY			CID000176
Gold			CCR Refinery - Glencore Canada Corporation			CANADA			CID000185
Gold			Cendres + Metaux S.A.			SWITZERLAND			CID000189
Gold			Chimet S.p.A.			ITALY			CID000233
Gold			Chugai Mining			JAPAN			CID000264
Gold			DODUCO Contacts and Refining GmbH			GERMANY			CID000362
Gold			Dowa			JAPAN			CID000401
Gold			DS PRETECH Co., Ltd.			KOREA, REPUBLIC OF			CID003195
Gold			DSC (Do Sung Corporation)			KOREA, REPUBLIC OF			CID000359
Gold			Eco-System Recycling Co., Ltd. East Plant			JAPAN			CID000425
Gold			Eco-System Recycling Co., Ltd. North Plant			JAPAN			CID003424

8

---

Gold			Eco-System Recycling Co., Ltd. West Plant			JAPAN			CID003425
Gold			Emirates Gold DMCC			UNITED ARAB EMIRATES			CID002561
Gold			Geib Refining Corporation			UNITED STATES OF AMERICA			CID002459
Gold			Gold Refinery of Zijin Mining Group Co., Ltd.			CHINA			CID002243
Gold			Heimerle + Meule GmbH			GERMANY			CID000694
Gold			Heraeus Metals Hong Kong Ltd.			CHINA			CID000707
Gold			Heraeus Precious Metals GmbH & Co. KG			GERMANY			CID000711
Gold			Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.			CHINA			CID000801
Gold			Ishifuku Metal Industry Co., Ltd.			JAPAN			CID000807
Gold			Istanbul Gold Refinery			TURKEY			CID000814
Gold			Italpreziosi			ITALY			CID002765
Gold			Japan Mint			JAPAN			CID000823
Gold			Jiangxi Copper Co., Ltd.			CHINA			CID000855
Gold			JSC Uralelectromed			RUSSIAN FEDERATION			CID000929
Gold			JX Nippon Mining & Metals Co., Ltd.			JAPAN			CID000937
Gold			Kazzinc			KAZAKHSTAN			CID000957
Gold			Kennecott Utah Copper LLC			UNITED STATES OF AMERICA			CID000969
Gold			KGHM Polska Miedz Spolka Akcyjna			POLAND			CID002511
Gold			Kojima Chemicals Co., Ltd.			JAPAN			CID000981
Gold			Korea Zinc Co., Ltd.			KOREA, REPUBLIC OF			CID002605
Gold			Kyrgyzaltyn JSC			KYRGYZSTAN			CID001029
Gold			L'Orfebre S.A.			ANDORRA			CID002762
Gold			LS-NIKKO Copper Inc.			KOREA, REPUBLIC OF			CID001078
Gold			LT Metal Ltd.			KOREA, REPUBLIC OF			CID000689
Gold			Marsam Metals			BRAZIL			CID002606
Gold			Materion			UNITED STATES OF AMERICA			CID001113
Gold			Matsuda Sangyo Co., Ltd.			JAPAN			CID001119
Gold			Metalor Technologies (Hong Kong) Ltd.			CHINA			CID001149
Gold			Metalor Technologies (Singapore) Pte., Ltd.			SINGAPORE			CID001152
Gold			Metalor Technologies (Suzhou) Ltd.			CHINA			CID001147
Gold			Metalor Technologies S.A.			SWITZERLAND			CID001153
Gold			Metalor USA Refining Corporation			UNITED STATES OF AMERICA			CID001157
Gold			Metalurgica Met-Mex Penoles S.A. De C.V.			MEXICO			CID001161
Gold			Mitsubishi Materials Corporation			JAPAN			CID001188
Gold			Mitsui Mining and Smelting Co., Ltd.			JAPAN			CID001193
Gold			MMTC-PAMP India Pvt., Ltd.			INDIA			CID002509
Gold			Moscow Special Alloys Processing Plant			RUSSIAN FEDERATION			CID001204
Gold			Nadir Metal Rafineri San. Ve Tic. A.S.			TURKEY			CID001220
Gold			Nihon Material Co., Ltd.			JAPAN			CID001259
Gold			Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH			AUSTRIA			CID002779
Gold			Ohura Precious Metal Industry Co., Ltd.			JAPAN			CID001325
Gold			OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)			RUSSIAN FEDERATION			CID001326

9

---

Gold			OJSC Novosibirsk Refinery			RUSSIAN FEDERATION			CID000493
Gold			PAMP S.A.			SWITZERLAND			CID001352
Gold			Planta Recuperadora de Metales SpA			CHILE			CID002919
Gold			Prioksky Plant of Non-Ferrous Metals			RUSSIAN FEDERATION			CID001386
Gold			PT Aneka Tambang (Persero) Tbk			INDONESIA			CID001397
Gold			PX Precinox S.A.			SWITZERLAND			CID001498
Gold			Rand Refinery (Pty) Ltd.			SOUTH AFRICA			CID001512
Gold			REMONDIS PMR B.V.			NETHERLANDS			CID002582
Gold			Royal Canadian Mint			CANADA			CID001534
Gold			SAAMP			FRANCE			CID002761
Gold			Safimet S.p.A			ITALY			CID002973
Gold			Samduck Precious Metals			KOREA, REPUBLIC OF			CID001555
Gold			SAXONIA Edelmetalle GmbH			GERMANY			CID002777
Gold			SEMPSA Joyeria Plateria S.A.			SPAIN			CID001585
Gold			Shandong Zhaojin Gold & Silver Refinery Co., Ltd.			CHINA			CID001622
Gold			Sichuan Tianze Precious Metals Co., Ltd.			CHINA			CID001736
Gold			Singway Technology Co., Ltd.			TAIWAN, PROVINCE OF CHINA			CID002516
Gold			SOE Shyolkovsky Factory of Secondary Precious Metals			RUSSIAN FEDERATION			CID001756
Gold			Solar Applied Materials Technology Corp.			TAIWAN, PROVINCE OF CHINA			CID001761
Gold			Sumitomo Metal Mining Co., Ltd.			JAPAN			CID001798
Gold			SungEel HiMetal Co., Ltd.			KOREA, REPUBLIC OF			CID002918
Gold			T.C.A S.p.A			ITALY			CID002580
Gold			Tanaka Kikinzoku Kogyo K.K.			JAPAN			CID001875
Gold			The Refinery of Shandong Gold Mining Co., Ltd.			CHINA			CID001916
Gold			Tokuriki Honten Co., Ltd.			JAPAN			CID001938
Gold			TOO Tau-Ken-Altyn			KAZAKHSTAN			CID002615
Gold			Torecom			KOREA, REPUBLIC OF			CID001955
Gold			Umicore Brasil Ltda.			BRAZIL			CID001977
Gold			Umicore Precious Metals Thailand			THAILAND			CID002314
Gold			Umicore S.A. Business Unit Precious Metals Refining			BELGIUM			CID001980
Gold			United Precious Metal Refining, Inc.			UNITED STATES OF AMERICA			CID001993
Gold			Valcambi S.A.			SWITZERLAND			CID002003
Gold			Western Australian Mint (T/a The Perth Mint)			AUSTRALIA			CID002030
Gold			WIELAND Edelmetalle GmbH			GERMANY			CID002778
Gold			Yamakin Co., Ltd.			JAPAN			CID002100
Gold			Yokohama Metal Co., Ltd.			JAPAN			CID002129
Gold			Zhongyuan Gold Smelter of Zhongjin Gold Corporation			CHINA			CID002224
Tantalum			Asaka Riken Co., Ltd.			JAPAN			CID000092
Tantalum			Changsha South Tantalum Niobium Co., Ltd.			CHINA			CID000211
Tantalum			CP Metals Inc.			UNITED STATES OF AMERICA			CID003402

10

---

Tantalum			D Block Metals, LLC			UNITED STATES OF AMERICA			CID002504
Tantalum			Exotech Inc.			UNITED STATES OF AMERICA			CID000456
Tantalum			F&X Electro-Materials Ltd.			CHINA			CID000460
Tantalum			FIR Metals & Resource Ltd.			CHINA			CID002505
Tantalum			Global Advanced Metals Aizu			JAPAN			CID002558
Tantalum			Global Advanced Metals Boyertown			UNITED STATES OF AMERICA			CID002557
Tantalum			Guangdong Zhiyuan New Material Co., Ltd.			CHINA			CID000616
Tantalum			H.C. Starck Co., Ltd.			THAILAND			CID002544
Tantalum			H.C. Starck Hermsdorf GmbH			GERMANY			CID002547
Tantalum			H.C. Starck Inc.			UNITED STATES OF AMERICA			CID002548
Tantalum			H.C. Starck Ltd.			JAPAN			CID002549
Tantalum			H.C. Starck Smelting GmbH & Co. KG			GERMANY			CID002550
Tantalum			H.C. Starck Tantalum and Niobium GmbH			GERMANY			CID002545
Tantalum			Hengyang King Xing Lifeng New Materials Co., Ltd.			CHINA			CID002492
Tantalum			Jiangxi Dinghai Tantalum & Niobium Co., Ltd.			CHINA			CID002512
Tantalum			Jiangxi Tuohong New Raw Material			CHINA			CID002842
Tantalum			JiuJiang JinXin Nonferrous Metals Co., Ltd.			CHINA			CID000914
Tantalum			Jiujiang Tanbre Co., Ltd.			CHINA			CID000917
Tantalum			Jiujiang Zhongao Tantalum & Niobium Co., Ltd.			CHINA			CID002506
Tantalum			KEMET Blue Metals			MEXICO			CID002539
Tantalum			LSM Brasil S.A.			BRAZIL			CID001076
Tantalum			Metallurgical Products India Pvt., Ltd.			INDIA			CID001163
Tantalum			Mineracao Taboca S.A.			BRAZIL			CID001175
Tantalum			Mitsui Mining and Smelting Co., Ltd.			JAPAN			CID001192
Tantalum			Ningxia Orient Tantalum Industry Co., Ltd.			CHINA			CID001277
Tantalum			NPM Silmet AS			ESTONIA			CID001200
Tantalum			PRG Dooel			MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF			CID002847
Tantalum			QuantumClean			UNITED STATES OF AMERICA			CID001508
Tantalum			Resind Industria e Comercio Ltda.			BRAZIL			CID002707
Tantalum			Solikamsk Magnesium Works OAO			RUSSIAN FEDERATION			CID001769
Tantalum			Taki Chemical Co., Ltd.			JAPAN			CID001869
Tantalum			Telex Metals			UNITED STATES OF AMERICA			CID001891
Tantalum			Ulba Metallurgical Plant JSC			KAZAKHSTAN			CID001969
Tantalum			XinXing HaoRong Electronic Material Co., Ltd.			CHINA			CID002508
Tantalum			Yanling Jincheng Tantalum & Niobium Co., Ltd.			CHINA			CID001522
Tin			Alpha			UNITED STATES OF AMERICA			CID000292
Tin			Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.			CHINA			CID000228
Tin			Chifeng Dajingzi Tin Industry Co., Ltd.			CHINA			CID003190
Tin			China Tin Group Co., Ltd.			CHINA			CID001070
Tin			Dowa			JAPAN			CID000402

11

---

Tin			EM Vinto			BOLIVIA (PLURINATIONAL STATE OF)			CID000438
Tin			Fenix Metals			POLAND			CID000468
Tin			Gejiu Kai Meng Industry and Trade LLC			CHINA			CID000942
Tin			Gejiu Non-Ferrous Metal Processing Co., Ltd.			CHINA			CID000538
Tin			Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.			CHINA			CID001908
Tin			Gejiu Zili Mining And Metallurgy Co., Ltd.			CHINA			CID000555
Tin			Guangdong Hanhe Non-Ferrous Metal Co., Ltd.			CHINA			CID003116
Tin			Guanyang Guida Nonferrous Metal Smelting Plant			CHINA			CID002849
Tin			HuiChang Hill Tin Industry Co., Ltd.			CHINA			CID002844
Tin			Huichang Jinshunda Tin Co., Ltd.			CHINA			CID000760
Tin			Jiangxi New Nanshan Technology Ltd.			CHINA			CID001231
Tin			Ma'anshan Weitai Tin Co., Ltd.			CHINA			CID003379
Tin			Magnu's Minerais Metais e Ligas Ltda.			BRAZIL			CID002468
Tin			Malaysia Smelting Corporation (MSC)			MALAYSIA			CID001105
Tin			Melt Metais e Ligas S.A.			BRAZIL			CID002500
Tin			Metallic Resources, Inc.			UNITED STATES OF AMERICA			CID001142
Tin			Metallo Belgium N.V.			BELGIUM			CID002773
Tin			Metallo Spain S.L.U.			SPAIN			CID002774
Tin			Mineracao Taboca S.A.			BRAZIL			CID001173
Tin			Minsur			PERU			CID001182
Tin			Mitsubishi Materials Corporation			JAPAN			CID001191
Tin			O.M. Manufacturing (Thailand) Co., Ltd.			THAILAND			CID001314
Tin			O.M. Manufacturing Philippines, Inc.			PHILIPPINES			CID002517
Tin			Operaciones Metalurgicas S.A.			BOLIVIA (PLURINATIONAL STATE OF)			CID001337
Tin			PT Artha Cipta Langgeng			INDONESIA			CID001399
Tin			PT ATD Makmur Mandiri Jaya			INDONESIA			CID002503
Tin			PT Menara Cipta Mulia			INDONESIA			CID002835
Tin			PT Mitra Stania Prima			INDONESIA			CID001453
Tin			PT Refined Bangka Tin			INDONESIA			CID001460
Tin			PT Timah Tbk Kundur			INDONESIA			CID001477
Tin			PT Timah Tbk Mentok			INDONESIA			CID001482
Tin			Resind Industria e Comercio Ltda.			BRAZIL			CID002706
Tin			Rui Da Hung			TAIWAN, PROVINCE OF CHINA			CID001539
Tin			Soft Metais Ltda.			BRAZIL			CID001758
Tin			Thai Nguyen Mining and Metallurgy Co., Ltd.			VIETNAM			CID002834
Tin			Thaisarco			THAILAND			CID001898
Tin			Tin Technology & Refining			UNITED STATES OF AMERICA			CID003325
Tin			White Solder Metalurgia e Mineracao Ltda.			BRAZIL			CID002036
Tin			Yunnan Chengfeng Non-ferrous Metals Co., Ltd.			CHINA			CID002158
Tin			Yunnan Tin Company Limited			CHINA			CID002180

12

---

Tin			Yunnan Yunfan Non-ferrous Metals Co., Ltd.			CHINA			CID003397
Tungsten			A.L.M.T. Corp.			JAPAN			CID000004
Tungsten			ACL Metais Eireli			BRAZIL			CID002833
Tungsten			Asia Tungsten Products Vietnam Ltd.			VIETNAM			CID002502
Tungsten			Chenzhou Diamond Tungsten Products Co., Ltd.			CHINA			CID002513
Tungsten			Chongyi Zhangyuan Tungsten Co., Ltd.			CHINA			CID000258
Tungsten			Fujian Ganmin RareMetal Co., Ltd.			CHINA			CID003401
Tungsten			Fujian Jinxin Tungsten Co., Ltd.			CHINA			CID000499
Tungsten			Ganzhou Haichuang Tungsten Co., Ltd.			CHINA			CID002645
Tungsten			Ganzhou Huaxing Tungsten Products Co., Ltd.			CHINA			CID000875
Tungsten			Ganzhou Jiangwu Ferrotungsten Co., Ltd.			CHINA			CID002315
Tungsten			Ganzhou Seadragon W & Mo Co., Ltd.			CHINA			CID002494
Tungsten			Global Tungsten & Powders Corp.			UNITED STATES OF AMERICA			CID000568
Tungsten			Guangdong Xianglu Tungsten Co., Ltd.			CHINA			CID000218
Tungsten			H.C. Starck Smelting GmbH & Co. KG			GERMANY			CID002542
Tungsten			H.C. Starck Tungsten GmbH			GERMANY			CID002541
Tungsten			Hunan Chenzhou Mining Co., Ltd.			CHINA			CID000766
Tungsten			Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji			CHINA			CID002579
Tungsten			Hunan Chunchang Nonferrous Metals Co., Ltd.			CHINA			CID000769
Tungsten			Hunan Litian Tungsten Industry Co., Ltd.			CHINA			CID003182
Tungsten			Hydrometallurg, JSC			RUSSIAN FEDERATION			CID002649
Tungsten			Japan New Metals Co., Ltd.			JAPAN			CID000825
Tungsten			Jiangwu H.C. Starck Tungsten Products Co., Ltd.			CHINA			CID002551
Tungsten			Jiangxi Gan Bei Tungsten Co., Ltd.			CHINA			CID002321
Tungsten			Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.			CHINA			CID002318
Tungsten			Jiangxi Xinsheng Tungsten Industry Co., Ltd.			CHINA			CID002317
Tungsten			Jiangxi Yaosheng Tungsten Co., Ltd.			CHINA			CID002316
Tungsten			Kennametal Fallon			UNITED STATES OF AMERICA			CID000966
Tungsten			Kennametal Huntsville			UNITED STATES OF AMERICA			CID000105
Tungsten			KGETS Co., Ltd.			KOREA, REPUBLIC OF			CID003388
Tungsten			Lianyou Metals Co., Ltd.			TAIWAN, PROVINCE OF CHINA			CID003407
Tungsten			Malipo Haiyu Tungsten Co., Ltd.			CHINA			CID002319
Tungsten			Masan Tungsten Chemical LLC (MTC)			VIETNAM			CID002543
Tungsten			Moliren Ltd.			RUSSIAN FEDERATION			CID002845
Tungsten			Niagara Refining LLC			UNITED STATES OF AMERICA			CID002589
Tungsten			Philippine Chuangxin Industrial Co., Inc.			PHILIPPINES			CID002827
Tungsten			Tejing (Vietnam) Tungsten Co., Ltd.			VIETNAM			CID001889
Tungsten			Unecha Refractory metals plant			RUSSIAN FEDERATION			CID002724
Tungsten			Wolfram Bergbau und Hutten AG			AUSTRIA			CID002044

13

---

Tungsten			Woltech Korea Co., Ltd.			KOREA, REPUBLIC OF			CID002843
Tungsten			Xiamen Tungsten (H.C.) Co., Ltd.			CHINA			CID002320
Tungsten			Xiamen Tungsten Co., Ltd.			CHINA			CID002082
Tungsten			Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.			CHINA			CID002830
Tungsten			Xinhai Rendan Shaoguan Tungsten Co., Ltd.			CHINA			CID002095

SORs that have not been validated by the RMAP program as Conformant:

Metal			SOR Name			SOR Country			SOR ID
Gold			Abington Reldan Metals, LLC			UNITED STATES OF AMERICA			CID002708
Gold			African Gold Refinery			UGANDA			CID003185
Gold			Atasay Kuyumculuk Sanayi Ve Ticaret A.S.			TURKEY			CID000103
Gold			Caridad			MEXICO			CID000180
Gold			CGR Metalloys Pvt Ltd.			INDIA			CID003382
Gold			Daye Non-Ferrous Metals Mining Ltd.			CHINA			CID000343
Gold			Degussa Sonne / Mond Goldhandel GmbH			GERMANY			CID002867
Gold			Dijllah Gold Refinery FZC			UNITED ARAB EMIRATES			CID003348
Gold			Fidelity Printers and Refiners Ltd.			ZIMBABWE			CID002515
Gold			Fujairah Gold FZC			UNITED ARAB EMIRATES			CID002584
Gold			GCC Gujrat Gold Centre Pvt. Ltd.			INDIA			CID002852
Gold			Great Wall Precious Metals Co., Ltd. of CBPM			CHINA			CID001909
Gold			Guangdong Jinding Gold Limited			CHINA			CID002312
Gold			Guoda Safina High-Tech Environmental Refinery Co., Ltd.			CHINA			CID000651
Gold			Hangzhou Fuchunjiang Smelting Co., Ltd.			CHINA			CID000671
Gold			Hunan Chenzhou Mining Co., Ltd.			CHINA			CID000767
Gold			Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.			CHINA			CID000773
Gold			HwaSeong CJ CO., LTD.			KOREA, REPUBLIC OF			CID000778
Gold			International Precious Metal Refiners			UNITED ARAB EMIRATES			CID002562
Gold			JSC Ekaterinburg Non-Ferrous Metal Processing Plant			RUSSIAN FEDERATION			CID000927
Gold			Kaloti Precious Metals			UNITED ARAB EMIRATES			CID002563
Gold			Kazakhmys Smelting LLC			KAZAKHSTAN			CID000956
Gold			Kyshtym Copper-Electrolytic Plant ZAO			RUSSIAN FEDERATION			CID002865
Gold			L'azurde Company For Jewelry			SAUDI ARABIA			CID001032
Gold			Lingbao Gold Co., Ltd.			CHINA			CID001056
Gold			Lingbao Jinyuan Tonghui Refinery Co., Ltd.			CHINA			CID001058
Gold			Luoyang Zijin Yinhui Gold Refinery Co., Ltd.			CHINA			CID001093
Gold			Modeltech Sdn Bhd			MALAYSIA			CID002857
Gold			Morris and Watson			NEW ZEALAND			CID002282
Gold			Navoi Mining and Metallurgical Combinat			UZBEKISTAN			CID001236

14

---

Gold			NH Recytech Company			KOREA, REPUBLIC OF			CID003189
Gold			Pease & Curren			UNITED STATES OF AMERICA			CID002872
Gold			Penglai Penggang Gold Industry Co., Ltd.			CHINA			CID001362
Gold			QG Refining, LLC			UNITED STATES OF AMERICA			CID003324
Gold			Refinery of Seemine Gold Co., Ltd.			CHINA			CID000522
Gold			Sabin Metal Corp.			UNITED STATES OF AMERICA			CID001546
Gold			SAFINA A.S.			CZECHIA			CID002290
Gold			Sai Refinery			INDIA			CID002853
Gold			Samwon Metals Corp.			KOREA, REPUBLIC OF			CID001562
Gold			Shandong Humon Smelting Co., Ltd.			CHINA			CID002525
Gold			Shandong Tiancheng Biological Gold Industrial Co., Ltd.			CHINA			CID001619
Gold			Sovereign Metals			INDIA			CID003383
Gold			State Research Institute Center for Physical Sciences and Technology			LITHUANIA			CID003153
Gold			Sudan Gold Refinery			SUDAN			CID002567
Gold			Tongling Nonferrous Metals Group Co., Ltd.			CHINA			CID001947
Gold			Tony Goetz NV			BELGIUM			CID002587
Gold			Yunnan Copper Industry Co., Ltd.			CHINA			CID000197
Tin			An Vinh Joint Stock Mineral Processing Company			VIETNAM			CID002703
Tin			Dongguan CiEXPO Environmental Engineering Co., Ltd.			CHINA			CID003356
Tin			Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC			VIETNAM			CID002572
Tin			Estanho de Rondonia S.A.			BRAZIL			CID000448
Tin			Gejiu City Fuxiang Industry and Trade Co., Ltd.			CHINA			CID003410
Tin			Modeltech Sdn Bhd			MALAYSIA			CID002858
Tin			Nghe Tinh Non-Ferrous Metals Joint Stock Company			VIETNAM			CID002573
Tin			Pongpipat Company Limited			MYANMAR			CID003208
Tin			Precious Minerals and Smelting Limited			INDIA			CID003409
Tin			Super Ligas			BRAZIL			CID002756
Tin			Tuyen Quang Non-Ferrous Metals Joint Stock Company			VIETNAM			CID002574
Tungsten			CNMC (Guangxi) PGMA Co., Ltd.			CHINA			CID000281
Tungsten			Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.			CHINA			CID002313
Tungsten			Jiangxi Xianglu Tungsten Co., Ltd.			CHINA			CID002647
Tungsten			JSC "Kirovgrad Hard Alloys Plant"			RUSSIAN FEDERATION			CID003408

15

---

Annex II

Countries from which the minerals in the Covered Products may have originated

        

Based on RMI’s Reasonable Country of Origin Inquiry report dated March 27, 2020, the countries of origin of the 3TG processed by SORs listed in ANNEX I are believed to include the countries identified below. Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP:

Gold:

Argentina

Japan

Tajikistan

Australia

Kazakhstan

Tanzania

Azerbaijan

Kenya

Togo

Benin

Laos

Turkey

Bolivia (Plurinational-State of)

Liberia

Uganda

Brazil

Malaysia

United Kingdom of Great Britain and Northern Ireland

Burkina Faso

Mali

United States of America

Canada

Mauritania

Uruguay

Chile

Mexico

Zambia

China

Mongolia

Zimbabwe

Colombia

Morocco

Congo, Democratic Republic of the

Namibia

Cyprus

Netherlands

Dominican Republic

New Zealand

Ecuador

Nicaragua

Egypt

Niger

Eritrea

Papua New Guinea

Ethiopia

Peru

Fiji

Philippines

Finland

Puerto Rico

Georgia

Russian Federation

Ghana

Rwanda

Guatemala

Saudi Arabia

Guinea

Senegal

Guyana

Serbia

Honduras

Slovakia

Indonesia

Solomon Islands

Iran(3)

South Africa

Ivory Coast

Spain

Suriname

Swaziland

Sweden

___________________

³ Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person.

16

---

Tantalum:

Australia

Ethiopia

Namibia

Austria

France

Nigeria

Bolivia (Plurinational-State of)

Germany

Russian Federation

Brazil

Guinea

Rwanda

Burundi

India

Sierra Leone

China

Madagascar

Somaliland

Colombia

Malaysia

Spain

Congo, Democratic-Republic of the

Mozambique

Thailand

Zimbabwe

Tin:

Australia

Guinea

Russian Federation

Bolivia (Plurinational-State of)

Indonesia

Rwanda

Brazil

Laos

Taiwan

Burundi

Malaysia

Thailand

China

Mongolia

Uganda

Congo, Democratic-Republic of the

Myanmar

United Kingdom of Great-Britain and Northern Ireland

Nigeria

Venezuela

Peru

Vietnam

Portugal

Tungsten:

Australia						Nigeria
Austria						Peru
Bolivia (Plurinational-State of)						Portugal
Brazil						Russian Federation
Burundi						Rwanda
China						Spain
Congo, Democratic-Republic of the						Taiwan
Guinea						Thailand
Indonesia						Uganda
Laos						United Kingdom of Great-Britain and Northern Ireland
Malaysia						United States of America
Mongolia						Uzbekistan
Myanmar						Vietnam

17