UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
_____________________________________________
FORM SD
Specialized Disclosure Report
_____________________________________________
Peloton Interactive Inc.
(Exact name of registrant as specified in its charter)
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| Delaware | | 001-39058 | | 47-3533761 |
(State or other Jurisdiction of Incorporation) | | (Commission File Number) | | (I.R.S. Employer Identification No.) |
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441 Ninth Avenue, Sixth Floor New York, New York | | | 10001 |
| (Address of principal executive offices) | | | (Zip Code) |
| | |
| Tammy Albarrán |
| Chief Legal Officer |
(929) 567-0006 |
| (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:
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☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
☐ |
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2023. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
A copy of Peloton Interactive, Inc.’s (the “Company”) Conflict Minerals Report for the reporting period January 1, 2023 to December 31, 2023 is provided as Exhibit 1.01 hereto and is publicly available at https://investor.onepeloton.com/sec-filings. The information contained on the Company’s website is not incorporated by reference into this Form SD or its Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report.
Not applicable.
Section 3 – Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this report.
*****
SIGNATURE
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.
Peloton Interactive, Inc.
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| By: | /s/ Tammy Albarrán | | Date: May 31, 2024 |
| Chief Legal Officer | | |
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CONFLICT MINERALS REPORT OF
Peloton Interactive, Inc.
FOR THE REPORTING PERIOD FROM JANUARY 1, 2023 TO DECEMBER 31, 2023
I.Introduction
Peloton Interactive, Inc. (“we,” “our,” “us,” “Peloton,” or the “Company”) provides this Conflict Minerals1 Report for calendar year 2023 (the “Reporting Period”) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “Act”).
At Peloton, we are committed to respecting and protecting the human rights for all our stakeholders, including our team members, Members, partners, and all people at all levels of our supply chain. We designed our processes to enable sufficient knowledge of input materials and components to reasonably assure that they were obtained from sources in compliance with applicable laws and regulatory requirements, including those relating to conflict minerals. As part of our commitment to responsible sourcing practices, we undertook due diligence with respect to potential sourcing of tin, tungsten, tantalum, and gold (“3TG” or “conflict minerals”) materials within our products. Our due diligence efforts were consistent with the internationally recognized framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.
The statements below are based on the activities performed to date in good faith by the Company and are based on the infrastructure and information available at the time of this filing. Factors that could cause actual results to differ materially from these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving identification of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding U.S. Securities and Exchange Commission (“SEC”) final rules, and other issues.
II.Overview
Company Profile
Peloton is the largest interactive fitness platform in the world, with a loyal community of over 6 million members. We pioneered connected, technology-enabled fitness and the streaming of immersive, instructor-led boutique classes to our Members anytime, anywhere. Peloton makes fitness entertaining, approachable, effective, and convenient, while fostering social connections that encourage our Members to be the best versions of themselves. Peloton provides Members with expert instruction and world class content to create impactful and entertaining workout experiences for anyone, anywhere, and at any stage in their fitness journey. At home, outdoors, traveling, or at the gym, Peloton offers an immersive and personalized experience. With tens-of-thousands of classes available across 16 fitness modalities, Members can access Peloton content via our hardware or via the Peloton App, on their phone, tablet, or TV, allowing them to workout when, where, and how they want.
1The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.
2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas: Third Edition, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264252479-en
We are subject to Rule 13p-1 as we have determined that, during the Reporting Period, conflict minerals were likely necessary to the functionality or production of products that Peloton, and its wholly-owned subsidiary, Precor, manufactured or contracted to manufacture based on the inclusion of metal and electronic components that contain 3TG materials. Although Peloton does not directly purchase, procure, or source conflict minerals, we are committed to meeting and exceeding internationally accepted due diligence standards for primary minerals in our supply chain. Our responsible minerals sourcing program includes requirements that apply to all levels of Peloton’s supply chain.
Reasonable Country of Origin Inquiry Information
We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by SEC Release No. 34-67716 (August 22, 2012) under the Act (the “Adopting Release”) and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI which indicated sourcing of 3TG minerals from the DRC or an adjoining country, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are discussed further in this Conflict Minerals Report.
Due Diligence Program Design
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
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 smelter/refiner's due diligence practices Step 5: Report annually on supply chain due diligence
III.Due Diligence Measures Performed by The Company
Consistent with the five steps of the OECD Due Diligence Guidance, Peloton has undertaken the following steps to reasonably determine the country of origin and to exercise due diligence in the 3TG mineral supply chain.
Step 1: Establish strong company management systems
We have established and maintain certain policies, procedures and systems in connection with the mineral supply chain and our commitments related thereto:
a.Supplier Code of Conduct – Peloton’s Supplier Code of Conduct (the “Supplier Code”), which incorporates Peloton’s Conflict Minerals Policy, applies to all levels of Peloton’s supply chain, including our trusted partners and sub-tier suppliers. The Supplier Code and Conflict Minerals Policy are based on industry and internationally accepted principles, including the International Labour Organization’s Labour Standards and the OECD Due Diligence Guidance.
b.Conflict Minerals Policy – The Conflict Minerals Policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by Rule 13p-1 and the Company’s expectations from its
suppliers that they comply with the same obligations. The policy is available on our corporate website at https://investor.onepeloton.com/corporate-governance.
c.Policy Commitments – The Supplier Code sets forth Peloton’s commitments for its suppliers in the areas of labor and human rights, health and safety, the environment, integrity in business dealings, and other risk areas. The Company’s policy commitments are sustained through the structures and processes set forth below. The Supplier Code establishes five Guiding Principles that shape our commitments to help maintain a responsible and ethical supply chain. A key Guiding Principle is acting as a responsible global citizen, which encompasses our conflict minerals due diligence commitments as reflected in the Company’s Conflict Minerals Policy.
d.Other Relevant Policies – We maintain other policies relevant to the Company’s Conflicts Minerals commitments, which include the following:
The Company’s Code of Conduct: sets forth the standards that govern all of our business dealings and establishes expectations for everyone at Peloton. Peloton’s commitments in the Code of Conduct are reflected in the Supplier Code, and we expect our partners and sub-tier suppliers to be aware of and adhere to Peloton’s standards and Guiding Principles for maintaining a responsible and ethical supply chain.
Global Integrity Reporting Policy: applies to Peloton’s team members, directors and officers, and contractors, and sets forth our approach to protecting and supporting individuals who report potential misconduct.
e.Peloton Management Systems – The Peloton Safety, Ethics and Compliance and Procurement Teams, in coordination with other stakeholders, manage the Company’s Conflict Mineral diligence efforts. These efforts include senior leadership involvement to ensure that critical information, including the Company’s conflict minerals standard and the Supplier Code, reach relevant team members and all suppliers. These teams coordinate efforts related to Peloton’s Supplier Code and across Peloton’s business teams and functions, including Supply Chain, Product, Peloton’s ESG team, legal, and finance. The Safety, Ethics and Compliance and Procurement teams regularly reports to, and consults with, Peloton’s senior management to review progress and set ongoing commitments for our responsible sourcing of materials and environmental due diligence efforts.
f.Board Oversight – Peloton’s Board of Directors oversees Peloton’s Chief Executive Officer and other senior management in the competent and ethical operation of Peloton on a day-to-day basis related to conflict minerals. The Audit Committee assists Peloton’s Board of Directors in monitoring significant business risks, including operational and reputational risks.
g.Internal Engagement – The Company administers a role based training program to educate team members on its conflict minerals process, the goals of its program, and its reporting obligations as a public company.
h.Supplier Engagement – The Company communicates its Conflict Minerals Policy and provides educational materials to its in-scope suppliers, enforced by the Supplier Code. In-scope suppliers are informed of the Company’s conflict minerals disclosure requirements on an annual basis when the Company requests information in connection with the Conflict Minerals Policy, along with recommendations for developing, implementing, and documenting a conflict minerals compliance program.
i.Company Level Reporting Mechanism – The Company has a dedicated, external Integrity Helpline as part of its open reporting culture and so that team members, contractors, and supplier partners can raise concerns or report misconduct on a confidential basis. Stakeholders, internal and external, can communicate directly and confidentially with the Company’s Safety, Ethics and Compliance team by reporting through available channels. All concerns are reviewed by dedicated investigators through our confidential investigation processes.
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
a.Identified products in scope – Peloton conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release.
b.Conducted RCOI – The Company utilized the most recent version of the industry-developed CMRT to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers who provide materials and components for the products deemed in-scope by our Conflict Minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.Completed additional follow-up – The Company contacted direct suppliers multiple times to request detailed conflict minerals information. We worked to clarify and validate the accuracy of information provided by our suppliers through standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtaining additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we received conflict minerals information specific to our supply-chain.
d.Identified smelters or refiners (“SORs”) – The Company compiled a list of SORs in our supply chain using our suppliers’ responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP conducts independent, third-party audits of SORs to determine which have validated systems that help ensure the minerals were responsibly sourced according to the OECD Due Diligence Guidance. The Company also utilized information provided by the London Bullion Market Association (“LBMA”), and Responsible Jewelry Council (“RJC”) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided that list in this report within section IV – Product Description; Processing Facilities.
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
a.Reporting results to senior management – The Conflict Minerals team reports the results of our RCOI to senior management at multiple points in time throughout the data collection period. These communications included the Conflict Minerals team’s plan to respond, as needed, to risks identified in the due diligence processes.
b.Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT, as well as any additional documentation furnished to support those responses and the suppliers’ due diligence processes. The resulting risk ratings were used to develop specific supplier outreach and training to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s Conflict Minerals Policy. This includes additional outreach to suppliers who failed to respond to our multiple requests for information, suppliers who provided inconsistent or erroneous information, and suppliers who indicated they had received responses from less than 50% of their in-scope suppliers. Our Conflicts Minerals team further reviews the responses to verify the validity of SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.
c.Provided informational materials – The Company provided each supplier with informational materials that explain Section 1502 of the Dodd Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most recent revision of the CMRT (including definitions of common phrases and frequently asked questions). These materials are provided to suppliers at the time of the initial request for a
completed CMRT. The informational materials serve as a point of reference for suppliers that are unfamiliar with the rule and helps limit the risk of obtaining inaccurate information from them. We offer assistance to our suppliers throughout the process to improve the quality of the information provided to us.
d.Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs.
Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices
The Company uses information provided by independent third-party audit programs, including the RMI RMAP, LBMA, and RJC, to confirm the existence, and verify the OECD-conformance status, of SORs identified during our due diligence.
For SORs that were audited as non-conformant, the Company sent a communication to encourage participation in the RMAP and requested the SOR to provide the mines and/or locations from which the SOR sources to assist in identifying all countries of origin. Additionally, the Company sent communications to all suppliers that reported SORs that were audited as non-conformant to request that these suppliers encourage the SORs’ participation in the RMAP.
The Company is also a member of the RMI (under member ID PLTN). As a member, the Company financially supports the development of the RMAP through its member dues and utilizes the RMI data to determine the country of origin of conflict minerals in the Company’s products in addition to the Company’s efforts of reaching out to smelters.
Step 5: Report annually on supply chain due diligence
Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our investor relations website at https://investor.onepeloton.com.
IV.Product Description; Processing Facilities
Product Description
Peloton’s Product and Services
Peloton’s business is managed and our financial results are reported on a segment basis, with those segments being Connected Fitness Products and Subscriptions. Our Connected Fitness Products are subject to Rule 13p-1 and include:
Bike
Our current Bike features a carbon steel frame, a nearly silent belt drive, durable magnetic resistance, and a 22” high-definition touchscreen with built-in stereo speakers to stream live and on-demand classes, all in a compact, 4’ by 2’ footprint. Our Bike is available in the United States, Canada, the United Kingdom, Germany, Australia and Austria.
Bike+
Our Bike+ provides an immersive cardio experience and seamless transition to floor-based exercises with its 24”, 360 degree rotating display. Members can easily pivot and tilt the screen to add strength, yoga, and stretching to their routine or take our Bike Bootcamp class series. Resistance on Bike+ is controlled digitally allowing Members
to “Auto Follow” their instructors’ class programs and control resistance from the touchscreen. A powerful built-in soundbar and subwoofer system offers an improved audio experience. Bike+ is currently available for purchase in the United States, Canada, the United Kingdom, Germany, Australia and Austria.
Tread+
Tread+ features a shock-absorbing rubber-slat belt and ball bearing system, ideal for low-impact training. Pace and incline ergonomic control knobs allow for seamless adjustments, and the 32” high-definition touchscreen features a 20-watt sound bar. Currently, new Tread+ units are available for sale in the U.S. and incorporate a rear safety guard that enhances the product’s safety features.
Tread
The newest addition to our Tread line has the essential elements of the Tread+ experience but in a more affordable and compact form factor – maintaining ample running surface area and runner comfort. The Tread features a sleek belt drive, 24” touchscreen with integrated soundbar and subwoofer, and ergonomic pace and incline control knobs and jump buttons. With an immersive audio and video experience and heart rate monitor integration, Peloton Tread is designed for both on-Tread as well as floor-based bootcamp content. Tread is currently available for purchase in the United States, Canada, the United Kingdom, Australia, and Germany.
Guide
Guide is our first connected fitness strength product designed to further enhance the full-body workout experience through a number of unique product features. Guide is supported with dedicated content, including exclusive programs for all levels, live body-training classes with instructors, and an extensive move library to help Members learn and perfect proper form. Guide is currently available for purchase in the United States, Canada, the United Kingdom, and Australia.
Peloton Row
Row combines the innovative software, premium hardware design, and exclusive content that make up the signature Peloton experience, providing Members with a unique low-impact, full-body cardio and strength rowing workout. Row is currently available for purchase in the United States and Canada.
Precor Products and Services
Precor products and services span across all major categories, including cardio, connected fitness consoles, strength, and functional fitness. Precor cardio products include treadmills, elliptical fitness crosstrainers, adaptive motion trainers, bikes, and a stairclimber. Cardio products may be equipped with touchscreen internet-connected fitness consoles, or non-internet-connected LED consoles. Precor strength products include a variety of selectorized and plate-loaded machines, as well as functional multi- station units, benches, racks, and stretching equipment.
Processing Facilities
Based on our due diligence process and the information received from our suppliers, the facilities listed in the table below were identified by the Company’s suppliers as the smelters and refiners of the 3TG present in and necessary to the functionality of products manufactured by the Company in the Reporting Period. As such, this smelter list is presented in good faith as the best information we have to date. During the Reporting Period, we identified 191 SORs in our supply chain, 189 of which have been audited by the RMI as conformant with the RMAP or an equivalent independent third-party audit program. This list may contain smelters that are not in our supply chain and/or there may be other smelters in our supply chain which have not yet been identified by our due diligence process.
| | | | | | | | | | | |
| Metal | Smelter Name | Country | Smelter ID |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Gold | Dowa | JAPAN | CID000401 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| 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 | Aurubis AG | GERMANY | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
| Gold | Chimet S.p.A. | ITALY | CID000233 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | CID001916 |
| Gold | Chugai Mining | JAPAN | CID000264 |
| 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 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | CID000711 |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
| 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 | 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 | Yamakin Co., Ltd. | JAPAN | CID002100 |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| | | | | | | | | | | |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| 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 USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Gold | MKS PAMP SA | SWITZERLAND | CID001352 |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
| 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 | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| 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 | SAFINA A.S. | CZECHIA | CID002290 |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| Gold | T.C.A S.p.A | ITALY | CID002580 |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
| Tantalum | AMG Brasil | BRAZIL | CID001076 |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| 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 | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 |
| | | | | | | | | | | |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 |
| Tantalum | TANIOBIS 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 de Mexico | MEXICO | CID002539 |
| 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 | NPM Silmet AS | ESTONIA | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Tantalum | PowerX Ltd. | RWANDA | CID004054 |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | CID003583 |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
| Tin | Aurubis Beerse | BELGIUM | CID002773 |
| Tin | Aurubis Berango | SPAIN | CID002774 |
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| 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 | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 |
| Tin | CRM Synergies | SPAIN | CID003524 |
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
| Tin | Dowa | JAPAN | CID000402 |
| Tin | DS Myanmar | MYANMAR | CID003831 |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
| | | | | | | | | | | |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | CID004065 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| Tin | Super Ligas | BRAZIL | CID002756 |
| Tin | Thaisarco | THAILAND | CID001898 |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | CID002513 |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | CID002641 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | CID003609 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | CID003417 |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| 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 | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 |
| | | | | | | | | | | |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | CID003993 |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
V.Future Due Diligence
We intend to continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of these ores will increase and improve our knowledge. We intend to continue to make inquiries to our direct suppliers, seek information as to the ultimate source of these raw materials, and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If a supplier does not meet our expectations regarding responsible sourcing, we will work with the supplier, including by leveraging industry-wide programs as appropriate, to build its capacity for responsible sourcing. We expect our suppliers to take similar measures with their suppliers to help ensure alignment throughout our supply chain.
In addition to the actions noted elsewhere in this report, the Company expects to undertake the following steps during the next compliance period:
●Review the Conflict Minerals Policy and update if necessary.
●Review supplier and team member training materials and update if necessary.
●Continue to collect responses from suppliers using the most recent revision of the CMRT.
●Engage with suppliers that did not provide a response in prior year(s) or provided incomplete responses to enhance our data collection for 2024.
●Monitor and track performance of our risk mitigation efforts, including the performance of suppliers deemed high-risk.
●Continue engagement with smelters by sending letters to those that have not been audited as conformant and asking our suppliers to do the same.
●Collect from suppliers product-level or user-defined level responses where useful.
●Compare and validate RCOI results to information collected via independent third-party audit programs, such as the RMI, and through the Company’s own coordinated outreach to smelters.
●Encourage responsible sourcing from the DRC and adjoining countries and continue to monitor global developments and the emergence of additional requirements or standards related to the sourcing of minerals or other materials from all regions to continually improve our conflict minerals program.
●Stay aware of new and related sourcing challenges that affect smelter RMI audit status.
●Continue to support efforts of industry groups, like the RMI, to strengthen due diligence efforts.
Forward-Looking Statements
This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. We intend such forward-looking statements to be covered by the safe harbor provisions for forward-looking statements contained in Section 27A of the Securities Act of 1933, as amended and Section 21E of the Securities Exchange Act of 1934, as amended. All statements contained in this report other than statements of historical fact, including, without limitation, statements regarding our future conflict minerals due diligence efforts, are forward-looking statements. The words “believe,” “may,” “will,” “estimate,” “potential,” “continue,” “anticipate,” “intend,” “expect,” “could,” “would,” “project,” “plan,” “target,” and similar expressions are intended to identify forward-looking statements, though not all forward-looking statements use these words or expressions. You should not rely upon forward-looking statements as predictions of future events. The events and circumstances reflected in the forward-looking statements may not be achieved or occur. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, performance, or achievements. Our forward-looking statements speak only as of the date of this report, and we undertake
no obligation to update any of these forward-looking statements for any reason after the date of this report or to conform these statements to actual results or revised expectations, except as required by law.
APPENDIX I – Countries of Origin
The information provided in this Appendix is based on the information collected from the Company’s suppliers.
| | | | | |
| Australia | Mozambique |
| Austria | Myanmar |
| Benin | Nicaragua |
| Bolivia (Plurinational State of) | Niger |
| Brazil | Nigeria |
| Burundi | Papua New Guinea |
| Canada | Peru |
| Chile | Philippines |
| China | Portugal |
| Colombia | Russian Federation |
| Congo, Democratic Republic of the | Rwanda |
| Ethiopia | Sierra Leone |
| France | South Africa |
| Ghana | Spain |
| Guinea | Sweden |
| Guyana | Tanzania |
| Indonesia | Thailand |
| Kazakhstan | Uganda |
| South Korea | United Kingdom of Great Britain and Northern Ireland |
| Laos | United States of America |
| Madagascar | Uzbekistan |
| Malaysia | Vietnam |
| Mexico | Zimbabwe |
| Mongolia | |
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