UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
HEWLETT PACKARD ENTERPRISE COMPANY
(Exact name of the registrant as specified in its charter)
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DELAWARE | | 001-37483 | | 47-3298624 |
(State or other jurisdiction of | | (Commission File Number) | | (IRS Employer Identification No.) |
incorporation or organization) | | | | |
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1701 EAST MOSSY OAKS ROAD, SPRING, TX | | 77389 |
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(Address of principal executive offices) | | (Zip Code) |
David Antczak
Senior Vice President, General Counsel and Corporate Secretary 678-259-9860 |
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| (Name and telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ______.
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
HPE Company Overview
We are a global technology leader focused on developing intelligent solutions that allow customers to capture, analyze and act upon data seamlessly from edge to cloud. We enable customers to accelerate business outcomes by driving new business models, creating new customer and employee experiences, and increasing operational efficiency today and into the future. Our customers range from small- and medium-sized businesses to large global enterprises and governmental entities. Our legacy dates back to a partnership founded in 1939 by William R. Hewlett and David Packard. We strive every day to uphold and enhance that legacy through our dedication to providing innovative technological solutions to our customers.
Unless otherwise specified or unless the context otherwise requires, we use the terms “Hewlett Packard Enterprise”, “HPE”, “the Company”, “we”, “us”, and “our” to refer to Hewlett Packard Enterprise Company and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD. References to our websites and information available through these websites are not incorporated by reference into this Conflict Minerals Disclosure and Report.
Our Responsible Minerals Program
HPE is committed to the responsible sourcing of minerals used in its products and expects its suppliers to conduct their worldwide operations in a socially and environmentally responsible and sustainable manner, pursuant to HPE’s Supply Chain Social and Environmental Responsibility Policy1 and HPE’s General Specification for the Environment.2 Both policies contain a section on the responsible sourcing of minerals.
We firmly believe that all people are entitled to basic freedoms and standards of treatment, and we embed respect for internationally recognized human rights within our Responsible Minerals Program. We commit to align our approach with the United Nations Guiding Principles on Business and Human Rights, as described in HPE’s Global Human Rights Policy.3 Likewise, we expect our suppliers to uphold and respect human rights, guided by best practice set out in these standards.
As outlined in HPE’s Supply Chain Responsibility: Our Approach guide,4 HPE takes a systematic approach to sensing, understanding, and addressing risk. We re-examine and refine our program each year in light of our experience and emerging best practices.
HPE has been recognized as an industry leader for the company’s efforts to advance the use of responsibly sourced minerals. HPE has been named by the Ethisphere Institute as one of the “World’s Most Ethical Companies” for six years in a row (2019 through 2024), for “exemplifying and advancing corporate citizenship, transparency and the standards of integrity.” HPE also earned the highest ranking among 60 of the largest global information communications and technology (“ICT”) companies, on KnowTheChain’s 2022 Benchmark (published every two years), and the highest ranking among 43 of the world’s largest ICT companies in the 2022 Corporate Human Rights Benchmark (the most recent evaluation of ICT companies).
1 HPE’s Supply Chain Social and Environmental Responsibility Policy is available at https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04797673.
2 HPE’s General Specification for the Environment is available at https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04862211&ENW.
3 HPE’s Global Human Rights Policy is available at https://h20195.www2.hpe.com/V2/getpdf.aspx/A00001847ENW.pdf.
4 HPE’s Supply Chain Responsibility – Our Approach is available at https://www.hpe.com/psnow/doc/a00001852enw.
Our goal is to improve the transparency of mineral sourcing within our supply chain, while striving to ensure that the tin, tantalum, tungsten, and gold (collectively, “3TG”) used in our products have not benefited armed groups in the Democratic Republic of the Congo (“DRC”) and the DRC adjoining countries (collectively, the “Covered Countries”). Ultimately, we aim to improve conditions in and around mining communities in the Covered Countries and other Conflict-Affected and High-Risk Areas (“CAHRAs”) identified by the presence of armed conflict, widespread violence, or other human rights abuses. Because we believe it is important to avoid the economic and humanitarian impacts associated with an embargo of a particular region, we continually review and seek to responsibly source – and do not prohibit our suppliers from sourcing – from the Covered Countries and other CAHRAs.
Conflict Minerals Disclosure
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any conflict minerals in our 2023 products originated in the Covered Countries, or were conflict minerals from recycled or scrap sources. To make this determination, downstream companies like HPE must obtain and review sourcing information on the entities reported to provide conflict minerals contained in or necessary to the functionality or production (collectively, “necessary conflict minerals”) of our products in the form of 3TG. We asked our direct suppliers to provide us with relevant information and to report to us the entities that were providing necessary conflict minerals to them or their suppliers. HPE’s supplier social and environmental responsibility requirements, which include responsible minerals due diligence and reporting obligations, are incorporated into contracts with direct suppliers. HPE engages in ongoing supplier outreach, education, and communications, addressing in particular the substance of our responsible minerals policies, and our expectations and objectives with respect to responsible sourcing.
Our 2023 RCOI included:
•reaching out to 101 of our direct suppliers to inquire whether they are direct suppliers of materials, parts, components, or products containing necessary conflict minerals (“3TG Direct Suppliers”);
•confirming that 96 of the direct suppliers are 3TG Direct Suppliers;
•requiring that 3TG Direct Suppliers use the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (the “CMRT”) to collect and provide information from their supply chains to identify the entities recognized by RMI to be smelters, refiners, recyclers, or scrap processors of 3TG (“3TG facilities”); and, in relation to smelters and refiners (“SORs”), asking our direct suppliers to collect and provide available information on the origin of necessary conflict minerals;
•engaging in regular communication – through email, online calls and virtual meetings – with 3TG Direct Suppliers regarding their CMRTs and addressing questions as necessary;
•analyzing 3TG Direct Suppliers’ submissions for completeness and consistency, including sub-tier supplier response rate and adoption of a conflict or responsible sourcing of minerals policy;
•specifying any deficiencies or feedback for our 3TG Direct Suppliers to address in their submissions;
•providing further training, resources, and education, as necessary, to support 3TG Direct Suppliers in improving the quality and completeness of their CMRT;
•obtaining acceptable responses from 3TG Direct Suppliers estimated to represent more than 98% of our 2023 spend with such suppliers;
•based on the information provided by our 3TG Direct Suppliers, identifying 298 operational 3TG facilities that may process the necessary conflict minerals contained in the products provided to us;
•encouraging 3TG facilities to participate in RMI’s Responsible Minerals Assurance Processes audit program or a similar OECD-aligned, independent assessment program such as the Responsible Jewellery Council’s Chain-of-Custody and Code of Practices Program, or the London Bullion Market Association’s Responsible Gold Programme when our 3TG Direct Suppliers report any not-yet-participating SORs in their CMRTs;
•reviewing any information available through our membership in RMI on countries of origin or recycled and scrap sourcing for the 3TG facilities; and
•engaging an external expert to directly engage with 3TG facilities and review other publicly available information to further assist us in evaluating whether or not certain 3TG facilities may have sourced from the Covered Countries or may source only conflict minerals from recycled or scrap sources.
For 2023, we have determined with respect to our products containing necessary conflict minerals, that we know or have reason to believe that some of the necessary conflict minerals from 3TG facilities originated or may have originated in the Covered Countries and may not be conflict minerals from recycled or scrap sources.
Accordingly, we conducted due diligence on the source and chain of custody of necessary conflict minerals from these 3TG facilities and have prepared the Conflict Minerals Report attached hereto as Exhibit 1.01.
A copy of the Conflict Minerals Report filed for the calendar year ended December 31, 2023 will be publicly available electronically for a period of one year at www.hpe.com/info/conflictminerals.
Item 1.02 Exhibit
The Conflict Minerals Report for the calendar year ended December 31, 2023 is filed as Exhibit 1.01 hereto.
Section 3 — Exhibits
Item 3.01 Exhibits
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.
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| HEWLETT PACKARD ENTERPRISE COMPANY |
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Dated: May 29, 2024 | By: | /s/ John Schultz |
| Name: | John Schultz |
| Title: | Executive Vice President, |
| | Chief Operating and Legal Officer |
Exhibit 1.01
CONFLICT MINERALS REPORT OF HEWLETT PACKARD ENTERPRISE PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
Hewlett Packard Enterprise Company (“HPE”) presents this Conflict Minerals Report for the reporting period of January 1, 2023 to December 31, 2023 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission.
Unless otherwise specified or unless the context otherwise requires, we use the terms “Hewlett Packard Enterprise”, “HPE”, “the Company”, “we”, “us”, and “our” to refer to Hewlett Packard Enterprise Company and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD. References to our websites and information available through these websites are not incorporated by reference into this Conflict Minerals Disclosure and Report.
HPE Company Overview
We are a global technology leader focused on developing intelligent solutions that allow customers to capture, analyze, and act upon data seamlessly from edge to cloud. We enable customers to accelerate business outcomes by driving new business models, creating new customer and employee experiences, and increasing operational efficiency today and into the future. Our customers range from small- and medium-sized businesses to large global enterprises and governmental entities. Our legacy dates back to a partnership founded in 1939 by William R. Hewlett and David Packard. We strive every day to uphold and enhance that legacy through our dedication to providing innovative technological solutions to our customers.
Our Responsible Minerals Program
HPE is committed to the responsible sourcing of minerals used in its products and expects its suppliers to conduct their worldwide operations in a socially and environmentally responsible and sustainable manner, pursuant to HPE’s Supply Chain Social and Environmental Responsibility Policy1 and HPE’s General Specification for the Environment.2 Both policies contain a section on the responsible sourcing of minerals.
We firmly believe that all people are entitled to basic freedoms and standards of treatment, and we embed respect for internationally recognized human rights within our Responsible Minerals Program. We commit to align our approach with the United Nations Guiding Principles on Business and Human Rights, as described in HPE’s Global Human Rights Policy.3 Likewise, we expect our suppliers to uphold and respect human rights, guided by best practice set out in these standards.
1 HPE’s Supply Chain Social and Environmental Responsibility Policy is available at https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04797673.
2 HPE’s General Specification for the Environment is available at https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04862211&ENW.
3 HPE’s Global Human Rights Policy is available at https://h20195.www2.hpe.com/V2/getpdf.aspx/A00001847ENW.pdf.
As outlined in HPE’s Supply Chain Responsibility: Our Approach guide,4 HPE takes a systematic approach to sensing, understanding, and addressing risk. We re-examine and refine our program each year in light of our experience and emerging best practices.
HPE has been recognized as an industry leader for the company’s efforts to advance the use of responsibly sourced minerals. HPE has been named by the Ethisphere Institute as one of the “World’s Most Ethical Companies” for six years in a row (2019 through 2024), for “exemplifying and advancing corporate citizenship, transparency and the standards of integrity.” HPE also earned the highest ranking among 60 of the largest global information communications and technology (“ICT”) companies, on KnowTheChain’s 2022 Benchmark (published every two years), and the highest ranking among 43 of the world’s largest ICT companies in the 2022 Corporate Human Rights Benchmark (the most recent evaluation of ICT companies).
Our goal is to improve the transparency of mineral sourcing within our supply chain, while striving to ensure that the tin, tantalum, tungsten, and gold (collectively, “3TG”) used in our products have not benefited armed groups in the Democratic Republic of the Congo (“DRC”) and the DRC adjoining countries (collectively, the “Covered Countries”). Ultimately, we aim to improve conditions in and around mining communities in the Covered Countries and other Conflict-Affected and High-Risk Areas (“CAHRAs”) identified by the presence of armed conflict, widespread violence, or other human rights abuses. Because we believe it is important to avoid the economic and humanitarian impacts associated with an embargo of a particular region, we continually review and seek to responsibly source – and do not prohibit our suppliers from sourcing – from the Covered Countries and other CAHRAs.
Since 2008, HPE has been a member of the Responsible Minerals Initiative (“RMI”), an organization instrumental in developing and advancing programs and shared industry tools such as the Responsible Minerals Assurance Process (“RMAP”),5 the Conflict Minerals Reporting Template (the “CMRT”), the Extended Minerals Reporting Template (the “EMRT”), and the accompanying Completion Guides for both reporting templates. HPE is an active member of RMI and participates in RMI workgroups in order to listen, learn, partner, and co-design shared solutions to address challenges and emerging issues in the area of responsible minerals sourcing. Consistent with past years, HPE participates in RMI’s workgroups including the Smelter Engagement Team, Multi-Stakeholder group, Emerging Minerals Team, and Emerging Trends and Technology Team. In 2023, we interacted with RMI, representatives from fellow RMI member organizations, and other business, government, non-profit, and supply chain stakeholders on the topic of responsible minerals sourcing in various forums. At these forums and at other times, we engaged in a series of one-on-one conversations with direct suppliers of materials, parts, components, or products containing necessary conflict minerals (“3TG Direct Suppliers”) and indirect smelters and refiners (“SORs”) to help drive improvement throughout the supply chain. We also met with representatives from peer companies, civil society stakeholders, and RMI to discuss opportunities to continually improve the industry’s approach to responsible minerals sourcing. We provided feedback to RMI and other OECD-aligned, independent assessment programs (such as London Bullion Market Association’s (“LBMA”) Responsib
4 HPE’s Supply Chain Responsibility – Our Approach is available at https://www.hpe.com/psnow/doc/a00001852enw.
5 RMAP is an RMI program that uses an independent third-party audit of smelter and refiner (“SOR”) management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The audit employs a risk-based approach to validate SORs’ company level management processes for responsible mineral procurement. RMAP has a cross-recognition policy with other OECD- aligned independent assessment programs in order to reduce audit duplication and support the implementation of the OECD Due Diligence Guidance. Currently these include the Responsible Jewellery Coalition’s (“RJC”) Chain-of-Custody and Code of Practices Program, and the London Bullion Market Association’s (“LBMA”) Responsible Gold Programme.
le Gold Programme) on opportunities to strengthen the audit protocol and ways to strengthen industry tools. We continue to encourage the overall strengthening of audit program requirements such as enhanced integration of human rights and environmental concerns and increased transparency throughout the supply chain.
Our approach to responsible minerals sourcing prioritizes engagement and outreach with 3TG and cobalt facilities to encourage their involvement in either RMAP or another OECD-aligned, independent assessment program.6 In line with our previous years’ efforts, we also made a financial contribution to RMI funds that enable SORs to undertake audits and conduct risk-based enhanced due diligence. We contributed to the Upstream Due Diligence Fund, which we previously helped launch, to support SORs in conducting mine-level assessments in CAHRAs. We also contributed to the Audit Fund for Participating Smelters, to support SORs with the costs of RMAP audits. In our communications with SORs, we encouraged their use of these funds to undertake appropriate supply chain due diligence in accordance with international standards (as described below).
Investing in the social development of mining communities is an important aspect of responsible sourcing. Since 2018, HPE has contributed to KEMET Corporation’s Friends of Kisengo organization, a nonprofit dedicated to effectively and sustainably improving the lives of people in the DRC through an integrated rural development program focused on infrastructure, health, education, and environmental development. HPE has continued to support the mission of Friends of Kisengo by making financial contributions to support the cost of childhood education for approximately 1,500 children in the tantalum mining community. In 2023, we funded over two months of school expenses in Kisengo and also purchased two sets of new school uniforms, which were designed locally by a newly founded woman-owned sewing business. Additionally in 2023, HPE maintained its membership in the Public-Private Alliance for Responsible Minerals Trade, which supports collaborative 3TG initiatives in the DRC region with peer companies and the U.S. government, and also continued to financially support the RMI-Pact Partnership for supporting Alternative Livelihoods through a vocational training program located in cobalt mining communities in the DRC.
HPE’s Responsible Minerals program continues to evolve in scope to identify and address risk across our supply chain, including expanding our minerals due diligence beyond 3TG and beyond the Covered Countries. In 2022, HPE incorporated cobalt into annual supplier surveys (using the EMRT). In 2023, HPE expanded its internal risk assessment criteria to extend to geographies outside of the formal CAHRAs list, with an approach designed to support our suppliers to conduct enhanced human rights due diligence at the smelter level, regardless of the country. In line with OECD guidance, HPE works with suppliers to identify smelter risk and develop action plans for due diligence, monitoring, and removal.
HPE Products and Supply Chain
Conflict minerals in the form of 3TG were necessary to the functionality or production of our 2023 products (i.e., were “necessary conflict minerals”). The products containing necessary conflict minerals that HPE manufactured or contracted to manufacture during 2023 are: 1) server, storage, and networking products; and 2) certain accessories.
6 3TG facilities and cobalt facilities are those entities reported by our 3TG Direct Suppliers that are also identified by RMI to be smelters, refiners, recyclers, or scrap processors of conflict minerals.
HPE does not directly purchase 3TG from raw material providers such as smelting or refining facilities nor raw materials from mine sites. Due to our position as a “downstream”7 company several tiers removed from raw materials providers, we set robust standards for our suppliers and engage with a variety of industry members, including RMI, to influence responsible sourcing.
Design of our Due Diligence Measures
We designed our due diligence measures to conform with applicable portions of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition, OECD 2016) and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures reflects our individual facts and circumstances, our downstream position in the minerals supply chain, and the OECD recommendations for downstream actors with no direct relationships to SORs. This design also includes the use of OECD-aligned independent assessment programs to provide information about SORs.
HPE’s design of Due Diligence Measures incorporates the following steps:
1.Establishment of strong internal company management systems, including a Responsible Minerals Policy;8 a Responsible Minerals Program team with senior management support that reports to the Audit Committee of the Board of Directors; a Supply Chain Transparency System;9 engagement with 3TG Direct Suppliers10 to communicate and reinforce our expectations with respect to necessary conflict minerals; a requirement that 3TG Direct Suppliers immediately begin transitioning all 3TG supply chains to 3TG facilities listed as participating in or successfully completing RMAP or another OECD-aligned independent assessment program or encouraging their known 3TG facilities to participate in such a program; integration of supplier responsible minerals performance, including response timeliness and quality, into sourcing decisions through the use of supplier Social and Environmental Responsibility Scorecards and feedback during business unit reviews with key suppliers; use of internal performance metrics such as the number of supplier responses received and our progress toward internal goals; and a corporate grievance mechanism that is available internally and externally to report concerns, including those related to the responsible sourcing of minerals. We encourage anyone with a concern to raise it, and provide multiple channels to raise concerns.11 Reports are confidential and can be made anonymously where local law allows. We take each and every report seriously, review every concern raised, respond promptly, and investigate alleged violations as appropriate. We also encourage the use of the global, cross-industry Minerals Grievance Platform, a platform developed in collaboration by RMI, the LBMA, and the Responsible Jewellery Coalition (“RJC”) to screen and address grievances linked
7 The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HPE; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
8 HPE’s Supply Chain Social and Environmental Responsibility Policy and HPE’s General Specification for the Environment Standards both contain sections on responsible minerals, and collectively serve as HPE’s Responsible Minerals Policy. HPE’s Supplier Code of Conduct also includes a section on responsible sourcing, alongside the topics of labor, health and safety, environment, ethics, and management systems.
9 The OECD Guidance sets forth specific recommendations for all downstream companies to establish a system of controls and transparency over the mineral supply chain: “Introduce a supply chain transparency system that allows the identification of the smelters/refiners in the company’s mineral supply chain through which the following information on the supply chain of minerals from “red flag locations of mineral origin and transit” should be obtained: the identification of all countries of origin, transport and transit for the minerals in the supply chains of each smelter/refiner.”
10 3TG Direct Suppliers are direct suppliers of materials, parts, components, or products containing necessary conflict minerals.
11 HPE’s Report Ethics Concerns website is available at https://www.hpe.com/us/en/about/governance/report-ethics-concerns.html.
to SORs present in minerals supply chains.12 Any member of the public or representative from an organization can submit an attributed or anonymous grievance, which is reviewed by C4ADS, an independent third-party non-profit organization. C4ADS compiles the grievances (including those from public sources, such as news articles, reports, and blogs), prepares investigative dossiers on the grievances, supports analysis of such grievances, tracks the mitigation progress, and shares a summary of the outcome with relevant platform participants. HPE has participated in the platform by submitting grievances based on potential concerns raised through various channels, analyzing and tracking grievances, and suggesting opportunities for the platform’s continual improvement. HPE assesses its suppliers on their responsible minerals company management systems by commissioning third-party audits of certain 3TG Direct Suppliers to assess conformance with HPE’s Supplier Code of Conduct, which includes an assessment on the responsible sourcing of minerals, alongside the topics of labor, health and safety, environment, ethics, and management systems. Beginning in 2021, HPE uses a specialized third-party platform to support supplier data management and verification. We also routinely update HPE’s Supply Chain Social and Environmental Responsibility Policy, HPE’s Global Human Rights Policy, HPE’s General Specification for the Environment Standards, and HPE’s Supplier Code of Conduct to align with our expectations and the OECD Guidance.13
2.Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Responsible Minerals Program team in systematically surveying, collecting, and analyzing information relating to 3TG facilities.
3.Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on facilities’ due diligence practices, formulation of a risk management plan, and reporting to senior management. If suppliers fail to meet HPE standards, we engage with suppliers to support their improvement, in accordance with the framework of progressive improvement under the OECD Guidance. We also directly contact 3TG facilities to request their participation in RMAP or another OECD-aligned, independent assessment program and recommend they leverage technical assistance and financial support resources through RMI, including the financial support funds to which HPE contributes.
4.Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership and active participation in RMI (member ID HPE), the industry initiative that conducts audits and assessments of facilities’ due diligence activities. We rely on the RMI program and OECD-aligned independent assessment programs cross-recognized by RMI to determine if 3TG facilities reported by our suppliers are conformant with audit standards. To further the mission of RMI and support the cost-sharing of due diligence throughout the supply chain, HPE contributes to RMI’s Audit Fund for Participating Smelters and the Upstream Due Diligence Fund, which supports SORs with the costs of RMAP audits and the costs associated with enhanced, upstream due diligence. We also provide feedback to industry audit programs related to increased transparency and continual improvement.
5.Annual reporting through this Conflict Minerals Report and in our Living Progress Report.14
Description of Our Due Diligence Measures Performed
12 At the time of publication, RMI has integrated the Minerals Grievance Platform into the RBA’s grievance mechanism, “RBA Voices”.
13 HPE’s Supplier Code of Conduct is available at https://psnow.ext.hpe.com/doc/c04797632.
14 HPE’s Living Progress Report is available at https://www.hpe.com/us/en/living-progress.html.
In 2023, we undertook the following due diligence measures with respect to the source and chain of custody of necessary conflict minerals contained in our products:
•compared reported 3TG facilities to the facilities that are listed by RMI as either RMAP conformant or active;15
•reached out (either directly or through a third party) to 3TG facilities with unknown sourcing to provide responsible minerals sourcing education, collect information (such as country of origin of necessary conflict minerals related to the supply chain for HPE’s products), or encourage participation in RMAP;
•if any 3TG Direct Supplier reported to us a facility for which we had information that identified a relevant concern, then we asked the supplier to investigate whether or not that facility contributed 3TG to our products, and, if so, to take steps to remove the facility from our supply chain;
•supported RMAP through our membership and participation in RMI;
•encouraged 3TG facilities to join RMAP and leverage available financial and technical assistance resources, as applicable;
•asked HPE’s 3TG Direct Suppliers to encourage the facilities in their supply chain to join RMAP;
•participated in the Minerals Grievance Platform (see detailed description above), which enables stakeholders to share information and resources to address grievances relating to SORs present in minerals supply chains, and regularly provided feedback to the platform developers on suggested platform improvements to drive efficiencies and transparency; and
•proactively considered information outside of the audit program from credible external sources such as government agency and NGO reports.
We reviewed the results of our due diligence with senior management, including the Senior Vice President & Chief Ethics and Compliance Officer.
Results
Below we set forth the results of our due diligence as well as our progress toward DRC conflict free products. We provide both a snapshot of our total progress as well as our progress with respect to each 3TG metal. Our suppliers reported 298 total 3TG facilities in 2023, 99% of which (as of the 2024 Cut-Off Date16) are conformant with or active with an OECD-aligned independent assessment program, are believed to source from outside the Covered Countries, or are exclusively providing conflict minerals from recycled or scrap sources. Additional information on the status of individual 3TG facilities is provided in Attachment B.
15 RMI lists as “active” those smelters or refiners that are engaged in RMAP and progressing toward an audit but not yet conformant.
16 The “2024 Cut-Off Date” is the date by which HPE stops accepting new conflict minerals data from its 3TG Direct Suppliers for purposes of identifying the RMAP status of smelters or refiners that have been identified in our supply chain. If HPE receives additional information from a 3TG Direct Supplier clarifying that 3TG from a SOR is not included in the 2023 products prior to or following the Cut-Off Date, HPE does not include that SOR in its list of 3TG facilities (Attachment B).
Due Diligence Results for 3TG Facilities
Our approach prioritizes engagement and outreach with 3TG facilities, and when we learn of 3TG facilities that are not yet participating in an OECD-aligned independent assessment program, we seek out and consider other credible sources of information on these facilities. Due to our position as a downstream company several tiers removed from smelters or refiners, our direct suppliers often cannot provide information on 3TG sourcing that is specific to HPE products; therefore, our ability to trace 3TG in our products to the smelter or mine level has limits; conversely, as further explained in Attachment B, the reported presence of a 3TG facility in our suppliers’ supply chain does not necessarily mean that 3TG from that facility was used in HPE products. Our results, accordingly, may fluctuate depending on the resources and abilities of our suppliers (and their suppliers), the economic leverage we can exercise in a particular scenario, and the quality of information available to us, among other factors. In 2023, we continued to focus on obtaining data relevant to the manufacturing of HPE products, and on requesting HPE-specific submissions from our 3TG Direct Suppliers.
We measure our results in part based on the number of all 3TG facilities reported to us by our supply chain that are listed as participating in, or that have successfully completed an OECD-aligned independent assessment program. Because participation in an audit program, such as RMAP, provides us (a downstream company) with a level of assurance of an upstream facility’s sourcing practices, we track and report on this participation. Where additional information is available to us as a result of our due diligence or RCOI efforts, we also consider whether any of the 3TG facilities not yet participating in an audit program may nonetheless be providing minerals that are DRC conflict free because they are sourced from outside the Covered Countries or are exclusively derived from recycled or scrap sources. Because many of our 3TG Direct Suppliers continued to submit company level reporting templates, we are unable to confirm whether all reported 3TG facilities are active in our supply chain; we continue to engage with our suppliers to improve due diligence efforts and transparency.
In reviewing the 3TG facilities reported to us, we also consider potential conflict-related and other OECD Annex II risks that may extend beyond the Covered Countries.17 HPE is aware of credible reports of other OECD Annex II risks beyond the Covered Countries involving certain additional SORs. We are actively engaging our 3TG Direct Suppliers reporting these SORs on removal of the SORs, or requiring them to confirm through HPE-specific submissions that 3TG from such SORs was not used in any products, parts, or components supplied to HPE.
Attachment A to this Conflict Minerals Report includes (to the extent information was available) the countries from which the supplier-reported SORs may (but were not confirmed to) have sourced necessary conflict minerals.
Attachment B to this Conflict Minerals Report sets forth the name and status of the supplier-reported 3TG facilities.
Progress toward DRC Conflict Free by Metal
17 OECD Annex II risks refer to serious abuses associated with the extraction, transport, or trade of minerals, outlined in the OECD Due Diligence Guidance for Responsible Mineral Supply Chains. Risks can be broken down into three overarching criteria: Human Rights, Conflict, and Good Governance.
We also measure our progress toward DRC conflict free products by mineral. Chart 1 further expands on our results by providing for each mineral the number and percentage (as of the 2024 Cut-Off Date) of all supplier-reported 3TG facilities that were either RMAP conformant or active (or cross-recognized by RMI), and/or that we reasonably believe exclusively source conflict minerals from recycled or scrap sources or from outside of the Covered Countries.
Chart 1 Progress toward DRC Conflict Free by Metal
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| Supplier- Reported 3TG Facilities | Progress toward DRC Conflict Free | Percentage |
| Tantalum Facilities | 34 | 34 | 100% |
| Tin Facilities | 83 | 83 | 100% |
| Tungsten Facilities | 37 | 37 | 100% |
| Gold Facilities | 144 | 14218 | 99% |
| Total | 298 | 296 | >99% |
Participation in RMAP
RMAP is an OECD-aligned, independent assessment program that uses an independent third-party audit of SOR management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The audit employs a risk-based approach to validate SORs’ company level management processes for responsible mineral procurement. The RMAP standards are developed to meet the requirements of the OECD Due Diligence Guidance, EU Regulation 2017/8219 and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. Facilities that are either RMAP conformant or active are considered participating in RMAP. The RMAP status of individual 3TG facilities is set forth in Attachment B.
Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity
As a downstream actor, we rely upon independent assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for a downstream actor like us, our efforts to facilitate upstream mine or location of origin determinations were focused on support of OECD-aligned independent assessment programs such as RMAP.
To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by audit programs, we:
•surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the CMRT (which included questions about the mine or location of origin)
18 In late 2023, one previously RMAP Conformant 3TG facility was removed from RMAP lists due to their decision to opt out of RMAP re-assessment. Additionally, one previously Active facility was removed from RMAP lists in early 2024, after maintaining Active status for the 2023 reporting year. Additional information from our due diligence indicates that the facilities still source from the Covered Countries. Thus, we have not included them in the progress toward DRC conflict free category.
19 Regulation (EU) 2017/821 of the European Parliament and of the Council of 17 May 2017 sets forth supply chain due diligence obligations for EU importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas.
and required those suppliers to make similar efforts to survey their supply chains using the CMRT;
•reviewed information obtained through those surveys on 3TG facilities, and any mine or location of origin information if it was provided; and
•assessed any information on countries of origin available through our membership in RMI for 3TG facilities (as part of the RMAP audit protocol, the independent auditor makes an examination of the countries of origin and the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to RMI members).
Steps to Further Mitigate Risk and Improve Due Diligence in 2024
In our journey to responsibly source minerals used in our products, we plan to continue the activities described in the “Design of Our Due Diligence Measures” section of this Conflict Minerals Report. Additionally, we will continue to explore opportunities to improve our approach and execution in order to better mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group or further negatively impact communities or the environment. To this end, we will:
•engage with 3TG Direct Suppliers to update information provided to us and engage potentially new in-scope suppliers to understand our responsible sourcing expectations, including our Responsible Minerals Policy;
•encourage 3TG Direct Suppliers that provided company level information in 2023 to provide HPE-specific information for 2024;
•repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the RMAP and encourage their transition to exclusively source from conformant and active 3TG facilities, and monitor their progress toward that objective;
•support the development of RMAP, including outreach efforts to encourage participation in the program;
•strengthen internal and external partnerships to identify and mitigate minerals risks, investigate the materiality and social, environmental, and human rights impact of minerals in our products beyond 3TG, and enhance HPE’s due diligence capabilities;
•continue to monitor best practices and work with stakeholders to contribute to the development of novel and impactful solutions in Conflict- Affected and High-Risk Areas; and
•explore opportunities to further HPE’s mission to advance the way people live and work as it relates to the responsible sourcing of minerals.
Attachment A
Countries of Origin
Based on information available from RMI as of the 2024 Cut-Off Date and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals from supplier-reported SORs may (but have not been confirmed to) include the following countries.
| | | | | |
Covered Countries | Outside Covered Countries |
| Burundi | Argentina |
| Congo, Democratic Republic of the | Australia |
| Rwanda | Austria |
| Tanzania | Bolivia |
| Uganda | Brazil |
| Burkina Faso |
| Canada |
| Chile |
| China |
| Colombia |
| Cote d’Ivoire |
| Egypt |
| Ethiopia |
| French Guinea |
| Germany |
| Ghana |
| Guinea |
| Guyana |
| India |
| Indonesia |
| Japan |
| Kazakhstan |
| Kenya |
| Korea, Republic of |
| Kyrgyzstan |
| Liberia |
| Malaysia |
| Mali |
| Mauritania |
| Mexico |
| Morocco |
| Mozambique |
| Myanmar |
| Namibia |
| New Zealand |
| | | | | |
| Nigeria |
| Papua New Guinea |
| Peru |
| Philippines |
| Poland |
| Portugal |
| Senegal |
| Serbia |
| South Africa |
| Spain |
| Sudan |
| Suriname |
| Tajikistan |
| Thailand |
| Tunisia |
| Turkey |
| United States of America |
| Uzbekistan |
| Vietnam |
Attachment B
3TG Facility List
This 3TG Facility List sets forth the name, location, and status of all 298 of the 3TG facilities our suppliers reported to us. It is the result of our review of data from several sources, including information reported to us by 3TG Direct Suppliers, obtained through supplemental engagement with certain 3TG facilities, and from RMI. Inclusion on this list is not necessarily an indication that any particular facility supplies materials that are ultimately incorporated into HPE products. In many cases facility information was provided to us for the entire supply chain of 3TG Direct Suppliers, and did not identify with specificity those 3TG facilities believed to contribute necessary conflict minerals to any of our products.
| | | | | | | | | | | |
| Metal | Facility Name1 | Facility Location2 | Status3 |
| Gold | 8853 S.p.A. | ITALY | Non Conformant |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA | Not yet participating |
| Gold | Abingdon Reldon Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Active |
| Gold | Agosi AG | GERMANY | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Non Conformant |
| Gold | Albino Mountinho Lta. | PORTUGAL | Not yet participating |
| Gold | Alexy Metals | UNITED STATES OF AMERICA | Non Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conformant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Gold | Augmont Enterprises Private Limited | INDIA | Non Conformant |
| Gold | Aurubis AG | GERMANY | Conformant |
| Gold | Bangalore Refinery | INDIA | Active |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | Boliden Ronnskar | SWEDEN | Conformant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | Caridad | MEXICO | Not yet participating |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Non Conformant |
| Gold | CGR Metalloys Pvt Ltd. | INDIA | Non Conformant |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Conformant |
| Gold | Coimpa Industrial LTDA | BRAZIL | Conformant |
| | | | | | | | | | | |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not yet participating |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not yet participating |
| Gold | Dongwu Gold Group | CHINA | Not yet participating |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | Not yet participating |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | Not yet participating |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | Not yet participating |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | Not yet participating |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | Non Conformant |
| Gold | Gold by Gold Colombia | COLOMBIA | Conformant |
| Gold | Gold Coast Refinery | GHANA | Not yet participating |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not yet participating |
| Gold | Guangdong Jinding Gold Limited | CHINA | Not yet participating |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not yet participating |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not yet participating |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not yet participating |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | Not yet participating |
| Gold | HwaSeong CJ Co., Ltd. | KOREA, REPUBLIC OF | Not yet participating |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| Gold | Italpreziosi | ITALY | Conformant |
| Gold | JALAN & Company | INDIA | Not yet participating |
| Gold | Japan Mint | JAPAN | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | K.A. Rasmussen | NORWAY | Not yet participating |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not yet participating |
| Gold | Kazzinc | KAZAKHSTAN | Conformant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Kundan Care Products Ltd. | INDIA | Not yet participating |
| Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not yet participating |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF
| Conformant |
| | | | | | | | | | | |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | MD Overseas | INDIA | Not yet participating |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | Not yet participating |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Conformant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Gold | MKS PAMP SA | SWITZERLAND | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | Morris and Watson | NEW ZEALAND | Not yet participating |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Conformant |
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | Not yet participating |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not yet participating |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| Gold | PX Précinox S.A. | SWITZERLAND | Conformant |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | Not yet participating |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Not yet participating |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | SAAMP | FRANCE | Non Conformant |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Not yet participating |
| Gold | Safimet S.p.A | ITALY | Non Conformant |
| Gold | SAFINA A.S. | CZECHIA | Conformant |
| Gold | Sai Refinery | INDIA | Not yet participating |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Non Conformant |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not yet participating |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Conformant |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | Not yet participating |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not yet participating |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA | Not yet participating |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | Not yet participating |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Non Conformant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | Sovereign Metals | INDIA | Not yet participating |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Not yet participating |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Not yet participating |
| Gold | T.C.A S.p.A | ITALY | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not yet participating |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| Gold | Umicore Precious Metals Thailand | THAILAND | Non Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | WEEEREFINING | FRANCE | Conformant |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| Gold | Yamakin Co., Ltd. | JAPAN | Conformant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not yet participating |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| Tantalum | 5D Production OU | ESTONIA | Not yet participating |
| Tantalum | AMG Brasil | BRAZIL | Conformant |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Active |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | KEMET de Mexico | MEXICO | Conformant |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Conformant |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| Tantalum | NPM Silmet AS | ESTONIA | Conformant |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Conformant |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | Conformant |
| Tantalum | TANIOBIS GmbH | GERMANY | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not yet participating |
| Tin | Aurubis Beerse | BELGIUM | Conformant |
| Tin | Aurubis Berango | SPAIN | Conformant |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Conformant |
| Tin | CRM Synergies | SPAIN | Conformant |
| Tin | CV Ayi Jaya | INDONESIA | Conformant |
| Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
| Tin | Dowa | JAPAN | Conformant |
| Tin | DS Myanmar | MYANMAR | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Non Conformant |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | Fenix Metals | POLAND | Conformant |
| | | | | | | | | | | |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | Not yet participating |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Non Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Non Conformant |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Non Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
| Tin | Luna Smelter, Ltd. | RWANDA | Conformant |
| Tin | Ma’anshan Weitai Tin Co., Ltd | CHINA | Non Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Non Conformant |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| Tin | Mineração Taboca S.A. | BRAZIL | Conformant |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | Conformant |
| Tin | Minsur | PERU | Conformant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not yet participating |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | Operaciones Metalúrgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Pongpipat Company Limited | MYANMAR | Not yet participating |
| Tin | Precious Minerals and Smelting Limited | INDIA | Active |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Conformant |
| Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
| Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| Tin | PT Bangka Tin Industry | INDONESIA | Active |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Active |
| Tin | PT Bukit Timah | INDONESIA | Conformant |
| Tin | PT Cipta Persada Mulia | INDONESIA | Conformant |
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | Conformant |
| Tin | PT Panca Mega Persada | INDONESIA | Not yet participating |
| Tin | PT Premium Tin Indonesia | INDONESIA | Conformant |
| Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | Conformant |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant |
| | | | | | | | | | | |
| Tin | PT Rajehan Ariq | INDONESIA | Conformant |
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
| Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
| Tin | PT Timah Nusantara | INDONESIA | Conformant |
| Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
| Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
| Tin | PT Tirus Putra Mandiri | INDONESIA | Not yet participating |
| Tin | PT Tommy Utama | INDONESIA | Conformant |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Conformant |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tin | Super Ligas | BRAZIL | Conformant |
| Tin | Thaisarco | THAILAND | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | Conformant |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not yet participating |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Not yet participating |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| Tungsten | China Molybdenum Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not yet participating |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF | Not yet participating |
| Tungsten | Fujian Xinlu Tungsten | CHINA | Conformant |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF | Not yet participating |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | Non Conformant |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not yet participating |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Masan High-Tech Materials | VIET NAM | Conformant |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | Conformant |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | YUDU ANSHENG TUNGSTEN CO, LTD | CHINA | Not yet participating |
1.Entities that have been reported to us by our 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by RMI (as of the 2024 Cut-Off Date) to be smelters, refiners, recyclers or scrap processors of conflict minerals (i.e., the “3TG facilities”). The facility names are listed as they appear on the RMI Facility Database. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler, or scrap processor) that is processing different types of minerals or metals.
2.The facility locations are listed as they appear for each of the 3TG facilities on the RMI Facility Database.
3.Conformant refers to 3TG facilities that are listed by RMI (as of the 2024 Cut-Off Date) as (a) conformant with RMAP protocols or (b) certified or accredited by a similar independent assessment program such as the RJC Chain-of-Custody and Code of Practices Program, or the LBMA Responsible Gold Programme. Active refers to smelter or refiner facilities that are engaged in RMAP but not yet conformant (as of the 2024 Cut-Off Date). Non-conformant refers to facilities that are non-conformant to the RMAP standard (as of the 2024 Cut-Off Date). Not yet participating refers to 3TG facilities that are not engaged with an audit program.
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