United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
ARCONIC INC.
(Exact name of registrant as specified in its charter)
| Delaware | 1-3610 | 25-0317820 | ||
|
(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
|
390 Park Avenue New York, New York |
10022-4608 | |
| (Address of principal executive offices) | (Zip Code) |
Office of Investor Relations 212-836-2758
Office of the Secretary 212-836-2732
(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, 2017. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Overview
Unless the context indicates otherwise, the terms “Arconic,” “Company,” “we,” “its,” “us” and “our” refer to Arconic Inc. and all subsidiaries consolidated for the purposes of its financial statements that were in-scope for the 2017 compliance period. The “Conflict Minerals Rule” means, collectively, Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.
See the Conflict Minerals Report filed as an exhibit to this report (the “Conflict Minerals Report”) for information regarding the applicability of the Conflict Minerals Rule to the Company generally.
Reasonable Country of Origin Inquiry Information
We conducted a “reasonable country of origin inquiry” (“RCOI”) within the meaning of the Conflict Minerals Rule to determine the origin of the necessary 3TG contained in our in-scope products. To the extent applicable, we utilized the same processes and procedures for our RCOI that we used for our due diligence described in the Conflict Minerals Report. We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (collectively, the “OECD Guidance”). For a discussion of our OECD Guidance framework and the due diligence measures that we performed in respect of 2017, see the Conflict Minerals Report filed as an exhibit to this Form SD.
Based on our RCOI, we determined that the necessary tin contained in certain of our in-scope products originated from smelters that we believe, based on publicly available information, sourced all of their ore from outside of the Democratic Republic of the Congo (the “DRC”) and its adjoining countries or from recycled or scrap sources. These products were (i) selected titanium alloys manufactured by our Arconic Engineered Structures (in 2017, Power and Propulsion) business unit, (ii) a wrought aluminum alloy product manufactured in the United States by our Arconic Engineered Structures (in 2017, Forgings and Extrusions) business unit and (iii) certain titanium mill products manufactured by our Arconic Engineered Structures (in 2017, Titanium and Engineered Products) business unit and the titanium fabricated parts made with titanium manufactured by that business unit. None of these products contained 3TG from any other sources.
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The foregoing information is available at the following Internet website: http://www.arconic.com. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or our Conflict Minerals Report.
Conflict Minerals Report
As provided for in the Conflict Minerals Rule, a Conflict Minerals Report is provided as an exhibit to this Form SD and is available at the following Internet website: http://www.arconic.com.
Item 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report for the calendar year ended December 31, 2017
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Arconic Inc. | ||
| (Registrant) | ||
| By: | /s/ Katherine H. Ramundo | May 30, 2018 |
| Name: | Katherine H. Ramundo | |
| Title: | Executive Vice President, | |
| Chief Legal Officer and Secretary | ||
EXHIBIT INDEX
|
Exhibit |
Description | |
| 1.01 | Conflict Minerals Report for the calendar year ended December 31, 2017 | |
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Exhibit 1.01
Conflict Minerals Report
Arconic Inc. has included this Conflict Minerals Report as an exhibit to its Form SD for 2017 as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”).
Unless the context indicates otherwise, the terms “Arconic,” “Company,” “we,” “its,” “us” and “our” refer to Arconic Inc. and all subsidiaries consolidated for the purposes of its financial statements that were in-scope for the 2017 compliance period. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.
Forward-Looking Statements
Certain statements in this report relate to future events and expectations, and as such constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include those containing such words as “anticipates,” “believes,” “could,” “estimates,” “expects,” “forecasts,” “goal,” “intends,” “may,” “outlook,” “plans,” “projects,” “seeks,” “sees,” “should,” “targets,” “will,” “would,” or other words of similar meaning. All statements that reflect Arconic’s expectations, assumptions, or projections about the future, other than statements of historical fact, are forward-looking statements, including, without limitation, statements concerning the additional steps that Arconic intends to take to mitigate the risk that its necessary 3TG finance or benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties may include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners (“SORs”) and other market participants responsibly source 3TG, and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere and the other risk factors summarized in Arconic’s Form 10-K for the year ended December 31, 2017, and other reports filed with the Securities and Exchange Commission (the “SEC”). Arconic disclaims any obligation to update publicly any forward-looking statements, whether in response to new information, future events or otherwise, except as required by applicable law.
| I. | Overview |
Arconic is a global leader in lightweight metals engineering and manufacturing. Arconic’s innovative, multi-material products, which include aluminum, titanium, and nickel, are used worldwide in aerospace, automotive, commercial transportation, building and construction, industrial applications, defense, and packaging.
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We are subject to the Conflict Minerals Rule because 3TG are necessary to the functionality or production of certain discrete products and product lines manufactured by Arconic (these 3TG are sometimes referred to herein as “necessary 3TG”). Necessary 3TG content constitutes a small portion of the materials content of our products and many of our products do not contain any 3TG. For a further discussion of our products, see our Annual Report on Form 10-K for the fiscal year ended December 31, 2017. The information contained in our Form 10-K is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or our Form SD.
We have filed this Conflict Minerals Report because, for 2017, some of our in-scope products contained 3TG that either were of an undetermined origin or were processed by Conformant (as defined below) SORs that we believe, based on publicly available information, may have sourced a portion of their ore from the DRC or an adjoining country. Through the date of this report, we are unaware and have no knowledge that any of the necessary 3TG contained in our in-scope products directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. However, we make no assertion that any of our products are “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
See “Product, Smelter and Refiner and Country of Origin Information” below for information concerning our in-scope products, identified SORs and country of origin information.
For 2017, we generally did not directly source 3TG from SORs, and we did not have direct relationships with any 3TG mines.
| II. | Reasonable Country of Origin Inquiry Information |
See the Form SD to which this Conflict Minerals Report is an exhibit for a discussion of the “reasonable country of origin inquiry” that we conducted.
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| III. | Due Diligence |
Due Diligence Program Design
We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”).
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Our application of the OECD Guidance in respect of 2017 is discussed below. The headings for each of the steps in the next section conform to the headings used in the OECD Guidance for each of its five steps.
Due Diligence Program Execution
In furtherance of our 3TG due diligence, we performed the following due diligence measures in respect of 2017. These were not all of the discrete measures that we took in furtherance of our 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance.
| 1. | OECD Guidance Step One: “Establish strong company management systems” |
| a. | We maintain a team charged with managing our 3TG compliance strategy, that ultimately reports to the Chief Procurement Officer and the Chief Legal Officer. The following functional areas were represented on the working group: external reporting; legal; and procurement. We also appointed representatives from each reporting segment or business unit with potentially in-scope products. Selected internal personnel were educated on the Conflict Minerals Rule and our compliance plan. We also used specialist outside counsel to assist us with certain aspects of our compliance efforts for 2017. |
| b. | Some of the compliance measures described herein were performed on our behalf by the Service Provider (as defined below). |
| c. | Arconic’s procurement function maintains a standard operating procedure (“SOP”) governing purchases of 3TG and materials or products containing 3TG. The SOP defines the processes that our procurement function uses to source 3TG and materials or products containing 3TG and to support the annual disclosure of country of origin information for those minerals. The SOP provides that we will only purchase 3TG or materials or products containing 3TG from suppliers that can provide acceptable certification that the minerals did not originate from sources that directly or indirectly financed or benefitted armed groups in the DRC or its adjoining countries. |
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| d. | We used the then latest version of the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”) (formerly the Conflict-Free Sourcing Initiative) to identify SORs in our supply chain. We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, in a structured computerized database, for at least five years. |
| e. | We furnished our direct suppliers that we determined to be potentially in-scope for purposes of our compliance with the Conflict Minerals Rule (the “Suppliers”) with an introductory email and a blank copy of the CMRT for their use in responding. |
| f. | To help ensure the quality and completeness of the CMRTs received from the Suppliers, certain Suppliers were provided access to the Service Provider’s online resource center. There were also opportunities to participate in webinars offered by the Service Provider, providing information on the Conflict Minerals Rule. |
| g. | We have a grievance mechanism for employees, suppliers and other interested parties to report violations of our 3TG program compliance requirements. |
| 2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” |
| a. | We determined which of our products were in-scope or potentially in-scope for purposes of our compliance with the Conflict Minerals Rule through product specifications, bills of material, supplier inquiries, elemental composition limits, spectrographic analysis of the product composition and other information known to us. |
| b. | We engaged a third-party supply chain compliance resource (the “Service Provider”) to conduct our supplier outreach, and collect and compile Supplier responses and to assist us in our review and analysis of CMRTs. |
| c. | The Service Provider requests by email that suppliers provide us with information, through the completion of a CMRT or its equivalent survey mechanism, concerning the usage and source of 3TG in their products, as well as information concerning the suppliers’ related compliance measures. Suppliers were requested to provide information at a “product” level. Both we and the Service Provider follow up multiple times, if required, by email or phone with suppliers that do not respond to the request within the specified time frame. For 2017, our overall Supplier response rate was 71%. |
| d. | The Service Provider reviews the responses received from suppliers for plausibility, consistency and gaps. It follows up by email or phone with suppliers that submit a response that triggers any one of seven specified quality control flags. We also reviewed the completed responses received from Suppliers and followed up with Suppliers where we determine it to be appropriate in accordance with our internal written evaluation criteria. |
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| e. | SOR information provided by suppliers is reviewed against the Service Provider’s internal database. To the extent not in that database, it requests that the supplier confirm that the listed entity is a SOR. |
| f. | SOR information also is reviewed by the Service Provider against the lists of Conformant and Active (as defined herein), or the equivalent, SORs published by the RMI, the London Bullion Market Association and the Responsible Jewellery Council. For 2017, our Suppliers identified 66 SORs. |
| g. | To the extent that a SOR identified by a supplier is not listed as Conformant or the equivalent by an independent third-party, the Service Provider attempts to contact the SOR to gain more information about its sourcing practices, including countries of origin and transfer and whether there are internal due diligence procedures in place or other processes that the SOR takes to track the chain of custody on the source of its 3TG. Internet research is also performed to determine whether there are any outside sources of information regarding the SOR’s sourcing practices. “Red flags” are assigned to SORs where there is evidence of sourcing from a “Level 2 country” (i.e., a known or plausible country for smuggling out of the DRC region, export or transit) or declaration of sourcing from countries which are unknown reserves for a given metal. Conformant SORs are reviewed against the Service Provider’s internal country of origin database. |
| h. | If a supplier does not provide information concerning the processors of 3TG in its supply chain, the Service Provider requests information on the suppliers’ Tier 2 suppliers. The Tier 2 suppliers, and subsequent tiers of suppliers as identified to the Service Provider, are then contacted by the Service Provider following the procedures described above. |
| i. | Based on the information furnished by our suppliers, the Service Provider and other information known to us, we assess the risks of adverse impacts. |
| 3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” |
| a. | Our 3TG compliance team reports its findings to our Chief Procurement Officer and Chief Legal Officer. |
| b. | Under our risk mitigation strategy, we take such risk mitigation efforts as we deem to be appropriate based on the findings of our supply chain risk assessment. Our risk mitigation efforts are determined by the particular facts and circumstances and risks identified. |
| c. | To mitigate the risk that our necessary 3TG finance or benefit armed groups, we also intend to engage in the additional measures discussed under “Additional Risk Mitigation Efforts” below. |
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| 4. | OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” |
In connection with our due diligence, we utilized information from the Service Provider and information made available by the RMI concerning independent third-party audits of SORs.
| 5. | OECD Guidance Step 5: “Report on supply chain due diligence” |
We have filed a Form SD and this Conflict Minerals Report with the SEC and made available on our website the Form SD and this Conflict Minerals Report.
| IV. | Product, Smelter and Refiner and Country of Origin Information |
Product Information
For 2017, the following in-scope products had necessary 3TG that originated or may have originated from the DRC or its adjoining countries: (1) certain investment cast airfoils (superalloy), investment cast structures (superalloy, aluminum and titanium) and coatings for nickel-based castings; (2) certain fastening systems or components and seamless rolled ring forgings; (3) certain building and construction products; (4) coated aluminum commercial vehicle wheels; (5) certain wrought aluminum alloy products; (6) an aluminum alloy billet product; (7) certain coated aluminum coil products for industrial applications; (8) certain fabricated titanium or specialty metal components; and (9) cast and wrought nickel-based, cobalt-based and iron-based alloys for metals fabricating.
Smelter and Refiner Information
The Suppliers identified to us the facilities listed in Annex A to this report as having processed the necessary 3TG contained in the in-scope products described above. The SORs listed in Annex A may not be all of the facilities used to process the necessary 3TG in our supply chain, since not all of the Suppliers responded to our request and the Suppliers that did respond to our request in some cases did not identify the processors of all of the 3TG content contained in these products. Although we requested “product” level disclosure from Suppliers, Suppliers responded on a “product” level, “company” level or “user defined” basis.
Country of Origin Information
Annex A to this report lists the identified facilities and provides country of origin information. However, if a SOR sourced from multiple countries, we were not able to determine the country of origin of the 3TG specific to our products. Therefore, not all of the countries of origin may apply to the 3TG in our in-scope products. We do not have country of origin information for 3TG processed by some of the SORs listed in Annex A.
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Some of Arconic’s products described above that contained 3TG for which we were not able to determine the origin also contained 3TG that, based on our reasonable country of origin inquiry, we believe came from recycled or scrap sources.
We sought to determine the mine or location of origin of the necessary 3TG contained in our in-scope products by requesting that the Suppliers provide us with a completed CMRT. Where a SOR was identified, we or the Service Provider on our behalf also reviewed publicly available information, to the extent available, to try to determine the mine or location of origin.
| V. | Additional Risk Mitigation Efforts |
We intend to take the following additional steps in respect of our 2018 compliance to mitigate the risk that the necessary 3TG in our in-scope products finance or benefit armed groups:
| 1. | Continue to encourage Suppliers that provided company level information for 2017 to provide product level information for 2018. |
| 2 | Request Suppliers that provided incomplete responses or that did not provide responses for 2017 to provide requested information for 2018. |
| 3. | Monitor the continuing development and progress of traceability measures at Suppliers that indicated for 2017 that the source of 3TG was unknown or undeterminable. |
| 4. | Communicate to in-scope suppliers our sourcing expectations through the conflict minerals clause in our standard terms and conditions. |
All of the foregoing steps are in addition to the steps that we took in respect of 2017, which we intend to continue to take in respect of 2018, to the extent applicable.
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Annex A
The following list contains SORs reported by our Suppliers as having been used to process the necessary conflict minerals contained in Arconic’s in-scope products. This data is presented as of May 22, 2018.
| Metal | Smelter or Refiner Name | Smelter or Refiner Location | Status |
| Tantalum | D Block Metals, LLC | United States | Conformant |
| Tantalum | Exotech Inc. | United States | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | China | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | Conformant |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | Conformant |
| Tantalum | Telex Metals | United States | Conformant |
| Tin | China Tin Group Co., Ltd. | China | Conformant |
| Tin | Cooperativa Metalurgica de Rondonia Ltda. | Brazil | Conformant |
| Tin | CV Tiga Sekawan | Indonesia | Conformant |
| Tin | CV United Smelting | Indonesia | Conformant |
| Tin | CV Venus Inti Perkasa | Indonesia | Conformant |
| Tin | EM Vinto | Bolivia | Conformant |
| Tin | Fenix Metals | Poland | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant |
| Tin | Metallo Belgium N.V. | Belgium | Conformant |
| Tin | Metallo-Chimique N.V. | Belgium | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | Conformant |
| Tin | Minsur | Peru | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | Conformant |
| Tin | Operaciones Metalurgical S.A. | Bolivia | 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 Bangka Prima Tin | Indonesia | Conformant |
| Tin | PT Bangka Tin Industry | Indonesia | Conformant |
| Tin | PT Belitung Industri Sejahtera | Indonesia | Conformant |
| Tin | PT Bukit Timah | Indonesia | Conformant |
| Tin | PT DS Jaya Abadi | Indonesia | Conformant |
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Conformant |
| Tin | PT Inti Stania Prima | Indonesia | Conformant |
| Tin | PT Lautan Harmonis Sejahtera | Indonesia | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | Conformant |
| Tin | PT Panca Mega Persada | Indonesia | Conformant |
| Tin | PT Prima Timah Utama | Indonesia | Conformant |
| Tin | PT Refined Bangka Tin | Indonesia | Conformant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | Conformant |
| Tin | PT Stanindo Inti Perkasa | Indonesia | Conformant |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia | Conformant |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia | Conformant |
| Tin | PT Tinindo Inter Nusa | Indonesia | Conformant |
| Tin | Rui Da Hung | Taiwan | Conformant |
| Tin | Thaisarco | Thailand | Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
| Tin | Yunnan Tin Company Limited | China | Conformant |
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| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Ganzhou Huaxing Tungsten Products 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 | Conformant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant |
| 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 Huntsville | United States | Conformant |
| Tungsten | Shaoguan Xinhai Rendan Tungsten Industry Co. Ltd | China | Conformant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Viet Nam | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Conformant |
| Tungsten | Zhangyuan Tungsten Co Ltd | China | Conformant |
| Tungsten | Jiangxi Tungsten Industry Group Co. Ltd. | China | On Smelter Look-up Tab List Only |
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The Company notes the following in connection with the information in the table above:
| a. | The SORs reflected above may not include all of the SORs in Arconic’s supply chain, since some Suppliers did not identify all of their SORs and because not all Suppliers responded to Arconic’s inquiries. |
| b. | The table only includes entities that were listed as SORs on the Smelter Look-up tab list of the CMRT. |
| c. | “Conformant” means that a SOR was listed as conformant with the Responsible Minerals Assurance Program’s (the “RMAP”) assessment protocols, including through mutual recognition. SORs that are listed as “Re-audit in process” by the RMAP are considered to be Conformant by the RMAP. Included SORs were not necessarily Conformant for all or part of 2017 and may not continue to be Conformant for any future period. |
| d. | While none of the SORs is listed as “Active,” “Active” is a RMAP designation that means that the SOR is a participant in the RMAP and has committed to undergo an audit or is participating in a cross-recognized certification program. |
| e. | “On Smelter Look-up Tab List Only” means that a SOR is listed on the Smelter Look-up tab list of the CMRT, but is not listed as “Conformant” or “Active.” |
| f. | SOR status and location reflected in the table is based solely on information made publicly available by the RMI, without independent verification by Arconic. |
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Country of Origin Information
The countries of origin of the 3TG processed by the SORs listed in the table above are believed to have potentially included the countries in the categories listed below. The categories are organized by risk. These may not be all of the countries from which the identified SORs have sourced, and the identified SORs may not have sourced from all of these countries.
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the Covered Countries: Argentina, Australia, Austria, Bolivia (Plurinational State of), Brazil, Cambodia, Canada, China, Colombia, Ethiopia, France, Germany, Guinea, Guyana, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mexico, Mongolia, Myanmar, Namibia, Nigeria, Peru, Portugal, Russian Federation, Sierra Leone, Spain, Thailand, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam and Zimbabwe
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Mozambique.
L3 - The DRC and its adjoining countries: Burundi, Rwanda, Uganda
DRC - The Democratic Republic of the Congo.
Alternatively, or in addition, some of the identified SORs may have sourced from recycled or scrap sources.
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