UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
________________________________
FORM SD
Specialized Disclosure Report
________________________________
ALLEGION PUBLIC LIMITED COMPANY
(Exact name of registrant as specified in its charter)
________________________________
| | | | | | | | | | | | | | |
| Ireland | | 001-35971 | | 98-1108930 |
| (State or other jurisdiction of incorporation or organization) | | (Commission File No.) | | (IRS Employer Identification No.) |
| | | | |
Block D
Iveagh Court
Harcourt Road
Dublin 2, Ireland | | D02 VH94 |
| (Address of principle executive offices) | | (Zip code) |
| | | | |
Eric Gunning
Deputy General Counsel and Company Secretary
(317) 810-3700 |
(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:
☒ 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 ________.
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
The Conflict Minerals Report of Allegion Public Limited Company (the "Company") for the calendar year ended December 31, 2023 is filed as Exhibit 1.01 to this specialized disclosure report on Form SD. The Conflict Minerals Report is publicly available at https://www.allegion.com/corp/en/about/csr/sustainability-and-safety/conflict-minerals.html. Information on the Company's website is not incorporated by reference into this Form SD.
Item 1.02 Exhibit
The Company's Conflict Minerals Report for the calendar year ended December 31, 2023 is filed as Exhibit 1.01 to this Form SD and is incorporated herein by reference.
Item 2.01 Exhibits
| | | | | |
| Exhibit | Description |
| Conflict Minerals Report for the Year Ended December 31, 2023 |
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.
| | | | | | | | |
| ALLEGION PUBLIC LIMITED COMPANY | | |
| (Registrant) | | |
| | |
| /s/ Eric Gunning | | May 31, 2024 |
Eric Gunning
Deputy General Counsel & Company Secretary | | (Date) |
Exhibit 1.01
Allegion plc
Conflict Minerals Report
For the reporting period January 1 to December 31, 2023
EXHIBIT 1.01
Allegion plc
Conflict Minerals Report
For the reporting period from January 1 to December 31, 2023
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Contents | |
| Background ..................................................................................................................................................... | 3 |
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Forward Looking Statements .......................................................................................................................... | 4 |
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| Covered Minerals ............................................................................................................................................ | 4 |
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| Company Overview.......................................................................................................................................... | 4 |
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| Product Description.......................................................................................................................................... | 5 |
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| Conflict Minerals Program Overview................................................................................................................ | 6 |
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| Reasonable Country of Origin Inquiry.............................................................................................................. | 6 |
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| OECD Due Diligence Framework in Practice................................................................................................... | 6 |
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| STEP 1: Establish Strong Company Management Systems........................................................................... | 7 |
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| Company Conflict Minerals Policy............................................................................................................. | 7 |
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| Internal Team............................................................................................................................................ | 7 |
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| Reporting Mechanism............................................................................................................................... | 9 |
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| STEP 2: Identify and Assess Risks in the Supply Chain.................................................................................. | 10 |
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| Scope…………………………............………………………………............………………........................... | 10 |
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| Execution.................................................................................................................................................. | 11 |
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| STEP 3: Design and Implement a Strategy to Respond to Identified Risks..................................................... | 14 |
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| STEP 4: Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices................................... | 14 |
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| STEP 5: Report Annually on Supply Chain Due Diligence............................................................................... | 15 |
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| 2023 Results............................................................................................................................................. | 15 |
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| Due Diligence Determination.................................................................................................................... | 16 |
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| Independent Private Sector Audit.............................................................................................................. | 16 |
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| Future Initiatives........................................................................................................................................ | 16 |
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| Reported Entities.............................................................................................................................................. | 17 |
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| Definitions........................................................................................................................................................ | 23 |
Background
This Specialized Disclosure Report on Form SD of Allegion plc ("Allegion," "we," "us" or the “Company") for the year ended Dec. 31, 2023 was prepared to comply with the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("the Dodd-Frank Act"). Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), adopted pursuant to Section 1502 the Dodd-Frank Act, was approved by the U.S. Securities and Exchange Commission (the "SEC") on Aug. 22, 2012 and imposes annual reporting requirements on SEC reporting companies relating to the presence of conflict minerals in the products that they manufacture or contract to manufacture.
The rule on conflict minerals focuses on the Democratic Republic of the Congo ("DRC") and its adjoining countries (the “Covered Countries”), a central African region with vast mineral wealth, including reserves of conflict minerals.
Forward-Looking Statements
Certain statements in this report, other than purely historical information, are “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These forward-looking statements generally are identified by the words “believe,” “project,” “expect,” “anticipate,” “estimate,” “forecast,” “outlook,” “intend,” “strategy,” “future,” “opportunity,” “plan,” “may,” “should,” “will,” “would,” “will be,” “will continue,” “will likely result” or the negative thereof or variations thereon or similar expressions generally intended to identify forward-looking statements.
Forward-looking statements are based on the Company's currently available information and our current assumptions, expectations and projections about future events. They are subject to future events, risks and uncertainties - many of which are beyond the Company’s control - as well as potentially inaccurate assumptions, that could cause actual results to differ materially from those in the forward-looking statements. Further information on these factors and other risks that may affect the Company's business is included in filings it makes with the Securities and Exchange Commission from time to time, including its Annual Reports filed on Form 10-K, its Quarterly Reports filed on Form 10-Q, and in its other SEC filings. The Company undertakes no obligation to update any forward-looking statements.
Covered Minerals
The minerals covered by the SEC rules go by the name conflict minerals, also referred to as 3TGs, an abbreviation for Tin, Tantalum, Tungsten and Gold. These conflict minerals are used in many manufactured goods across many industries, including the aerospace, appliances, automotive, electronics, jewelry, medical and tool and die industries. The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or certain of their derivatives (currently limited to tin, tantalum and tungsten); or (B) any other minerals or derivatives designated by the Secretary of State in the future, although no additional minerals or derivatives have been so designated at this time.
Company Overview
We are a global pioneer in seamless access, providing security products and solutions that keep people and their assets safe and secure in the places they live, learn, work and visit. We create peace of mind by pioneering safety and security with a vision of seamless access and a safer world. Seamless access allows authorized, automated and safe passage and movement through spaces and places in the most efficient and frictionless manner possible. Central to our vision is partnering and developing ecosystems to create a flawless experience and enable an uninterrupted and secure flow of people and assets. We offer an extensive and versatile portfolio of security and access control products and solutions across a range of market-leading brands. Our experts across the globe deliver high-quality security
products, services and systems, and we use our deep expertise to serve as trusted partners to end-users who seek customized solutions to their security needs. We have prepared this report to satisfy the requirements of Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Exchange Act.
Product Description
The following categories of electronic and other products we manufacture or contract to manufacture may contain conflict minerals that are necessary to the functionality or production of such products:
•Locks, locksets, portable locks and key systems: A broad array of cylindrical, tubular and mortise door locksets, security levers and master key systems that are used to protect and control access and a range of portable security products, including bicycle, small vehicle and travel locks;
•Electronic security products and access control systems: A broad range of electrified locks, electrified door closers and exit devices, access control products and systems, credentials and credential readers and accessories, including IoT, Bluetooth Low Energy, Power over Ethernet and cloud-based solutions;
•Time, attendance and workforce productivity systems: These products are designed to help business customers manage and monitor workforce access, attendance and employee scheduling;
•Door controls and systems and exit devices: An extensive portfolio of life-safety products and solutions generally installed on fire doors and facility entrances and exits. Exit devices, also known as panic hardware, provide rapid egress to allow building occupants to exit safely in an emergency. Door controls and systems include mechanical door closers, automatic door operators, as well as high-performance interior and storefront door systems. In addition, with our recently acquired Access Technologies business, we now offer a full range of automatic entrance solutions, including sliding, swing, folding and ICU doors, as well as an array of sensors, controls and security options for commercial and institutional buildings;
•Doors, accessories and other: A portfolio of hollow metal, glass and specialty doors, as well as a variety of additional security products and components, including hinges, door pulls, door stops, bike lights, louvers, weather stripping, thresholds and other accessories, as well as certain bathroom fittings and accessibility aids; and
•Services and software: Our Access Technologies business offers extensive planned inspection, maintenance and repair services for its automatic entrance solutions throughout the U.S. and Canada. Additionally, we offer software as a service ("SaaS") offerings throughout the U.S. and internationally, including access control, IoT integration and workforce management solutions. We also offer ongoing aftermarket services, design and installation offerings and locksmith services in select locations.
Conflict Minerals Program Overview
As a purchaser, we are many layers removed from the mining of the conflict minerals, and we do not directly purchase raw ore or unrefined conflict minerals. We rely on collaboration with our supplier base by building awareness through training and provide support to identify the upstream supply chain and the originating smelter(s)/refiner(s) for the conflict minerals that ultimately are found in our products.
This effort is both challenging and demanding, as many of our suppliers are private entities that are not directly affected by the Rule, and many times do not have the financial and human resources to comply with the requests. Furthermore, our suppliers have their own supply chains and need to collaborate with their own upstream suppliers in order provide transparency of the end-to-end supply chain and to identify the smelter(s)/refiner(s).
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) regarding the conflict minerals by utilizing the conflict minerals reporting template (“CMRT”) provided by the Responsible Business Alliance’s (“RBA”) through its Responsible Minerals Initiative (“RMI”). Our RCOI was designed to determine whether any of the conflict minerals in the products we manufacture or contract to manufacture originated in the Covered Countries or were from recycled or scrap sources by asking our suppliers to identify the smelters and refiners of the conflict minerals contained in the products or raw materials that they supply to us. We reviewed the information our suppliers provided and compared it to publicly available information about such smelters and refiners.
OECD Due Diligence Framework in Practice
We designed our due diligence measures to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) and the related Supplements for gold, tin, tantalum and tungsten (the “Guidance”). The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:
1.Establishing strong company management systems regarding conflict minerals;
2.Identifying and assessing risks in our supply chain;
3.Designing and implementing a strategy to respond to identified risks in our supply chain;
4.Utilizing independent third-party audits of supply chain diligence; and
5.Publicly reporting on our supply chain due diligence
The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our strategic, direct suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.
STEP 1: Establish Strong Company Management Systems
Company Conflict Minerals Policy
Our policy is to support the legitimate businesses within the Covered Countries, and we expect our suppliers to source conflict minerals responsibly by establishing conflict minerals compliance policies and a due diligence process to support their conflict minerals data collection efforts.
To view our complete Conflict Minerals Policy, visit our webpage located at:
https://www.allegion.com/corp/en/about/ESG/environmental/conflict-minerals.html.
Internal Team
Our conflict minerals program is designed to conform to the internationally recognized due diligence framework of the OECD. The framework includes standard operating procedures, supplier risk segmentation, established processes for RCOI, due diligence and escalation, training and communication, as well as a website containing our Conflict Minerals Policy with information about the regulation, contact information and the latest Form SD filing.
We have a global supply chain compliance team that reports up to the Vice President - Global Supply Chain & Operations Support and is responsible to the Corporate Secretary for the Form SD report creation and filing. The global supply chain compliance team focuses on driving the compliance efforts of the conflict minerals program, executing the procedures, working closely with a third-party regulatory compliance consulting firm to advance the maturity and sophistication of the program and further
strengthening the conformance with the OECD Guidance and standards. Our continued conflict minerals program maturity progress can be attributed to several successfully executed initiatives:
•Attendance at virtual conferences that include topics related to conflict minerals;
•Advancing internal knowledge through continuing education;
•Following any updates to relevant regulations (such as following news releases, webinars, industry initiatives); and
•Third-party software solution and consulting services, such as –
◦We leveraged this software to upload related legacy documents for retention purposes and will retain the records for a period of five years per the OECD Guidelines;
◦We are leveraging this software to offer training and updates for suppliers; and
◦We utilize their resources for benchmarking purposes.
We collaborate closely with our suppliers by developing long-lasting relationships. Our supplier development team has the responsibility to qualify and develop our suppliers. This team conducts periodic reviews of our Global Supplier Requirements Manual, which lays out the Company’s expectations of suppliers with respect to compliance with local, state and national regulations, including conflict mineral requirements.
Further, we have a dedicated commodity management team responsible for maintaining relationships with suppliers within their assigned commodities. This team also monitors supplier performance and selectively manages strategic relationships with preferred suppliers to help preserve the stability and longevity of the supplier relationships. Our supplier contracts contain a regulatory clause that explicitly lays out the expectations with the suppliers to comply with laws, including the Rule, and allows our company to audit and inspect data, records and other materials to evidence conflict minerals use and controls.
Per the OECD Guidelines, we retain and maintain our records for a period of five years on a company share-drive system. These records are also loaded into our third-party software system, Assent, and we will continue to leverage this system for record keeping purposes.
Reporting Mechanism
As part of our continuing efforts to ensure lawful and ethical behavior, the Allegion Code of Conduct and Allegion Business Partner Code of Conduct advise employees and business partners to report legal and ethical questions or concerns. Both documents can be found by clicking on the following link: https://www.allegion.com/corp/en/about/ESG/governance/ethics-and-compliance-program.html. Information contained on, or that may be accessed through, our websites is not incorporated by reference into, and is not part of this filing.
A variety of options are available for employees and business partners to ask questions or report concerns in the area of ethics and compliance.
Employees. As set forth in the Allegion Code of Conduct (“Code”), employees may contact their manager, local management or local Human Resources partner; they may also contact the Allegion Legal Department, Chief Compliance Officer or Ethics HelpLine (“HelpLine”). Specific instructions for contacting these resources are provided in the Code. Employees contacting the HelpLine may choose to remain anonymous if consistent with applicable local law. The HelpLine is available 24/7 and is staffed by an independent organization. The Code also includes a section entitled “Zero-tolerance for retaliation,” which prohibits retaliation against individuals asking questions or raising concerns.
Business Partners. The Allegion Business Partner Code of Conduct (“Business Partner Code”) states business partners who wish to seek guidance or report concerns in the ethics and compliance area may send an email to Allegion, submit a report to Allegion via the Internet, send a letter to Allegion by mail or contact the HelpLine. Specific instructions and information (such as email, internet and mailing addresses, and U. S. and international HelpLine phone numbers) on reporting using each of these resources is provided in the Business Partner Code. Examples of business partners noted in the Business Partner Code include agents, distributors, dealers, contractors, suppliers, vendors, service providers, intermediaries, joint venture partners and others.
STEP 2: Identify and Assess Risks in Our Supply Chain
Scope Identification
Due to our size, the complexity of our products, and the depth, breadth and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified by Assent Compliance (“Assent”), our third-party service provider, and members of our internal conflict minerals team who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
The primary risk we identified with respect to the reporting period ended Dec. 31, 2023, is related to the nature of the responses received. Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to Allegion. Additionally, some suppliers indicated that they received information regarding their supply chains from 50% or less of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains. Based on historical supply chain information, we performed a risk-based approach in our due diligence that included:
•Risk Identification through a commodity segmentation across the company for components (including electronic products) or products previously identified as containing, or were suspected of containing, conflict mineral(s).
•Risk Assessment and prioritization based on information about purchased components or products from engineering, catalogs, sourcing managers and commodity-taxonomy definition. Our categories were as follows:
◦High Concern
▪Electronic products / components
▪Materials / mechanical components containing 3TG’s
◦Low Concern
▪Mechanical products, molded components, finishing, powered coats
◦No Concern / Out of Scope
▪Plastics extrusions, foam/insulation
▪Packaging, paper, wood, chemicals, service providers, etc.
•Risk Monitoring of new suppliers and additional information, including changes in regulatory landscape. When new suppliers are identified, we conduct a risk assessment of the anticipated purchases to determine the concern level. Based on this assessment, we engage with all relevant suppliers and request that they complete and return the CMRT.
Execution
We retained Assent to oversee our 2023 CMRT campaign. Assent initiated the campaign with a communication to our supply base authorizing Assent to solicit information from our suppliers. Next, Assent distributed a “campaign kick-off” letter in multiple languages that laid out the timing of the campaign, the process and expectations. Following the campaign kick-off, Assent provided each supplier with:
•Allegion’s Conflict Minerals Policy;
•Information about the conflict minerals regulations;
•Training materials for the program and CMRT form (version 6.31);
•Allegion contact information and conflict minerals website; and
•CMRT response deadline.
We followed this pre-established process for all selected suppliers with reminders to complete and return the CMRT and validated the CMRT responses for completion and accuracy. In addition, we followed an escalation process for all suppliers who failed to timely complete and return the CMRT or who provided incomplete or inconsistent responses - the process included alternative communication medium (e.g., phone calls or emails from private accounts as opposed to company accounts), leveraging the commodity managers (including local commodity managers in other regions of the world) who had established relationships with the suppliers and online research of the suppliers to see if they provided any public information regarding conflict minerals (e.g., policy or Form SD filing).
Assent validated the smelter information provided by the suppliers using the most recent smelter and refinery validation list from the Responsible Minerals Initiative (RMI). Before the validation, the lists were reviewed and scrubbed for:
•Electronic component suppliers declaring NO 3TGs;
•Convert old smelter identification number (“CID”) to new CID;
•Remove duplicates and non-actionable submissions;
•Identify the CID based on the mineral, name, location;
•Remove any entries that don’t meet the RMI definition of a smelter or refiner; and
•Correct misspelled smelters/refiners.
Assent reviewed the list to identify smelters/refiners that were participating in the Responsible Minerals Assurance Process (“RMAP”), while a risk-based assessment was also performed on the remaining smelters/refiners in order to determine which suppliers posed increased risks in the supply chain. This risk assessment and further investigation consisted of, among other things:
•Reviews of Dun and Bradstreet reports;
•Checks of the U.S. Department of Commerce Conflict Mineral processing facilities;
•Verification of country of origin risk, as listed in the RMAP Audit Procedure; and
•Internet searches.
Assent used numerous factors to determine the level of risk that each smelter posed to the supply chain by identifying red flags. These factors include:
•Geographic proximity to Conflict-Affected and High-Risk Areas.
•Known mineral source country of origin.
•RMAP audit status.
•Credible evidence of unethical or conflict sourcing.
•Peer assessments conducted by credible third-party sources.
•Sanctions risks
Based on these criteria Assent identified the following third-party facilities in the received CMRT responses as “SORs of Interest”:
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| Yunnan Copper Industry Co., Ltd. | China | CID000197 |
| JSC Novosibirsk Refinery | Russian Federation | CID000493 |
| Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 |
| Hunan Jintai New Material Co., Ltd. | China | CID000769 |
| JSC Uralelectromed | Russian Federation | CID000929 |
| Gejiu Kai Meng Industry and Trade LLC | China | CID000942 |
| Lingbao Gold Co., Ltd. | China | CID001056 |
| Moscow Special Alloys Processing Plant | Russian Federation | CID001204 |
| Novosibirsk Tin Combine | Russian Federation | CID001305 |
| OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 |
| Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 |
| Samduck Precious Metals | Korea, Republic Of | CID001555 |
| SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 |
| Solikamsk Magnesium Works OAO | Russian Federation | CID001769 |
| Umicore Precious Metals Thailand | Thailand | CID002314 |
| Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516 |
| Emirates Gold DMCC | United Arab Emirates | CID002561 |
| Kaloti Precious Metals | United Arab Emirates | CID002563 |
| Hydrometallurg, JSC | Russian Federation | CID002649 |
| Unecha Refractory metals plant | Russian Federation | CID002724 |
| Moliren Ltd. | Russian Federation | CID002845 |
| AU Traders and Refiners | South Africa | CID002850 |
| GGC Gujrat Gold Centre Pvt. Ltd. | India | CID002852 |
| Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865 |
| Pongpipat Company Limited | Myanmar | CID003208 |
| Artek LLC | Russian Federation | CID003553 |
| LLC Vostok | Russian Federation | CID003643 |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927 |
| PT Panca Mega Persada | Indonesia | CID001457 |
| Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515 |
| Sudan Gold Refinery | Sudan | CID002567 |
| Industrial Refining Company | Belgium | CID002587 |
| | | | | | | | |
| JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408 |
| VQB Mineral and Trading Group JSC | Vietnam | CID002015 |
| African Gold Refinery | Uganda | CID003185 |
| NPP Tyazhmetprom LLC | Russian Federation | CID003416 |
| OOO “Technolom” 2 | Russian Federation | CID003612 |
| OOO “Technolom” 1 | Russian Federation | CID003614 |
Through Assent, submissions that included any of the above facilities immediately produced a response instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to components or products that they supply to us, if any, and escalating up to removal of these “Smelters of Interest” from their supply chain.
Due to our continued partnership with Assent, we were able to leverage the provider to assist us with the smelter review and country-of-origin determination for the data we collected during our due diligence and supplier campaign.
Additionally, suppliers were evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program were based on these four questions in the CMRT:
A. Have you established a responsible minerals sourcing policy?
D. Have you implemented due diligence measures for conflict-free sourcing?
F. Do you review due diligence information received from your suppliers against your company’s expectations?
G. Does your review process include corrective action management?
When suppliers met or exceeded those criteria (Yes to questions A, D, F and G), they were deemed to have a strong program. When suppliers did not meet those criteria, they were deemed to have a weak program. As of April 4, 2024, 23.55% of our responsive suppliers have been identified as having a strong program, and 15.29% of suppliers have been identified as having a weak program. The remaining suppliers claimed no 3 TGs.
STEP 3: Design and Implement a Strategy to Respond to Identified Risks
We provide periodic reports on the progress of our campaign process to our internal leadership. On an annual basis, we provide an update to the Executive Leadership Team about our conflict minerals program and have a separate meeting with the Senior Vice President – Allegion Americas and the Deputy General Counsel and Corporate Secretary where we review the process, efforts, challenges, milestones and results before the final Form SD report is signed by the Deputy General Counsel and Corporate Secretary and filed with the SEC.
•Further, we have established a supplier risk management process that evaluates many factors and determines the next steps for concerning suppliers (including any need for renegotiation of supplier terms, termination of supplier relationships, creation of a remediation plan, etc.).
•Declarations (CMRTs) look retrospectively at materials procured throughout the calendar year; at the time a CMRT is provided, material from smelters may already be part of the company’s supply chain and products. Requests for immediate removal of a smelter of concern from the CMRT and supply chain may not be practical, hence the intent of OECD step 3: to arm and inform the supply chain regarding future purchases. The CMRT must accurately reflect past sourcing in order to support appropriate, ongoing due diligence and monitor changes over time. As a result, Allegion has disclosed all information identified through the supply chain.
•Minerals and metals are durable goods, and typical practice in industry may include using feedstock purchased several months prior. As a result, high-risk or inoperative smelters, may continue to appear on downstream CMRTs even if upstream suppliers no longer engage in business with these smelters. In many cases, this accurately reflects the continued downstream use of metal originally processed by these smelters in the past, either before smelter risks were identified or before smelter operations ceased.
STEP 4: Utilize Independent Third-Party Audits of Supply Chain Diligence Practices
While we do not have a team of resources to independently audit the smelters/refiners within our supply chain, we have partnered with Assent, a ‘best-in-class’ third-party software and regulatory consulting company, who performs audits and verification activities of smelters/refiners across the globe as part of their business services for Allegion.
STEP 5: Publicly Report on Supply Chain Due Diligence
This is the eleventh year that we have reported on our conflict minerals program, our risk assessment and due diligence, as well as our results. While progress has been made, we were unable to determine with certainty that all the conflict minerals contained in our products are from conflict-free sources due to, among other things, the following:
a. Several of our suppliers identified smelters/refiners that do not participate in the RMAP or a similar program and other suppliers failed to identify any smelter / refiners in their responses to us. Furthermore, we were unable to obtain responses from all our suppliers, and some suppliers provided incomplete or inconsistent data.
b. Many of our suppliers submitted responses that were declared on a company-wide basis (i.e., representing the smelters and refiners associated with all product offerings of the supplier that contained conflict minerals) and not specific to the materials supplied to Allegion. Therefore, in combination with multiple layers in our supply chain, we believe these declarations might include smelters and refiners that do not provide the conflict minerals that are in our products.
As a result, we do not have sufficient information to conclusively determine the country of origin of all the conflict minerals in our products and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict-free sources.
2023 Results
For 2023, we reviewed 937 suppliers and actively engaged with 488 suppliers that we deemed relevant based on historical CMRT responses and purchases. We received CMRT submissions from 242 suppliers (response rate of 49.59%). All CMRTs were reviewed for completeness and accuracy. Out of the received CMRTs, 235 were validated and provided the basis for our list of “Reported Entities.”
Based on the due diligence process described under the heading “OECD Due Diligence Framework in Practice” on page 5 of this report and the information provided by our suppliers, we believe, to the extent reasonably determinable by us, that the facilities used to process the conflict minerals in our products or the other sources of the conflict minerals in our products consist of the following 350 entities (listed in the Reported Entities section), and that we have categorized as follows:
•224 smelters were classified as “RMAP Conformant;”
•90 smelters had a status of “Not Enrolled;”
•7 smelters are “RMAP Active;” and
•29 smelters are “Non-Conformant.”
“RMAP Conformant” means the smelter has successfully completed a RMAP audit and maintains good standing in the program, through a continual validation process. These smelters or refiners (SOR’s) have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support their sourcing activities.
Due Diligence Determination
For the reasons stated in this report, we do not have sufficient information to conclusively determine the country of origin of all the conflict minerals in our products described under the heading “Product Description” on page 4 of this report and, if such conflict minerals did originate in the Covered Countries, whether such conflict minerals were from recycled or scrap sources or were from other conflict-free sources.
We have provided this information as of the date of this report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters, or refiners to provide us with complete information, may affect our future determinations under the Rule.
Independent Private Sector Audit
As permitted by Rule 13p-1 and the SEC’s guidance with respect thereto, we did not obtain an independent private-sector audit of this Conflict Minerals Report.
Future Initiatives
We continue to execute several initiatives to enhance our conflict minerals program, such as:
•Continued education and training both for our company and our supply chain;
•Continued partnerships with industry groups and subject matter experts to define and improve best practices and build leverage over our supply chain;
•Continued engagement with our suppliers to obtain current, accurate and complete information from them and their upstream supply chain; and
•Continued engagement with our third-party software solution and consulting company who are working on independently verifying smelters outside of the RMI smelter certification program.
Reported Entities
| | | | | | | | |
| Metal | Smelter Name | Smelter Country (*) |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Caridad | Mexico |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Agosi AG | Germany |
| Gold | Advanced Chemical Company | United States of America |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Chugai Mining | Japan |
| Gold | Aurubis AG | Germany |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Boliden AB | Sweden |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of |
| Gold | JSC Novosibirsk Refinery | Russian Federation |
| Gold | LT Metal Ltd. | Korea, Republic of |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | Dowa | Japan |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heraeus Germany GmbH Co. KG | Germany |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Materion | United States of America |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| | | | | | | | |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor USA Refining Corporation | United States of America |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Royal Canadian Mint | Canada |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | MKS PAMP SA | Switzerland |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Shandong Gold Smelting Co., Ltd. | China |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province of China |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Torecom | Korea, Republic of |
| Gold | United Precious Metal Refining, Inc. | United States of America |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Morris and Watson | New Zealand |
| Gold | SAFINA A.S. | Czechia |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | T.C.A S.p.A | Italy |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province of China |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | Abington Reldan Metals, LLC | United States of America |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | SAAMP | France |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| | | | | | | | |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of |
| Gold | Italpreziosi | Italy |
| Gold | Marsam Metals | Brazil |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| Gold | AU Traders and Refiners | South Africa |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | 8853 S.p.A. | Italy |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | ABC Refinery Pty Ltd. | Australia |
| Gold | NH Recytech Company | Korea, Republic of |
| Gold | Pease & Curren | United States of America |
| Gold | JALAN & Company | India |
| Gold | African Gold Refinery | Uganda |
| Gold | Gold Coast Refinery | Ghana |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Gold | Augmont Enterprises Private Limited | India |
| Gold | Kundan Care Products Ltd. | India |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Sovereign Metals | India |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India |
| Gold | K.A. Rasmussen | Norway |
| Gold | MD Overseas | India |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India |
| Gold | Gold by Gold Colombia | Colombia |
| Gold | Coimpa Industrial LTDA | Brazil |
| Gold | WEEEREFINING | France |
| Gold | Dongwu Gold Group | China |
| Gold | Chimet S.p.A. | Italy |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Japan Mint | Japan |
| Gold | Asahi Refining USA Inc. | United States of America |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | Kennecott Utah Copper LLC | United States of America |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Sabin Metal Corp. | United States of America |
| Gold | Samduck Precious Metals | Korea, Republic of |
| Gold | Samwon Metals Corp. | Korea, Republic of |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Valcambi S.A. | Switzerland |
| | | | | | | | |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Industrial Refining Company | Belgium |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Albino Mountinho Lda. | Portugal |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | Sai Refinery | India |
| Gold | Bangalore Refinery | India |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | Safimet S.p.A | Italy |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | QG Refining, LLC | United States of America |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India |
| Gold | Alexy Metals | United States of America |
| Gold | Metallix Refining Inc. | United States of America |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa |
| Gold | Sam Precious Metals | United Arab Emirates |
| Gold | Smelter Not Listed | Tanzania, United Republic of |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | Smelter Not Listed | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | AMG Brasil | Brazil |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | QuantumClean | United States of America |
| Tantalum | Telex Metals | United States of America |
| Tantalum | D Block Metals, LLC | United States of America |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | KEMET de Mexico | Mexico |
| Tantalum | Materion Newton Inc. | United States of America |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tantalum | Global Advanced Metals Boyertown | United States of America |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | TANIOBIS Co., Ltd. | Thailand |
| Tantalum | TANIOBIS GmbH | Germany |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China |
| Tantalum | PowerX Ltd. | Rwanda |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | NPM Silmet AS | Estonia |
| | | | | | | | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | 5D Production OU | Estonia |
| Tin | Alpha | United States of America |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Premium Tin Indonesia | Indonesia |
| Tin | Dowa | Japan |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | EM Vinto | Bolivia (Plurinational State of) |
| Tin | Fenix Metals | Poland |
| Tin | Metallic Resources, Inc. | United States of America |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | Novosibirsk Tin Combine | Russian Federation |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State of) |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | Minsur | Peru |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tin | PT Babel Surya Alam Lestari | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT Timah Tbk Kundur | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT Timah Nusantara | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | Rui Da Hung | Taiwan, Province of China |
| Tin | VQB Mineral and Trading Group JSC | Vietnam |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | PT Tirus Putra Mandiri | Indonesia |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | PT Cipta Persada Mulia | Indonesia |
| Tin | Super Ligas | Brazil |
| Tin | Smelter Not Listed | Indonesia |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Aurubis Berango | Spain |
| | | | | | | | |
| Tin | Aurubis Beerse | Belgium |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Tin | PT Bangka Serumpun | Indonesia |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Smelter Not Listed | China |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | PT Rajawali Rimba Perkasa | Indonesia |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Tin | CRM Synergies | Spain |
| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic of The |
| Tin | Smelter Not Listed | Malaysia |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Timah Tbk Mentok | Indonesia |
| Tin | Thaisarco | Thailand |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | Smelter Not Listed | China |
| Tin | Tin Technology & Refining | United States of America |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Tin | Precious Minerals and Smelting Limited | India |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | PT Mitra Sukses Globalindo | Indonesia |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil |
| Tin | DS Myanmar | Myanmar |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia |
| Tungsten | A.L.M.T. Corp. | Japan |
| Tungsten | Kennametal Huntsville | United States of America |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders LLC | United States of America |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Kennametal Fallon | United States of America |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| | | | | | | | |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Masan High-Tech Materials | Vietnam |
| Tungsten | Niagara Refining LLC | United States of America |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province of China |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | Cronimet Brasil Ltda | Brazil |
| Tungsten | Artek LLC | Russian Federation |
| Tungsten | OOO “Technolom” 1 | Russian Federation |
| Tungsten | LLC Vostok | Russian Federation |
| Tungsten | Tungsten Vietnam Joint Stock Company | Vietnam |
| Tungsten | Smelter Not Listed | Vietnam |
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic of |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China |
| Tungsten | OOO “Technolom” 2 | Russian Federation |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic of |
| Tungsten | Smelter Not Listed | Taiwan, Province of China |
| Tungsten | Smelter Not Listed | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China |
| Tungsten | Nam Viet Cromit Joint Stock Company | Vietnam |
Definitions
Conflict-Free Smelters or refiners that have been verified as complying with the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program or an equivalent third-party audit program
Covered Countries Refer to the Democratic Republic of the Congo ("DRC") and any country that shares an internationally recognized border with the DRC
OECD Organisation for Economic Co-operation and Development
Dodd-Frank Act Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
CID Smelter Identification Number
RMI Responsible Minerals Initiative
SORs of Interest Smelters or Refiners that present significant risk to supply chains, as per the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
Grafico Azioni Allegion (NYSE:ALLE)
Storico
Da Ott 2024 a Nov 2024
Grafico Azioni Allegion (NYSE:ALLE)
Storico
Da Nov 2023 a Nov 2024
