UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
FORM SD
Specialized Disclosure
Report
NRG
Energy, Inc.
(Exact name of registrant
as specified in its charter)
|
| Delaware |
001-15891 |
41-1724239 |
(State
or other jurisdiction of
incorporation) |
(Commission File Number)
|
(I.R.S.
Employer Identification
Number) |
| 910 Louisiana
Street, Houston, Texas |
77002 |
| (Address
of principal executive offices) |
(Zip
Code)
|
| Name and telephone number,
including area code, of person to contact in connection with this report: |
Paolo Berard
Chief Compliance Officer
(713) 537-3000 |
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.
Section 1 — Conflict
Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure
and Report
NRG Energy, Inc.
(“NRG” or the “Company”) has evaluated its current product lines and determined that certain products it manufactures
or contracts to manufacture contain tin, tungsten, tantalum and/or gold (“3TGs”). On the basis of the responses to the Company’s
reasonable country of origin inquiries, the Company is unable to determine that the 3TGs necessary to the functionality or production
of its products did not originate in the Democratic Republic of Congo or any of the other Covered Countries as defined under Rule 13p-1
of the Securities Exchange Act of 1934, as amended. As a result, the Company has prepared a conflict minerals report, which is attached
as Exhibit 1.01 to this Form SD and available on the Company’s website at http://investors.nrg.com/phoenix.zhtml?c=121544&p=irol-sec.
Item 1.02 Exhibit
See Item 1.01
and Item 2.01.
Section 2 — Exhibits
Item 2.01 Exhibits
Exhibit 1.01 — Conflict Minerals
Report as required by Items 1.01 and 1.02 of this Form.
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
undersigned hereunto duly authorized.
| |
NRG Energy, Inc. (Registrant) |
| |
|
|
By: |
/s/ Paolo Berard |
| |
Paolo Berard |
| |
Chief Compliance Officer |
| |
|
Date:
May 31, 2024 |
|
Exhibit 1.01
NRG Energy, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2023
Introduction
This report for
the year ended December 31, 2023, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”).
The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements
related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”).
The term “conflict minerals” is defined as columbite-tantalite (coltan), cassiterite, gold, wolframite and their derivatives,
which are limited to tantalum, tin and tungsten. For the purposes of this report, tin, tungsten, tantalum and gold will collectively be
referred to as “3TGs”. The term “Covered Countries” for purposes of the Rule are the Democratic Republic
of the Congo (the “DRC”) and the following adjoining countries: the Republic of the Congo, the Central African Republic, South
Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola.
Company Overview
This report has
been prepared by the management of NRG Energy, Inc (herein referred to as “NRG,” the “Company,” “we,”
“us,” or “our”) with the assistance of our third-party vendor, Assent Compliance (“Assent”). The information
includes the activities of all majority-owned subsidiaries and consolidated joint ventures. It does not include the activities of minority-owned
subsidiaries and variable interest entities that are not required to be consolidated.
NRG Energy, Inc.,
or NRG or the Company, is a consumer services company built on dynamic retail brands. NRG brings the power of energy to customers by producing
and selling energy and related products and services, nation-wide in the U.S. and Canada in a manner that delivers value to all of NRG's
stakeholders. NRG sells power, natural gas, and home and power services, and develops innovative, sustainable solutions, predominately
under the brand names NRG, Reliant, Direct Energy, Green Mountain Energy, Stream, Vivint, and XOOM Energy. The Company has a customer
base that includes approximately 5.4 million Home customers as well as commercial, industrial, and wholesale customers, supported by approximately
16 GW of generation as of December 31, 2023. NRG was incorporated as a Delaware corporation on May 29, 1992.
This report is
made on behalf of Goal Zero, Vivint and Reliant, which contract for the manufacture of certain products for sale, hereinafter collectively
referred to as “NRG.”
Description of Products
No NRG subsidiary
directly manufactures any products. A subsidiary contracts for the manufacture and assembly of its products through a competitive global
supply process. The suppliers then source both raw materials and purchased parts. Goal Zero has 16 direct material suppliers globally,
and Vivint has 18 direct material suppliers globally. There are generally multiple tiers between the 3TG mines and both Goal Zero and
Vivint’s direct suppliers. Therefore, we rely on the direct suppliers to provide information on the origin of the 3TGs contained
in components and materials supplied to Goal Zero and Vivint — including sources of 3TGs that are supplied to them from lower tier
suppliers. Contracts with suppliers are frequently in force for multiple years and we cannot always unilaterally impose new contract terms
and flow-down requirements. As we enter into new contracts, we are requiring such suppliers to provide information about the presence
of conflict minerals in the products they supply to us and about the smelter sources of any 3TGs.
NRG conducted
an analysis of the materials used in the production of products manufactured on behalf of its subsidiaries and determined that substantially
all of such products may contain 3TGs. The Company expects that 3TGs may be found in those products within the following component parts:
| · | Tantalum, used in capacitors; |
| · | Tin, used in soldered components; |
| · | Tungsten, used in coatings, alloys, heating elements and electrodes; and |
| · | Gold, used in circuit boards, electrodes and electronic components. |
Conflict Minerals Program
NRG has actively
engaged with its customers and suppliers for several years with respect to the use of conflict minerals. NRG’s applicable supply
contracts require suppliers to represent and ensure that they supply only 3TGs that are “conflict-free” as that term is defined
in the Rule, unless otherwise agreed to by the parties. NRG also requires that its applicable suppliers agree that they will inform all
of their own suppliers of this policy and undertake to ensure that such policy is complied with throughout the supply chain. NRG reserves
the right, in such contracts, to audit its suppliers’ compliance at any time, and to terminate supply agreements if there is a material
breach of the agreement.
In addition,
in May 2016, NRG adopted manufacturing standards (the “Manufacturing Standards”) with which all contract manufacturers
of the Company are required to comply, which can be found here: https://investors.nrg.com/static-files/b383e0f6-a2bf-467d-b8e8-4052d4941884.
The Manufacturing Standards address compliance with laws and regulations, and require manufacturers to abide by the applicable laws and
regulations of the country in which they are doing business, including, but not limited to, laws related to labor practices, health and
safety, environmental responsibility, and anti-corruption. NRG employs third-party auditors to periodically audit contract manufacturers
against the Manufacturing Standards, and reports such results to the Audit Committee of the Board of Directors. We believe that the standards
also set requirements based on industry best practices and international conventions, including those related to 3TGs.
Reasonable Country of Origin Inquiry
To determine
whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Inc. (“Assent”), our third-party
service provider, to assist us in reviewing our supply chain and identifying risks. We provided a list composed of suppliers associated
with the Covered Products to Assent for upload to the Assent Sustainability Manager tool (“ASM”). We deemed it impractical
to filter this list further to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or
absence of conflict minerals in all parts supplied to NRG for our products.
To trace materials,
and demonstrate transparency procured by the supply chain, NRG utilized the Conflict Minerals Reporting Template (CMRT) Version 6.31 or
higher to conduct a survey of all in-scope suppliers. The CMRT was developed to facilitate disclosure and communication of information
regarding smelters and refiners that provide material to a manufacturer’s supply chain. It includes questions about a direct supplier’s
conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters
and refiners as well as the origin of 3TGs used by those facilities.
During the supplier
survey, the Company contacted suppliers via the Assent Sustainability Manager, a software-as-a-service (SaaS) platform provided by Assent
which enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to
the platform for validation, assessment and management. The Assent Sustainability Manager also provides functionality that meets the OECD
Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s
declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier
engagement and upstream due diligence investigations, are managed through this platform.
Via the Assent
Sustainability Manager and Assent team, NRG then requested that all identified suppliers complete a CMRT. Training and education to guide
suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ASM for
future reporting and transparency. NRG directly contacted suppliers that were unresponsive to Assent’s communications during the
diligence process and requested such suppliers to complete the CMRT form and submit such form to Assent.
Our program continues
to include automated data validation on all submitted CMRTs. Data validation aims to increase the accuracy of submissions and identify
any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps
identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 suppliers.
The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they
understand areas that require clarification or improvement.
All submitted
forms are accepted and classified as valid or invalid based on a set criteria of validation errors (see appendix C for CMRT validation
criteria) so that data is still retained. Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors
and re-submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback
to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since
some suppliers may remain unresponsive to feedback, NRG tracks program gaps to account for future improvement opportunities.
For reporting
year 2023, there were 24 suppliers in-scope of the conflict minerals program and 24 provided a completed CMRT the total response rate
for this reporting year was 100%. These metrics are summarized in the table below in order to assess progress over time:
| Year | |
Suppliers in Scope | |
% Responded |
| RY 2021 | |
13 | |
100% |
| RY 2022 | |
13 | |
100% |
| RY 2023 | |
24 | |
100% |
Design of Due Diligence
NRG Energy, Inc.
designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements.
The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate
market expectations for data collection and reporting to achieve continuous improvement opportunities.
Due diligence
requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of
incomplete or inaccurate data as the process cannot be fully owned by the Company. However, through active risk identification, and risk
assessment, as well as continued outreach and process validation, risk gaps can be mitigated. This aligns with industry standards and
market expectations for downstream companies’ due diligence.
Due Diligence Performed
1. Establish Strong Management
Systems
Internal Compliance Team
NRG’s management
system for conflict minerals covering calendar year 2023 was sponsored by our Chief Compliance Officer and was supported by appropriate
members of the management team, and a team of subject matter experts from relevant functions such as Corporate Compliance, Supply Chain,
and Legal. The team of subject matter experts was responsible for implementing our conflict minerals compliance strategy for calendar
year 2023, and was led by the Chief Compliance Officer, who acted as the executive conflict minerals program manager. The Audit Committee
of the Board of Directors of the Company (the “Audit Committee”) and senior management have been and continue to be informed
about the results of our due diligence efforts on a regular basis.
The Company also
uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential
risks, and in the development and implementation of additional due diligence steps that the Company will undertake with suppliers and/or
respective stakeholders in regards to conflict minerals.
The Company leverages
Assent’s Managed Services in order to work with dedicated program specialists who support NRGs conflict minerals program. The Company
communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success
team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and CMRs, as well
as Section 1502 of the
Dodd-Frank Act.
Control Systems
The Company expects
all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to NRG are “conflict
free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from areas that have been
identified to be in the presence of widespread human rights abuses and violations of law either directly or indirectly. The Company expects
direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of
3TGs that are supplied to them from lower-tier suppliers.
NRG’s Supplier
Code of Conduct applies to all direct suppliers and outlines certain expected behaviours and practices.
The Supplier
Code of Conduct is available on the public NRG website and is provided to all direct suppliers. If a supplier does not meet the Company’s
requirements, the relationship with this supplier will be evaluated.
Supplier Engagement
NRG Energy, Inc.
has a strong relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, NRG has leveraged processes
and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs,
help desk support, and other multilingual resources. NRG’s suppliers are able to leverage Assent’s team of supplier support
specialists to ensure they receive appropriate support and understand how to properly fill a CMRT. Suppliers are provided guidance in
their native language, if needed.
The Company engages
with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. With respect
to the OECD requirement to strengthen engagement with suppliers, we have developed an internal procedure that includes supplier risk identification
process that then leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective
actions. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance
for this initiative.
Additionally,
the Company includes contractual provisions relating to compliance with conflict mineral laws in supplier contracts, as a requirement
of doing business with NRG. When entering into or renewing supplier contracts, a clause is added that requires suppliers to provide information
about the source of 3TGs and smelters.
The Company continues
to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and
all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, Assent’s
automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain
conflict minerals’ risks.
We believe that
the combination of the Supplier Code of Conduct, our conflict mineral-related contract language , and direct engagement with suppliers
for Conflict Minerals training and requests constitute a strong program when it comes to supplier engagement.
Grievance Mechanisms
The Company established
multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of NRG’s policies, including conflict
minerals. NRG has a Code of Conduct whereby employees and third-parties can learn about NRG’s policies (the “NRG Code of Conduct”).
The NRG Code of Conduct, which is posted on NRG’s public website and its internal intranet site, contains multiple methods to report
violations of NRG’s policies. In addition, NRG has a Supplier Code of Conduct containing similar information to the NRG Code of
Conduct. The NRG Code of Conduct establishes the manner in which employees and others may report any matters they believe may violate
the NRG Code of Conduct, and for the investigation and resolution of all such reports. They include the Ethics Alert line at nrg.alertline.com
and the NRG Ethics Helpline at 888-2630463, which permits individuals to provide confidential and anonymous reporting. The NRG Ethics
Helpline (888-263-0463) and Alertline (www.nrg.alertline.com) are available 24 hours a day, seven days a week. They are administered by
an outside company to ensure confidentiality and anonymity, if desired. Calls are not traced or recorded, and NRG does not keep any identifiable
information regarding the sender of an online communication.
NRG’s
Code of Conduct is accessible on the Company’s website at https://investors.nrg.com/static-files/3911d684-818a-46f7-af82-23702c264ecc.
Violations or grievances at the industry level can be reported to
the RMI directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/
Maintain records
The Company has
adopted a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict
minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented.
The Company stores all of the information and findings from this process in a database that can be audited by internal or external parties.
2. Identify and Assess
Risk in the Supply Chain
Supplier Risk Evaluation
Risks associated
with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the Assent Sustainability
Manager identifies automatically based on established criteria. These risks are addressed by Assent staff and members of the Company’s
internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing
an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”
Risks at the
supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares
there are no 3TGs in any of its products) is submitted, NRG is unable to determine if all of the specified smelters/refiners were used
for 3TGs in the products supplied to the Company.
Assent’s
supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s
supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis
that takes into account multiple conflict minerals factors.
Smelter/Refiners Risk Evaluation
Risks were identified
by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral
processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and
refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TGs processing facility that was operational
during the 2023 calendar year.
Assent determined
if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. We do not typically have a
direct relationship with 3TGs smelters and refiners and do not perform or direct audits of these entities within our pre-supply chain.
Smelters that have completed an RMAP audit are considered to be have their sourcing validated as “conflict free or responsibly sourced.”
In cases where the smelter’s due diligence practices have not been audited against the RMAP, further due diligence steps
are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks
pertaining to conflict minerals.
Each facility
that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD
Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses 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; |
| ● | Responsible Minerals Assurance Process (RMAP) audit status; |
| ● | Credible evidence of unethical or conflict sourcing; |
| ● | Peer Assessments conducted by credible third-party sources. |
As part of our
risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed,
risk mitigation activities are initiated. Through Assent, submissions that include any red flag facilities immediately produce a receipt
instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify
the connection to products that they supply to NRG.
As per the OECD
Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within
reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers
are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners
on the supply chain.
Additionally,
suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength
of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses.
The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:
| A. | Have you established a conflict 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? |
If any smelter
or refiner is not recognized by the RMI CFSI, we conduct outreach and research to gain more information about whether they are a smelter
or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, we conduct
outreach providing education on the RMAP and encouraging them to join this program. Through Assent, any CMRTs submitted by our suppliers
that included any Red Flag smelters were asked to submit a product-level CMRT so we could determine if there was a connection between
the red flag smelters originally listed and the products they supply to us. Suppliers were notified of the fact that one or more high-risk
smelters appeared on their CMRT and were encouraged to engage in risk mitigation activities.
Neither
NRG nor Goal Zero have a direct relationship with any smelters and refiners and, as a result, do not perform or direct audits of
these entities within their supply chain. Smelter and refiner information was captured as part of the CMRT, as some suppliers
provided the names of facilities it used as smelters or refiners. After obtaining the CMRT through the due diligence processes
described above, we compared the smelters and refiners used by relevant suppliers against an independently verified list of smelters
and refiners leveraging the audit results from the RMI (http://www.responsiblemineralsinitiative.org ) (which website is not
incorporated by reference herein) as well as responses in the CMRT to gather the country, location and mine of origin
information.
3. Design and Implement
a Strategy to Respond to Risks
Together with
Assent, NRG developed processes to assess and respond to the risks identified in the supply chain. NRG has created a risk management plan,
through which the conflict minerals program is implemented, managed and monitored. As the program progresses, escalations are sent to
non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the
conflict minerals rules and the Company’s expectations. The status of and any updates to this risk management plan are provided
regularly to the Audit Committee and to senior management.
As part of our
risk management plan, to ensure our applicable suppliers understand our expectations, we have communicated directly with these suppliers
(orally and in writing), and included relevant information in our contracts with these suppliers, the Manufacturing Standards and the
NRG Code of Conduct.
As described
above, NRG reserves the right to terminate supplier agreements where we have reason to believe they are supplying us with 3TGs from sources
that may support conflict in the Covered Countries. Should a supplier report information on a CMRT that would lead us to believe that
their sourcing of 3TGs would support such conflict, we would engage in risk mitigation activities with such supplier.
We believe that
the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs
in Goal Zero’s products, including (1) seeking information about 3TG smelters and refiners in NRG’s supply chain through
requesting that suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting
the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
| 4. | Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points
in the Supply Chain |
NRG does not
have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain.
Instead, we rely on the RMAP to oversee and coordinate third-party audits of these facilities, which include audits conducted by RMI.
The RMAP audit protocols and procedures were designed by the RMI who engage specially trained third-party auditors to independently verify
that these smelters and refiners can be deemed conflict-free. We utilize the information provided by the RMI to validate the sourcing
practices of processing facilities in NRG’s supply chain.
Assent directly
engages smelters/refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their participation
and for those smelters/refiners already conformant to the corresponding program’s standards, Assent thanks them for their efforts
on behalf of its compliance partners. NRG is a signatory of these communications in accordance with the requirements of downstream companies
detailed in the OECD Guidance.
| 5. | Report Annually on Supply Chain Due Diligence |
NRG has published the Form SD for the year ended December 31,2023.
This report is publicly available on our website at http://investors.nrg.com/phoenix.zhtml?c=121544&p=irol-sec.. Information
found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. NRG has also
publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission (SEC).
This year the
Company has also considered impacts from the EU Conflict Minerals Regulation when disclosing details with regards to due diligence efforts.
The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as
the disclosure of efforts through the form of public report.
Due Diligence Results
Supply Chain Outreach Results
Supply chain
outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten, and gold. Following the industry standard
process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner
sources are identified. The following is the result of the outreach conducted by NRG for the 2023 reporting year.
Supply Chain Outreach Metrics
| Year |
Change in Suppliers in Scope from previous year |
Response Rate |
| RY 2023 |
11 |
100% |
Upstream Data Transparency
Appendix A includes
all smelters/refiners that suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were
operational during the 2023 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase
materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result,
those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period.
Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners
which actually processed the 3TGs contained in the Company’s products.
Although the
potential for over-reporting is understood, NRG has taken measures to validate all smelter/refiner data against validated audit programs
and databases intended to verify the material types and mine sources of origin.
| Status |
Number of identified smelters/refiners |
| RMAP Conformant |
219 |
| RMAP Active |
4 |
| Not Enrolled |
80 |
| Non-Conformant |
28 |
Countries of Origin
Appendix
B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable
identification of country of origin data obtained via Assent’s supply chain database (or other RCOI data, in the scenario NRG decides
to use alternative data sources). Despite the additional smelter information obtained from these suppliers, in most cases information
has been provided on a company or division level, rather than on a product level. Therefore, we cannot ascertain whether the smelters
identified by our applicable suppliers are related to any parts or components actually provided to us by such suppliers.
Steps to be taken to mitigate risk
For the reporting
year 2023 NRG intends to take, the following steps to improve the due diligence conducted to further mitigate any risk that the necessary
3TGs in the Company’s products could originate from Conflict-Affected and High-Risk Areas:
| · | Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to: |
○ Using
a comprehensive smelter and refiner library with detailed status and notes for each entity.
○ Scanning for verifiable media sources
on each smelter and refiner to flag risk issues.
○ Comparing
the list of smelters/refiners against government watch and denied parties lists.
| · | Engage with suppliers more closely,
and provide more information and training resources regarding responsible sourcing of 3TGs. |
| · | Encourage suppliers to have due
diligence procedures in place for their supply chains to improve the content of the responses from such suppliers. |
| · | Continue to include a conflict minerals flow-down clause in
new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued. |
| · | Following the OECD Guidance process, increase the emphasis on
clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis. |
Appendix A: Smelter List
| Metal |
Smelter
Name |
Smelter
Facility Location |
Smelter
ID |
RMAP
Audit Status |
| Gold |
Aida
Chemical Industries Co., Ltd. |
Japan |
CID000019 |
Conformant |
| Gold |
Argor-Heraeus
S.A. |
Switzerland |
CID000077 |
Conformant |
| Gold |
Asahi
Pretec Corp. |
Japan |
CID000082 |
Conformant |
| Gold |
Asaka
Riken Co., Ltd. |
Japan |
CID000090 |
Conformant |
| Gold |
CCR
Refinery - Glencore Canada Corporation |
Canada |
CID000185 |
Conformant |
| Gold |
Dowa |
Japan |
CID000401 |
Conformant |
| Gold |
Eco-System
Recycling Co., Ltd. East Plant |
Japan |
CID000425 |
Conformant |
| Gold |
Heraeus
Metals Hong Kong Ltd. |
China |
CID000707 |
Conformant |
| Gold |
Ishifuku
Metal Industry Co., Ltd. |
Japan |
CID000807 |
Conformant |
| Gold |
Asahi
Refining USA Inc. |
United
States Of America |
CID000920 |
Conformant |
| Gold |
JX
Nippon Mining & Metals Co., Ltd. |
Japan |
CID000937 |
Conformant |
| Gold |
Kojima
Chemicals Co., Ltd. |
Japan |
CID000981 |
Conformant |
| Gold |
LS-NIKKO
Copper Inc. |
Korea,
Republic Of |
CID001078 |
Conformant |
| Gold |
Materion |
United
States Of America |
CID001113 |
Conformant |
| Gold |
Matsuda
Sangyo Co., Ltd. |
Japan |
CID001119 |
Conformant |
| Gold |
Metalor
Technologies (Suzhou) Ltd. |
China |
CID001147 |
Conformant |
| Gold |
Metalor
Technologies (Hong Kong) Ltd. |
China |
CID001149 |
Conformant |
| Gold |
Metalor
Technologies (Singapore) Pte., Ltd. |
Singapore |
CID001152 |
Conformant |
| Gold |
Metalor
Technologies S.A. |
Switzerland |
CID001153 |
Conformant |
| Gold |
Metalor
USA Refining Corporation |
United
States Of America |
CID001157 |
Conformant |
| Gold |
Mitsubishi
Materials Corporation |
Japan |
CID001188 |
Conformant |
| Gold |
Mitsui
Mining and Smelting Co., Ltd. |
Japan |
CID001193 |
Conformant |
| Gold |
Nihon
Material Co., Ltd. |
Japan |
CID001259 |
Conformant |
| Gold |
Ohura
Precious Metal Industry Co., Ltd. |
Japan |
CID001325 |
Conformant |
| Gold |
Royal
Canadian Mint |
Canada |
CID001534 |
Conformant |
| Gold |
Shandong
Zhaojin Gold & Silver Refinery Co., Ltd. |
China |
CID001622 |
Conformant |
| Gold |
Solar
Applied Materials Technology Corp. |
Taiwan,
Province Of China |
CID001761 |
Conformant |
| Gold |
Sumitomo
Metal Mining Co., Ltd. |
Japan |
CID001798 |
Conformant |
| Gold |
Tanaka
Kikinzoku Kogyo K.K. |
Japan |
CID001875 |
Conformant |
| Gold |
Shandong
Gold Smelting Co., Ltd. |
China |
CID001916 |
Conformant |
| Gold |
Tokuriki
Honten Co., Ltd. |
Japan |
CID001938 |
Conformant |
| Gold |
United
Precious Metal Refining, Inc. |
United
States Of America |
CID001993 |
Conformant |
| Gold |
Western
Australian Mint (T/a The Perth Mint) |
Australia |
CID002030 |
Conformant |
| Gold |
Zhongyuan
Gold Smelter of Zhongjin Gold Corporation |
China |
CID002224 |
Conformant |
| Gold |
Advanced
Chemical Company |
United
States Of America |
CID000015 |
Active |
| Gold |
Agosi
AG |
Germany |
CID000035 |
Conformant |
| Gold |
Almalyk
Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
CID000041 |
Conformant |
| Gold |
AngloGold
Ashanti Corrego do Sitio Mineracao |
Brazil |
CID000058 |
Conformant |
| Gold |
Aurubis
AG |
Germany |
CID000113 |
Conformant |
| Gold |
Bangko
Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
CID000128 |
Conformant |
| Gold |
Boliden
AB |
Sweden |
CID000157 |
Conformant |
| Gold |
C.
Hafner GmbH + Co. KG |
Germany |
CID000176 |
Conformant |
| Gold |
Cendres
+ Metaux S.A. |
Switzerland |
CID000189 |
Non
Conformant |
| Gold |
Chimet
S.p.A. |
Italy |
CID000233 |
Conformant |
| Gold |
Chugai
Mining |
Japan |
CID000264 |
Conformant |
| Gold |
DSC
(Do Sung Corporation) |
Korea,
Republic Of |
CID000359 |
Conformant |
| Gold |
LT
Metal Ltd. |
Korea,
Republic Of |
CID000689 |
Conformant |
| Gold |
Heimerle
+ Meule GmbH |
Germany |
CID000694 |
Conformant |
| Gold |
Heraeus
Germany GmbH Co. KG |
Germany |
CID000711 |
Conformant |
| Gold |
Inner
Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
China |
CID000801 |
Conformant |
| Gold |
Istanbul
Gold Refinery |
Turkey |
CID000814 |
Conformant |
| Gold |
Japan
Mint |
Japan |
CID000823 |
Conformant |
| Gold |
Jiangxi
Copper Co., Ltd. |
China |
CID000855 |
Conformant |
| Gold |
Asahi
Refining Canada Ltd. |
Canada |
CID000924 |
Conformant |
| Gold |
Kazzinc |
Kazakhstan |
CID000957 |
Conformant |
| Gold |
Kennecott
Utah Copper LLC |
United
States Of America |
CID000969 |
Conformant |
| Gold |
Metalurgica
Met-Mex Penoles S.A. De C.V. |
Mexico |
CID001161 |
Conformant |
| Gold |
Nadir
Metal Rafineri San. Ve Tic. A.S. |
Turkey |
CID001220 |
Conformant |
| Gold |
Navoi
Mining and Metallurgical Combinat |
Uzbekistan |
CID001236 |
Conformant |
| Gold |
MKS
PAMP SA |
Switzerland |
CID001352 |
Conformant |
| Gold |
PT
Aneka Tambang (Persero) Tbk |
Indonesia |
CID001397 |
Conformant |
| Gold |
PX
Precinox S.A. |
Switzerland |
CID001498 |
Conformant |
| Gold |
Rand
Refinery (Pty) Ltd. |
South
Africa |
CID001512 |
Conformant |
| Gold |
Samduck
Precious Metals |
Korea,
Republic Of |
CID001555 |
Non
Conformant |
| Gold |
SEMPSA
Joyeria Plateria S.A. |
Spain |
CID001585 |
Conformant |
| Gold |
Sichuan
Tianze Precious Metals Co., Ltd. |
China |
CID001736 |
Conformant |
| Gold |
Tongling
Nonferrous Metals Group Co., Ltd. |
China |
CID001947 |
Outreach
Required |
| Gold |
Torecom |
Korea,
Republic Of |
CID001955 |
Conformant |
| Gold |
Umicore
S.A. Business Unit Precious Metals Refining |
Belgium |
CID001980 |
Conformant |
| Gold |
Valcambi
S.A. |
Switzerland |
CID002003 |
Conformant |
| Gold |
Yamakin
Co., Ltd. |
Japan |
CID002100 |
Conformant |
| Gold |
Yokohama
Metal Co., Ltd. |
Japan |
CID002129 |
Conformant |
| Gold |
Gold
Refinery of Zijin Mining Group Co., Ltd. |
China |
CID002243 |
Conformant |
| Gold |
SAFINA
A.S. |
Czechia |
CID002290 |
Conformant |
| Gold |
Umicore
Precious Metals Thailand |
Thailand |
CID002314 |
Non
Conformant |
| Gold |
MMTC-PAMP
India Pvt., Ltd. |
India |
CID002509 |
Conformant |
| Gold |
KGHM
Polska Miedz Spolka Akcyjna |
Poland |
CID002511 |
Conformant |
| Gold |
Singway
Technology Co., Ltd. |
Taiwan,
Province Of China |
CID002516 |
Non
Conformant |
| Gold |
Al
Etihad Gold Refinery DMCC |
United
Arab Emirates |
CID002560 |
Non
Conformant |
| Gold |
Emirates
Gold DMCC |
United
Arab Emirates |
CID002561 |
Non
Conformant |
| Gold |
T.C.A
S.p.A |
Italy |
CID002580 |
Conformant |
| Gold |
REMONDIS
PMR B.V. |
Netherlands |
CID002582 |
Conformant |
| Gold |
Korea
Zinc Co., Ltd. |
Korea,
Republic Of |
CID002605 |
Conformant |
| Gold |
TOO
Tau-Ken-Altyn |
Kazakhstan |
CID002615 |
Conformant |
| Gold |
Abington
Reldan Metals, LLC |
United
States Of America |
CID002708 |
Conformant |
| Gold |
SAAMP |
France |
CID002761 |
Non
Conformant |
| Gold |
L'Orfebre
S.A. |
Andorra |
CID002762 |
Conformant |
| Gold |
8853
S.p.A. |
Italy |
CID002763 |
Non
Conformant |
| Gold |
Italpreziosi |
Italy |
CID002765 |
Conformant |
| Gold |
WIELAND
Edelmetalle GmbH |
Germany |
CID002778 |
Conformant |
| Gold |
Ogussa
Osterreichische Gold- und Silber-Scheideanstalt GmbH |
Austria |
CID002779 |
Conformant |
| Gold |
GGC
Gujrat Gold Centre Pvt. Ltd. |
India |
CID002852 |
Non
Conformant |
| Gold |
Bangalore
Refinery |
India |
CID002863 |
Active |
| Gold |
SungEel
HiMetal Co., Ltd. |
Korea,
Republic Of |
CID002918 |
Conformant |
| Gold |
Planta
Recuperadora de Metales SpA |
Chile |
CID002919 |
Conformant |
| Gold |
Safimet
S.p.A |
Italy |
CID002973 |
Non
Conformant |
| Gold |
NH
Recytech Company |
Korea,
Republic Of |
CID003189 |
Conformant |
| Gold |
Eco-System
Recycling Co., Ltd. North Plant |
Japan |
CID003424 |
Conformant |
| Gold |
Eco-System
Recycling Co., Ltd. West Plant |
Japan |
CID003425 |
Conformant |
| Gold |
Augmont
Enterprises Private Limited |
India |
CID003461 |
Non
Conformant |
| Gold |
Alexy
Metals |
United
States Of America |
CID003500 |
Non
Conformant |
| Gold |
Metal
Concentrators SA (Pty) Ltd. |
South
Africa |
CID003575 |
Conformant |
| Gold |
WEEEREFINING |
France |
CID003615 |
Conformant |
| Gold |
Gold
by Gold Colombia |
Colombia |
CID003641 |
Conformant |
| Gold |
Atasay
Kuyumculuk Sanayi Ve Ticaret A.S. |
Turkey |
CID000103 |
Outreach
Required |
| Gold |
Caridad |
Mexico |
CID000180 |
Outreach
Required |
| Gold |
Yunnan
Copper Industry Co., Ltd. |
China |
CID000197 |
Outreach
Required |
| Gold |
Daye
Non-Ferrous Metals Mining Ltd. |
China |
CID000343 |
Outreach
Required |
| Gold |
JSC
Novosibirsk Refinery |
Russian
Federation |
CID000493 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Refinery
of Seemine Gold Co., Ltd. |
China |
CID000522 |
Outreach
Required |
| Gold |
Guoda
Safina High-Tech Environmental Refinery Co., Ltd. |
China |
CID000651 |
Outreach
Required |
| Gold |
Hangzhou
Fuchunjiang Smelting Co., Ltd. |
China |
CID000671 |
Outreach
Required |
| Gold |
Hunan
Chenzhou Mining Co., Ltd. |
China |
CID000767 |
Outreach
Required |
| Gold |
Hunan
Guiyang yinxing Nonferrous Smelting Co., Ltd. |
China |
CID000773 |
Outreach
Required |
| Gold |
HwaSeong
CJ CO., LTD. |
Korea,
Republic Of |
CID000778 |
Communication
Suspended - Not Interested |
| Gold |
JSC
Ekaterinburg Non-Ferrous Metal Processing Plant |
Russian
Federation |
CID000927 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
JSC
Uralelectromed |
Russian
Federation |
CID000929 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Kazakhmys
Smelting LLC |
Kazakhstan |
CID000956 |
Outreach
Required |
| Gold |
Kyrgyzaltyn
JSC |
Kyrgyzstan |
CID001029 |
Non
Conformant |
| Gold |
L'azurde
Company For Jewelry |
Saudi
Arabia |
CID001032 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Lingbao
Gold Co., Ltd. |
China |
CID001056 |
Outreach
Required |
| Gold |
Lingbao
Jinyuan Tonghui Refinery Co., Ltd. |
China |
CID001058 |
Outreach
Required |
| Gold |
Luoyang
Zijin Yinhui Gold Refinery Co., Ltd. |
China |
CID001093 |
Outreach
Required |
| Gold |
Moscow
Special Alloys Processing Plant |
Russian
Federation |
CID001204 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
OJSC
"The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
Russian
Federation |
CID001326 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Penglai
Penggang Gold Industry Co., Ltd. |
China |
CID001362 |
Outreach
Required |
| Gold |
Prioksky
Plant of Non-Ferrous Metals |
Russian
Federation |
CID001386 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Sabin
Metal Corp. |
United
States Of America |
CID001546 |
Communication
Suspended - Not Interested |
| Gold |
Samwon
Metals Corp. |
Korea,
Republic Of |
CID001562 |
Communication
Suspended - Not Interested |
| Gold |
Shandong
Tiancheng Biological Gold Industrial Co., Ltd. |
China |
CID001619 |
Outreach
Required |
| Gold |
SOE
Shyolkovsky Factory of Secondary Precious Metals |
Russian
Federation |
CID001756 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Super
Dragon Technology Co., Ltd. |
Taiwan,
Province Of China |
CID001810 |
Outreach
Required |
| Gold |
Great
Wall Precious Metals Co., Ltd. of CBPM |
China |
CID001909 |
Outreach
Required |
| Gold |
Morris
and Watson |
New
Zealand |
CID002282 |
Outreach
Required |
| Gold |
Guangdong
Jinding Gold Limited |
China |
CID002312 |
Outreach
Required |
| Gold |
Fidelity
Printers and Refiners Ltd. |
Zimbabwe |
CID002515 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Shandong
Humon Smelting Co., Ltd. |
China |
CID002525 |
Outreach
Required |
| Gold |
Shenzhen
Zhonghenglong Real Industry Co., Ltd. |
China |
CID002527 |
Outreach
Required |
| Gold |
International
Precious Metal Refiners |
United
Arab Emirates |
CID002562 |
Outreach
Required |
| Gold |
Kaloti
Precious Metals |
United
Arab Emirates |
CID002563 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Sudan
Gold Refinery |
Sudan |
CID002567 |
Outreach
Required |
| Gold |
Fujairah
Gold FZC |
United
Arab Emirates |
CID002584 |
Outreach
Required |
| Gold |
Industrial
Refining Company |
Belgium |
CID002587 |
Non
Conformant |
| Gold |
Shirpur
Gold Refinery Ltd. |
India |
CID002588 |
Outreach
Required |
| Gold |
Marsam
Metals |
Brazil |
CID002606 |
Non
Conformant |
| Gold |
AU
Traders and Refiners |
South
Africa |
CID002850 |
Non
Conformant |
| Gold |
Sai
Refinery |
India |
CID002853 |
Outreach
Required |
| Gold |
Modeltech
Sdn Bhd |
Malaysia |
CID002857 |
Non
Conformant |
| Gold |
Kyshtym
Copper-Electrolytic Plant ZAO |
Russian
Federation |
CID002865 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Degussa
Sonne / Mond Goldhandel GmbH |
Germany |
CID002867 |
Outreach
Required |
| Gold |
Pease &
Curren |
United
States Of America |
CID002872 |
Communication
Suspended - Not Interested |
| Gold |
JALAN &
Company |
India |
CID002893 |
Outreach
Required |
| Gold |
ABC
Refinery Pty Ltd. |
Australia |
CID002920 |
Outreach
Required |
| Gold |
State
Research Institute Center for Physical Sciences and Technology |
Lithuania |
CID003153 |
Outreach
Required |
| Gold |
African
Gold Refinery |
Uganda |
CID003185 |
RMI
Due Diligence Review - Unable to Proceed |
| Gold |
Gold
Coast Refinery |
Ghana |
CID003186 |
Outreach
Required |
| Gold |
QG
Refining, LLC |
United
States Of America |
CID003324 |
Outreach
Required |
| Gold |
Dijllah
Gold Refinery FZC |
United
Arab Emirates |
CID003348 |
Outreach
Required |
| Gold |
CGR
Metalloys Pvt Ltd. |
India |
CID003382 |
Outreach
Required |
| Gold |
Sovereign
Metals |
India |
CID003383 |
Outreach
Required |
| Gold |
Kundan
Care Products Ltd. |
India |
CID003463 |
Outreach
Required |
| Gold |
Emerald
Jewel Industry India Limited (Unit 1) |
India |
CID003487 |
Outreach
Required |
| Gold |
Emerald
Jewel Industry India Limited (Unit 2) |
India |
CID003488 |
Outreach
Required |
| Gold |
Emerald
Jewel Industry India Limited (Unit 3) |
India |
CID003489 |
Outreach
Required |
| Gold |
Emerald
Jewel Industry India Limited (Unit 4) |
India |
CID003490 |
Outreach
Required |
| Gold |
K.A.
Rasmussen |
Norway |
CID003497 |
Outreach
Required |
| Gold |
MD
Overseas |
India |
CID003548 |
Outreach
Required |
| Gold |
Metallix
Refining Inc. |
United
States Of America |
CID003557 |
Outreach
Required |
| Tantalum |
F&X
Electro-Materials Ltd. |
China |
CID000460 |
Conformant |
| Tantalum |
XIMEI
RESOURCES (GUANGDONG) LIMITED |
China |
CID000616 |
Conformant |
| Tantalum |
JiuJiang
JinXin Nonferrous Metals Co., Ltd. |
China |
CID000914 |
Conformant |
| Tantalum |
Jiujiang
Tanbre Co., Ltd. |
China |
CID000917 |
Conformant |
| Tantalum |
Metallurgical
Products India Pvt., Ltd. |
India |
CID001163 |
Conformant |
| Tantalum |
Mitsui
Mining and Smelting Co., Ltd. |
Japan |
CID001192 |
Conformant |
| Tantalum |
NPM
Silmet AS |
Estonia |
CID001200 |
Conformant |
| Tantalum |
Ningxia
Orient Tantalum Industry Co., Ltd. |
China |
CID001277 |
Conformant |
| Tantalum |
Ulba
Metallurgical Plant JSC |
Kazakhstan |
CID001969 |
Conformant |
| Tantalum |
Hengyang
King Xing Lifeng New Materials Co., Ltd. |
China |
CID002492 |
Conformant |
| Tantalum |
D
Block Metals, LLC |
United
States Of America |
CID002504 |
Conformant |
| Tantalum |
FIR
Metals & Resource Ltd. |
China |
CID002505 |
Conformant |
| Tantalum |
Jiangxi
Dinghai Tantalum & Niobium Co., Ltd. |
China |
CID002512 |
Conformant |
| Tantalum |
TANIOBIS
Co., Ltd. |
Thailand |
CID002544 |
Conformant |
| Tantalum |
TANIOBIS
GmbH |
Germany |
CID002545 |
Conformant |
| Tantalum |
Materion
Newton Inc. |
United
States Of America |
CID002548 |
Conformant |
| Tantalum |
TANIOBIS
Japan Co., Ltd. |
Japan |
CID002549 |
Conformant |
| Tantalum |
TANIOBIS
Smelting GmbH & Co. KG |
Germany |
CID002550 |
Conformant |
| Tantalum |
Global
Advanced Metals Boyertown |
United
States Of America |
CID002557 |
Conformant |
| Tantalum |
Global
Advanced Metals Aizu |
Japan |
CID002558 |
Conformant |
| Tantalum |
Jiangxi
Tuohong New Raw Material |
China |
CID002842 |
Conformant |
| Tantalum |
AMG
Brasil |
Brazil |
CID001076 |
Conformant |
| Tantalum |
Mineracao
Taboca S.A. |
Brazil |
CID001175 |
Conformant |
| Tantalum |
QuantumClean |
United
States Of America |
CID001508 |
Conformant |
| Tantalum |
Yanling
Jincheng Tantalum & Niobium Co., Ltd. |
China |
CID001522 |
Conformant |
| Tantalum |
Taki
Chemical Co., Ltd. |
Japan |
CID001869 |
Conformant |
| Tantalum |
Telex
Metals |
United
States Of America |
CID001891 |
Conformant |
| Tantalum |
Jiujiang
Zhongao Tantalum & Niobium Co., Ltd. |
China |
CID002506 |
Conformant |
| Tantalum |
XinXing
HaoRong Electronic Material Co., Ltd. |
China |
CID002508 |
Conformant |
| Tantalum |
KEMET
de Mexico |
Mexico |
CID002539 |
Conformant |
| Tantalum |
Resind
Industria e Comercio Ltda. |
Brazil |
CID002707 |
Conformant |
| Tantalum |
RFH
Yancheng Jinye New Material Technology Co., Ltd. |
China |
CID003583 |
Conformant |
| Tantalum |
Solikamsk
Magnesium Works OAO |
Russian
Federation |
CID001769 |
RMI
Due Diligence Review - Unable to Proceed |
| Tin |
Chenzhou
Yunxiang Mining and Metallurgy Co., Ltd. |
China |
CID000228 |
Conformant |
| Tin |
Alpha |
United
States Of America |
CID000292 |
Conformant |
| Tin |
Dowa |
Japan |
CID000402 |
Conformant |
| Tin |
EM
Vinto |
Bolivia
(Plurinational State Of) |
CID000438 |
Conformant |
| Tin |
Fenix
Metals |
Poland |
CID000468 |
Conformant |
| Tin |
Gejiu
Non-Ferrous Metal Processing Co., Ltd. |
China |
CID000538 |
Conformant |
| Tin |
China
Tin Group Co., Ltd. |
China |
CID001070 |
Conformant |
| Tin |
Malaysia
Smelting Corporation (MSC) |
Malaysia |
CID001105 |
Conformant |
| Tin |
Metallic
Resources, Inc. |
United
States Of America |
CID001142 |
Conformant |
| Tin |
Mineracao
Taboca S.A. |
Brazil |
CID001173 |
Conformant |
| Tin |
Minsur |
Peru |
CID001182 |
Conformant |
| Tin |
Mitsubishi
Materials Corporation |
Japan |
CID001191 |
Conformant |
| Tin |
Operaciones
Metalurgicas S.A. |
Bolivia
(Plurinational State Of) |
CID001337 |
Conformant |
| Tin |
PT
Babel Inti Perkasa |
Indonesia |
CID001402 |
Conformant |
| Tin |
PT
Bukit Timah |
Indonesia |
CID001428 |
Conformant |
| Tin |
PT
Mitra Stania Prima |
Indonesia |
CID001453 |
Conformant |
| Tin |
PT
Refined Bangka Tin |
Indonesia |
CID001460 |
Conformant |
| Tin |
PT
Sariwiguna Binasentosa |
Indonesia |
CID001463 |
Conformant |
| Tin |
PT
Stanindo Inti Perkasa |
Indonesia |
CID001468 |
Conformant |
| Tin |
PT
Timah Tbk Kundur |
Indonesia |
CID001477 |
Conformant |
| Tin |
PT
Timah Tbk Mentok |
Indonesia |
CID001482 |
Conformant |
| Tin |
Rui
Da Hung |
Taiwan,
Province Of China |
CID001539 |
Conformant |
| Tin |
Thaisarco |
Thailand |
CID001898 |
Conformant |
| Tin |
White
Solder Metalurgia e Mineracao Ltda. |
Brazil |
CID002036 |
Conformant |
| Tin |
Yunnan
Chengfeng Non-ferrous Metals Co., Ltd. |
China |
CID002158 |
Conformant |
| Tin |
Tin
Smelting Branch of Yunnan Tin Co., Ltd. |
China |
CID002180 |
Conformant |
| Tin |
O.M.
Manufacturing Philippines, Inc. |
Philippines |
CID002517 |
Conformant |
| Tin |
Aurubis
Beerse |
Belgium |
CID002773 |
Conformant |
| Tin |
PT
Menara Cipta Mulia |
Indonesia |
CID002835 |
Conformant |
| Tin |
Guangdong
Hanhe Non-Ferrous Metal Co., Ltd. |
China |
CID003116 |
Conformant |
| Tin |
Chifeng
Dajingzi Tin Industry Co., Ltd. |
China |
CID003190 |
Conformant |
| Tin |
Estanho
de Rondonia S.A. |
Brazil |
CID000448 |
Conformant |
| Tin |
Gejiu
Zili Mining And Metallurgy Co., Ltd. |
China |
CID000555 |
Non
Conformant |
| Tin |
Jiangxi
New Nanshan Technology Ltd. |
China |
CID001231 |
Conformant |
| Tin |
O.M.
Manufacturing (Thailand) Co., Ltd. |
Thailand |
CID001314 |
Conformant |
| Tin |
Magnu's
Minerais Metais e Ligas Ltda. |
Brazil |
CID002468 |
Conformant |
| Tin |
Resind
Industria e Comercio Ltda. |
Brazil |
CID002706 |
Conformant |
| Tin |
Super
Ligas |
Brazil |
CID002756 |
Conformant |
| Tin |
Aurubis
Berango |
Spain |
CID002774 |
Conformant |
| Tin |
Tin
Technology & Refining |
United
States Of America |
CID003325 |
Conformant |
| Tin |
Luna
Smelter, Ltd. |
Rwanda |
CID003387 |
Conformant |
| Tin |
Yunnan
Yunfan Non-ferrous Metals Co., Ltd. |
China |
CID003397 |
Conformant |
| Tin |
PT
Mitra Sukses Globalindo |
Indonesia |
CID003449 |
Conformant |
| Tin |
CRM
Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Brazil |
CID003486 |
Conformant |
| Tin |
CRM
Synergies |
Spain |
CID003524 |
Conformant |
| Tin |
Fabrica
Auricchio Industria e Comercio Ltda. |
Brazil |
CID003582 |
Conformant |
| Tin |
DS
Myanmar |
Myanmar |
CID003831 |
Conformant |
| Tin |
PT
Putera Sarana Shakti (PT PSS) |
Indonesia |
CID003868 |
Conformant |
| Tin |
Mining
Minerals Resources SARL |
Congo,
Democratic Republic Of The |
CID004065 |
Conformant |
| Tin |
PT
Aries Kencana Sejahtera |
Indonesia |
CID000309 |
Conformant |
| Tin |
PT
Babel Surya Alam Lestari |
Indonesia |
CID001406 |
Conformant |
| Tin |
PT
Prima Timah Utama |
Indonesia |
CID001458 |
Conformant |
| Tin |
PT
Tommy Utama |
Indonesia |
CID001493 |
Conformant |
| Tin |
CV
Venus Inti Perkasa |
Indonesia |
CID002455 |
Conformant |
| Tin |
PT
ATD Makmur Mandiri Jaya |
Indonesia |
CID002503 |
Conformant |
| Tin |
PT
Cipta Persada Mulia |
Indonesia |
CID002696 |
Conformant |
| Tin |
PT
Sukses Inti Makmur |
Indonesia |
CID002816 |
Conformant |
| Tin |
PT
Bangka Serumpun |
Indonesia |
CID003205 |
Conformant |
| Tin |
PT
Rajawali Rimba Perkasa |
Indonesia |
CID003381 |
Conformant |
| Tin |
PT
Premium Tin Indonesia |
Indonesia |
CID000313 |
Conformant |
| Tin |
Gejiu
Kai Meng Industry and Trade LLC |
China |
CID000942 |
Non
Conformant |
| Tin |
Novosibirsk
Tin Combine |
Russian
Federation |
CID001305 |
RMI
Due Diligence Review - Unable to Proceed |
| Tin |
PT
Artha Cipta Langgeng |
Indonesia |
CID001399 |
Conformant |
| Tin |
PT
Bangka Tin Industry |
Indonesia |
CID001419 |
Active |
| Tin |
PT
Belitung Industri Sejahtera |
Indonesia |
CID001421 |
Conformant |
| Tin |
PT
Panca Mega Persada |
Indonesia |
CID001457 |
Outreach
Required |
| Tin |
PT
Timah Nusantara |
Indonesia |
CID001486 |
Conformant |
| Tin |
PT
Tinindo Inter Nusa |
Indonesia |
CID001490 |
Conformant |
| Tin |
Gejiu
Yunxin Nonferrous Electrolysis Co., Ltd. |
China |
CID001908 |
Non
Conformant |
| Tin |
VQB
Mineral and Trading Group JSC |
Viet
Nam |
CID002015 |
Outreach
Required |
| Tin |
PT
Tirus Putra Mandiri |
Indonesia |
CID002478 |
Communication
Suspended - Not Interested |
| Tin |
Melt
Metais e Ligas S.A. |
Brazil |
CID002500 |
Non
Conformant |
| Tin |
CV
Ayi Jaya |
Indonesia |
CID002570 |
Conformant |
| Tin |
Electro-Mechanical
Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
Viet
Nam |
CID002572 |
Non
Conformant |
| Tin |
Nghe
Tinh Non-Ferrous Metals Joint Stock Company |
Viet
Nam |
CID002573 |
Outreach
Required |
| Tin |
Tuyen
Quang Non-Ferrous Metals Joint Stock Company |
Viet
Nam |
CID002574 |
Outreach
Required |
| Tin |
An
Vinh Joint Stock Mineral Processing Company |
Viet
Nam |
CID002703 |
Outreach
Required |
| Tin |
PT
Bangka Prima Tin |
Indonesia |
CID002776 |
Conformant |
| Tin |
Modeltech
Sdn Bhd |
Malaysia |
CID002858 |
Non
Conformant |
| Tin |
Pongpipat
Company Limited |
Myanmar |
CID003208 |
Outreach
Required |
| Tin |
Dongguan
CiEXPO Environmental Engineering Co., Ltd. |
China |
CID003356 |
Non
Conformant |
| Tin |
Precious
Minerals and Smelting Limited |
India |
CID003409 |
Active |
| Tin |
Gejiu
City Fuxiang Industry and Trade Co., Ltd. |
China |
CID003410 |
Outreach
Required |
| Tin |
HuiChang
Hill Tin Industry Co., Ltd. |
China |
CID002844 |
Conformant |
| Tungsten |
A.L.M.T.
Corp. |
Japan |
CID000004 |
Conformant |
| Tungsten |
Kennametal
Huntsville |
United
States Of America |
CID000105 |
Conformant |
| Tungsten |
Guangdong
Xianglu Tungsten Co., Ltd. |
China |
CID000218 |
Conformant |
| Tungsten |
Chongyi
Zhangyuan Tungsten Co., Ltd. |
China |
CID000258 |
Conformant |
| Tungsten |
Global
Tungsten & Powders LLC |
United
States Of America |
CID000568 |
Conformant |
| Tungsten |
Hunan
Chenzhou Mining Co., Ltd. |
China |
CID000766 |
Conformant |
| Tungsten |
Hunan
Jintai New Material Co., Ltd. |
China |
CID000769 |
Non
Conformant |
| Tungsten |
Japan
New Metals Co., Ltd. |
Japan |
CID000825 |
Conformant |
| Tungsten |
Kennametal
Fallon |
United
States Of America |
CID000966 |
Conformant |
| Tungsten |
Wolfram
Bergbau und Hutten AG |
Austria |
CID002044 |
Conformant |
| Tungsten |
Xiamen
Tungsten Co., Ltd. |
China |
CID002082 |
Conformant |
| Tungsten |
Ganzhou
Jiangwu Ferrotungsten Co., Ltd. |
China |
CID002315 |
Conformant |
| Tungsten |
Jiangxi
Yaosheng Tungsten Co., Ltd. |
China |
CID002316 |
Conformant |
| Tungsten |
Jiangxi
Xinsheng Tungsten Industry Co., Ltd. |
China |
CID002317 |
Conformant |
| Tungsten |
Jiangxi
Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
China |
CID002318 |
Conformant |
| Tungsten |
Malipo
Haiyu Tungsten Co., Ltd. |
China |
CID002319 |
Conformant |
| Tungsten |
Xiamen
Tungsten (H.C.) Co., Ltd. |
China |
CID002320 |
Conformant |
| Tungsten |
Jiangxi
Gan Bei Tungsten Co., Ltd. |
China |
CID002321 |
Conformant |
| Tungsten |
Ganzhou
Seadragon W & Mo Co., Ltd. |
China |
CID002494 |
Conformant |
| Tungsten |
Asia
Tungsten Products Vietnam Ltd. |
Viet
Nam |
CID002502 |
Conformant |
| Tungsten |
Hunan
Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
China |
CID002513 |
Conformant |
| Tungsten |
H.C.
Starck Tungsten GmbH |
Germany |
CID002541 |
Conformant |
| Tungsten |
TANIOBIS
Smelting GmbH & Co. KG |
Germany |
CID002542 |
Conformant |
| Tungsten |
Masan
High-Tech Materials |
Viet
Nam |
CID002543 |
Conformant |
| Tungsten |
Jiangwu
H.C. Starck Tungsten Products Co., Ltd. |
China |
CID002551 |
Conformant |
| Tungsten |
Hydrometallurg,
JSC |
Russian
Federation |
CID002649 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
Unecha
Refractory metals plant |
Russian
Federation |
CID002724 |
Non
Conformant |
| Tungsten |
Philippine
Chuangxin Industrial Co., Inc. |
Philippines |
CID002827 |
Conformant |
| Tungsten |
ACL
Metais Eireli |
Brazil |
CID002833 |
Non
Conformant |
| Tungsten |
Moliren
Ltd. |
Russian
Federation |
CID002845 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
Niagara
Refining LLC |
United
States Of America |
CID002589 |
Conformant |
| Tungsten |
China
Molybdenum Tungsten Co., Ltd. |
China |
CID002641 |
Conformant |
| Tungsten |
Lianyou
Metals Co., Ltd. |
Taiwan,
Province Of China |
CID003407 |
Conformant |
| Tungsten |
Hubei
Green Tungsten Co., Ltd. |
China |
CID003417 |
Conformant |
| Tungsten |
Cronimet
Brasil Ltda |
Brazil |
CID003468 |
Conformant |
| Tungsten |
Fujian
Xinlu Tungsten Co., Ltd. |
China |
CID003609 |
Conformant |
| Tungsten |
Tungsten
Vietnam Joint Stock Company |
Viet
Nam |
CID003993 |
Conformant |
| Tungsten |
CNMC
(Guangxi) PGMA Co., Ltd. |
China |
CID000281 |
Outreach
Required |
| Tungsten |
Jiangxi
Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
China |
CID002313 |
Communication
Suspended - Not Interested |
| Tungsten |
JSC
"Kirovgrad Hard Alloys Plant" |
Russian
Federation |
CID003408 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
NPP
Tyazhmetprom LLC |
Russian
Federation |
CID003416 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
Albasteel
Industria e Comercio de Ligas Para Fundicao Ltd. |
Brazil |
CID003427 |
Non
Conformant |
| Tungsten |
Artek
LLC |
Russian
Federation |
CID003553 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
OOO
“Technolom” 2 |
Russian
Federation |
CID003612 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
OOO
“Technolom” 1 |
Russian
Federation |
CID003614 |
RMI
Due Diligence Review - Unable to Proceed |
| Tungsten |
LLC
Vostok |
Russian
Federation |
CID003643 |
RMI
Due Diligence Review - Unable to Proceed |
Appendix B: Countries of Origin
| Country of Origin |
| China |
Djibouti |
| Brazil |
Guinea |
| Australia |
Ghana |
| Indonesia |
Tanzania |
| Japan |
Democratic Republic of Congo |
| Peru |
Italy |
| Canada |
Saudi Arabia |
| Malaysia |
Sweden |
| Germany |
Belarus |
| Spain |
United Arab Emirates |
| Russian Federation |
Papua New Guinea |
| India |
Eritrea |
| Chile |
Morocco |
| United Kingdom |
Poland |
| United States of America |
Zambia |
| Austria |
Mali |
| Niger |
New Zealand |
| Thailand |
Sudan |
| Nigeria |
Azerbaijan |
| Portugal |
Benin |
| Argentina |
Finland |
| Belgium |
Guatemala |
| Ireland |
Honduras |
| France |
Liechtenstein |
| Switzerland |
Nicaragua |
| Myanmar |
Uganda |
| Colombia |
Angola |
| Mongolia |
Armenia |
| Kazakhstan |
Burkina Faso |
| Singapore |
Congo |
| Mexico |
El Salvador |
| Israel |
Jersey |
| Hungary |
Kyrgyzstan |
| Guyana |
Mauritania |
| Luxembourg |
VietNam |
| Ecuador |
Bulgaria |
| Ethiopia |
Central African Republic |
| Cambodia |
Dominican Republic |
| Estonia |
Georgia |
| Egypt |
Liberia |
| Sierra Leone |
Senegal |
| Namibia |
Tajikistan |
| Madagascar |
Botswana |
| Rwanda |
Cyprus |
| Hong Kong |
Fiji |
| Netherlands |
Kenya |
| Slovakia |
Lithuania |
| Korea |
Oman |
| Mozambique |
Serbia |
| South Africa |
South Sudan |
| Bolivia (Plurinational State of) |
Uruguay |
| Burundi |
Albania |
| Panama |
Bermuda |
| Suriname |
Dominica |
| Philippines |
Guam |
| Taiwan |
Ivory Coast |
| Andorra |
Norway |
| Uzbekistan |
Togo |
| Turkey |
Solomon Islandss |
Appendix C: CMRT Declaration Rejection/Approval
Criteria
Assent Sustainability Platform
Logic Structure
The following
tables map the Assent Sustainability Platform’s status outputs and CMRT logic structure when determining supplier conflict mineral
statuses as displayed on the dashboard. Using this table, and referencing the CMRT questions listed above, users will be able to determine
what answers were provided by their suppliers to earn their conflict minerals statuses.
Dashboard Supplier Response Statuses
| Supplier Status |
Description |
| Not Submitted |
A CMRT has not been submitted by the supplier |
| Complete |
A CMRT has been submitted, and is valid and complete |
| Incomplete |
A supplier with parts associated to them has submitted a partially completed Product-Level or User-Defined CMRT |
| Invalid Submission |
A CMRT has been submitted and deemed invalid based on contradicting responses in the template |
| Out of Scope |
The supplier is out of scope for conflict minerals and does not need to be contacted |
Grafico Azioni NRG Energy (NYSE:NRG)
Storico
Da Mag 2024 a Giu 2024
Grafico Azioni NRG Energy (NYSE:NRG)
Storico
Da Giu 2023 a Giu 2024
