Exhibit 1.01
CONFLICT MINERALS REPORT OF PHILIP MORRIS INTERNATIONAL INC. FOR THE YEAR ENDED DECEMBER 31, 20231
INTRODUCTION
Philip Morris International Inc., a Virginia holding company, was incorporated in 1987. Our subsidiaries and affiliates and their licensees are engaged in the manufacture and sale of cigarettes and smoke-free products.2 We operate in markets primarily outside of the United States of America, with manufacturing and sales facilities in various locations around the world.
This Conflict Minerals Report (the “Report”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”), for the reporting period from January 1 to December 31, 2023.
Conflict Minerals are defined by the Securities and Exchange Commission (the “SEC”) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “3TGs”). During the reporting period, we contracted to manufacture the following products within the meaning of Rule 13p-1:
•Platform 1 – a precisely controlled heating device incorporating our IQOS HeatControl Technology, commercialized under the IQOS brand name, into which a specially designed and proprietary tobacco unit is inserted and heated to create an aerosol, as well as IQOS ILUMA, a precisely controlled heating device which relies on using induction instead of heating a blade, and also includes related accessories and parts, as well as a heated tobacco product which utilizes external resistive heating technology and that is commercialized under the BONDS brand;
•Platform 4 – includes battery powered e-vapor products that produce an aerosol by vaporizing a tobacco-free liquid solution; and
•Breelib – an inhalation system designed to nebulize a proprietary inhalation solution and which is being commercialized by our Wellness and Healthcare business segment.
In this report, we refer to Platform 1, Platform 4 and Breelib products as “Covered Products.”
In 2023, we sourced our Covered Products from ten direct suppliers (the “Direct Suppliers”). The electronic components of the Covered Products contain one or more 3TGs. The 3TGs used in the Covered Products are necessary for the functionality or production of the Covered Products.
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1 In this report, “PMI,” “Company,” “we,” “us,” and “our” refers to Philip Morris International Inc. and its subsidiaries. Trademarks and science marks in this report are the intellectual property of, or licensed by, the subsidiaries of Philip Morris International Inc. and are italicized.
2 Smoke-free products (“SFPs”) is the term PMI uses to refer to all of its products that provide nicotine without combusting tobacco, such as heat-not-burn, e-vapor, and oral smokeless, and that therefore generate far lower levels of harmful chemicals. As such, these products have the potential to present less risk of harm versus continued smoking.
We have implemented policies, procedures and due diligence processes to determine whether any of the 3TGs contained in the Covered Products are sourced from the Democratic Republic of the Congo (“DRC”) or any of its adjoining countries (“Covered Countries”), and contribute to the financing of armed conflict in the region. In order to support the economic activity in the region, we have communicated to our Direct Suppliers that we do not discourage them from sourcing 3TGs from the Covered Countries under our Conflict Minerals Policy, (also referred to in this report as the “Policy”), so long as they are sourced in accordance with our Responsible Sourcing Principles (“RSPs”) and the Organization for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”).
We are far removed from the sources of ores from which the 3TGs contained in the Covered Products are procured, and the smelters and refiners that process those ores (“SORs”). Therefore, the efforts to identify the countries of origin for 3TGs that may be used in the Covered Products reflect both (i) our downstream position in the supply chain3; and (ii) the applicable OECD Guidance (as defined below).
DUE DILIGENCE MEASURES
A.Design of Our Due Diligence Measures
In 2023, our Conflict Minerals due diligence processes were performed in line with the internationally recognized due diligence framework provided by the OECD Guidance, as applicable for 3TGs and downstream companies (as the term “downstream companies” is defined in the OECD Guidance)4. As described below, our due diligence measures in relation to Covered Products included:
1.Establishing a process managed by members of management, including a dedicated cross-functional team (the “Conflict Minerals Team”) for carrying out Conflict Minerals supply chain due diligence and reporting compliance;
2.Identifying, assessing and prioritizing Conflict Minerals risks in our supply chain;
3.Engaging with our Direct Suppliers requesting their compliance to our RSPs and encouraging them to invite their value chain partners to join the Responsible Minerals Initiative (the “RMI”);
4.Designing and implementing strategies to respond to Conflict Minerals risks to the extent identified;
5. Requiring that, in relation to the Covered Products, our Direct Suppliers source only from SORs that have been validated as “conflict free” by the RMI’s Responsible Minerals Assurance Process (“RMAP”), the London Bullion Market Association (“LBMA”), the Responsible Jewelry Council, or a comparable program, and to undertake reasonable due diligence in their respective supply chains to ensure the same; and
6.Reporting annually on PMI supply chain due diligence measures.
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3 As a result of our downstream position in the supply chain, our due diligence processes involve PMI seeking data from our Direct Suppliers and those suppliers seeking similar information in their respective supply chains to identify the original sources of the applicable Conflict Minerals. We also rely, to a large extent, on information collected and provided by third-party validation programs. Because our diligence processes rely on information provided by third parties, they may yield inaccurate or incomplete information.
4 “Downstream companies” include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
B. Due Diligence Program Elements
1.Processes Implemented by Company Management
Conflict Minerals Policy
We have a Conflict Minerals Policy which is communicated to our Direct Suppliers to help achieve responsible sourcing of 3TGs in our supply chain. We are committed to operating with integrity and are focused on the responsible sourcing of 3TGs. In 2024, we updated the Policy to better align it to PMI’s Human Rights Commitment and our RSPs. The Policy is publicly available on our website at: http://www.pmi.com/our-views-and-standards/standards/transparency and it is also attached to this Report as Appendix A.
Internal Team
Under the oversight of our Senior Vice President, Operations, our Conflict Minerals Team is comprised by representatives from our operations, finance and legal functions. The Conflict Minerals Team has the overall responsibility for developing and implementing our Conflict Minerals compliance strategy, as well as for reviewing the ongoing progress and effectiveness of the Conflict Minerals reporting. In addition, when needed this cross-functional team engages with specialists in other functions throughout PMI to review and analyze the information relevant to PMI’s Conflict Minerals due diligence processes and reporting, and to update our due diligence process in order to improve our Direct Suppliers’ performance, where necessary. In 2023, our Conflict Minerals Team commissioned a specialized external consultant to conduct a benchmark to better understand industry leading practices related to the responsible sourcing of minerals. This engagement contributed to the development of an enhanced conflict minerals due diligence strategy, including the updated Policy.
As part of our organizational framework, our Product Compliance Team, which is part of the Life Sciences Department reporting to our Chief Life Sciences Officer, also verifies ingredients and materials used in the direct materials for our Covered Products. Any Conflict Minerals reporting and compliance matters that arise during this verification process are analyzed and addressed by the Conflict Minerals Team.
Our senior management and our Board of Directors are informed of the results of our due diligence efforts, supply chain integrity and relationships with our Direct Suppliers.
Supply Chain Transparency Framework
To support PMI’s Conflict Minerals compliance and due diligence program, PMI’s supply chain transparency framework combines internal activities, collaboration with our Direct Suppliers and reliance on the information published by industry programs such as the Responsible Minerals Initiative (the “RMI”). The RMI is a global, non-governmental organization that was founded in 2008 by members of the Responsible Business Alliance (the “RBA”) and the Global e-Sustainability Initiative. It is comprised by over 500 companies and associations from a range of industries. The RMI focuses on the responsible sourcing of minerals and develops best practices and services to support such responsible minerals sourcing. PMI joined the RBA and its Responsible Minerals Initiative in January of 2021.
As part of our Conflict Minerals due diligence processes, we require our Direct Suppliers to use RMI’s Conflict Minerals Reporting Template (“CMRT”) to collect and retain the necessary information on the chain of custody of the 3TGs contained in the parts of the Covered Products that they respectively supplied to us, including information about the SORs from which those 3TGs were sourced. The CMRT is generally regarded as the most widely-used standard to collect information about Conflict Minerals through the supply chain.
In addition to the CMRTs, we ask each of our Direct Suppliers to sign declarations on an annual basis certifying that the information they present to us in their CMRTs is, to the best of their knowledge, accurate and complete, and that each Direct Supplier’s certification is based upon that supplier’s due diligence review and the reasonable country of origin inquiry with respect to any 3TGs in the Covered Products.
Supplier Engagement and Other Compliance Efforts
Our Direct Supplier arrangements also include Conflict Minerals-related provisions that: (i) are consistent with our Conflict Minerals Policy, (ii) require our Direct Suppliers to comply with our due diligence requests; and (iii) encourage our Direct Suppliers to participate in industry-wide or material-specific supply chain mapping initiatives.
In addition, and consistent with our efforts as described in the Conflict Minerals report for the period ended December 31, 2022 (the “2022 Report”), in 2023, we continued to undertake the following efforts to further improve due diligence and supplier engagement:
•Supplier capability building through dedicated sessions focused on understanding compliance requirements for sourcing of conflict minerals, including the underlying SEC regulations.
•Further engagements with our Direct Suppliers to exercise reasonable due diligence on the source and chain of custody of minerals from conflict-affected and high risk areas, as described in our Policy and our Responsible Sourcing Principles.
•Our Direct Suppliers were further encouraged to actively engage in third party audit programs such as the RMAP and to participate in trainings provided by RMI with regards to Conflict Minerals sourcing, review their supply chain due diligence processes related to Conflict Minerals sourcing in terms of accuracy and timeliness of responses, and continue to improve compliance.
As a result of these efforts, in 2023, we continued to see satisfactory levels of both timeliness and completeness of the information submitted to us by our Direct Suppliers. Specifically in 2023:
•We continued to deploy the RBA due diligence process to manage our supply chain – this program includes self-assessment questionnaires and a validated assurance program (that includes on-site audits) to monitor the sourcing of conflict minerals from our Direct Suppliers;
•We conducted conflict minerals orientation seminars to the two new Direct Suppliers and we held regular meetings with all our Direct Suppliers to discuss our requirements relating to the responsible sourcing of minerals;
•We used our supplier due diligence program to assess our Direct Suppliers’ compliance with our Responsible Sourcing Principles, which also cover the responsible sourcing of the 3TGs;
•We communicated to our Direct Suppliers our expectation that they use SORs certified as compliant with the Responsible Minerals Assurance Process (“Compliant SORs”)5 for the manufacture of the Covered Products, and have held online conferences with our Direct Suppliers to reinforce this expectation. Please see “Section C” below for additional information;
•We continued to mandate conflict minerals due diligence based on the OECD Guidance and training as a prerequisite to engagement with any new direct suppliers of electronics; and
•We continued to support our due diligence efforts with appropriate record retention practices; and
•We continued to regularly monitor and assess potential risks within our value chain, including those linked to sourcing of minerals.
Grievance Mechanism
We have a grievance mechanism called the PMI Ethics & Compliance Help Line that allows our employees, our business partners and stakeholders to report any suspected violation of PMI´s principles and practices to the senior management or the Ethics & Compliance Department. Reports can be made through face-to-face discussions or via email if the employee prefers to remain anonymous. We maintain both a dedicated email address: PMI.EthicsandCompliance@pmi.com, and an independently operated and confidential Compliance Helpline, that operates a phone line and a webline. Concerns can also be reported by our employees confidentially or anonymously. Any such reports related to Conflict Minerals are to be forwarded to the Conflict Minerals Team that will review them and help design appropriate response measures. In addition, we encourage our suppliers to establish their own grievance mechanisms.
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5 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process (“RMAP”) and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of the audit, such SORs are then designated as RMAP-Compliant SORs.
2. Identify and Assess Risk in the Supply Chain
We reviewed the answers to the CMRT received from our Direct Suppliers and assessed their completeness, clarity and consistency. We worked with our Direct Suppliers to understand their due diligence process, ensuring their understanding of our Conflict Minerals policy and requirements, as well as obtaining a list of SORs in their respective supply chains for the Covered Products.
Our Direct Suppliers confirmed that some of the SORs in their supply chain may source 3TGs from the Covered Countries and that the 3TGs may not be from recycled or scrap sources. As part of our risk assessment, we checked whether these SORs were Compliant SORs by comparing the facilities identified by our Direct Suppliers against the list provided by the RMI and its Responsible Minerals Assurance Process (“RMAP”), as well as the list provided by the London Bullion Market Association (“LBMA”). We also followed up with additional information requests to obtain the necessary details to better assess the reliability of the responses and the risks in our supply chain in instances where the responses received were not clear or where the SORs were not certified as RMAP- compliant.
Please also see Section B.1 for the discussion of our efforts in 2023 to help identify and assess risk in our supply chain related to 3TG sourcing.
3. Design and Implement a Strategy to Respond to Risks in the Supply Chain
We designed a strategy to respond to risks related to Conflict Minerals in our supply chain. When the members of the Conflict Minerals Team become aware that the due diligence of our direct or indirect suppliers needs improvement, they provide feedback, ask clarifying questions and demand corrective actions where necessary. The members of the Conflict Minerals Team provide information and training to our Direct Suppliers and determine appropriate follow-up actions, if any, to mitigate any identified risks. Follow-up actions may include, but are not limited to, finding alternate sources of supply or terminating existing supplier relationships, as appropriate. We have communicated to our Direct Suppliers that they should further implement, and communicate to their suppliers to implement, the due diligence standards that reflect the OECD Guidance. Steps to improve the accuracy of the due diligence process are described in Sections B.1 above and D below.
4. Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We rely on the RMI’s Responsible Minerals Assurance Process for the performance of third-party audits of SORs. To the extent possible, we review whether any 3TGs sourced from the Covered Countries are “DRC conflict-free” based on the information provided by our Direct Suppliers and the information available on the RMI’s website. We encourage our suppliers to join the RBA and the RMI. In addition, as described above, we have communicated to our Direct Suppliers our expectation that they use Compliant SORs for the manufacture of our Covered Products.
5. Report on Supply Chain Due Diligence
This Report will be filed with the SEC and will also be publicly available at http://www.pmi.com/our-views-and-standards/standards/transparency.
C. Reasonable Country of Origin Inquiry ("RCOI") and Due Diligence on the Source and Chain of Custody
We asked our Direct Suppliers to provide answers to the CMRT to ascertain whether any 3TGs contained in the Covered Products originated from Covered Countries. Based on the evaluation of our Direct Suppliers’ responses to their CMRT, we had reason to believe that some of the 3TGs in the Covered Products manufactured in 2023 may have originated in the Covered Countries and were not entirely from recycled or scrap sources.
With respect to the Covered Products, through the CMRT, based on information received from our Direct Suppliers, for 2023: (i) 100% of their suppliers provided responses to the CMRT; (ii) 3TGs contained in some Covered Products may have originated from the Covered Countries; and (iii) no 3TGs contained in the Covered Products come from recycled or scrap resources. On an aggregate basis, our Direct Suppliers have identified 268 SORs supplying 3TGs in our supply chain that were found to be eligible for the Reasonable Minerals Assurance Process. Of these SORs:
•245 (approximately 91%6) were confirmed to be RMAP-Compliant or RMAP-Active,7 effectively confirming that they are already engaged in the Reasonable Minerals Assurance Process.
•9 (approximately 3%6) of the SORs in our supply chain were confirmed to be undergoing initial screening by RMAP. Our Conflict Minerals Team will continue tracking these SORs’ progress in obtaining an RMAP-Compliant or RMAP-Active status by monitoring their engagement with RMI, and will engage with these SORs (either directly or through RMI) going forward in order to ensure that they are on track to be covered by RMAP.
•14 (approximately 5%6) of the SORs in our supply chain were confirmed to be non-conformant. Our Conflict Minerals Team, directly or through RMI, will contact these SORs in order to encourage them to obtain RMAP certification and, if they are not responsive or not interested, we will ask our Direct Suppliers to disengage them from our supply chain for the Covered Products going forward.
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6 Percentages do not foot due to rounding.
7 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of such audit, such SORs would become Compliant SORs.
D. Steps to Further Improve Due Diligence
As part of PMI’s RMI membership, in 2023 we have continued our active participation in RMI projects and initiatives. In addition, we plan to concentrate on the following steps in the future:
•As part of our Responsible Sourcing Principles framework, continue to engage with our Direct Suppliers to further clarify our expectation related to responsible sourcing of conflict minerals/3TGs for our products from Compliant SORs;
•Continue to encourage our Direct Suppliers to further strengthen due diligence measures in line with the OECD Guidance, thereby improving the quality and completeness of supply chain information available to us.
•Continue raising awareness and provide training on our Policy, grievance mechanism requirements, compliance expectations and information to our present Direct Suppliers and future direct suppliers – this includes encouraging them to take e-learning courses available through the RBA eLearning Academy;
•Encourage our Direct Suppliers to continue to enforce their respective Conflict Minerals policies throughout their value chain;
• Increase our engagement and collaboration with RMI to strengthen the implementation of RMI due diligence tools in our due diligence program. This will also support our determination of our Direct Suppliers' compliance with our RSPs;
•Continue training our employees responsible for the procurement of electronics and those in related supporting roles, including through programs made available by RMI;
•Continue to enhance the CMRT data assurance process with our Direct Suppliers;
•Based on the positive outcome of the pilot project launched in 2023 with two of our Direct Suppliers to increase the CMRT data collection frequency to biannual, we will continue our efforts to expand this approach to our other Direct Suppliers, as this process increases transparency and improves performance in our supply chain for the Covered Products;
•Collaborate with other value chain partners to strengthen our due diligence and source minerals responsibly; and
•Continue to contact non-conformant SORs in order to encourage them to obtain RMAP certification and, if they are not responsive or not interested, continue to ask our Direct Suppliers to disengage such SORs from our supply chain for the Covered Products going forward.
E. Independent Private Sector Audit
An independent private sector audit is not required for this Report.
Forward-Looking and Cautionary Statements
This Conflict Minerals Report contains projections of future results and goals and other forward-looking statements, including statements regarding business and operational plans and strategies. Achievement of future results is subject to risks, uncertainties and inaccurate assumptions. In the event that risks or uncertainties materialize, or underlying assumptions prove inaccurate, actual results could vary materially from those contained in such forward-looking statements. Pursuant to the “safe harbor” provisions of the Private Securities Litigation Reform Act of 1995, PMI is identifying important factors that, individually or in the aggregate, could cause actual results and outcomes to differ materially from those contained in any forward-looking statements made by PMI.
PMI’s business risks include: excise tax increases and discriminatory tax structures; increasing marketing and regulatory restrictions that could reduce our competitiveness, eliminate our ability to communicate with adult consumers, or ban certain of our products in certain markets or countries; health concerns relating to the use of tobacco and other nicotine-containing products and exposure to environmental tobacco smoke; litigation related to tobacco and/or nicotine use and intellectual property; intense competition; the effects of global and individual country economic, regulatory and political developments, natural disasters and conflicts; the impact and consequences of Russia’s invasion of Ukraine; changes in adult smoker behavior; the impact of natural disasters and pandemics on PMI’s business; lost revenues as a result of counterfeiting, contraband and cross-border purchases; governmental investigations; unfavorable currency exchange rates and currency devaluations, and limitations on the ability to repatriate funds; adverse changes in applicable corporate tax laws; adverse changes in the cost, availability, and quality of tobacco and other agricultural products and raw materials, as well as components and materials for our electronic devices; and the integrity of its information systems and effectiveness of its data privacy policies. PMI’s future profitability may also be adversely affected should it be unsuccessful in its attempts to introduce, commercialize, and grow smoke-free products or if regulation or taxation do not differentiate between such products and cigarettes; if it is unable to successfully introduce new products, promote brand equity, enter new markets or improve its margins through increased prices and productivity gains; if it is unable to expand its brand portfolio internally or through acquisitions and the development of strategic business relationships; if it is unable to attract and retain the best global talent, including women or diverse candidates; or if it is unable to successfully integrate and realize the expected benefits from recent transactions and acquisitions. Future results are also subject to the lower predictability of our smoke-free products’ performance.
PMI is further subject to other risks detailed from time to time in its publicly filed documents, including PMI’s Quarterly Report on Form 10-Q for the quarter ended March 31, 2024. PMI cautions that the foregoing list of important factors is not a complete discussion of all potential risks and uncertainties. PMI does not undertake to update any forward-looking statement that it may make from time to time, except in the normal course of its public disclosure obligations.
Appendix A
Conflict Minerals Policy
PMI Responsible Sourcing of Minerals Policy
At Philip Morris International (PMI), we are committed to doing business in line with internationally recognized principles on human rights, environmental management, business integrity, and anti-corruption. PMI recognizes that the responsible sourcing of minerals is an important societal issue, and in alignment with our Human Rights Commitment and Responsible Sourcing Principles (RSPs), PMI exercises reasonable due diligence to ensure that minerals entering PMI’s supply chain do not contribute to the funding of armed groups, fuel forced labor, or support other human rights abuses through our purchasing decisions and practices.
We endorse the Organization for Economic Cooperation and Development’s (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (hereafter referred to as "OECD Guidance").
In accordance with the rules of the U.S. Securities and Exchange Commission (the “SEC”) on conflict minerals, we have implemented policies, procedures and due diligence processes, to determine whether tin, tantalum, tungsten and gold (collectively, the “3TGs” or “conflict minerals”) contained in Covered Products1 are sourced from the Democratic Republic of the Congo (“DRC”) or any of its adjoining countries (“Covered Countries”2), and contribute to the financing of armed groups that are committing human rights abuses. In order to support the economic activity in the region, we have communicated to the suppliers from whom we source our Covered Products (“Direct Suppliers”), that we do not discourage them from sourcing 3TGs from the Covered Countries, so long as they are sourced in accordance with the SEC’s rules on conflict minerals, our RSPs and the OECD Guidance.
In support of this policy, PMI commits to:
1.Not knowingly procure conflict minerals that originate from a Covered Country;
2.Implement and update a process managed by members of management, including a dedicated cross-functional team (the “Conflict Minerals Team”), for carrying out conflict minerals supply chain due diligence and reporting compliance;
3.Identify, assess, and prioritize conflict minerals risks in our supply chain;
4.Engage with our Direct Suppliers requiring their compliance to our RSPs;
5.Encourage Direct Suppliers to invite their value chain partners to join the Responsible Minerals Initiative (the “RMI”);
6.Require that, in relation to the Covered Products, our Direct Suppliers source only from smelters or refiners (SORs) that have been validated as “conflict free” by the RMI’s Responsible Minerals Assurance Process (RMAP), the London
1 “Covered products” are defined by the US SEC as those products that PMI manufactures or contracts to be manufactured that contain tin, tungsten, tantalum or gold.
2 “Conflict minerals” and “covered countries” are defined by Section 1502 of the US Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”)
Bullion Market Association (LBMA), the Responsible Jewelry Council (RJC), or a comparable program, and to undertake reasonable due diligence in their respective supply chains to assure the same;
7.Design and implement strategies to respond to conflict minerals risks identified;
8.Collaborate with customers, suppliers and industry associations such as the RMI to advance the agenda related to the responsible sourcing of minerals;
9.Report annually on PMI conflict minerals’ supply chain due diligence activities, following SEC’s rules on conflict minerals.
We require our Direct Suppliers to exercise reasonable due diligence on the source and chain of custody of minerals and metals from conflict-affected and high-risk areas, including the 3TGs, in accordance with the SEC’s rules on conflict minerals, the OECD Guidance, or any other nationally or internationally recognized supply chain due diligence standard of equivalent nature. We also expect our suppliers to perform reasonable due diligence for other materials that are, from time to time, identified by PMI as directly or indirectly contributing to violations of human rights, including risks identified in Annex II of the OECD guidance3, and/or climate change.
Recognizing the social and environmental impacts of cobalt, in addition, we also take reasonable measures to ensure that all smelters and refiners in our cobalt supply chain take part and actively engage in third party audit programs such as the RMAP from the RMI.
If these requirements are not met, PMI will proactively work with the supplier to further develop their capabilities in responsible mineral due diligence. PMI may terminate relationships with its suppliers that do not make efforts to comply with our policy.
As our company transforms, a key area of focus is our expanding electronics manufacturing supply base. The electronics supply chain is complex and dynamic, and comes with specific challenges, including the presence of conflict minerals and other minerals. In this respect, PMI recognizes the growing concerns related to a broad range of human rights and environmental issues across Conflict-Affected and High-Risk Areas (CAHRAs) globally. Through our continuous engagement with the RMI, we will expand our approach to the responsible sourcing of minerals and related due diligence practices to reflect the evolution of our business and advancing industry standards for responsible sourcing. We will also explore opportunities to expand our sourcing standards to a wider set of minerals beyond 3TGs.
The policy will be periodically reviewed and updated to reflect changes in regulations and leading practices.
3 Risks identified in OECD Annex II as associated with the extraction, transport or trade of minerals include, but are not limited to, forced labor and child labor.
Appendix B
List of SORs identified by our Direct Suppliers as part of the supply chain for Covered Products1
| | | | | | | | |
| Subject Mineral | Smelter or Refiner Name | Country Location of Smelter or Refiner |
| Gold | Bangalore Refinery | INDIA |
| Gold | Geib Refining Corporation* | UNITED STATES OF AMERICA |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. * | INDIA |
| Gold | Augmont Enterprises Private Limited* | INDIA |
| Gold | Sancus ZFS (L’Orfebre, SA) * | COLOMBIA |
| Gold | Gold by Gold Colombia* | COLOMBIA |
| Gold | Shandong Gold Smelting Co., Ltd. * | CHINA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. * | CHINA |
| Gold | Heraeus Metals Hong Kong Ltd. * | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. * | JAPAN |
| Gold | JX Nippon Mining & Metals Co., Ltd. * | JAPAN |
| Gold | LS MnM Inc. * | SOUTH KOREA |
| Gold | Metalor Technologies (Hong Kong) Ltd. * | CHINA |
| Gold | Metalor Technologies (Suzhou) Ltd. * | CHINA |
| Gold | Metalor Technologies S.A. * | SWITZERLAND |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. * | CHINA |
| Gold | Tanaka Kikinzoku Kogyo K.K. * | JAPAN |
| Gold | Western Australian Mint (T/a The Perth Mint) * | AUSTRALIA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
| Gold | Agosi AG* | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. * | JAPAN |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) * | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | BRAZIL |
| Gold | Argor-Heraeus S.A. * | SWITZERLAND |
| Gold | Asahi Pretec Corp. * | JAPAN |
| Gold | Asahi Refining Canada Ltd. * | CANADA |
| Gold | Asahi Refining USA Inc. * | UNITED STATES OF AMERICA |
| Gold | Asaka Riken Co., Ltd. * | JAPAN |
| Gold | Aurubis AG* | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) * | PHILIPPINES |
| Gold | Boliden Ronnskar* | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG* | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation* | CANADA |
| Gold | Chimet S.p.A. * | ITALY |
| Gold | Chugai Mining* | JAPAN |
| Gold | Dowa* | JAPAN |
| Gold | DSC (Do Sung Corporation) * | SOUTH KOREA |
| Gold | Eco-System Recycling Co., Ltd. East Plant* | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. North Plant* | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant* | JAPAN |
| Gold | Heimerle + Meule GmbH* | GERMANY |
| Gold | Heraeus Germany GmbH Co. KG* | GERMANY |
| | | | | | | | |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. * | CHINA |
| Gold | Istanbul Gold Refinery* | TURKEY |
| Gold | Italpreziosi* | ITALY |
| Gold | Japan Mint* | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. * | CHINA |
| Gold | Kazzinc* | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC* | UNITED STATES OF AMERICA |
| Gold | KGHM Polska Miedz Spolka Akcyjna* | POLAND |
| Gold | Kojima Chemicals Co., Ltd. * | JAPAN |
| Gold | Korea Zinc Co., Ltd. * | SOUTH KOREA |
| Gold | L'Orfebre S.A. * | ANDORRA |
| Gold | LT Metal Ltd. * | SOUTH KOREA |
| Gold | Materion* | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. * | JAPAN |
| Gold | Metal Concentrators SA (Pty) Ltd. * | SOUTH AFRICA |
| 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 | Mitsubishi Materials Corporation* | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. * | JAPAN |
| Gold | MKS PAMP SA* | SWITZERLAND |
| Gold | MMTC-PAMP India Pvt., Ltd. * | INDIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. * | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat* | UZBEKISTAN |
| Gold | NH Recytech Company* | SOUTH KOREA |
| Gold | Nihon Material Co., Ltd. * | JAPAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. * | JAPAN |
| Gold | Planta Recuperadora de Metales SpA* | CHILE |
| Gold | PT Aneka Tambang (Persero) Tbk* | INDONESIA |
| Gold | PX Precinox S.A. * | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. * | SOUTH AFRICA |
| Gold | REMONDIS PMR B.V. * | NETHERLANDS |
| Gold | Royal Canadian Mint* | CANADA |
| Gold | SAFINA A.S. * | CZECHIA |
| Gold | SEMPSA Joyeria Plateria S.A. * | SPAIN |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. * | CHINA |
| Gold | Solar Applied Materials Technology Corp. * | TAIWAN, REPUBLIC OF |
| Gold | Sumitomo Metal Mining Co., Ltd. * | JAPAN |
| Gold | SungEel HiMetal Co., Ltd. * | SOUTH KOREA |
| Gold | T.C.A S.p.A* | ITALY |
| Gold | Tokuriki Honten Co., Ltd. * | JAPAN |
| Gold | TOO Tau-Ken-Altyn* | KAZAKHSTAN |
| Gold | Torecom* | SOUTH KOREA |
| Gold | Umicore S.A. Business Unit Precious Metals Refining* | BELGIUM |
| | | | | | | | |
| Gold | United Precious Metal Refining, Inc. * | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. * | SWITZERLAND |
| Gold | WIELAND Edelmetalle GmbH* | GERMANY |
| Gold | Yamakin Co., Ltd. * | JAPAN |
| Gold | Yokohama Metal Co., Ltd. * | JAPAN |
| Gold | Abington Reldan Metals, LLC* | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company* | UNITED STATES OF AMERICA |
| Gold | Coimpa Industrial LTDA* | BRAZIL |
| Gold | WEEEREFINING* | FRANCE |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Samduck Precious Metals | SOUTH KOREA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, REPUBLIC OF |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | SAAMP | FRANCE |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Safimet S.p.A | ITALY |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Tantalum | Taike Technology (Suzhou) Co.,Ltd. * | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. * | CHINA |
| Tantalum | AMG Brasil* | BRAZIL |
| Tantalum | D Block Metals, LLC* | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. * | CHINA |
| Tantalum | FIR Metals & Resource Ltd. * | CHINA |
| Tantalum | Global Advanced Metals Aizu* | JAPAN |
| Tantalum | Global Advanced Metals Boyertown* | UNITED STATES OF AMERICA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. * | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material* | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. * | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. * | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. * | CHINA |
| Tantalum | KEMET de Mexico* | MEXICO |
| Tantalum | Materion Newton Inc. * | UNITED STATES OF AMERICA |
| Tantalum | Metallurgical Products India Pvt., Ltd. * | INDIA |
| Tantalum | Mineracao Taboca S.A. * | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. * | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. * | CHINA |
| Tantalum | NPM Silmet AS* | ESTONIA |
| Tantalum | QuantumClean* | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. * | BRAZIL |
| Tantalum | Taki Chemical Co., Ltd. * | JAPAN |
| Tantalum | TANIOBIS Co., Ltd. * | THAILAND |
| Tantalum | TANIOBIS GmbH* | GERMANY |
| | | | | | | | |
| Tantalum | TANIOBIS Japan Co., Ltd. * | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG* | GERMANY |
| Tantalum | Telex Metals* | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED* | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. * | CHINA |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. * | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. * | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. * | CHINA |
| Tantalum | PowerX Ltd. * | RWANDA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. * | CHINA |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. * | CHINA |
| Tantalum | Plansee SE Reutte* | AUSTRIA |
| Tantalum | RFH Recycling Metals Co., Ltd. * | CHINA |
| Tantalum | Jiujiang Janny New Material Co., Ltd. * | CHINA |
| Tantalum | V&D New Materials (Jiangsu) Co., Ltd. * | CHINA |
| Tantalum | XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD. * | CHINA |
| Tin | Dragon Silver Holdings Limited* | CHINA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. * | CHINA |
| Tin | DS Myanmar* | MYANMAR |
| Tin | Super Ligas* | BRAZIL |
| Tin | PT Bangka Prima Tin* | INDONESIA |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. * | CHINA |
| Tin | China Tin Group Co., Ltd. * | CHINA |
| Tin | Alpha* | UNITED STATES OF AMERICA |
| Tin | Aurubis Beerse* | BELGIUM |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. * | CHINA |
| Tin | Dowa* | JAPAN |
| Tin | EM Vinto* | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. * | BRAZIL |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. * | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) * | MALAYSIA |
| Tin | Mineracao Taboca S.A. * | BRAZIL |
| Tin | Minsur* | PERU |
| Tin | Mitsubishi Materials Corporation* | JAPAN |
| Tin | O.M. Manufacturing Philippines, Inc. * | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. * | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Babel Inti Perkasa* | INDONESIA |
| Tin | PT Bukit Timah* | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa* | INDONESIA |
| Tin | PT Timah Tbk Kundur* | INDONESIA |
| Tin | PT Timah Tbk Mentok* | INDONESIA |
| Tin | Rui Da Hung* | TAIWAN, REPUBLIC OF |
| | | | | | | | |
| Tin | Thaisarco* | THAILAND |
| Tin | Tin Technology & Refining* | UNITED STATES OF AMERICA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. * | CHINA |
| Tin | Aurubis Berango* | SPAIN |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. * | CHINA |
| Tin | CRM Synergies* | SPAIN |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. * | BRAZIL |
| Tin | Fenix Metals* | POLAND |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. * | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd. * | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. * | BRAZIL |
| Tin | Metallic Resources, Inc. * | UNITED STATES OF AMERICA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. * | THAILAND |
| Tin | PT Artha Cipta Langgeng* | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya* | INDONESIA |
| Tin | PT Babel Surya Alam Lestari* | INDONESIA |
| Tin | PT Bangka Serumpun* | INDONESIA |
| Tin | PT Cipta Persada Mulia* | INDONESIA |
| Tin | PT Menara Cipta Mulia* | INDONESIA |
| Tin | PT Mitra Stania Prima* | INDONESIA |
| Tin | PT Mitra Sukses Globalindo* | INDONESIA |
| Tin | PT Prima Timah Utama* | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS) * | INDONESIA |
| Tin | PT Refined Bangka Tin* | INDONESIA |
| Tin | PT Sariwiguna Binasentosa* | INDONESIA |
| Tin | PT Stanindo Inti Perkasa* | INDONESIA |
| Tin | PT Sukses Inti Makmur (SIM) * | INDONESIA |
| Tin | PT Timah Nusantara* | INDONESIA |
| Tin | PT Tinindo Inter Nusa* | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. * | BRAZIL |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda* | BRAZIL |
| Tin | HuiChang Hill Tin Industry Co., Ltd. * | CHINA |
| Tin | CV Ayi Jaya* | INDONESIA |
| Tin | CV Venus Inti Perkasa* | INDONESIA |
| Tin | PT Aries Kencana Sejahtera* | INDONESIA |
| Tin | PT Tommy Utama* | INDONESIA |
| Tin | PT Rajehan Ariq* | INDONESIA |
| Tin | PT Premium Tin Indonesia* | INDONESIA |
| Tin | Luna Smelter, Ltd. * | RWANDA |
| Tin | White Solder Metalurgia e Mineracao Ltda. * | BRAZIL |
| Tin | PT Belitung Industri Sejahtera* | INDONESIA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | Soft Metais Ltda. * | BRAZIL |
| Tin | VQB Mineral and Trading Group JSC | VIETNAM |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| | | | | | | | |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
| Tin | Pongpipat Company Limited | MYANMAR |
| Tin | Feinhutte Halsbrucke GmbH* | GERMANY |
| Tin | Precious Minerals and Smelting Limited* | INDIA |
| Tin | TRATHO Metal Quimica* | BRAZIL |
| Tin | Rian Resources SDN. BHD. * | MALAYSIA |
| Tin | Mining Minerals Resources SARL* | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. * | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. * | CHINA |
| Tungsten | Japan New Metals Co., Ltd. * | JAPAN |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. * | CHINA |
| Tungsten | Kennametal Huntsville* | UNITED STATES OF AMERICA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. * | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. * | CHINA |
| Tungsten | A.L.M.T. Corp. * | JAPAN |
| Tungsten | Asia Tungsten Products Vietnam Ltd. * | VIETNAM |
| Tungsten | China Molybdenum Tungsten Co., Ltd. * | CHINA |
| Tungsten | Cronimet Brasil Ltda* | BRAZIL |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. * | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. * | CHINA |
| Tungsten | Global Tungsten & Powders LLC* | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. * | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH* | GERMANY |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. * | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch* | CHINA |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. * | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. * | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. * | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. * | CHINA |
| Tungsten | Kennametal Fallon* | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd. * | TAIWAN, REPUBLIC OF |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. * | CHINA |
| Tungsten | Masan High-Tech Materials* | VIETNAM |
| Tungsten | Niagara Refining LLC* | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. * | PHILIPPINES |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG* | GERMANY |
| Tungsten | Wolfram Bergbau und Hutten AG* | AUSTRIA |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. * | CHINA |
| Tungsten | Hubei Green Tungsten Co., Ltd. * | CHINA |
| Tungsten | Tungsten Vietnam Joint Stock Company* | VIETNAM |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA |
| Tungsten | ACL Metais Eireli | BRAZIL |
| | | | | | | | |
| Tungsten | Avon Specialty Metals Ltd* | UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND |
| Tungsten | Ganzhou Sunny Non-Ferrous Metals Co., Ltd. * | CHINA |
_____________________
1 SORs that were designated, to our knowledge, as Compliant or Active as of December 31, 2023 are marked with an asterisk.
