Alphabet Inc.
Conflict Minerals Report
For The Year Ended December 31, 2023
This Conflict Minerals Report for the year ended December 31, 2023 (this “CMR”) is presented
to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”),
which requires certain reporting and disclosure related to conflict minerals. Conflict minerals are
currently defined as cassiterite, columbite-tantalite, wolframite, gold, or their derivatives, which
are limited to tin, tantalum, tungsten, and gold (“3TG”)1 for the purpose of this assessment.
These requirements apply to registrants whatever the geographic origin of their conflict minerals
and whether or not their conflict minerals fund armed conflict. Please refer to the Rule, Form
SD, and SEC Release No. 34-67716 for definitions to the terms used in this CMR, unlessotherwise defined herein.
Statements in this CMR are based on our due diligence activities performed in good faith for thecalendar year 2023 and are based on information available at the time of this filing, unlessotherwise indicated. Factors that could affect the accuracy of these statements include, but are
not limited to, incomplete supplier data or available smelter and/or refiner (collectively referred toas “smelter(s)”) data, errors or omissions by suppliers or smelters, ongoing certifications of
smelters, continued guidance or amendments to the Rule, and other issues. Additionally, thisCMR may contain forward-looking statements that reflect what we strive to achieve in the future
as we continue to improve our responsible sourcing program. These forward-looking statements
are based on current expectations and assumptions that are subject to risks and uncertainties.
References to our websites and information available through these websites are notincorporated into this CMR.
Throughout this CMR, we use “Alphabet,” “we,” “our,” “us” and similar terms to refer to Alphabet
Inc. and its subsidiaries (collectively, “Alphabet”), unless otherwise indicated, and use “Google”
to refer to Google LLC, a wholly owned subsidiary of Alphabet.
1. Overview(A) Company
Alphabet is a collection of businesses — the largest of which is Google — which we report as
two segments: Google Services and Google Cloud; we also report all non-Google businesses
collectively as Other Bets. Alphabet’s structure is about helping each of our businesses prosper
through strong leaders and independence.

1

The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform andConsumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from whichtantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metalore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives
determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of theCongo or an adjoining country.

1Our Google Services and Google Cloud segments together represented approximately 99% of
our consolidated revenues in 2023. Our Google Services segment generates revenues primarily
by delivering both performance advertising and brand advertising. In addition, Google Services
increasingly generates revenues from products and services beyond advertising, including (i)consumer subscriptions, which primarily include revenues from YouTube services, such as
YouTube TV, YouTube Music and Premium; (ii) platforms, which primarily include revenues from
Google Play from the sales of apps and in-app purchases; and (iii) devices, which primarily
include sales of the Pixel family of devices. Our Google Cloud segment generates revenues
primarily from consumption-based fees and subscriptions for infrastructure, platform,
collaboration tools and other cloud services. Our Other Bets are emerging businesses at various
stages of development, ranging from those in the research and development phase to thosethat are in the beginning stages of commercialization, and our goal is for them to become
thriving, successful businesses.
(B) In-Scope Products
Products assessed for the scoping of the CMR included tangible products that enter the streamof commerce as defined by the Rule. The hardware products considered in scope for this CMR
pertain to consumer-facing devices such as healthcare technology, home devices, phones,
wearable devices, streaming devices, tablets, video cameras, and, more specifically, thecomponents of the hardware, such as circuit boards, chips, capacitors, alloys, motor
components, and wires.
(C) Supply Chain
Our supply chain consists of a broad range of suppliers and several manufacturing models.
Other companies manufacture the hardware components, such as those described in 1(B), on
our behalf. Whether we are working with Original Equipment Manufacturers or more closely withthe product design, we do not directly purchase raw materials and are several tiers away fromthe smelter and country of origin of the 3TG used in our products. In addition, many of the
suppliers we work with are not directly subject to the Rule and its corresponding requirements.
To influence activities through multiple tiers of the supply chain, we actively engage with avariety of industry members, including the Responsible Minerals Initiative (the “RMI”). Our
engagement with RMI includes using tools such as the Conflict Minerals Reporting Template(the “CMRT”), Extended Minerals Reporting Template (the “EMRT”) for select suppliers, andparticipating in numerous workgroups and activities that support the RMI’s efforts, including the
Responsible Minerals Assurance Process (the “RMAP”).
(D) Conflict Minerals Policy
We believe it is essential to establish validated conflict-free sources of 3TG within the
Democratic Republic of the Congo (the “DRC”) and adjoining countries (together, with the DRC,
the “Covered Countries”), so that these minerals can be procured in a way that contributes toeconomic growth and development in the region. To aid in this effort, we have established a2

conflict minerals policy and an internal team to implement the policy. Our conflict minerals policy
is accessible on our website at https://abc.xyz/investor/conflictminerals/. We expect our
suppliers to assure the 3TG in our products are sourced from conformant conflict-free smelters,such as those audited through the RMI’s RMAP (http://www.responsiblemineralsinitiative.org),
the London Bullion Market Association (LBMA) or the Responsible Jewellery Council (RJC),
each of whom perform due diligence on the source and chain of custody of the 3TG used in our
products and provide their due diligence measures to us upon request. The due diligencestandards of the aforementioned organizations all meet the OECD Due Diligence Standard,
which is discussed further below.
2. Reasonable Country of Origin Inquiry
To identify which of our suppliers to survey regarding the source of the 3TG used in our
products, we inventoried our products to determine which products were either manufactured orcontracted for manufacture by us between January 1, 2023 and December 31, 2023, and if they
were intended to enter the stream of commerce. For all products in scope, we identified andcompiled a list of our suppliers (our “in-scope suppliers”) from whom we requested information
regarding their sourcing of 3TG.
We requested that such identified in-scope suppliers provide us with information regarding their
supply chain using the CMRT from the RMI. We also followed up with our own
company-developed tools and templates to review CMRT completeness, ensure at least a baseminimum of response across all respondents, and identify potential inconsistencies. The CMRT
included questions about location or mine of origin of the 3TG in the products, and requested
in-scope suppliers to make similar efforts to survey their supply chains and report the smelters
and location or mine of origin of necessary 3TG. We reviewed and monitored responses from
our in-scope suppliers and followed up if we identified information to be incomplete orinconsistent with the information we would expect from the supplier. Our follow-up actions
included the following:
●
●

●

●

If an in-scope supplier did not respond, we initiated a supplier escalation process until a
response was received.
If an in-scope supplier had inconsistent or incomplete information, we contacted the
supplier and requested updated information, provided additional training resources, andreaffirmed our applicable supplier codes of conduct and conflict minerals policy
expectations.
We worked with suppliers to improve their responses and commitment to conflict-freesourcing at both company and product levels and sourcing from RMAP conformant
smelters.
We also encouraged suppliers to join industry collaborations to further support
conflict-free sourcing.

We received a 100% response rate from our in-scope suppliers who provided data to us ateither the company or product level. In-scope suppliers are continuously gathering information3

from their suppliers and we continue to work with them to ensure that suppliers are fully
represented.
Some in-scope supplier responses indicated that some smelters used by them at various levelsof our supply chain obtain 3TG from the Covered Countries. Some in-scope supplier responses
also indicated sourcing 3TG from outside of the Covered Countries, from recycled or scrap
sources, and/or from unknown origins. Based on the results of our supply chain survey and thenature of our supply chain as described in Section 1(C) above, we were unable to verify withcertainty the source and chain of custody of all of the 3TG used by our suppliers and in our
products. We completed due diligence on all smelters reported in our supply chain as describedin Section 3 below.
3. Due Diligence
Our due diligence measures were designed to conform in all material respects to the five step
framework set forth in the Organisation for Economic Co-operation and Development (“OECD”)
Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected andHigh-Risk Areas, Third Edition, 2016 (“OECD Guidance”).
Below is a description of our due diligence activities performed for the 2023 reporting year as
they relate to the five-step framework set forth in the OECD Guidance.
OECD Step 1 - Establish strong company management systems● Our conflict minerals policy described in Section 1(D) is publicly available on our Investor
Relations website.
● Our governance structure includes senior management from our in-scope supply chains,
legal and finance organizations who are responsible for monitoring our due diligence
activities. Oversight of the program consists of our CFO, Chief Compliance Officer, andvice presidents from supply chain and business operations, finance, and legal.
● We include responsible sourcing and due diligence requirements in our applicablesupplier codes of conduct and in supplier contract templates. Our suppliers are expected
to source from conflict-free sources, and utilize the CMRT to disclose sourcing
information about the 3TG in their products. We provide additional templates forfollow-up, training and resources to our suppliers on our requirements.
● Our product areas utilize a system that includes online platforms for storing andmanaging our conflict minerals due diligence activities, communications, and results.
● We have a document retention policy for maintaining conflict minerals program
documentation for a minimum of five years.
● We have a grievance mechanism for reporting violations of our policies.
OECD Step 2 - Identify and assess risk in the supply chain● We requested that our in-scope suppliers provide a CMRT to collect information about
the smelters of 3TG used in our products.

4

●

●
●
●

●

●
●

We assessed the CMRTs received from our in-scope suppliers for completeness, andreasonableness based on OECD Guidance for Conflict and High Risk Areas (CAHRAs)
globally, including the Covered Countries.
We validated each smelter disclosed by our in-scope suppliers by checking against thesmelter data provided by the RMI.
We provided conflict minerals feedback as needed to in-scope suppliers that wereaudited by our internal Supplier Responsibility audit program.
For the seventh consecutive year, we utilized an independent third party to provide anassessment of 100% of the smelters disclosed by our in-scope suppliers, to track data,
and to identify risks in smelters that have not yet undergone the RMAP. This prompted
additional direct follow-up with smelters and suppliers.
We communicated with in-scope suppliers that reported smelters which were not yet
identified as RMAP conformant. We worked with in-scope suppliers to improve thecompleteness and accuracy of their responses and fostered their ongoing commitment
to conflict-free minerals at both company and product levels. We also encouraged all
suppliers to join industry collaborations.
We developed a plan, for in-scope suppliers not sourcing exclusively from conformant
smelters for products, to bring those smelters into conformance.
We worked with our in-scope suppliers and reviewed the CMRT responses they received
from their suppliers. This process helped inform our direct suppliers on how to identify
risks in the information they receive from their suppliers. As part of this process, we also
encouraged suppliers to source from RMAP conformant smelters in the DRC and other
CAHRAs.

OECD Step 3 - Design and implement a strategy to respond to identified risks
Program Governance:● We created a list of suppliers for in-scope product areas that are in conformance with our
Supplier Code of Conduct, and we use this list to guide our supplier selections andcontinuing business with known conflict-free sourcing suppliers.
● We provided updates to our Supplier Responsibility team, Supplier Responsibility
Steering Committee, and Audit and Compliance Committee on our due diligence
activities and CMR.
Supplier Due Diligence and Industry Engagement:● We reviewed allegations and incidents in the supply chain and worked with suppliers andindustry stakeholders to improve responsible sourcing outcomes. One way we do this isby encouraging suppliers to adopt responsible sourcing policies and practices instead ofbanning all minerals from the DRC and Covered Countries, which negatively impacts
communities that depend on mining.
● We also contributed to the RMI upstream due diligence fund and conducted due
diligence on smelters in the DRC and Covered Countries through direct outreach as partof the RMI Smelter Engagement Team Working Group. We emphasized the importanceof RMAP conformance when we engaged with smelters that were not yet conformant or
active.

5Economic and Energy Sustainability:● Diversifying economies, investing in sustainable development, and providing foralternative livelihoods are important components of any strategy to promote responsible
mining. Thus, we contributed funding to the Public-Private Alliance for Responsible
Minerals Trade (PPA), which signed a renewed 2023 Memorandum of Understandingthat extended Google’s partnership for five more years. PPA also broadened its scope tofocus on global transition minerals beyond 3TG within and outside of the Great Lakes
Region of Africa in order to respond to global minerals demand.
● As planned, we transitioned ownership of Congo Power projects to the PPA, and wehelped formalize and centralize a partnership with the PPA and other donors to continue
these energy sustainability efforts.2 For example, this work provided two solar energy
installations for the Good Shepherd International Foundation (also known as Bon
Pasteur), which works directly with mining communities to address human rights abuses.
The Foundation specifically focuses on breaking the cycle of abuse against children,
women, and girls. The last step of installation was completed in early 2024.
● Separate from Congo Power, we also began scoping a solar installation that will provide
renewable energy to a Fair Cobalt Alliance partner organization. This is expected to be
deployed in mid-2024 and is a continuation of our work on advancing energy resources
and alternative livelihoods.
OECD Step 4 - Carry out independent third-party audits of supply chain due diligence at
identified points in the supply chain● We joined the RMI in 2013 (member ID: GOOG), and we continue to be a member.
● We relied upon the RMI to validate that companies meet the criteria of a smelter, andthen verify that they conform to the RMAP.
● We worked with a third party to provide an assessment of smelters not participating in
RMI to give Alphabet visibility on all smelters identified in supplier outreach.
● We conducted supplier responsibility audits with independent third parties on a portion of
our suppliers with a risk-based approach, which included reviewing their conflict minerals
programs.
● We continued activities to supplement the RMAP process and audits such as direct
inquiries, communications, and development of industry tools to support audit programs
and reporting mechanisms. This allowed us to better understand issues smelters face inthe compliance process and how we can best align to support management systems
used for compliance and in-region due diligence.

Congo Power is an effort we began in 2017 to provide energy resources, alternative
opportunities for livelihoods, and increased economic stability to communities committed toresponsible sourcing. The newly developed partnership group expects to initiate a slate of
grants in the second half of 2024, which are intended to grow Congo Power’s scope and impact
through updating grantee evaluation criteria and expanding current objectives. Current
objectives primarily focus on developing renewable electricity, but they will expand to include
additional social objectives, such as gender equity.
2

6

●

We continued our communication with civil society and NGOs with staff operating on the
ground during the 2023 cycle. These communications helped us to better understandrisks and opportunities, such as enhancing responsible supply chains.

OECD Step 5 - Report annually on supply chain due diligence● We publish a CMR annually, and our reports are accessible on our Investor Relations
website at https://abc.xyz/investor/conflictminerals/.
● We published our 2023 Supplier Responsibility Report, which also included an update on
our conflict minerals program and industry collaborations(https://sustainability.google/reports/).
4. Due Diligence Results
Smelter Disclosure
Based on our due diligence of the information provided by our in-scope suppliers for the 2023
reporting period, we have reason to believe that a portion of the 3TG used in our products
originated from the Covered Countries. In some instances, information provided by our in-scope
suppliers was unverifiable or incomplete and, as such, we are not declaring any of our products
to be “DRC Conflict Free” since we were unable to verify with certainty the source and chain ofcustody of all of the necessary 3TG in our products. Based on the due diligence performed, oursuppliers identified 302 unique smelters and we evaluated each of them based on third party
audits and/or assessments; 224 are considered “conformant” and 5 are considered “active” on
the RMI website. Based on our third party assessment and RCOI, we identified an additional 70
smelters as not sourcing from the Covered Countries (or have no reason to believe they aresourcing from the Covered Countries) bringing the total number of smelters identified as“conformant”, “active” or not sourcing from the DRC to 299 (99%). As for the 3 remaining
smelters, the RMI statuses were updated to “Non Conformant” in Q4 2023 for 2 of them andearly 2024 for the remaining 1. Our suppliers have communicated a need for further time torectify the use of these non-conformant smelters, and we are currently engaging with them andsupporting their efforts to do so.
The results of our due diligence on the 3TG used in our in-scope products are noted below:
2023 Smelters

Tin

Tungsten

Tantalum

Gold

Total

Total number of smelters

85

38

36

143

302

Number (%) of smelters listed as“conformant” by RMI

68 (80%)32 (84%)35 (97%)89 (62%)224 (74%)

Number (%) of smelters listed as “active”
by RMI

2 (2%)

0 (0%)

1 (3%)

2 (1%)

5 (2%)

7

Number (%) of smelters confirmed by anindependent third party to not be sourcing
from the Covered Countries

15 (18%)6 (16%)

Number (%) of smelters that are
conformant, active, or not sourced fromthe Covered Countries
85 (100%) 38 (100%)0 (0%)

49 (34%)70 (23%)36 (100%)

140 (98%)

299 (99%)

Efforts to Determine Mine or Location of Origin
As part of our due diligence process described in Section 3 of this report, we worked to ensurethat our efforts to identify mines and the countries of origin of the 3TG in our products have beenreasonable and aligned with industry practices through our support of processes and tools
developed by the RMI.
5. Continuous Improvement in Understanding Source of Material
We recognize that efforts to reduce violence associated with conflict minerals are ongoing andare required to continually adapt to changing situations. We are committed to reviewing ourcompliance processes and actively engaging upstream directly in-region for opportunities toimprove our processes.
We include more detail on our policies and our results in our Supplier Responsibility Report,
including work in other minerals and materials and in other regions that are not in scope of theRules.
We will continue to review our compliance processes including, but not limited to, taking thefollowing steps for the 2024 reporting year:● We will continue to engage with in-scope suppliers to gain better visibility of the countryof origin and chain of custody of the 3TG used in our in-scope products.
● We will use and encourage our in-scope suppliers to use publicly available tools from theRMI.
● We will continue to work with our in-scope suppliers and engage with our supply chain to
increase the quality of the data provided to us.
● We will continue to be a member of the RMI, and contribute to the various initiatives andworking groups, as described above.
● We will continue to encourage our in-scope suppliers to source from conflict-freesmelters that are listed as conformant by the RMI.
● As we enter into contracts with new suppliers and renew contracts with existing
suppliers, we will continue to include requirements that our suppliers support our conflictminerals policy and due diligence efforts.

8●

We will continue to explore additional opportunities to support livelihoods and health,improve conservation outcomes, improve stability, and support renewable energy
projects to enhance conflict-free mining communities.

9Appendix I: Smelter List
Metal

Smelter Name

Smelter Location Country

Gold

Advanced Chemical
Company

UNITED STATES OF
AMERICAGold

Aida Chemical Industries
Co., Ltd.

JAPAN

Gold

Agosi AGGERMANYGold

Almalyk Mining andMetallurgical Complex(AMMC)UZBEKISTAN

Gold

AngloGold Ashanti Corrego
do Sitio Mineracao
BRAZILGold

Argor-Heraeus S.A.

SWITZERLAND

Gold

Asahi Pretec Corp.

JAPAN

Gold

Asaka Riken Co., Ltd.

JAPAN

Gold

Atasay Kuyumculuk Sanayi
Ve Ticaret A.S.

TURKEYGold

Aurubis AG

GERMANYGold

Bangko Sentral ng Pilipinas(Central Bank of thePhilippines)
PHILIPPINES

Gold

Boliden Ronnskar

SWEDENGold

C. Hafner GmbH + Co. KG

GERMANYGold

Caridad

MEXICOGold

CCR Refinery - Glencore
Canada Corporation

CANADAGold

Cendres + Metaux S.A.

SWITZERLAND

Gold

Yunnan Copper Industry Co.,
Ltd.
CHINA

Gold

Chimet S.p.A.

ITALY

Gold

Chugai Mining

JAPAN

Gold

DSC (Do Sung Corporation) KOREA, REPUBLIC OF

Gold

Dowa

JAPAN

Gold

Eco-System Recycling Co.,
Ltd. East Plant

JAPAN
10

Gold

Refinery of Seemine Gold
Co., Ltd.

Gold

Guoda Safina High-TechEnvironmental Refinery Co.,
Ltd.
CHINA

Gold

Hangzhou Fuchunjiang
Smelting Co., Ltd.

CHINA

Gold

LT Metal Ltd.

KOREA, REPUBLIC OFGoldHeimerle + Meule GmbHGERMANYGold

Heraeus Metals Hong Kong
Ltd.
CHINA

Gold

Heraeus Germany GmbH
Co. KGGERMANYGold

Hunan Chenzhou Mining
Co., Ltd.

CHINA

Gold

Hunan Guiyang yinxing
Nonferrous Smelting Co.,
Ltd.

CHINA

Gold

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

Gold

Inner Mongolia Qiankun
Gold and Silver Refinery
Share Co., Ltd.

CHINA

Gold

Ishifuku Metal Industry Co.,
Ltd.
JAPAN

Gold

Istanbul Gold Refinery

TURKEY

Gold

Japan Mint

JAPAN

Gold

Jiangxi Copper Co., Ltd.

CHINA

Gold

Asahi Refining USA Inc.

UNITED STATES OF
AMERICAGold

Asahi Refining Canada Ltd.

CANADAGold

JX Nippon Mining & Metals
Co., Ltd.
JAPAN

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

Gold

Kazzinc

KAZAKHSTANGoldUNITED STATES OF
Kennecott Utah Copper LLC AMERICA

CHINA

11

Gold

Kojima Chemicals Co., Ltd.

JAPAN

Gold

Kyrgyzaltyn JSC

KYRGYZSTANGold

L'azurde Company For
Jewelry

SAUDI ARABIAGold

Lingbao Jinyuan Tonghui
Refinery Co., Ltd.

CHINA

Gold

LS MnM Inc.

KOREA, REPUBLIC OFGold

Materion

UNITED STATES OF
AMERICAGold

Matsuda Sangyo Co., Ltd.

JAPAN

Gold

Metalor Technologies(Suzhou) Ltd.

CHINA

Gold

Metalor Technologies (HongKong) Ltd.
CHINA

Gold

Metalor Technologies(Singapore) Pte., Ltd.

SINGAPOREGold

Metalor Technologies S.A.

SWITZERLAND

Gold

Metalor USA Refining
Corporation

UNITED STATES OF
AMERICAGold

Metalurgica Met-Mex
Penoles S.A. De C.V.

MEXICOGold

Mitsubishi Materials
Corporation

JAPAN

Gold

Mitsui Mining and Smelting
Co., Ltd.
JAPAN

Gold

Nadir Metal Rafineri San. Ve
Tic. A.S.
TURKEYGold

Navoi Mining andMetallurgical Combinat

UZBEKISTANGold

Nihon Material Co., Ltd.

JAPAN

Gold

Ohura Precious Metal
Industry Co., Ltd.

JAPAN

Gold

MKS PAMP SA

SWITZERLAND

Gold

Penglai Penggang Gold
Industry Co., Ltd.

CHINA

Gold

PT Aneka Tambang

INDONESIA

12

(Persero) Tbk
Gold

PX Precinox S.A.

SWITZERLAND

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Gold

Royal Canadian Mint

CANADAGold

Sabin Metal Corp.

UNITED STATES OF
AMERICAGold

Samduck Precious Metals

KOREA, REPUBLIC OFGold

Samwon Metals Corp.

KOREA, REPUBLIC OFGold

SEMPSA Joyeria Plateria
S.A.

SPAIN

Gold

Shandong Tiancheng
Biological Gold IndustrialCo., Ltd.

CHINA

Gold

Shandong Zhaojin Gold &Silver Refinery Co., Ltd.

CHINA

Gold

Sichuan Tianze Precious
Metals Co., Ltd.

CHINA

Gold

Solar Applied Materials
Technology Corp.

TAIWAN, PROVINCE OF
CHINA

Gold

Sumitomo Metal Mining Co.,
Ltd.
JAPAN

Gold

Super Dragon Technology
Co., Ltd.

TAIWAN, PROVINCE OF
CHINA

Gold

Tanaka Kikinzoku Kogyo
K.K.

JAPAN

Gold

Great Wall Precious Metals
Co., Ltd. of CBPM

CHINA

Gold

Shandong Gold Smelting
Co., Ltd.

CHINA

Gold

Tokuriki Honten Co., Ltd.

JAPAN

Gold

Tongling Nonferrous Metals
Group Co., Ltd.
CHINA

Gold

TorecomGold

Umicore S.A. Business Unit
Precious Metals Refining
BELGIUM

Gold

United Precious Metal

KOREA, REPUBLIC OF

UNITED STATES OF

13

Refining, Inc.

AMERICAGold

Valcambi S.A.

SWITZERLAND

Gold

Western Australian Mint
(T/a The Perth Mint)

AUSTRALIAGold

Yamakin Co., Ltd.

JAPAN

Gold

Yokohama Metal Co., Ltd.

JAPAN

Gold

Zhongyuan Gold Smelter ofZhongjin Gold Corporation CHINA

Gold

Gold Refinery of Zijin Mining
Group Co., Ltd.
CHINA

Gold

Morris and Watson

NEW ZEALANDGold

SAFINA A.S.

CZECHIAGold

Guangdong Jinding Gold
Limited

CHINA

Gold

Umicore Precious Metals
Thailand

THAILANDGold

MMTC-PAMP India Pvt., Ltd. INDIAGold

KGHM Polska Miedz Spolka
Akcyjna
POLANDGold

Singway Technology Co.,
Ltd.

Gold

Shandong Humon Smelting
Co., Ltd.
CHINA

Gold

Shenzhen Zhonghenglong
Real Industry Co., Ltd.

CHINA

Gold

Al Etihad Gold Refinery
DMCC

UNITED ARAB EMIRATESGoldEmirates Gold DMCC

UNITED ARAB EMIRATESGold

T.C.A S.p.A

ITALY

Gold

REMONDIS PMR B.V.

NETHERLANDS

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OFGoldTOO Tau-Ken-Altyn

KAZAKHSTAN

Gold

Abington Reldan Metals,
LLC

UNITED STATES OF
AMERICA

Gold

SAAMP

FRANCETAIWAN, PROVINCE OF
CHINA

14

Gold

L'Orfebre S.A.

ANDORRAGold

8853 S.p.A.

ITALY

Gold

Italpreziosi

ITALY

Gold

WIELAND Edelmetalle
GmbH

GERMANYGold

Ogussa Osterreichische
Gold- undSilber-Scheideanstalt GmbH AUSTRIAGoldAU Traders and RefinersGold

GGC Gujrat Gold Centre Pvt.
Ltd.
INDIA

Gold

Sai Refinery

INDIA

Gold

Modeltech Sdn Bhd

MALAYSIAGold

Bangalore Refinery

INDIA

Gold

Degussa Sonne / Mond
Goldhandel GmbHGERMANYGold

Pease & Curren

UNITED STATES OF
AMERICAGold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OFGold

Planta Recuperadora deMetales SpA

CHILE

Gold

Safimet S.p.A

ITALY

Gold

State Research InstituteCenter for PhysicalSciences and Technology

LITHUANIAGoldNH Recytech Company

KOREA, REPUBLIC OFGold

QG Refining, LLC

UNITED STATES OF
AMERICAGold

CGR Metalloys Pvt Ltd.

INDIA

Gold

Sovereign Metals

INDIA

Gold

Eco-System Recycling Co.,
Ltd. North Plant

JAPAN

Gold

Eco-System Recycling Co.,
Ltd. West Plant

JAPAN

Gold

Augmont Enterprises
Private Limited

INDIA

SOUTH AFRICA

15

Gold

Emerald Jewel Industry
India Limited (Unit 1)

INDIA

Gold

Emerald Jewel Industry
India Limited (Unit 2)

INDIA

Gold

Emerald Jewel Industry
India Limited (Unit 3)

INDIA

Gold

Emerald Jewel Industry
India Limited (Unit 4)

INDIA

Gold

K.A. Rasmussen

NORWAYGold

Alexy Metals

UNITED STATES OF
AMERICAGoldMD Overseas

INDIA

Gold

Metallix Refining Inc.

UNITED STATES OF
AMERICAGold

Metal Concentrators SA(Pty) Ltd.

SOUTH AFRICAGold

WEEEREFININGFRANCE

Gold

Gold by Gold Colombia

COLOMBIA

Tantalum

Changsha South Tantalum
Niobium Co., Ltd.

CHINA

Tantalum

Guangdong Rising Rare
Metals-EO Materials Ltd.

CHINA

Tantalum

F&X Electro-Materials Ltd.

CHINA

Tantalum

XIMEI RESOURCES(GUANGDONG) LIMITEDCHINA

Tantalum

JiuJiang JinXin Nonferrous
Metals Co., Ltd.
CHINA

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

Tantalum

AMG Brasil

BRAZIL

Tantalum

Metallurgical Products India
Pvt., Ltd.
INDIA

Tantalum

Mineracao Taboca S.A.

Tantalum

Mitsui Mining and Smelting
Co., Ltd.
JAPAN

Tantalum

NPM Silmet AS

ESTONIA

Tantalum

Ningxia Orient Tantalum

CHINA

BRAZIL

16

Industry Co., Ltd.
Tantalum

QuantumClean

UNITED STATES OF
AMERICA

Tantalum

Yanling Jincheng Tantalum& Niobium Co., Ltd.

CHINA

Tantalum

Taki Chemical Co., Ltd.

JAPAN

Tantalum

Telex Metals

UNITED STATES OF
AMERICA

Tantalum

Ulba Metallurgical Plant JSC KAZAKHSTAN

Tantalum

Hengyang King Xing Lifeng
New Materials Co., Ltd.

CHINA

Tantalum

D Block Metals, LLC

UNITED STATES OF
AMERICA

Tantalum

FIR Metals & Resource Ltd.

CHINA

Tantalum

Jiujiang Zhongao Tantalum& Niobium Co., Ltd.
CHINA

Tantalum

XinXing HaoRong Electronic
Material Co., Ltd.
CHINA

Tantalum

Jiangxi Dinghai Tantalum &Niobium Co., Ltd.
CHINA

Tantalum

KEMET de Mexico

MEXICO

Tantalum

TANIOBIS Co., Ltd.

THAILAND

Tantalum

TANIOBIS GmbHGERMANY

Tantalum

QSIL Metals Hermsdorf
GmbH

GERMANY

Tantalum

Materion Newton Inc.

UNITED STATES OF
AMERICA

Tantalum

TANIOBIS Japan Co., Ltd.

JAPAN

Tantalum

TANIOBIS Smelting GmbH &Co. KGGERMANY

Tantalum

Global Advanced Metals
Boyertown

UNITED STATES OF
AMERICA

Tantalum

Global Advanced Metals
Aizu

JAPAN

TantalumResind Industria e Comercio
Ltda.
BRAZIL17

Tantalum

Jiangxi Tuohong New Raw
Material

CHINA

Tantalum

RFH Yancheng Jinye New
Material Technology Co.,
Ltd.

CHINA

Tantalum

PowerX Ltd.

RWANDA

Tin

Chenzhou Yunxiang Mining
and Metallurgy Co., Ltd.
CHINAUNITED STATES OF
AMERICA

Tin

Alpha

Tin

PT Aries Kencana Sejahtera INDONESIA

Tin

PT Premium Tin Indonesia

INDONESIA

Tin

Dowa

JAPAN

Tin

EM Vinto

BOLIVIA (PLURINATIONAL
STATE OF)Tin

Estanho de Rondonia S.A.

BRAZILTin

Fenix Metals

POLANDTin

Gejiu Non-Ferrous Metal
Processing Co., Ltd.

CHINA

Tin

Gejiu Zili Mining And
Metallurgy Co., Ltd.

CHINA

Tin

Gejiu Kai Meng Industry andTrade LLC
CHINA

Tin

China Tin Group Co., Ltd.

CHINA

Tin

Malaysia Smelting
Corporation (MSC)

MALAYSIA

Tin

Metallic Resources, Inc.

UNITED STATES OF
AMERICA

Tin

Mineracao Taboca S.A.

BRAZILTin

MinsurPERU

Tin

Mitsubishi Materials
Corporation

JAPAN

Tin

Jiangxi New Nanshan
Technology Ltd.

CHINA

Tin

O.M. Manufacturing(Thailand) Co., Ltd.

THAILAND

18

Tin

Operaciones Metalurgicas
S.A.

BOLIVIA (PLURINATIONAL
STATE OF)Tin

PT Artha Cipta Langgeng

INDONESIATin

PT Babel Inti Perkasa

INDONESIATin

PT Babel Surya Alam Lestari INDONESIA

Tin

PT Bangka Tin Industry

INDONESIA

Tin

PT Belitung Industri
Sejahtera

INDONESIATin

PT Bukit Timah

INDONESIATin

PT Mitra Stania Prima

INDONESIATin

PT Panca Mega Persada

INDONESIATin

PT Prima Timah Utama

INDONESIATin

PT Refined Bangka Tin

INDONESIATin

PT Sariwiguna Binasentosa INDONESIA

Tin

PT Stanindo Inti Perkasa

INDONESIATin

PT Timah Tbk Kundur

INDONESIATin

PT Timah Tbk Mentok

INDONESIATin

PT Timah Nusantara

INDONESIATin

PT Tinindo Inter Nusa

INDONESIATin

PT Tommy Utama

INDONESIATin

Rui Da Hung

TAIWAN, PROVINCE OF
CHINA

Tin

Soft Metais Ltda.

BRAZILTin

Thaisarco

THAILANDTin

Gejiu Yunxin Nonferrous
Electrolysis Co., Ltd.

CHINA

Tin

VQB Mineral and TradingGroup JSCVIET NAM

Tin

White Solder Metalurgia e
Mineracao Ltda.

BRAZILTin

Yunnan Chengfeng
Non-ferrous Metals Co., Ltd. CHINA

Tin

Tin Smelting Branch of
Yunnan Tin Co., Ltd.

CHINA

Tin

CV Venus Inti Perkasa

INDONESIA
19

Tin

Magnu's Minerais Metais e
Ligas Ltda.

BRAZILTin

PT Tirus Putra Mandiri

INDONESIA

Tin

Melt Metais e Ligas S.A.

BRAZILTin

PT ATD Makmur Mandiri
Jaya

INDONESIA

Tin

O.M. Manufacturing
Philippines, Inc.

PHILIPPINESTin

CV Ayi Jaya

INDONESIA

Tin

Electro-Mechanical Facilityof the Cao Bang Minerals &Metallurgy Joint Stock
Company
VIET NAM

Tin

Nghe Tinh Non-Ferrous
Metals Joint Stock
Company

VIET NAM

Tin

Tuyen Quang Non-Ferrous
Metals Joint Stock
Company

VIET NAM

Tin

PT Rajehan Ariq

INDONESIATin

PT Cipta Persada Mulia

INDONESIATin

An Vinh Joint Stock Mineral
Processing Company
VIET NAM

Tin

Resind Industria e Comercio
Ltda.
BRAZIL

Tin

Super Ligas

BRAZILTin

Aurubis Beerse

BELGIUM

Tin

Aurubis Berango

SPAIN

Tin

PT Bangka Prima Tin

INDONESIATin

PT Sukses Inti Makmur(SIM)

INDONESIATin

PT Menara Cipta Mulia

INDONESIA

Tin

HuiChang Hill Tin Industry
Co., Ltd.

CHINA

Tin

Modeltech Sdn Bhd

MALAYSIA

Tin

Guangdong Hanhe

CHINA

20

Non-Ferrous Metal Co., Ltd.
Tin

Chifeng Dajingzi Tin
Industry Co., Ltd.

CHINA

Tin

PT Bangka Serumpun

INDONESIA

Tin

Tin Technology & Refining

UNITED STATES OF
AMERICA

Tin

Dongguan CiEXPO
Environmental Engineering
Co., Ltd.

CHINA

Tin

Ma'anshan Weitai Tin Co.,
Ltd.

CHINA

Tin

PT Rajawali Rimba Perkasa INDONESIA

Tin

Luna Smelter, Ltd.

Tin

Yunnan Yunfan Non-ferrous
Metals Co., Ltd.
CHINA

Tin

Precious Minerals andSmelting Limited

INDIA

Tin

Gejiu City Fuxiang Industry
and Trade Co., Ltd.

CHINA

Tin

PT Mitra Sukses Globalindo INDONESIATin

CRM Fundicao De Metais E
Comercio De Equipamentos
Eletronicos Do Brasil Ltda
BRAZILTin

CRM Synergies

SPAIN

Tin

Fabrica Auricchio Industriae Comercio Ltda.

BRAZILTin

DS Myanmar

MYANMARTin

PT Putera Sarana Shakti (PT
PSS)
INDONESIA

Tin

Mining Minerals Resources CONGO, DEMOCRATICSARLREPUBLIC OF THE

Tungsten

A.L.M.T. Corp.

JAPAN

Tungsten

Kennametal Huntsville

UNITED STATES OF
AMERICA

Tungsten

Guangdong Xianglu
Tungsten Co., Ltd.

CHINA

RWANDA

21

TungstenChongyi Zhangyuan
Tungsten Co., Ltd.

Tungsten

CNMC (Guangxi) PGMA Co.,
Ltd.
CHINA

Tungsten

Global Tungsten & Powders UNITED STATES OF
LLC
AMERICA

Tungsten

Hunan Chenzhou Mining
Co., Ltd.

CHINA

Tungsten

Hunan Jintai New MaterialCo., Ltd.

CHINA

TungstenJapan New Metals Co., Ltd. JAPANTungsten

Kennametal Fallon

UNITED STATES OF
AMERICA

Tungsten

Wolfram Bergbau undHutten AG

AUSTRIA

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

Tungsten

Jiangxi Minmetals Gao'an
Non-ferrous Metals Co., Ltd. CHINA

TungstenGanzhou Jiangwu
Ferrotungsten Co., Ltd.

Tungsten

Jiangxi Yaosheng Tungsten
Co., Ltd.
CHINA

Tungsten

Jiangxi Xinsheng Tungsten
Industry Co., Ltd.

Tungsten

Jiangxi Tonggu Non-ferrous
Metallurgical & ChemicalCo., Ltd.
CHINA

Tungsten

Malipo Haiyu Tungsten Co.,
Ltd.
CHINA

Tungsten

Xiamen Tungsten (H.C.) Co.,
Ltd.
CHINA

Tungsten

Jiangxi Gan Bei Tungsten
Co., Ltd.

CHINA

TungstenGanzhou Seadragon W &Mo Co., Ltd.

CHINA

Tungsten

Asia Tungsten Products
Vietnam Ltd.

VIET NAM

CHINA

CHINA

CHINA

22

Tungsten

Hunan Shizhuyuan
Nonferrous Metals Co., Ltd.
Chenzhou Tungsten
Products Branch
CHINA

Tungsten

H.C. Starck Tungsten GmbH GERMANY

TungstenTANIOBIS Smelting GmbH &Co. KGGERMANY

Tungsten

Masan High-Tech Materials VIET NAM

Tungsten

Jiangwu H.C. Starck
Tungsten Products Co., Ltd. CHINA

Tungsten

Niagara Refining LLC

UNITED STATES OF
AMERICA

Tungsten

China Molybdenum
Tungsten Co., Ltd.

CHINA

Tungsten

Philippine Chuangxin
Industrial Co., Inc.

PHILIPPINES

Tungsten

ACL Metais Eireli

BRAZIL

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF
CHINA

Tungsten

Hubei Green Tungsten Co.,
Ltd.

CHINA

Tungsten

Albasteel Industria eComercio de Ligas Para
Fundicao Ltd.

BRAZIL

Tungsten

Cronimet Brasil Ltda

BRAZIL

Tungsten

Fujian Xinlu Tungsten Co.,
Ltd.

CHINA

TungstenTungsten Vietnam Joint
Stock Company

VIET NAM

The RMI does not provide a specific country of origin of the conflict minerals processed by conformant
smelters. Due to business confidentiality reasons, the country of origin data is provided in an aggregated
way based on country risk level. Thus, we were not able to determine with certainty the specific countriesof origin of the conflict minerals processed by the listed conformant smelters. The list is the possible
countries the material may have come from and references the plausible list of mineral mine production
by country (RMI report published March 2020, Mineral Mine Production Country”). The list is based on the
country of origin data provided by the RMI for RMAP LBMA, and RJC conformant smelters only. To
supplement this list, Google conducts independent due diligence into all identified smelters. On acontinuous basis, Google requests its suppliers to cease doing business with non-conformant smelters23and notifies suppliers that non-conformant smelters are no longer approved to be in Google’s supply
chain.

24