Kaloti's African gold shakes up EY in London
In late December, consultant Amjad Rihan filed for damages before a British court from his former employer EY. He has accused the audit giant of making him leave the company after he refused to validate an audit on supply sources
Thursday, 18 January 2018
‘Blood gold’ in your jewelry is poisoning workers and the rainforest. Here’s how to stop it.
‘Blood gold’ in your jewelry is poisoning workers and the rainforest. Here’s how to stop it.
Illegal gold molded into our wedding rings, dangling around our necks and hidden in our smartphones is polluting the rainforest with toxic chemicals and exploiting workers in Latin America.
Gold miners have stripped roughly 415,000 acres of South American tropical forest, an area twice as big as New York City, according to researchers at the University of Puerto Rico — and the rate of deforestation is only getting worse.
In Colombia, teenagers swim in mercury-filled pools of water as they use powerful hoses to suck up gold, an investigation by Massachusetts-based nonprofit Verité found.
This week Pope Francis will bring his moral authority to the crisis when he visits Peru’s epicenter of illegal gold mining, Madre de Dios.
Solutions won’t be easy — but they exist.
“There are ways of mining gold without mercury, without massive deforestation, without child slavery,” said Douglas Farah, a national security consultant who has studied illegal gold mining.
To stop the unrelenting environmental and human devastation, an array of competing interests will have to collaborate to extract gold in a more humane way, according to workers’ rights advocates, environmentalists and industry experts. In the mix of this crisis are large multinational companies that use gold in their products, American consumers, U.S. and foreign law enforcement agencies, non-governmental organizations, precious-metals refineries and the miners themselves.
Complicating matters further: Violent Latin American drug traffickers who have infiltrated the industry seeking to launder money.
Illegal gold mining in southwestern Colombia has turned this stretch of river into a muddy pit. Colombia’s police are scrambling to stop the illicit industry that authorities say is funneling money into the pockets of criminal gangs.
Juan Manuel Barrero Bueno Special to the Miami Herald
The kind of sweeping change needed to clean up the gold industry has happened before, experts say — take “blood diamonds.”
Today, no company wants to buy or sell diamonds that contribute to violent conflict. That’s because consumers, advocacy groups and world governments woke up to the havoc caused by their extraction — and pressured big companies not to trade them anymore.
It worked. Since 2003, more than 75 countries, including the United States, have signed onto a United Nations-backed accord called the Kimberley Process that certifies diamonds as “conflict-free,” meaning rebel groups do not profit from their sale.
The campaign “brought the issue to people’s attention in ways that people like myself never thought possible,” Farah said. “I think the same thing is entirely possible with gold” — if consumers demand greater transparency.
In from the cold
Without more stringent precautions, American consumers should be aware “there is a strong likelihood that a percentage of gold in their jewelry or electronics comes from illegal gold mines,” said Quinn Kepes, program director for Verité, which investigates abuses in the international gold industry.
The implications are huge: Nearly three-quarters of gold imports into the United States come from Latin America.
In southeastern Peru’s vulnerable Madre de Dios region, illegal miners have invaded pristine Amazonian rainforests and turned them into “toxic deserts” where wildlife cannot thrive, said Luis Fernandez, a tropical ecologist at Wake Forest University’s Center for Amazonian Scientific Innovation.
Machines chew up the forest, digging 30 feet down into the soil and then sifting for gold. The mining work leaves behind massive piles of dirt and rocks that clog up riverbeds. The waterways are poisoned by mercury used to separate gold from rock.
“It completely destroys the area,” said Fernandez. “You don’t expect these areas to reforest in hundreds of years. There’s no more soil. You’re basically doing strip mining on a massive scale.”
A rock ball containing crude gold will be melted to extract the precious metal at a gold-buying store in Segovia, a mining town in the Antioquia department in Colombia, on May 8, 2017.
PEDRO PORTAL pportal@miamiherald.com
In Madre de Dios, where Fernandez’s center runs a research laboratory, aerial imagery shows hundreds of thousands of acres have been deforested.
Much of the damage is happening in national parks and ecological preserves.
“It would be the equivalent of having thousands of acres of illegal strip mines in Yellowstone National Park — and the government not being able to stop it,” Fernandez said.
He and a team of researchers are leading efforts to study how to reforest such a devastated ecosystem, including using charcoal-enriched soil to grow vegetation again and testing a mix of 40 native plant species for their viability.
“How do you reforest something like that?” Fernandez said. “We have to figure how to do this efficiently and cost effectively.”
One of the most horrific byproducts of illegal mining: widespread mercury poisoning.
Gold miners in the Amazon region pollute rivers and lakes with more than 30 tons of mercury every year, according to the Global Initiative, a New York nonprofit that researches organized crime.
Artisanal miners have used mercury for centuries. They mix rocks containing gold with the toxic chemical to form an amalgam. Then they heat the mixture, burning the mercury away — sending it into their own lungs and the environment — and leaving behind gold.
Pits left by miners fill with mercury-contaminated water — and local people sometimes use those pits to farm fish, Fernandez said. His research shows that across Madre de Dios — where there are tens of thousands of small-scale miners — three in four people suffer from dangerous levels of mercury. Indigenous tribes are particularly vulnerable, he said. They are three times as likely to suffer from elevated levels of mercury as other residents.
Prolonged exposure to the chemical can harm nervous, immune and digestive systems, and lead to respiratory and kidney failure and even death.
Many miners are only vaguely aware of the health risks posed by mercury, just like tobacco smokers of previous generations, said Kevin Telmer, executive director of the Artisanal Gold Council, a Vancouver-based organization that advocates for improving the conditions and practices of artisanal miners.
Telmer said convincing miners to stop using mercury is not as daunting as it might seem.
While mercury is fast, cheap and yields gold immediately, some of the precious metal is lost in the process.
“You’ve got to give them a solution,” he said.
A big incentive: mining without mercury makes miners more money because more gold is recovered, according to Telmer.
“We typically get a 30 percent lift in their recovery,” he said. “If it’s going to induce a pay cut, they’re not going to be interested.”
The Artisanal Gold Council has launched three pilot mining projects, including one in Peru, to showcase mercury-free methods of extracting gold.
These include basic gravity techniques such as panning, shaking tables and centrifuges. Large-scale industrial mines have long stopped using mercury because it is inefficient.
Both Peru and Colombia have signed the U.N. Minamata Convention, which is intended to phase out the use of mercury in traditional gold mining by the end of the year.
Telmer said the government could also help by abandoning ineffective drug-war tactics that include airborne rainforest raids.
“They blow up some [illegal] dredges this week and then next week the dredges are back in there,” Telmer said.
Carlos Durango, who works in the Las Brisas mine in the Colombian town of Segovia, discusses the difficulties facing independent miners.
PEDRO PORTAL pportal@miamiherald.com
An alternative is to provide resources to artisans.
One organization doing that is the Global Environmental Facility, which is funded by the United Nations, development banks and international non-governmental organizations. The group is providing $45 million in financing to help artisanal gold miners eliminate the use of mercury in Peru, Colombia and six other countries.
“The only way to fix this problem is to bring [small miners] into the formal sector,” Telmer said, “and that includes formal financing.”
Drug trade
Even as they fend off harsh tactics from South American law enforcement, artisanal miners are vulnerable to extortion and outright takeover by drug cartels, who see the gold trade as a way to launder drug profits. In effect, the miners are squeezed between the government and the cartels.
This is where U.S. law enforcement can play a critical role — by aggressively attacking the cartels’ use of gold to launder drug profits, according to Lou Bock, , a retired agent with the Department of Homeland Security.
For decades, however, the United States has taken a haphazard approach to regulating the gold market.
Criminals manipulating gold knew no one was “looking at them,” Bock said.
Consider the Financial Crimes Enforcement Network, a U.S. Treasury Department agency responsible for enforcing anti-money-laundering laws. FinCEN has imposed only one civil sanction against a U.S. precious-metals company — a $200,000 fine in 2015 against a Los Angeles dealer that failed to set up an anti-money-laundering program.
John Cassara, a retired U.S. Treasury agent who worked at FinCEN, said his bosses forbade him from going after the industry following the 9/11 attacks. Instead, top officials wanted to focus on traditional targets like money laundering through banks.
“I was literally given a gag order,” Cassara said.
A FinCEN spokesman did not respond to requests for comment.
But there are signs the U.S. government is getting more aggressive.
Last year, federal prosecutors in Miami uncovered a staggering $3.6 billion money-laundering scheme by employees of a major South Florida precious-metals company, Doral-based NTR Metals. The three NTR traders pleaded guilty to buying dirty gold from narco-traffickers and other criminals in Latin America.
“We’re now putting pressure on the money-laundering end of it,” said John Tobon, deputy special agent in charge of Homeland Security Investigations in South Florida, which worked with the FBI on the NTR case. “The criminal organizations have been able to infiltrate the [precious-metals] industry to a level we were not familiar with.”
Police officers stand watch in southwestern Colombia after authorities destroyed backhoes involved in illegal gold mining operations.
Juan Manuel Barrero Bueno Special to the Miami Herald
A reflection of this shift in emphasis: Almost a year ago, the U.S. Attorney’s Office in Miami renamed its narcotics division, indicating a sharper focus on money laundering. It’s now the International Narcotics and Money Laundering Section.
Peter Quinter, a former U.S. Customs attorney now in private practice representing Miami gold dealers, said his clients are eager to assist federal authorities.
“There has definitely been increased scrutiny” since the NTR case, including more gold seizures and stricter examination of Customs forms, Quinter said.
But the fallout extends far beyond Customs searches, all the way to the banks that prop up the international precious-metals market.
“A major aspect of this racket is the banks,” said Charles Intriago, a money-laundering expert and former federal prosecutor in Miami. “Where are they when these multibillion-dollar gold transactions are conducted? The Justice Department, FBI and IRS should not leave the banks on the sidelines.”
In the meantime, Scotiabank, the Canadian lending institution that services NTR’s parent company, Elemetal, is looking to sell off its gold-lending arm, the world’s oldest, according to the Financial Times.
That is no small matter.
If the banks pull out, the U.S. gold industry would be undermined: Banks provide financing to dealers and refineries for a steady stream of shipments to the United States.
A group of people, including women and children, search for gold in fine sand in a river called Cianurada — “cyanide-filled river.” The gold-laced water comes from processing at the Gran Colombia Gold Corporation factory in the mining town of Segovia, Colombia.
PEDRO PORTAL pportal@miamiherald.com
Just as the U.S. government has awoken to the threat of money laundering in the gold industry, America’s largest companies are taking a keener interest in the source of their gold.
Elemetal supplied dozens of blue-chip companies, according to corporate disclosure forms, including Tiffany & Co. and Apple. Those companies said they constantly check to make sure they aren’t using “blood gold” in their products.
Tiffany said it bought only domestic “scrap” from Elemetal, rather than mined materials from Latin America. Scrap gold is collected from pawnshops and jewelry stores in the United States.
Apple declined to comment. But a spokesman said last year the company had found “no evidence of illegal gold entering our supply chain.”
Fernandez, the tropical ecologist, said that U.S. companies should buy only gold that is certified as “fair-trade,” meaning the mining process does not damage workers or the environment.
“That could be a game-changer,” he said.
One Colombian nonprofit, the Alliance for Responsible Mining, has already created a fair-trade brand of gold it calls “Fairmined.” The group works with artisanal miners in Latin America, Asia and Africa to make sure they follow environmental and labor laws and don’t use mercury or interact with criminals.
That comes at a price, just as organic foods cost more than processed ones.
Fairmined gold is sold for a premium between $2,200 to $4,000 per kilogram above the market price. Some of that money is shared with the miners. (In January, a kilogram of standard gold cost more than $42,000.)
Despite the premium, the program is finding success: Swiss watchmaker and jeweler Chopard uses Fairmined gold. And when Colombian President Juan Manuel Santos was awarded the Nobel Peace Prize in 2016, the medal was minted from Fairmined Colombian gold.
Last year, Fairmined produced roughly 250 kilograms of gold. In 2018, the Alliance for Responsible Mining hopes to double that.
“What we need is to certify more mines to be able to supply the market,” said Yves Bertran, the group’s executive director. “It’s a slow process but we are really making progress.”
Dirty metal
Cleaning up the gold trade can’t happen without a commitment from U.S. and international refineries that buy precious metal from Latin America and sell it to jewelers, banks and electronics companies.
They need to know their suppliers aren’t criminals.
“Anybody dealing in gold legally has to trace it back to the source and confirm that it’s legitimate,” said David Bolton, a Miami private investigator who has worked for U.S. refineries and Latin American gold exporters.
There are two major sources of gold in Latin America: large mines controlled by multinational conglomerates, and gold brokers known as “aggregators” who buy from artisans.
A banner advertises a gold-buying store in Segovia, a mining town in Colombia.
PEDRO PORTAL pportal@miamiherald.com
Aggregators offer a riskier business model, experts say, because it’s so difficult to trace the origins of their gold. Some buy gold from mines controlled by criminals — and cover it up by falsifying paperwork and bribing officials, as NTR employees did.
When dealing with aggregators, “it’s impossible to know the original source of the gold,” said Mike Riess, a precious-metals consultant who sits on a U.S. Treasury Department anti-money-laundering advisory board. “It’s more likely at this point that you’re dealing with a criminal organization.”
Despite the risks, many global gold firms seeking to meet endless demand still buy from aggregators instead of large mines. That includes two of the world’s biggest refineries, Switzerland-based Metalor and Japan-based Asahi, which both have operations in the United States.
José Ramon Camino, Metalor’s general counsel, acknowledged in an email that buying from large, regulated mines “reduces the risk.”
“However, in Colombia, the majority of the mining operations are small,” Camino said. “Business can still be done, provided that compliance is not compromised in any way.”
Camino said Metalor compliance officers visit Latin American suppliers to ensure that they have permits, pay taxes and meet regulations.
“If there are doubts that we cannot clarify, we stop the business,” he said.
Asahi declined to answer questions. But spokesman David Dorris said Asahi’s suppliers source “material in a legal and responsible manner.”
Gold companies realize vetting aggregators is no easy task, nor foolproof.
“Even though we carry out exhaustive due diligence and know-your-customer processes, there’s never any guarantee of certainty,” said Pacco Liano, compliance officer for Miami-based Kaloti Metals & Logistics, which buys gold from Latin America and sells it to a refinery in Dubai.
Republic Metals, an Opa-locka-based refinery that is one of North America’s largest, once bought from aggregators, too. But no more.
The firm stopped dealing with aggregators in 2014. It now buys only from big, regulated mines in both Colombia and Peru.
CEO Jason Rubin says large mines owned by publicly traded companies are less vulnerable to criminal infiltration because of greater government scrutiny and internal resources for due diligence.
In fact, executives at Goldex, an aggregator that once supplied Republic, were charged in Colombia in a scheme to launder almost $1 billion through gold exports. The case is ongoing and Goldex denied wrongdoing.
“I don’t want to risk our reputation,” said Rubin, whose father started Republic in 1980 and grew the refinery into a massive operation, where cauldrons pour molten gold in a searing furnace straight out of Tolkien.
But dealing only with large mines cuts out subsistence miners from the global gold economy.
One startup Miami gold company that still uses aggregators believes that “fair-mined” branding can help distinguish legitimate artisanal miners from those with ties to criminals.
Alejandro Esponda, vice president of Doral-based Universal Precious Metals, said U.S. companies have a duty to support small miners who labor in remote jungle regions where mining has been practiced for centuries.
“It’s a social enterprise,” he said.
Nicholas Nehamas: 305-376-3745, @NickNehamas
Jay Weaver: 305-376-3446, @jayhweaver
Kyra Gurney: 305-376-3205, @KyraGurney
Monday, 31 October 2016
Abbott Laboratories Conflict Minerals Report 2015
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Abbott Laboratories (Abbott) is filing a Conflict Minerals Report as an exhibit to this specialized disclosure report and is providing
that report on Abbott’s publicly available Internet website at http://www.abbott.com/policies/conflict-minerals.html.
Abbott’s determination and related disclosures relating to materials that may come from recycled and scrap sources are included in our
Conflict Minerals Report and are incorporated by reference herein.
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as an exhibit to this Form SD.
Section 2 — Exhibits
Item 2.01 Exhibits
The following exhibit is filed as a part of this report.
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
SIGNATURES
Abbott Laboratories
(Registrant)
/s/ Brian B. Yoor May 31, 2016
By (Signature and Title) (Date)
Brian B. Yoor
Senior Vice President, Finance & Chief Financial Officer
EXHIBIT INDEX
Exhibit 1.01 Conflict Minerals Report for the Year Ended December 31, 2015
Exhibit 1.01
Abbott Laboratories
Conflict Minerals Report
For the Year Ended December 31, 2015
the Rule. This report is available on our website at http://www.abbott.com/policies/conflict-minerals.html.
1. Overview
Abbott is a broad-based, global health care company. We discover, develop, manufacture and market a wide range of health care products, including nutritional products, diagnostic systems and tests, branded generic pharmaceuticals, and medical devices.
We analyzed the products we manufacture or contract to have manufactured, and found that small quantities of tin, tantalum, tungsten, and gold (3TG) may be present in a number of our products; primarily, in electronic diagnostic and monitoring instruments, in medical and surgical devices and equipment, and in product components containing metal alloys. After requesting information from our suppliers as described below, we are unable to determine whether the limited quantities of 3TG actually present in our products originated from the Democratic Republic of the Congo (DRC) or adjoining countries, and whether such 3TG came from recycled or scrap sources. We similarly have been unable to conclusively identify the specific facilities used to process the 3TG actually present in
our products.
Supply Chain
Abbott manufactures thousands of products. Because of the diversity and complexity of our products, we have thousands of suppliers that supply us with parts, components, or other materials. Each of these suppliers may in turn have large numbers of sub-suppliers. We typically do not have direct relationships with mines, smelters, or refiners. We rely on our suppliers to provide information on the
origin of 3TG contained in the parts, components, and materials supplied to us — including sources of 3TG that are supplied to them from their lower-tier suppliers. Many of our smaller suppliers, as well as those further upstream in the supply chain, are not SEC registrants subject to the Rule.
Our contracts with direct suppliers may be in force for multiple years and historically did not require the supplier to provide Abbott with information regarding the origin of 3TG. As we renew or enter into new contracts with suppliers for parts, components, or other materials that may contain 3TG, we are working to add language requiring those suppliers to provide information about the source and
chain of custody of 3TG present in the parts, components, and materials they supply to Abbott. While these supplier contracts are being updated to contain appropriate flow-down provisions, we rely on the cooperation of our direct suppliers to provide the necessary information on the origin of 3TG and are continuing to work with our suppliers to obtain current 3TG sourcing information, as described in more detail below.
Requesting Information from Suppliers
Abbott’s supplier query program was designed to survey direct suppliers who provide parts, components, or materials likely to contain 3TG. We also surveyed lower-tier, sub-suppliers that were identified by a distributor providing parts, components, or materials to Abbott.
We surveyed suppliers using the Conflict Minerals Reporting Template (CMRT) developed by the Conflict Free Sourcing Initiative (CFSI). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a manufacturer’s supply chain, and forms a basis for our Reasonable Country of Origin Inquiry (RCOI). The CMRT includes questions regarding the supplier’s “conflict-free policy,” its engagement with its direct upstream suppliers, and a listing of smelters used in the supply chain. In addition, the CMRT contains questions about the origin of 3TG included in the supplier’s products, as well as the respondent’s due diligence on their suppliers.
If a supplier response is received early in the reporting year, at the end of the year we ask the supplier to confirm its response is still accurate. We provide suppliers with training materials on Conflict Minerals when we send out the CMRT. CFSI also makes written instructions and recorded training on the CMRT available on its website.
2. Design of Due Diligence Process
Abbott’s due diligence measures have been designed to conform in all material respects with the framework set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten. Below is a description of the measures that we implemented and the diligence we performed.
3. Description of Due Diligence Performed
The due diligence measures we performed are presented below according to the five-step framework established by the OECD.
3.1 Company Management Systems
Communication
Abbott’s company statement relating to conflict minerals is available at: http://www.abbott.com/policies/conflict-minerals.html.
Internal Management Structure
We established an internal management structure and processes to support supply chain due diligence related to 3TG. This includes a cross-functional conflict minerals steering committee sponsored by senior management, as well as sub-teams focused on development, implementation, and ongoing enhancements to our compliance processes. The sub-teams include management representatives and
subject matter experts from each of our operating divisions, as well as representatives from Legal, Quality Assurance, Purchasing, Finance, Government Affairs, and Public Affairs. Senior management is briefed on the results of our supplier due diligence efforts.
System of Controls and Transparency
Through our membership in the CFSI we actively follow and support national and international efforts to identify upstream actors in the supply chain and increase traceability.
We have established various supplier controls, including our Supplier Guidelines, which outline expected behaviors and practices for all Abbott suppliers. The Supplier Guidelines instruct suppliers to report on the source and chain of custody of any 3TGs contained in the parts, components, or materials supplied to Abbott, following the guidelines developed by the OECD. This includes providing information on the location of the mine or the country of origin and/or the smelter where the 3TG was processed.
In addition, our Code of Business Conduct outlines Abbott’s core values and expectations for Abbott employees.
Abbott has established procedures and control systems designed to ensure relevant documentation is retained for an appropriate time period.
Supplier Engagement
Abbott has developed model contract language requiring suppliers to provide adequate information regarding the source and chain of custody of 3TGs. We are working to add this language to agreements where the supplier is providing parts, components, assemblies, materials, or other products that may contain any 3TGs. Our Supplier Guidelines also include expectations for suppliers regarding the tracking and reporting of 3TGs in the parts, components, or materials they supply to Abbott. As part of our supplier query process, we also make available training materials on the requirements of the Conflict Minerals Rule and the proper procedure to complete the CMRT.
Grievance Mechanism
We have longstanding grievance mechanisms for employees and suppliers to report potential concerns or violations of Abbott policies. These mechanisms include direct reporting to managers or compliance officers, on-line reporting, and a toll-free Helpline that is available 24 hours a day, seven days a week, with interpreters available in multiple languages.
3.2 Identify and Assess Risk in the Supply Chain
We identified and surveyed suppliers who provide Abbott with parts, components, or materials likely to contain 3TG. We evaluated the responses we received to determine if the response was complete based on internally defined criteria, or if further engagement with the supplier was required. In accordance with our defined procedure, we also attempted to engage suppliers who did not respond,
provided an incomplete response, or provided inconsistent data within the CMRT. We have worked, and will continue to work, with these suppliers to obtain additional information to supplement their responses.
In many cases, suppliers identified facilities that could not be confirmed as known smelters. In such situations we notified CFSI, which has implemented a process to confirm whether such facilities are legitimate smelters. We continue to work with suppliers and CFSI to improve the accuracy of reported processing facility information and to verify the identity of these reported facilities. We also
partner with our suppliers to encourage smelters to engage with CFSI and participate in CFSI’s Conflict-Free Smelter Program.
3.3 Design and Implement a Strategy to Respond to Risks
Abbott’s strategy to respond to identified risks in the supply chain includes the following elements:
We identify potential risks or red flags by evaluating the responses provided by our suppliers, and we have developed processes to address incomplete, inconsistent, or otherwise unsatisfactory responses received from our suppliers, including a process to elevate issues to appropriate management for resolution.
We maintain a dashboard to regularly monitor and track our supply chain risk assessment process.
Management is briefed about our due diligence efforts on a regular basis.
3.4 Carry out Independent Third Party Audit Supply Chain Due Diligence at Identified Points in the Supply Chain
We support audits of 3TG smelters and refiners conducted by third parties through our participation and membership in the CFSI.
3.5 Report on Supply Chain Due Diligence
This Conflict Minerals Report constitutes our annual report on our 3TG due diligence, is filed with the SEC, and is available on our
website at the following link: http://www.abbott.com/policies/conflict-minerals.html
4. Steps to Mitigate Risk
Abbott has taken or intends to take the following steps to continuously improve the due diligence conducted on the source and chain
of custody of 3TG in our products:
a) Participate as a member in the CFSI in efforts to increase the number of smelters and refiners participating in the Conflict-
Free Smelter Program (CFS Program).
b) Engage with suppliers and direct them to training and other resources designed to help them increase the response rate,
improve the content of the supplier survey responses, and ensure that the processing facilities they identify are actual, known
smelters or refiners.
c) For identified known smelters that are not participating in the CFS Program, work with suppliers and CFSI to engage these
smelters to encourage participation in the CFS Program.
d) Work with peer groups and relevant trade associations to define and improve best practices with our supply chain in
accordance with the OECD Guidance.
e) For new or renewed supplier contracts, include a clause requiring the supplier to provide requested information regarding
3TG in the parts, components or materials they supply to Abbott.
5. Determination
For 2015, we received responses from a majority of the suppliers we surveyed, improving on the response rates we have experienced in previous years. Many of the responding suppliers provided processing facility data. Using that data, and cross-checking against existing CFSI smelter lists, we were able to confirm 314 of the processing facilities identified by our suppliers as actual known
smelters.
Of the known smelters, 208 are compliant with the Conflict-Free Smelter Program assessment protocols and are considered conflict-free. Another 45 were reported to have committed to undergo a Conflict-Free Smelter Program audit or are participating in another recognized certification program.
Based on information provided by CFSI, 23 of the 208 conflict-free smelters identified by our suppliers were reported as sourcing minerals from the DRC or an adjoining country, 107 were reported as not sourcing from the DRC or an adjoining country and 16 were reported as sourcing solely from recycled or scrap materials. Sourcing was not disclosed for 62 of the conflict-free smelters. Annex I contains a listing of the known smelters and refiners identified by Abbott’s suppliers.
Numerous suppliers reported some use of 3TG produced from recycled or scrap sources in their supply chain during 2015, but did not provide information on whether any of the parts, components, or materials actually supplied to Abbott contained any 3TG from those recycled or scrap sources. In addition, none of the responding suppliers were able to identify the specific facility that processed 3TG in the products actually supplied to Abbott. As a result, we were unable to conclusively identify the specific facilities that were used to process the 3TG contained in the parts, components, or materials actually supplied to Abbott, or whether the 3TG came from recycled or scrap sources.
Similarly, based on our due diligence efforts, we do not have sufficient information to conclusively determine the country of origin of the 3TG contained in the parts, components, or materials actually supplied to Abbott.
We seek reasonable information about 3TG smelters and refiners and the mines or locations of origin of 3TG in our supply chain through the following efforts: supporting industry initiatives like the CFSI through our membership; reviewing best practices established in the Organization for Economic Co-operation and Development (OECD) and other due diligence implementation programs; and requesting our suppliers to complete the CMRT, and evaluating supplier responses as described above.
Forward-looking Statements
Please note that forward-looking statements relating to Abbott’s future plans are based on current expectations and assumptions, and are not intended to be guarantees. Our actual actions may differ from these forward-looking statements.
Smelter List and Country of Origin List
Metal Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)
Gold Advanced Chemical Company **
Gold Aida Chemical Industries Co. Ltd.*
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold Almalyk Mining and Metallurgical Complex (AMMC)**
Gold AngloGold Ashanti Córrego do Sítio Minerção*
Gold Argor-Heraeus SA*
Gold Asahi Pretec Corp*
Gold Asaka Riken Co Ltd*
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold Aurubis AG*
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
Gold Boliden AB*
Gold C. Hafner GmbH + Co. KG*
Gold Caridad Gold CCR Refinery – Glencore Canada Corporation*
Gold Cendres + Métaux SA**
Gold Chimet S.p.A.*
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.**
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation**
Gold Doduco*
Gold Dowa*
Gold Eco-System Recycling Co., Ltd.*
Gold Emirates Gold DMCC*
Gold Faggi Enrico S.p.A.**
Gold Fidelity Printers and Refiners Ltd.
Gold FSE Novosibirsk Refinery*
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation**
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH*
Gold Heraeus Ltd. Hong Kong*
Gold Heraeus Precious Metals GmbH & Co. KG*
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold Ishifuku Metal Industry Co., Ltd.*
Gold Istanbul Gold Refinery*
Gold Japan Mint*
Gold Jiangxi Copper Company Limited*
Gold Johnson Matthey Inc*
Gold Johnson Matthey Ltd*
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold JSC Uralectromed*
Gold JX Nippon Mining & Metals Co., Ltd*
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc Ltd*
Gold Kennecott Utah Copper LLC*
Gold Gold Kojima Chemicals Co., Ltd*
Gold Korea Zinc Co. Ltd.**
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.*
Gold Luoyang Zijin Yinhui Gold Refinery
Co., Ltd. Gold Materion*
Gold Matsuda Sangyo Co., Ltd.*
Gold Met-Mex Peñoles, S.A.*
Gold Metalor Technologies (Hong Kong) Ltd*
Gold Metalor Technologies (Singapore) Pte. Ltd.*
Gold Metalor Technologies (Suzhou) Ltd.**
Gold Metalor Technologies SA*
Gold Metalor USA Refining Corporation*
Gold Mitsubishi Materials Corporation*
Gold Mitsui Mining and Smelting Co., Ltd.*
Gold MMTC-PAMP India Pvt., Ltd.*
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant*
Gold Gold Navoi Mining and Metallurgical Combinat**
Gold Nihon Material Co. LTD*
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
Gold Ohio Precious Metals, LLC*
Gold Ohura Precious Metal Industry Co., Ltd*
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold PAMP SA*
Gold Penglai Penggang Gold Industry Co., Ltd.
Gold Prioksky Plant of Non-Ferrous Metals*
Gold PT Aneka Tambang (Persero) Tbk*
Gold PX Précinox SA*
Gold Rand Refinery (Pty) Ltd*
Gold Republic Metals Corporation*
Gold Royal Canadian Mint*
Gold Sabin Metal Corp.
Gold Samduck Precious Metals**
Gold SAMWON METALS Corp.
Gold SAXONIA Edelmetalle GmbH**
Gold Schone Edelmetaal*
Gold SEMPSA Joyería Platería SA*
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold Sichuan Tianze Precious Metals Co., Ltd.*
Gold Singway Technology Co., Ltd.*
Gold So Accurate Group, Inc.
Gold SOE Shyolkovsky Factory of Secondary Precious Metals*
Gold Solar Applied Materials Technology Corp.*
Gold Sumitomo Metal Mining Co., Ltd.*
Gold T.C.A S.p.A*
Gold Tanaka Kikinzoku Kogyo K.K.*
Gold The Refinery of Shandong Gold Mining Co. Ltd*
Gold Tokuriki Honten Co. Ltd*
Gold Tongling nonferrous Metals Group Co.,Ltd
Gold Torecom**
Gold Umicore Brasil Ltda*
Gold Umicore Precious Metals Thailand*
Gold Umicore SA Business Unit Precious Metals Refining*
Gold United Precious Metal Refining, Inc.*
Gold Valcambi SA*
Gold Western Australian Mint trading as The Perth Mint*
Gold WIELAND Edelmetalle GmbH**
Gold YAMAMOTO PRECIOUS METAL CO., LTD.*
Gold Yokohama Metal Co Ltd*
Gold Yunnan Copper Industry Co Ltd
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold Zijin Mining Group Co. Ltd*
Tantalum Changsha South
Tantalum Niobium Co., Ltd.*
Tantalum Conghua Tantalum and Niobium Smeltry*
Tantalum D Block Metals, LLC*
Tantalum Duoluoshan*
Tantalum Exotech Inc.*
Tantalum F&X Electro-Materials Ltd.*
Tantalum FIR Metals & Resource Ltd.*
Tantalum Global Advanced Metals Boyertown*
Tantalum Global Advanced Metals*
Tantalum Guangdong Zhiyuan New Material Co., Ltd.*
Tantalum H.C. Starck Co., Ltd.*
Tantalum H.C. Starck GmbH Goslar*
Tantalum H.C. Starck GmbH Laufenburg*
Tantalum H.C. Starck Hermsdorf GmbH*
Tantalum H.C. Starck Inc.*
Tantalum H.C. Starck Ltd.*
Tantalum H.C. Starck Smelting GmbH & Co.KG*
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.*
Tantalum Hi-Temp* Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum Jiujiang Tanbre Co., Ltd.*
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tantalum KEMET Blue Metals*
Tantalum Kemet Blue Powder*
Tantalum King-Tan Tantalum Industry Ltd* Tantalum LSM Brasil S.A.* Tantalum Metallurgical Products India (Pvt.) Ltd.*
Tantalum Mineração Taboca S.A.*
Tantalum Mitsui Mining & Smelting*
Tantalum Molycorp Silmet A.S.*
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum Plansee SE Liezen* Tantalum Plansee SE Reutte*
Tantalum QuantumClean* Tantalum Resind Indústria e Comércio Ltda.*
Tantalum RFH Tantalum Smeltry Co., Ltd* Tantalum Solikamsk Metal Works* Tantalum Taki Chemicals* Tantalum Telex*
Tantalum Tranzact, Inc.* Tantalum Ulba*
Tantalum XinXing HaoRong Electronic Material Co., Ltd.*
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.*
Tantalum Zhuzhou Cement Carbide* Tin Alpha*
Tin An Vinh Joint Stock Mineral Processing Company**
Tin Chenzhou Yunxiang Mining Smelting Company LTD**
Tin China Tin Group Co., Ltd.*
Tin CNMC (Guangxi) PGMA Co. Ltd. Tin Cooper Santa*
Tin CV Ayi Jaya* Tin CV Gita Pesona* Tin CV JusTindo*
Tin CV Nurjanah*
Tin CV Serumpun Sebalai* Tin CV United Smelting*
Tin CV Venus Inti Perkasa* Tin Dowa*
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company**
Tin Elmet S.L.U. (Metallo Group)*
Tin EM Vinto*
Tin Estanho de Rondônia S.A.
Tin Fenix Metals*
Tin Gejiu Jin Ye Mineral Co., Ltd.**
Tin Gejiu Kai Meng Industry and Trade LLC**
Tin Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.**
Tin Gejiu Zi-Li Tin Huichang Jinshunda Tin Co. Ltd
Tin Jiangxi Ketai Advanced Material Co., Ltd.*
Tin Jiangxi Nanshan Tin Linwu Xianggui Ore Smelting Co., Ltd.
Tin Magnu's Minerais Metais e Ligas LTDA*
Tin Malaysia Smelting Corporation (MSC)*
Tin Melt Metais e Ligas S/A*
Tin Metallic Resources Inc*
Tin METALLO-CHIMIQUE N.V. (MC)*
Tin Mineração Taboca S.A.* Tin Minsur*
Tin Mitsubishi Materials Corporation*
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company**
Tin O.M. Manufacturing (Thailand) Co., Ltd.*
Tin O.M. Manufacturing Philippines, Inc.*
Tin Operaciones Metalurgical S.A.*
Tin Phoenix Metal Ltd.**
Tin PT Artha Cipta Langgeng*
Tin PT ATD Makmur Mandiri Jaya*
Tin PT Babel Inti Perkasa*
Tin PT Bangka Prima Tin*
Tin PT Bangka Tin Industry*
Tin PT Belitung Industri Sejahtera*
Tin PT BilliTin Makmur Lestari*
Tin PT Bukit Timah*
Tin PT Cipta Persada Mulia*
Tin PT DS Jaya Abadi*
Tin PT DS Jaya Abadi**
Tin PT Eunindo Usaha Mandiri*
Tin PT Inti Stania Prima*
Tin PT Karimun Mining**
Tin PT Mitra Stania Prima*
Tin PT Panca Mega Persada*
Tin PT Prima Timah Utama*
Tin PT REFINED BANGKA TIN*
Tin PT Sariwiguna Binasentosa*
Tin PT Stanindo Inti Perkasa*
Tin PT Sukses Inti Makmur*
Tin PT Sumber Jaya Indah*
Tin PT Tambang Timah*
Tin PT Timah (Persero) Tbk Mentok*
Tin PT Tinindo Inter Nusa*
Tin PT Tirus Putra Mandiri Tin PT Tommy Utama*
Tin PT Wahana Perkit Jaya*
Tin Resind Indústria e Comércio Ltda.*
Tin Rui Da Hung* Tin Soft Metais, Ltda.* Tin Thaisarco*
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company**
Tin VQB Mineral and Trading Group JSC*
Tin White Solder Metalurgia e Mineração Ltda.*
Tin Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.**
Tin Yunnan Tin Company, Ltd.* Tungsten A.L.M.T. Corp.*
Tungsten Asia Tungsten Products Vietnam Ltd.*
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.*
Tungsten Chongyi Zhangyuan Tungsten Co Ltd*
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.*
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.**
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten Ganzhou Yatai Tungsten Co., Ltd.*
Tungsten Global Tungsten & Powders Corp.*
Tungsten Guangdong Xianglu Tungsten Co., Ltd.*
Tungsten H.C. Starck GmbH*
Tungsten H.C. Starck Smelting GmbH & Co.KG*
Tungsten Hunan Chenzhou Mining Group Co., Ltd.*
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.* Tungsten Hydrometallurg, JSC*
Tungsten Japan New Metals Co Ltd*
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.**
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.*
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.**
Tungsten Kennametal Fallon**
Tungsten Kennametal Huntsville*
Tungsten Malipo Haiyu Tungsten Co., Ltd.*
Tungsten Niagara Refining LLC*
Tungsten Nui Phao H.C. Starck
Tungsten Chemicals Manufacturing LLC*
Tungsten Tejing (Vietnam) Tungsten Co., Ltd.*
Tungsten Vietnam Youngsun
Tungsten Industry Co., Ltd*
Tungsten Wolfram Bergbau und Hütten AG*
Tungsten Wolfram Company CJSC Tungsten Xiamen Tungsten (H.C.) Co., Ltd.* Tungsten Xiamen Tungsten Co., Ltd*
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
Country of Origin List 3
Angola France Portugal Argentina Germany Republic of Congo Australia Guyana Russia Austria Hungary Rwanda Belgium India Sierra Leone Bolivia Indonesia Singapore Brazil Ireland Slovakia Burundi Israel South Africa Cambodia Japan South Korea Canada Kazakhstan South Sudan Central African Republic Kenya Spain Chile Laos Suriname China Luxembourg Switzerland Colombia Madagascar Taiwan Côte D'Ivoire Malaysia Tanzania Czech Republic Mongolia Thailand Democratic Republic of Congo Mozambique Uganda Djibouti Myanmar United Kingdom Ecuador Namibia United States of America Egypt Netherlands Vietnam Estonia Nigeria Zambia Ethiopia Peru Zimbabwe
3 The CFSI generally does not specify individual countries of origin of the conflict minerals processed by compliant smelters and refiners and thus we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed compliant smelters and refiners. In addition, for some of the listed compliant smelters and refiners, origin information is not disclosed. The list is based on the country of origin data provided to the CFSI for compliant smelters only.
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