Washington, D.C. 20549




Specialized Disclosure Report



(Exact name of registrant as specified in its charter)


NEW YORK   1-2360   13-0871985
(State or other jurisdiction of
incorporation or organization)
  (Commission File Number)   (IRS Employer
Identification No.)







(Address of principal executive offices)   (Zip Code)


(914) 499-1900

(Name and telephone number, including area code, of the person to contact in connection with this report.)


Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:


x  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.







Section 1 — Conflict Minerals Disclosure


Item 1.01 Conflict Minerals Disclosure and Report


Conflict Minerals Disclosure


This Form SD of International Business Machines Corporation (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.


A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is publicly available at https://www.ibm.com/procurement/responsibleminerals.


Item 1.02 Exhibit


As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.


Section 2 — Exhibits


Item 2.01 Exhibit


The following exhibit is filed as part of this report.


Exhibit Number   Description
Exhibit 1.01   Conflict Minerals Report of International Business Machines Corporation







Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.




/s/ Ric Lewis   May 24, 2024
Name: Ric Lewis   Date
Title: Senior Vice President, Infrastructure    





Exhibit 1.01



Conflict Minerals Report

For the reporting period from January 1, 2023 through December 31, 2023


This Conflict Minerals Report (Report) of International Business Machines Corporation (IBM) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the Rule) promulgated under the Securities Exchange Act of 1934, as amended, for the period from January 1, 2023, through December 31, 2023 (Reporting Period).


The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products, and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are columbite-tantalite (coltan), cassiterite, and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten, and gold (collectively, Conflict Minerals or 3TG). As described in this Report, Conflict Minerals are necessary for the functionality or production of certain products that IBM manufactures or contracts to manufacture.


Design of IBM’s Responsible Minerals Program


IBM’s Responsible Minerals Program, which includes IBM’s Conflict Minerals Initiative, and Cobalt and Mica Initiative, is run by full-time, experienced supply chain professionals within IBM’s Global Procurement organization. This team reports to IBM’s Vice President and Chief Procurement Officer, who has responsibility for IBM’s external supply base in support of products listed in this report. IBM is highly committed to sourcing 3TG and other minerals responsibly. In support of its established goals, IBM continued work to develop future platforms for mineral traceability due diligence, optimized Responsible Minerals supply chain education and evolved practices through strong collaboration with companies, smelters and refiners, and industry groups.


Description of IBM’s Products


This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by IBM; and (iii) for which the manufacture was completed during the Reporting Period. IBM products include the following categories that were manufactured or contracted to be manufactured by IBM in 2023:


IBM Hybrid Infrastructure: provides clients with innovative infrastructure platforms to help meet the new requirements of hybrid multi-cloud and enterprise AI workloads leveraging flexible and as-a-service consumption models. Hybrid Infrastructure includes zSystems and Distributed Infrastructure.


zSystems (also referred to as IBM Z): the premier transaction processing platform with leading security, resilience and scale, highly optimized for mission-critical, high-volume transaction workloads and enabled for enterprise AI and hybrid cloud. It includes zSystems and LinuxONE, with a range of high-performance systems designed to address enterprise computing capacity, security and performance needs, z/OS, a security-rich, high-performance enterprise operating system, as well as Linux and other operating systems.


Distributed Infrastructure: includes Power, Storage, and IBM Cloud Infrastructure-as-a-Service (IaaS). Power consists of high-performance servers, designed and engineered for data intensive and AI-enabled workloads and optimized for hybrid cloud and Linux. The Storage portfolio consists of a broad range of storage hardware and software-defined offerings, including Z-attach and distributed flash, tape solutions, software-defined storage controllers, data protection software and network-attach storage. IBM Cloud IaaS is built on enterprise-grade hardware with leading security and compliance capabilities and offers flexible computing options across architectures to meet client workload needs.





Reasonable Country of Origin Inquiry


IBM conducted a good faith reasonable country of origin inquiry regarding 3TG. This inquiry was designed to determine whether any of the 3TG originated in the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, or Angola (collectively Covered Countries), and whether any of the Conflict Minerals may be from recycled or scrap sources.


IBM’s Conflict Minerals Due Diligence Design


IBM’s due diligence measures for 3TG conforms in all applicable respects to the framework outlined in the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including Annex II and the related supplements pertaining to downstream companies (OECD Guidance).


IBM is not a direct purchaser of ore or unrefined minerals; it is several tiers “downstream” from the smelters or refiners (SORs) of such minerals. SORs are at a point in the supply chain where ore, concentrates, and/or scrap material are converted to metal. IBM, like many downstream companies, does not have direct business relationships with SORs or visibility to the extraction and movement of 3TG between SORs and upstream entities. This position increases the difficulty of determining the origin of the 3TG in IBM products and, as a result, IBM relies on established industry processes and information provided by its in-scope direct suppliers.


Description of Due Diligence Measures Performed


IBM upholds a high standard of due diligence to meet legal requirements and internationally accepted standards, with the ultimate goal of establishing and maintaining a responsible supply chain for 3TG. IBM aligns its Responsible Minerals Policy with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs). As a member of the Responsible Minerals Initiative (RMI) our due diligence process utilizes RMI resources including the Conflict Minerals Reporting Template (CMRT) and the Responsible Minerals Assurance Process (RMAP), augmented by the London Bullion Market Association (LBMA), the Responsible Jewellery Council Chain of Custody Standard (RJC CoC), and the Tungsten Industry – Conflict Minerals Council (TI-CMC). The RMAP, LBMA, RJC CoC, and TI-CMC use independent third-party audits to identify SORs that have systems in place to ensure focus minerals are sourced responsibly. RMAP, LBMA, RJC CoC, and TI-CMC are recognized by the industry as third-party validation schemes. Independently, IBM also conducts further due diligence on SORs only processing 3TG recycled scrap as a part of our sustainability commitment.


Below is a description of the due diligence measures performed by IBM for the Reporting Period, based on the OECD Guidance:


1. OECD Step 1: Establish strong company management systems


§Positioned the IBM Responsible Minerals team within IBM’s Global Procurement organization to orchestrate the execution of IBM's 3TG Program.


§The IBM Responsible Minerals team reports through IBM’s Chief Procurement Officer and this Report is reviewed by IBM’s Senior Vice President of Infrastructure. During the year, we reported to IBM’s Global Procurement management on topics such as CMRT collection efforts, in-scope supplier progress, SOR risk mitigation, and driving identified SORs toward RMAP, LBMA, RJC CoC, or TI-CMC engagement.





§Implemented IBM’s Responsible Minerals Policy to include 3TG from the Covered Countries and CAHRAs. This policy outlines IBM’s dedication to ethical and responsible minerals sourcing due diligence consistent with the OECD Guidance. This policy also emphasizes IBM’s expectations with its hardware suppliers for sourcing minerals ethically and responsibly. Our policy is publicly available and can be found at https://www.ibm.com/procurement/responsibleminerals


§Designated members of the Responsible Minerals team engaged with in-scope suppliers, fostering collaboration, providing invaluable support, and offering expert guidance to facilitate the realization of the objectives outlined within IBM's Responsible Minerals program.


§Utilized a well-established communication portal for both internal and external stakeholders to report concerns about 3TG, directing them to the independent Ombudsman Office of IBM for resolution at: https://www.ibm.com/procurement/ombudsman-information


§Included Responsible Minerals requirements in standard contract templates: All IBM’s hardware suppliers are required to sign a contract agreement to only source minerals responsibly, in alignment with IBM’s Responsible Minerals Policy.


2. OECD Step 2: Identify and assess risks in the supply chain


§Requested IBM’s in-scope suppliers to survey their upstream suppliers twice per year to identify SORs and related 3TG information through the RMI CMRT.


§Oversaw the aggregation of supplier CMRTs and conducted comprehensive evaluations of the data contained within, aligning with IBM's stringent validation criteria, and adhering to the guidelines outlined by the OECD.


§Utilized curated data from RMI, supplemented by extensive research, to discern the potential provenance of 3TG present in IBM products, particularly scrutinizing any trace of origin from the designated Covered Countries and CAHRAs.


§Validated SORs status to confirm compliance with either RMAP, LBMA, RJC CoC, and/or TI-CMC standards.


§In situations when a nonconformant SOR was identified, the Responsible Minerals team collaborated and supported firms across multiple layers of the supply chain to trace and transition from use of the SOR.


§Deployed a third-party analytics tool to conduct a comprehensive evaluation of specific SORs for ownership risk.


3. OECD Step 3: Design and implement a strategy to respond to identified risks


§IBM requested suppliers to promptly transition away from SORs that had not been validated as conformant or active by a recognized third-party assessment scheme.


§Extended Responsible Minerals support beyond first-tier suppliers. We continued one-on-one training and joint outreach for new suppliers or personnel.


§Participated in the annual Responsible Minerals Initiative conference and forged strategic alliances with industry peers across the supply chain spectrum and relevant industry consortiums, harnessing efforts toward the establishment of an ethical and conscientious minerals-sourcing supply chain.


§Remained at the vanguard of macro-level Conflict Minerals discourse and advancements by actively engaging in the RMI, ensuring a comprehensive understanding of pertinent issues and evolving trends in the field.





§Implemented a strategic shift away from non-participatory or non-compliant SORs, redirecting focus towards those aligned with accredited schemes such as RMAP, LBMA, RJC, and/or TI-CMC, thereby ensuring adherence to stringent regulatory standards and industry best practices.


4. OECD Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices


§Contributed to the advancement of RMI endeavors by actively engaging in collaborative RMI workgroups, thereby fostering synergy and innovation in the pursuit of responsible mineral-sourcing practices.


§Since its inception, supported RMI’s RMAP accreditation of SORs engaged in Responsible Minerals to build a global network of validated sources of material meeting the needs of IBM’s Responsible Minerals Policy. With the backing of over 500 members in RMI, the network of accredited SORs has grown considerably allowing for downstream companies to utilize greater percentages of third-party verified 3TG.


§Served as the exclusive liaison for designated SORs lacking accredited status, collaborating closely with RMI's smelter engagement teams to facilitate and advocate for their integration into third-party validation schemes such as RMAP and others.


§Participated in teleconferences with SORs to discuss matters regarding RMAP, such as understanding the dynamics of the SORs and downstream users of 3TG, SOR participation in the program, and retention of SORs in the program.


§Engaged in collaborative partnerships with metal organizations to explore the prospective expansion of third-party audit frameworks, fostering enhanced accountability and transparency within the responsible minerals and smelting sector.


§Delved into and advocated for expanded cross-recognition audit initiatives within the RMAP, thereby providing SORs with a broader array of audit program options compliant with both US and EU regulatory frameworks.


5. OECD Step 5: Report annually on supply chain due diligence


§According to the Rule, annually file Form SD and Exhibit 1.01 (Conflict Minerals Report).


§Published the 2022 Conflict Minerals Report on IBM’s Responsible Minerals website https://www.ibm.com/procurement/responsibleminerals


§Incorporated updates on the advancements made in Responsible Minerals management within IBM's annual Impact Report, exemplifying our steadfast commitment to transparency and accountability in responsible minerals and smelting practices.


§Retained records related to 3TG in conformance with IBM’s records retention policy.


Reporting Period Determination and Findings


Based on the information obtained through the due diligence process described herein, IBM believes SORs that may be used to process the 3TG contained in IBM products are listed in Appendix A. The list identifies SORs present at year-end 2023. Further, as listed in Appendix B, IBM has reasonably determined the potential countries of origin of the 3TG in IBM products.


The following chart illustrates the composition of 245 3TG SORs in IBM’s supply chain that (as of December 31) were conformant or actively participating in a third-party scheme or were processing 100 percent recycled scrap.







IBM’s progress in this area since 2016 is illustrated below and reflects that, at year-end 2023, 100 percent of 3TG SORs reported in the IBM supply chain are pursuing or are accredited as conformant to a recognized third-party validation scheme (or operating as refiners of 100 percent recycled 3TG). This is the fifth consecutive year of IBM’s supply chain achieving this level of performance.


From 2016 onward, SORs that were active in a recognized third-party validation scheme in addition to RMAP (LBMA, RJC, and/or TI-CMC) were added to the conformant category. In 2019 and beyond, IBM included in the conformant category SORs that do not seek third-party validation but are determined to operate solely from recycled or scrap sources – which the Rule designates as Conflict-Free.




IBM Requirement for Suppliers to be Conflict-Free


During 2023, IBM continued its initiative to have all in-scope direct suppliers achieve a conformant supply chain as defined by its Responsible Minerals Policy. In-scope direct suppliers with CMRTs containing SORs that are not progressing toward, or have not already received conflict-free accreditation, are required to transition those SORs from products provided to IBM. The IBM Responsible Minerals team and the Global Procurement organization work with those suppliers to help them achieve this goal. Their progress is tracked and reported to IBM Global Procurement executives monthly along with IBM’s progress toward attaining 100 percent conformant status. IBM has received CMRTs from 100 percent of our in-scope suppliers, containing over 99.8 percent reporting of the extended supply chain.





IBM’s Next Steps to Mitigate Conflict Minerals Risk


IBM expects to take the following steps to enhance its due diligence measures and to continue mitigating the risk that the 3TG contained in IBM products finance or benefit armed groups in the Covered Countries:


§Participating in the RMI contributes to the continued development of collaborative tools and resources for companies to assess their supply chains and avoid the inclusion of non-validated Conflict Minerals 3TG in the extended supply chain.


§Remain aware of developments in 3TG due diligence processes by participation in the RMI and apply that knowledge to IBM’s 3TG risk assessment and mitigation actions.


§As an ardent supporter of Environmental and Social stewardship, IBM continues to grow usage of 3TG SORs processing 100 percent recycled scrap.


§Work with RMI members and IBM in-scope suppliers to gain SOR’s commitment for their continued engagement with an RMAP assessment or another recognized validation scheme.


§Pursue resolution in 2024 for any identified SORs in IBM’s supply chain that are not validated as conformant to one of the recognized assessment schemes.


§Improve in-scope direct suppliers’ CMRT upstream supplier completeness; provide collaboration from IBM and other upstream suppliers to attain 100 percent upstream coverage.


§Drive in-scope direct suppliers to provide product-specific CMRTs versus company-level CMRTs, as company-level CMRTs may include SORs not used in the supply chain for IBM products; use of product-specific CMRTs by in-scope direct suppliers enables IBM to have a more precise list of SORs used in IBM products.


§Engage IBM Hardware Development and Global Procurement on future products to ascertain the conformant status of SORs to be used by the proposed in-scope direct suppliers. Eliminate the use of nonconformant SORs before introducing the product to the marketplace.


IBM’s Support of the RMI


As outlined in the OECD Guidance, the internationally recognized standard on which IBM’s due diligence is based, IBM supports an industry initiative that audits the due diligence activities of SORs. That industry initiative is the RMI’s RMAP. The potential countries of origin found in Appendix B, and upon which IBM relied for certain statements in this Report, were obtained through RMI and other accreditation source data. IBM is an active contributor to the RMI through our participation in various working groups. IBM’s member ID is MIBM.





Appendix A


Smelters or Refiners (SORs) that may be used to process 3TG contained in IBM Products.


SOR Status (as of December 31, 2023):


§“Conformant” indicates the SOR has completed an assessment and is listed by the RMAP, LBMA Good Delivery List, RJC Chain-of-Custody, or TI-CMC websites.


§“Active” indicates that the SOR is in the process of conformance assessment by one or more of the recognized third-party validation schemes.


§“Recycled Scrap” indicates that the SOR has demonstrated conformance to criteria for a facility processing only recycled or scrap materials and is currently not participating in one of the noted validation schemes.


IBM 2023 Conflict Minerals Report - Appendix A
(SORs for year-end 2023 with 3rd Party Assessment Status as of Dec 31, 2023)

Legend SOR Status:  Conformant or Active (RMAP, LBMA, RJC, Ti-CMC),
or Recycled Scrap (IBM)


Metal Smelter Name 2023 Status
Tantalum AMG Brasil Conformant (RMAP)
Tantalum D Block Metals, LLC Conformant (RMAP)
Tantalum F&X Electro-Materials Ltd. Conformant (RMAP)
Tantalum FIR Metals & Resource Ltd. Conformant (RMAP)
Tantalum Global Advanced Metals Aizu Conformant (RMAP)
Tantalum Global Advanced Metals Boyertown Conformant (RMAP)
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. Active (RMAP)
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. Conformant (RMAP)
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. Conformant (RMAP)
Tantalum Jiangxi Tuohong New Raw Material Conformant (RMAP)
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. Conformant (RMAP)
Tantalum Jiujiang Tanbre Co., Ltd. Conformant (RMAP)
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. Conformant (RMAP)
Tantalum KEMET de Mexico Conformant (RMAP)
Tantalum Materion Newton Inc. Conformant (RMAP)
Tantalum Metallurgical Products India Pvt., Ltd. Conformant (RMAP)
Tantalum Mineracao Taboca S.A. Conformant (RMAP)
Tantalum Mitsui Mining and Smelting Co., Ltd. Conformant (RMAP)
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. Conformant (RMAP)
Tantalum NPM Silmet AS Conformant (RMAP)
Tantalum PowerX Ltd. Conformant (RMAP)
Tantalum QuantumClean Conformant (RMAP)
Tantalum Resind Industria e Comercio Ltda. Conformant (RMAP)





Metal Smelter Name 2023 Status
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. Conformant (RMAP)
Tantalum Taki Chemical Co., Ltd. Conformant (RMAP)
Tantalum TANIOBIS Co., Ltd. Conformant (RMAP)
Tantalum TANIOBIS GmbH Conformant (RMAP)
Tantalum TANIOBIS Japan Co., Ltd. Conformant (RMAP)
Tantalum TANIOBIS Smelting GmbH & Co. KG Conformant (RMAP)
Tantalum Telex Metals Conformant (RMAP)
Tantalum Ulba Metallurgical Plant JSC Conformant (RMAP)
Tantalum Ximei Resource (Guangdong) Limited Conformant (RMAP)
Tantalum XinXing HaoRong Electronic Material Co., Ltd. Conformant (RMAP)
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. Conformant (RMAP)
Tin Alpha Conformant (RMAP)
Tin Aurubis Beerse Conformant (RMAP)
Tin Aurubis Berango Conformant (RMAP)
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. Conformant (RMAP)
Tin Chifeng Dajingzi Tin Industry Co., Ltd. Conformant (RMAP)
Tin China Tin Group Co., Ltd. Conformant (RMAP)
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Conformant (RMAP)
Tin CRM Synergies Conformant (RMAP)
Tin CV Ayi Jaya Conformant (RMAP)
Tin CV Venus Inti Perkasa Conformant (RMAP)
Tin Dowa Conformant (RMAP)
Tin DS Myanmar Conformant (RMAP)
Tin EM Vinto Conformant (RMAP)
Tin Estanho de Rondonia S.A. Conformant (RMAP)
Tin Fabrica Auricchio Industria e Comercio Ltda. Conformant (RMAP)
Tin Fenix Metals Conformant (RMAP)
Tin Gejiu Non-Ferrous Metal
Processing Co., Ltd.
Conformant (RMAP)

Guangdong Hanhe Non-Ferrous

Metal Co., Ltd.

Conformant (RMAP)
Tin HuiChang Hill Tin Industry Co., Ltd. Conformant (RMAP)
Tin Jiangxi New Nanshan Technology Ltd. Conformant (RMAP)
Tin Luna Smelter, Ltd. Conformant (RMAP)
Tin Magnu's Minerais Metais e Ligas Ltda. Conformant (RMAP)
Tin Malaysia Smelting Corporation (MSC) Conformant (RMAP)
Tin Ma'anshan Weitai Tin Co., Ltd. Active (RMAP)
Tin Metallic Resources, Inc. Conformant (RMAP)
Tin Mineracao Taboca S.A. Conformant (RMAP)
Tin Minsur Conformant (RMAP)
Tin Mining Minerals Resources SARL Conformant (RMAP)
Tin Mitsubishi Materials Corporation Conformant (RMAP)
Tin O.M. Manufacturing (Thailand) Co., Ltd. Conformant (RMAP)
Tin O.M. Manufacturing Philippines, Inc. Conformant (RMAP)





Metal Smelter Name 2023 Status
Tin Operaciones Metalurgicas S.A. Conformant (RMAP)
Tin Precious Minerals and Smelting Limited  Active (RMAP)
Tin PT Aries Kencana Sejahtera Conformant (RMAP)
Tin PT Artha Cipta Langgeng Conformant (RMAP)
Tin PT ATD Makmur Mandiri Jaya Conformant (RMAP)
Tin PT Babel Inti Perkasa Conformant (RMAP)
Tin PT Babel Surya Alam Lestari Conformant (RMAP)
Tin PT Bangka Prima Tin Conformant (RMAP)
Tin PT Bangka Serumpun Conformant (RMAP)
Tin PT Bangka Tin Industry Active (RMAP)
Tin PT Belitung Industri Sejahtera Active (RMAP)
Tin PT Bukit Timah Conformant (RMAP)
Tin PT Cipta Persada Mulia Conformant (RMAP)
Tin PT Menara Cipta Mulia Conformant (RMAP)
Tin PT Mitra Stania Prima Conformant (RMAP)
Tin PT Mitra Sukses Globalindo Conformant (RMAP)
Tin PT Premium Tin Indonesia Conformant (RMAP)
Tin PT Prima Timah Utama Conformant (RMAP)
Tin PT Putera Sarana Shakti (PT PSS) Conformant (RMAP)
Tin PT Rajawali Rimba Perkasa Conformant (RMAP)
Tin PT Rajehan Ariq Conformant (RMAP)
Tin PT Refined Bangka Tin Conformant (RMAP)
Tin PT Sariwiguna Binasentosa Conformant (RMAP)
Tin PT Stanindo Inti Perkasa Conformant (RMAP)
Tin PT Sukses Inti Makmur (SIM) Conformant (RMAP)
Tin PT Timah Tbk Kundur Conformant (RMAP)
Tin PT Timah Tbk Mentok Conformant (RMAP)
Tin PT Tinindo Inter Nusa Conformant (RMAP)
Tin PT Tommy Utama Conformant (RMAP)
Tin Resind Industria e Comercio Ltda. Conformant (RMAP)
Tin Rui Da Hung Conformant (RMAP)
Tin Super Ligas Conformant (RMAP)
Tin Thaisarco Conformant (RMAP)
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. Conformant (RMAP)
Tin Tin Technology & Refining Conformant (RMAP)
Tin White Solder Metalurgia e Mineracao Ltda. Conformant (RMAP)
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. Conformant (RMAP)
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. Conformant (RMAP)
Tungsten A.L.M.T. Corp. Conformant (RMAP, TI-CMC)
Tungsten Asia Tungsten Products Vietnam Ltd. Conformant (RMAP)
Tungsten China Molybdenum Tungsten Co., Ltd. Conformant (RMAP)
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Cronimet Brasil Ltda Conformant (RMAP)
Tungsten Fujian Xinlu Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)





Metal Smelter Name 2023 Status
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. Conformant (RMAP)
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Global Tungsten & Powders LLC. Conformant (RMAP, TI-CMC)
Tungsten Guangdong Xianglu Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Hubei Green Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Hunan Chenzhou Mining Co., Ltd. Conformant (RMAP)
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch Conformant (RMAP, TI-CMC)
Tungsten Japan New Metals Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Kenee Mining Corporation Vietnam Active (RMAP)
Tungsten Kennametal Fallon Conformant (RMAP, TI-CMC)
Tungsten Kennametal Huntsville Conformant (RMAP, TI-CMC)
Tungsten Lianyou Metals Co., Ltd. Conformant (RMAP)
Tungsten Lianyou Resources Co., Ltd. Active (RMAP)
Tungsten Malipo Haiyu Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Masan High-Tech Materials Conformant (RMAP, TI-CMC)
Tungsten Niagara Refining LLC Conformant (RMAP, TI-CMC)
Tungsten Philippine Chuangxin Industrial Co., Inc. Conformant (RMAP, TI-CMC)
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. Conformant (RMAP)
Tungsten Taniobis Smelting GmbH & Co. KG Conformant (RMAP, TI-CMC)
Tungsten Tungsten Vietnam Joint Stock Company Conformant (RMAP)
Tungsten Wolfram Bergbau und Hutten AG Conformant (RMAP, TI-CMC)
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. Conformant (RMAP, TI-CMC)
Tungsten Xiamen Tungsten Co., Ltd. Conformant (RMAP, TI-CMC)
Gold 8853 S.p.A. Conformant (RJC)
Gold Abington Reldan Metals, LLC Conformant (RMAP)
Gold Advanced Chemical Company Active (RMAP)
Gold Agosi AG Conformant (LBMA, RMAP)
Gold Aida Chemical Industries Co., Ltd. Conformant (RMAP)
Gold Al Etihad Gold Refinery DMCC Conformant (RJC)
Gold Alexy Metals Recycled Scrap
Gold Almalyk Mining and Metallurgical Complex (AMMC) Conformant (LBMA, RMAP)
Gold AngloGold Ashanti Corrego do Sitio Mineracao Conformant (LBMA, RMAP)
Gold Argor-Heraeus S.A. Conformant (LBMA, RJC, RMAP)
Gold Asahi Pretec Corp. Conformant (LBMA, RMAP)
Gold Asahi Refining Canada Ltd. Conformant (LBMA, RMAP)





Metal Smelter Name 2023 Status
Gold Asahi Refining USA Inc. Conformant (LBMA, RMAP)
Gold Asaka Riken Co., Ltd. Conformant (RMAP)
Gold Augmont Enterprises Private Limited Conformant (RJC)
Gold Aurubis AG Conformant (LBMA, RMAP)
Gold Bangalore Refinery Active (RMAP)
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Conformant (LBMA, RMAP)
Gold Boliden AB Conformant (LBMA, RMAP)
Gold C. Hafner GmbH + Co. KG Conformant (LBMA, RJC, RMAP)
Gold CCR Refinery - Glencore Canada Corporation Conformant (LBMA, RMAP)
Gold Cendres + Metaux S.A. Conformant (RJC)
Gold Chimet S.p.A. Conformant (LBMA, RMAP)
Gold Chugai Mining Conformant (RMAP)
Gold Daye Non-Ferrous Metals Mining Ltd. Conformant (LBMA)
Gold Dowa Conformant (RMAP)
Gold DSC (Do Sung Corporation) Conformant (RMAP)
Gold Eco-System Recycling Co., Ltd. East Plant Conformant (RMAP)
Gold Eco-System Recycling Co., Ltd. North Plant Conformant (RMAP)
Gold Eco-System Recycling Co., Ltd. West Plant Conformant (RMAP)
Gold Coimpa Industrial LTDA Conformant (RMAP)
Gold GG Refinery Ltd. Active (RMAP)
Gold GGC Gujrat Gold Centre Pvt. Ltd. Active (RMAP)
Gold Gold by Gold Colombia Conformant (RMAP)
Gold Gold Refinery of Zijin Mining Group Co., Ltd. Conformant (LBMA, RMAP)
Gold Great Wall Precious Metals Co., Ltd. of CBPM Conformant (LBMA)
Gold Heimerle + Meule GmbH Conformant (LBMA, RMAP)
Gold Heraeus Germany GmbH Co. KG Conformant (LBMA, RMAP)
Gold Heraeus Metals Hong Kong Ltd. Conformant (LBMA, RJC, RMAP)
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. Conformant (LBMA, RMAP)
Gold Ishifuku Metal Industry Co., Ltd. Conformant (LBMA, RMAP)
Gold Istanbul Gold Refinery Conformant (LBMA, RMAP)
Gold Italpreziosi Conformant (LBMA, RJC, RMAP)
Gold Japan Mint Conformant (LBMA, RMAP)
Gold Jiangxi Copper Co., Ltd. Conformant (LBMA, RMAP)
Gold JX Nippon Mining & Metals Co., Ltd. Conformant (LBMA, RMAP)
Gold Kazzinc Conformant (LBMA, RMAP)
Gold Kennecott Utah Copper LLC Conformant (LBMA, RMAP)
Gold KGHM Polska Miedz Spolka Akcyjna Conformant (LBMA, RMAP)
Gold Kojima Chemicals Co., Ltd. Conformant (RMAP)
Gold Korea Zinc Co., Ltd. Conformant (RMAP)
Gold L'Orfebre S.A. Conformant (RMAP)
Gold LS MnM Inc. Conformant (LBMA, RMAP)
Gold LT Metal Ltd. Conformant (RMAP)
Gold Materion Conformant (RMAP)





Metal Smelter Name 2023 Status
Gold Matsuda Sangyo Co., Ltd. Conformant (LBMA, RMAP)
Gold Metal Concentrators SA (Pty) Ltd. Conformant (RJC, RMAP)
Gold Metalor Technologies (Hong Kong) Ltd. Conformant (LBMA, RJC, RMAP)
Gold Metalor Technologies (Singapore) Pte., Ltd. Conformant (LBMA, RJC, RMAP)
Gold Metalor Technologies (Suzhou) Ltd. Conformant (LBMA, RJC, RMAP)
Gold Metalor Technologies S.A. Conformant (LBMA, RJC, RMAP)
Gold Metalor USA Refining Corporation Conformant (LBMA, RJC, RMAP)
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Conformant (LBMA, RMAP)
Gold Mitsubishi Materials Corporation Conformant (LBMA, RMAP)
Gold Mitsui Mining and Smelting Co., Ltd. Conformant (LBMA, RMAP)
Gold MKS PAMP SA Conformant (LBMA, RMAP)
Gold MMTC-PAMP India Pvt., Ltd. Conformant (LBMA, RMAP)
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Conformant (LBMA, RMAP)
Gold Navoi Mining and Metallurgical Combinat Conformant (LBMA, RMAP)
Gold NH Recytech Company Recycled Scrap
Gold Nihon Material Co., Ltd. Conformant (LBMA, RMAP)
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Conformant (RJC, RMAP)
Gold Ohura Precious Metal Industry Co., Ltd. Conformant (RMAP)
Gold Planta Recuperadora de Metales SpA Conformant (RMAP)
Gold PT Aneka Tambang (Persero) Tbk Conformant (LBMA, RMAP)
Gold PX Precinox S.A. Conformant (LBMA, RMAP)
Gold Rand Refinery (Pty) Ltd. Conformant (LBMA, RMAP)
Gold REMONDIS PMR B.V. Conformant (LBMA, RMAP)
Gold Royal Canadian Mint Conformant (LBMA, RMAP)
Gold SAAMP Conformant (RJC)
Gold Safimet S.p.A Conformant (RJC)
Gold SAFINA A.S. Conformant (RMAP)
Gold Samduck Precious Metals Recycled Scrap
Gold SEMPSA Joyeria Plateria S.A. Conformant (LBMA, RJC, RMAP)
Gold Shandong Gold Smelting Co., Ltd. Conformant (LBMA, RMAP)
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. Conformant (LBMA, RMAP)
Gold Sichuan Tianze Precious Metals Co., Ltd. Conformant (LBMA, RMAP)
Gold Singway Technology Co., Ltd. Recycled Scrap
Gold Solar Applied Materials Technology Corp. Conformant (LBMA, RMAP)
Gold Sumitomo Metal Mining Co., Ltd. Conformant (LBMA, RMAP)
Gold SungEel HiMetal Co., Ltd. Conformant (RMAP)
Gold T.C.A S.p.A Conformant (LBMA, RMAP)
Gold Tanaka Kikinzoku Kogyo K.K. Conformant (LBMA, RMAP)
Gold Tokuriki Honten Co., Ltd. Conformant (LBMA, RMAP)
Gold TOO Tau-Ken-Altyn Conformant (LBMA, RMAP)
Gold Torecom Conformant (RMAP)
Gold Umicore Precious Metals Thailand Recycled Scrap
Gold Umicore S.A. Business Unit Precious Metals Refining Conformant (LBMA)





Metal Smelter Name 2023 Status
Gold United Precious Metal Refining, Inc. Conformant (RMAP)
Gold Valcambi S.A. Conformant (LBMA, RJC, RMAP)
Gold Western Australian Mint (T/a The Perth Mint) Conformant (LBMA, RMAP)
Gold WIELAND Edelmetalle GmbH Conformant (RJC, RMAP)
Gold Yamakin Co., Ltd. Conformant (RMAP)
Gold Yokohama Metal Co., Ltd. Conformant (RMAP)
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation Conformant (LBMA, RMAP)


Appendix B


Reasonable Country of Origin Inquiry for Conflict Minerals associated with the SORs listed in Appendix A

(Based on RMI, LBMA, RJC, and TI-CMC accreditation source data)


IBM RCOI Data 2023
Country of Origin
(Alphabetical List) -
RJC, Ti-CMC due
Material Origin Country of Origin
(Alphabetical List) -
RJC, Ti-CMC due
Material Origin
Algeria Recycled Scrap Brazil Mined Ores & Recycled Scrap
Andorra Recycled Scrap Bulgaria Recycled Scrap
Antigua and Barbuda Recycled Scrap Burkina Faso Mined Ores & Recycled Scrap
Argentina Mined Ores & Recycled Scrap Burundi Mined Ores
Australia Mined Ores & Recycled Scrap Cambodia Mined Ores
Austria Mined Ores & Recycled Scrap Cameroon Recycled Scrap
Azerbaijan Mined Ores Canada Mined Ores & Recycled Scrap
Bahamas Recycled Scrap Cayman Islands Recycled Scrap
Bangladesh Recycled Scrap Chile Mined Ores & Recycled Scrap
Barbados Recycled Scrap China Mined Ores & Recycled Scrap
Belarus Recycled Scrap Chinese Taipei (Taiwan) Recycled Scrap
Belgium Recycled Scrap Colombia Mined Ores & Recycled Scrap
Benin Mined Ores & Recycled Scrap Congo, Democratic Republic of the Mined Ores & Recycled Scrap
Bolivia (Plurinational State of) Mined Ores & Recycled Scrap Costa Rica Recycled Scrap
Bosnia and Herzegovina Recycled Scrap Côte d'Ivoire (Ivory Coast) Mined Ores & Recycled Scrap
Botswana Mined Ores Croatia Recycled Scrap





IBM RCOI Data 2023
Country of Origin
(Alphabetical List) -
RJC, Ti-CMC due
Material Origin Country of Origin
(Alphabetical List) -
RJC, Ti-CMC due
Material Origin
Curacao Recycled Scrap Kuwait Recycled Scrap
Cyprus Recycled Scrap Kyrgyzstan Mined Ores & Recycled Scrap
Czech Republic Recycled Scrap Lao People's Democratic Republic Mined Ores
Denmark Recycled Scrap Latvia Recycled Scrap
Dominican Republic Mined Ores & Recycled Scrap Lebanon Recycled Scrap
Ecuador Mined Ores & Recycled Scrap Liberia Mined Ores
Egypt Mined Ores & Recycled Scrap Liechtenstein Recycled Scrap
El Salvador Recycled Scrap Lithuania Recycled Scrap
Estonia Recycled Scrap Luxembourg Recycled Scrap
Ethiopia Mined Ores Macau Recycled Scrap
Fiji Mined Ores Madagascar Mined Ores
Finland Mined Ores & Recycled Scrap Malaysia Mined Ores & Recycled Scrap
France and French Guiana Mined Ores & Recycled Scrap Mali Mined Ores & Recycled Scrap
Georgia Mined Ores & Recycled Scrap Malta Recycled Scrap
Germany Recycled Scrap Mauritania Mined Ores
Ghana Mined Ores & Recycled Scrap Mauritius Recycled Scrap
Greece Recycled Scrap Mexico Mined Ores & Recycled Scrap
Grenada Recycled Scrap Monaco Recycled Scrap
Guatemala Mined Ores & Recycled Scrap Mongolia Mined Ores
Guinea Mined Ores Morocco Mined Ores & Recycled Scrap
Guyana Mined Ores Mozambique Mined Ores
Honduras Mined Ores & Recycled Scrap Myanmar Mined Ores
Hong Kong Recycled Scrap Namibia Mined Ores & Recycled Scrap
Hungary Recycled Scrap Netherlands Recycled Scrap
Iceland Recycled Scrap New Zealand Mined Ores & Recycled Scrap
India Recycled Scrap Nicaragua Mined Ores
Indonesia Mined Ores & Recycled Scrap Republic of the Niger Mined Ores & Recycled Scrap
Ireland Recycled Scrap Nigeria Mined Ores & Recycled Scrap
Israel Recycled Scrap Norway Recycled Scrap
Italy Recycled Scrap Oman Mined Ores & Recycled Scrap
Jamaica Recycled Scrap Pakistan Recycled Scrap
Japan Mined Ores & Recycled Scrap Panama Mined Ores & Recycled Scrap
Jordan Recycled Scrap Papua New Guinea Mined Ores
Kazakhstan Mined Ores & Recycled Scrap Peru Mined Ores & Recycled Scrap
Kenya Mined Ores & Recycled Scrap Philippines Mined Ores & Recycled Scrap
Korea, Republic of Mined Ores & Recycled Scrap Poland Recycled Scrap





IBM RCOI Data 2023
Country of Origin
(Alphabetical List) -
RJC, Ti-CMC due
Material Origin Country of Origin
(Alphabetical List) -
RJC, Ti-CMC due
Material Origin
Portugal Recycled Scrap Sweden Mined Ores & Recycled Scrap
Puerto Rico Recycled Scrap Switzerland Recycled Scrap
Romania Recycled Scrap Tajikistan Recycled Scrap
Russian Federation* Mined Ores & Recycled Scrap Tanzania Mined Ores & Recycled Scrap
Rwanda Mined Ores Thailand Mined Ores & Recycled Scrap
Saint Kitts and Nevis Recycled Scrap Trinidad and Tobago Recycled Scrap
Saudi Arabia Mined Ores & Recycled Scrap Tunisia Recycled Scrap
Senegal Mined Ores & Recycled Scrap Turkey Mined Ores & Recycled Scrap
Serbia Mined Ores & Recycled Scrap Turks and Caicos Recycled Scrap
Sierra Leone Mined Ores Uganda Mined Ores
Singapore Recycled Scrap Ukraine Recycled Scrap
Sint Maarten Recycled Scrap United Arab Emirates Recycled Scrap
Slovakia Recycled Scrap United Kingdom of Great Britain and Northern Ireland Mined Ores & Recycled Scrap
Slovenia Recycled Scrap United States of America Mined Ores & Recycled Scrap
South Africa Mined Ores & Recycled Scrap Uruguay Recycled Scrap
Spain Mined Ores & Recycled Scrap Uzbekistan Mined Ores & Recycled Scrap
St Vincent and Grenadines Recycled Scrap Vietnam Mined Ores
Sudan Mined Ores Zambia Mined Ores
Suriname Mined Ores Zimbabwe Mined Ores


RCOI: Reasonable Country of Origin Inquiry. Data provided in aggregated fashion by the third parties noted.


* In 2022, IBM carried out an orderly wind-down of its business in Russia. During 2023, RMI and other accreditation source data continued identifying the Russian Federation as a country of origin for 3TG. IBM has no affirmative knowledge that minerals from this country are incorporated into finished products furnished to IBM. To the extent that minerals from this country were used, they would have been substantially transformed outside of the United States in a third country by a non-U.S. person before being incorporated into production of certain products that IBM manufactures or contracts to manufacture.




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