UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Polestar Automotive Holding UK PLC
(Exact Name of Registrant as Specified in Charter)
| England and Wales | 001-41431 | |
| (State or other jurisdiction of incorporation or organization) | (Commission File Number) |
Assar Gabrielssons Väg 9
405 31 Gothenburg, Sweden
(Address of principal executive offices) (Zip Code)
Michael Lohscheller
Chief Executive Officer
Tel: +1 551 284 9479
(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 submitted, 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, 2024. |
| ¨ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended . |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
A copy of the Conflict Minerals Report of Polestar Automotive Holding UK PLC (the “Company”) for the reporting period from January 1, 2024 to December 31, 2024 is filed as Exhibit 1.01 hereto.
The Company’s Conflict Minerals Report is also publicly available on the Company’s website at https://www.polestar.com/global/legal/ethics/. The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and the Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.
Item 1.02 Exhibit
The Company has filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable
Section 3 - Exhibits
Item 3.01 Exhibits
| Exhibit No. | Description |
| 1.01 | Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. |
| 2 |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has caused this report to be signed on its behalf by the undersigned, hereunto duly authorized.
| POLESTAR AUTOMOTIVE HOLDING UK PLC | |||
| By: | /s/ Michael Lohscheller | Date: May 30, 2025 | |
| Name: | Michael Lohscheller | ||
| Title: | Chief Executive Officer | ||
| By: | /s/ Jean-François Mady | Date: May 30, 2025 | |
| Name: | Jean-François Mady | ||
| Title: | Chief Financial Officer | ||
| 3 |
Exhibit 1.01
Conflict Minerals Report by Polestar
For the Year Ending December 31, 2024
Company Overview
This report has been prepared by the management of Polestar Automotive Holding UK PLC (herein referred to as “Polestar,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated.
Polestar is the Swedish electric performance car brand with a focus on uncompromised design and innovation, and the ambition to accelerate the change towards a sustainable future. Headquartered in Gothenburg, Sweden, its cars are available in 27 markets globally across North America, Europe and Asia Pacific.
Polestar has three models in its line-up: Polestar 2, Polestar 3, and Polestar 4. Planned models include the Polestar 5 four-door GT (to be introduced in 2025), the Polestar 6 roadster and the Polestar 7 compact SUV. With its vehicles currently manufactured on two continents, North America and Asia, Polestar plans to diversify its manufacturing footprint further, with production of Polestar 7 planned in Europe.
Polestar has an unwavering commitment to sustainability and has set an ambitious roadmap to reach its climate targets: halve greenhouse gas emissions by 2030 per-vehicle-sold and become climate-neutral across its value chain by 2040. Polestar’s comprehensive sustainability strategy covers the four areas of Climate, Transparency, Circularity, and Inclusion.
Forward-Looking Statements
This Report includes statements that express Polestar’s opinions, expectations, beliefs, plans, objectives, assumptions or projections regarding future events or future results and therefore are, or may be deemed to be, “forward-looking statements” as defined in Section 27A of the U.S. Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, that involve significant risks and uncertainties. These forward-looking statements can generally be identified by the use of forward-looking terminology, including the terms “believes,” “estimates,” “anticipates,” “expects,” “seeks,” “projects,” “intends,” “plans,” “may,” “will” or “should” or, in each case, their negative or other variations or comparable terminology. These forward-looking statements include all matters that are not historical facts. They appear in a number of places throughout this Report and include statements regarding Polestar’s intentions, beliefs or current expectations concerning, among other things: the due diligence of suppliers, risk mitigation measures, and efforts to increase transparency through data collection and risk evaluation. These forward-looking statements involve a number of risks, uncertainties (some of which are beyond Polestar’s control) or other assumptions that may cause actual results or performance to be materially different from those expressed or implied by these forward-looking statements. These risks and uncertainties include, but are not limited to, those factors described in the section entitled “Risk Factors” and “Cautionary Note Regarding Forward-Looking Statements” in Polestar’s Form 20-F, and other documents filed, or to be filed, with the SEC by Polestar. Should one or more of these risks or uncertainties materialize, or should any of the assumptions prove incorrect, actual results may vary in material respects from those projected in these forward-looking statements. Polestar will not undertake any obligation to update or revise any forward-looking statements, whether as a result of new information, future events or otherwise, except as may be required under applicable securities laws.
Internal Information - Polestar
Introduction
For the 2024 calendar year, Polestar determined that tin, tungsten, tantalum, and/or gold (3TGs) were necessary to the functionality or production of its Polestar 2, Polestar 3 and Polestar 4 product lines that were manufactured or contracted to be manufactured. Therefore, Polestar conducted a reasonable country of origin inquiry in good faith to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Democratic Republic of the Congo (DRC) or an adjoining country (collectively referred to as the “Covered Countries”).
Based on the country of origin data, Polestar believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question to determine whether its products are “conflict free or responsibly sourced.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of 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 and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).
Polestar is committed to complying with the requirements and upholding responsible sourcing practices. As such the Company has put into place a robust due diligence program to help ensure its contributions to upholding human rights and responsible practices across the supply chain.
Conflict Minerals Program & Policy
The Company has actively engaged with suppliers with respect to the use of conflict minerals. Polestar adopted a Conflict Minerals Position articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals. The Conflict Minerals Position is available online, and can be found here:
https://www.polestar.com/global/legal/ethics/
The Company has contributed to industry efforts to address conflict minerals through involvement on the Polestar Board and through serving as an active and affiliate member of the Responsible Business Alliance (RBA) and the Responsible Minerals Initiative (RMI). This engagement and the contributions made have helped develop standards, best practices, and tools that benefit all companies working to end the link between 3TGs and conflict in the DRC.
Reasonable Country of Origin Inquiry
To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Polestar retained Assent Inc. (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. Polestar provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager. To trace materials, and demonstrate transparency procured by the supply chain, Polestar utilized the Conflict Minerals Reporting Template (CMRT) Version 6.4 or higher to conduct a survey of all in-scope suppliers.
For the 2024 calendar year, Volvo Cars has manufactured Polestar cars and contracted the suppliers of components and parts used in Polestar 2 and 3, and Geely has manufactured and contracted the suppliers of components and parts used in Polestar 4. During the CMRT campaign 2024/2025 there were 2 suppliers, Polestar’s business partner Volvo Cars and Geely, in scope of the conflict minerals program/survey. Volvo Cars and Geely provided a completed CMRT. The Company’s total response rate for this reporting year was 100%.
Internal Information - Polestar
In addition, Polestar conducted further actions to identify Tier 2 suppliers, which are Volvo Cars’ and Geely’s direct material suppliers, to track program gaps of Polestar 2,3 and 4 and discuss with our Tier 1 and business partners future improvement opportunities.
Polestar’s ambition is to use the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent, as it enters into further agreements with other manufacturing business partners as well direct supplier sourcing.
The Assent Compliance Manager enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management.
The Assent Compliance Manager also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform.
Via the Assent Compliance Manager and Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the Assent Compliance Manager for future reporting and transparency. According to the process, Polestar will contact suppliers that are unresponsive to Assent’s communications during the diligence process and request these suppliers to complete the CMRT and submit it to Assent.
Polestar’s program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 and Tier 2 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.
All submitted declaration forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors (see Appendix C for CMRT validation criteria). Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Polestar tracks program gaps to account for future improvement opportunities.
Through reasonable due diligence practices, Polestar was able to take advantage of a broader set of country-of-origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Polestar can determine all the possible countries minerals (such as 3TGs) used in its product originated from. As such, Polestar can then perform further due diligence on the source and chain of custody of the minerals in question.
Due Diligence
Polestar designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.
Internal Information - Polestar
Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot be fully owned by the Company. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps can be mitigated. This aligns with industry standards and market expectations for downstream companies’ due diligence.
| 1) | Establish Strong Company Management Systems |
Internal Compliance Team
Polestar has just finalized its conflict mineral campaign and has established a cross-functional Conflict Minerals Compliance Team led by our Inclusion Lead and our Supply Chain Inclusion Expert. The Conflict Minerals Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the result of these due diligence efforts.
Polestar also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that Polestar will undertake with suppliers and/or respective stakeholders about conflict minerals.
Polestar leverages Assent’s Managed Services to work with dedicated program specialists who support Polestar’s conflict minerals program. Polestar communicates regularly with the Assent team to receive updates on program status.
Control Systems
Polestar expects all of its manufacturers and suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Polestar are “conflict free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from areas that have been identified to be in the presence of widespread human rights abuses and violations of law either directly or indirectly. Polestar expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.
Our business partners, including Volvo Cars and Geely, are required to adhere to the principles set in our Code of Conduct for Business Partners. This code of conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Code of Conduct for Business partners outlines expectation for responsible sourcing of minerals and metals and is reviewed annually to ensure it continues to align with industry best practices.. The supplier code of conduct can be found here: https://www.polestar.com/global/legal/ethics/
Supplier Engagement
Polestar has a strong relationship with Tier 1 direct suppliers Volvo Cars and Geely and is also, through Volvo Cars and Geely, identifying response status of Tier 2 suppliers. Polestar’s Tier 1 and Tier 2 suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Tier 1 and Tier 2 suppliers are provided guidance in their native language, if needed.
For the 2024 calendar year, Polestar engaged with Volvo Cars and Geely directly to request a valid (free of validated errors) CMRT for the products that Volvo Cars and Geely supplies to Polestar.
Internal Information - Polestar
Polestar places a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources will be leveraged, and all in-scope suppliers will be provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.
Polestar believes that the combination of the Code of Conduct for Business partners, the Conflict Minerals Position, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.
Grievance Mechanisms
Polestar established grievance mechanisms whereby employees, suppliers and others outside Polestar can report grievances, suspected violations or other concerns to the Company, including conflict minerals. Suppliers and others outside of Polestar can direct such reports via the whistleblowing channel SpeakUp, available in the Code of Conduct for Business partners, on Polestar’s external website and in other communications with suppliers. Please find link https://www.polestar.com/global/legal/ethics/
Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/
Maintain Records
Polestar has a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. Polestar stores all the information and findings from this process in a database that can be audited by internal or external parties.
| 2) | Identifying & Assessing Risk in the Supply Chain |
Supplier Risk Evaluation
Risks associated with Tier 1 suppliers’ due diligence processes as well as to some extent Tier 2 suppliers is assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by members of Polestars internal Conflict Minerals Team, in collaboration with Assent staff, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”
Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Polestar is unable to determine if all the specified smelters/refiners were used for 3TGs in the products supplied to the Company.
Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that considers multiple conflict minerals factors.
Internal Information - Polestar
Smelter/Refiners Risk Evaluation
Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s Smelter validation program compared listed facilities to the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2024 calendar year.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Polestar does not have a direct relationship with smelters/refiners and does not perform direct audits of these entities within their pre-supply chain.
Smelters that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict-free or responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to conflict minerals.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
| • | Geographic proximity to Conflict-Affected and High-Risk Areas. |
| • | Known mineral source country of origin. |
| • | RMAP audit status. |
| • | Credible evidence of unethical or conflict sourcing. |
| • | Peer assessments conducted by credible third-party sources. |
| • | Sanctions risks |
Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions. Examples include the submission of a product specific CMRT to better identify the connection to products that they supply to Polestar. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these smelters of concern from the supply chain.
In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
| 3) | Design & Implement A Strategy to Respond to Risks |
Polestar, in consultation with Assent, has developed processes to assess and respond to the risks identified in the supply chain. Polestar has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations will be sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.
Internal Information - Polestar
Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, Polestar shall assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Compliance Team and the Polestar’s Management Team to ensure transparency within the Company.
For the 2024 calendar year, Volvo Cars and Geely have contracted the suppliers manufacturing components and materials used in Polestar 2, 3 and 4. Together with Volvo Cars’ and Geely, Polestar will discuss the outcome of conflict mineral reports and align necessary risk mitigation actions needed.
| 4) | Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
Polestar does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, Polestar relies on third-party audits of smelters/refiners (industry recognized audit/assessment programs). As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters/refiners that agree to participate in the program.
Assent directly engages smelters/refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their participation. Smelters/refiners already conformant to the corresponding program’s standards, are complemented for their efforts. Polestar is a signatory of these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance.
Through Polestar’s membership with the RMI, smelters/refiners have been encouraged to participate in the RMAP. Any smelters/refiners that were reported by suppliers who were not part of the RMAP were also contacted directly by Assent to encourage them to participate in the RMAP as stated earlier.
| 5) | Report Annually on Supply Chain Due Diligence |
Polestar is publishing the Conflict Mineral Report for the year ended December 31, 2024. This report will be made available in the Ethics section of Polestar’s website at https://www.polestar.com/global/legal/ethics/.
Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. Polestar has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission (SEC).
This year Polestar has also considered impacts from the EU Conflict Minerals Regulation when disclosing details with regards to due diligence efforts. Polestar will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public reporting.
Due Diligence Results
Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten, and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Polestar for the 2024 reporting year.
Internal Information - Polestar
Supply Chain Outreach Metrics
| Supplier Name Tier 1 | Response rate Tier 1 | Number
of in-scope suppliers Tier 2 | Response rate | |||||||||
| Geely | 100 | % | 77 | 61.04 | % | |||||||
| VCC | 100 | % | 124 | 64.52 | % | |||||||
Upstream Data Transparency
Appendix A includes all smelters/refiners that Tier 1 and Tier 2 suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2024 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners which processed the 3TGs contained in Polestar’s products.
Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections.
| Status | Number of identified smelters/refiners | |||
| RMAP Conformant | 232 | |||
| RMAP Active | 6 | |||
| Not Enrolled | 98 | |||
| Non-Conformant | 32 | |||
Country of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country-of-origin data obtained via Assent’s supply chain database (or other RCOI data, in the scenario Polestar decides to use alternative data sources).
As mentioned in the above section, it is understood that overreporting might occur which could result in Appendix B having more countries than those strictly relevant to Polestar’s products. Smelters sourcing from the Russian Federation were identified as high-risk smelters during our CM due diligence.
Internal Information - Polestar
Steps to Mitigate Risk
Polestar has taken, or intends to take, the following steps to improve the due diligence conducted to further mitigate the risk that the necessary 3TGs in Polestar’s products could originate from Conflict-Affected and High-Risk Areas:
| • | Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to: |
| o | Using a comprehensive smelter and refiner library with detailed status and notes for each entity. |
| o | Scanning for verifiable media sources on each smelter and refiner to flag risk issues. |
| o | Comparing the list of smelters/refiners against government watch and denied parties lists. |
| • | Engage with our business partners and suppliers more closely and provide more information and training resources regarding responsible sourcing of 3TGs. |
| • | Encourage business partners and suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers. |
| • | Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
| • | Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis. |
Internal Information - Polestar
Appendix A: Smelter List
Includes: mineral, smelter/refinery name, location
| Metal | Smelter Name | Smelter Facility Location |
Smelter ID | RMAP
Audit Status |
| Gold | Advanced Chemical Company | United States Of America | CID000015 | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | CID000019 | Conformant |
| Gold | Agosi AG | Germany | CID000035 | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | CID000041 | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | CID000058 | Conformant |
| Gold | Argor-Heraeus S.A. | Switzerland | CID000077 | Conformant |
| Gold | Asahi Pretec Corp. | Japan | CID000082 | Conformant |
| Gold | Asaka Riken Co., Ltd. | Japan | CID000090 | Conformant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | CID000103 | Outreach Required |
| Gold | Aurubis AG | Germany | CID000113 | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | CID000128 | Conformant |
| Gold | Boliden Ronnskar | Sweden | CID000157 | Conformant |
| Gold | C. Hafner GmbH + Co. KG | Germany | CID000176 | Conformant |
| Gold | Caridad | Mexico | CID000180 | Outreach Required |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | CID000185 | Conformant |
| Gold | Cendres + Metaux S.A. | Switzerland | CID000189 | Non Conformant |
| Gold | Yunnan Copper Industry Co., Ltd. | China | CID000197 | Outreach Required |
| Gold | Chimet S.p.A. | Italy | CID000233 | Conformant |
| Gold | Chugai Mining | Japan | CID000264 | Conformant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | CID000343 | Outreach Required |
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | CID000359 | Conformant |
| Gold | Dowa | Japan | CID000401 | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | CID000425 | Conformant |
| Gold | JSC Novosibirsk Refinery | Russian Federation | CID000493 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Refinery of Seemine Gold Co., Ltd. | China | CID000522 | Outreach Required |
Internal Information - Polestar
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | CID000651 | Outreach Required |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | CID000671 | Outreach Required |
| Gold | LT Metal Ltd. | Korea, Republic Of | CID000689 | Conformant |
| Gold | Heimerle + Meule GmbH | Germany | CID000694 | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | China | CID000707 | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | Germany | CID000711 | Conformant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | CID000767 | Outreach Required |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | CID000773 | Outreach Required |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | CID000778 | Communication Suspended - Not Interested |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | CID000801 | Conformant |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | CID000807 | Conformant |
| Gold | Istanbul Gold Refinery | Turkey | CID000814 | Conformant |
| Gold | Japan Mint | Japan | CID000823 | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | China | CID000855 | Conformant |
| Gold | Asahi Refining USA Inc. | United States Of America | CID000920 | Conformant |
| Gold | Asahi Refining Canada Ltd. | Canada | CID000924 | Conformant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | CID000927 | RMI Due Diligence Review - Unable to Proceed |
| Gold | JSC Uralelectromed | Russian Federation | CID000929 | RMI Due Diligence Review - Unable to Proceed |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | CID000937 | Conformant |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | CID000956 | Outreach Required |
| Gold | Kazzinc | Kazakhstan | CID000957 | Conformant |
| Gold | Kennecott Utah Copper LLC | United States Of America | CID000969 | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | Japan | CID000981 | Conformant |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | CID001029 | Non Conformant |
| Gold | L'azurde Company For Jewelry | Saudi Arabia | CID001032 | RMI Due Diligence Review - Unable to Proceed |
Internal Information - Polestar
| Gold | Lingbao Gold Co., Ltd. | China | CID001056 | Outreach Required |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | CID001058 | Outreach Required |
| Gold | LS MnM Inc. | Korea, Republic Of | CID001078 | Conformant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | CID001093 | Outreach Required |
| Gold | Materion | United States Of America | CID001113 | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | CID001119 | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | CID001147 | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | CID001149 | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | CID001152 | Conformant |
| Gold | Metalor Technologies S.A. | Switzerland | CID001153 | Conformant |
| Gold | Metalor USA Refining Corporation | United States Of America | CID001157 | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | CID001161 | Conformant |
| Gold | Mitsubishi Materials Corporation | Japan | CID001188 | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001193 | Conformant |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | CID001204 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | CID001220 | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | CID001236 | Conformant |
| Gold | Nihon Material Co., Ltd. | Japan | CID001259 | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | CID001325 | Conformant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | CID001326 | RMI Due Diligence Review - Unable to Proceed |
| Gold | MKS PAMP SA | Switzerland | CID001352 | Conformant |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | CID001362 | Outreach Required |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | CID001386 | RMI Due Diligence Review - Unable to Proceed |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | CID001397 | Conformant |
Internal Information - Polestar
| Gold | PX Precinox S.A. | Switzerland | CID001498 | Conformant |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | CID001512 | Conformant |
| Gold | Royal Canadian Mint | Canada | CID001534 | Conformant |
| Gold | Sabin Metal Corp. | United States Of America | CID001546 | Communication Suspended - Not Interested |
| Gold | Samduck Precious Metals | Korea, Republic Of | CID001555 | Non Conformant |
| Gold | Samwon Metals Corp. | Korea, Republic Of | CID001562 | Communication Suspended - Not Interested |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | CID001585 | Conformant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | CID001619 | Outreach Required |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | CID001622 | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | CID001736 | Conformant |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | CID001756 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | CID001761 | Conformant |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | CID001798 | Conformant |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | CID001810 | Outreach Required |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | CID001875 | Conformant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | CID001909 | Outreach Required |
| Gold | Shandong Gold Smelting Co., Ltd. | China | CID001916 | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | CID001938 | Conformant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | CID001947 | Outreach Required |
| Gold | Torecom | Korea, Republic Of | CID001955 | Non Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | CID001980 | Conformant |
| Gold | United Precious Metal Refining, Inc. | United States Of America | CID001993 | Conformant |
| Gold | Valcambi S.A. | Switzerland | CID002003 | Conformant |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | CID002030 | Conformant |
| Gold | Yamakin Co., Ltd. | Japan | CID002100 | Conformant |
| Gold | Yokohama Metal Co., Ltd. | Japan | CID002129 | Conformant |
Internal Information - Polestar
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | CID002224 | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | CID002243 | Conformant |
| Gold | Morris and Watson | New Zealand | CID002282 | Outreach Required |
| Gold | SAFINA A.S. | Czechia | CID002290 | Conformant |
| Gold | Guangdong Jinding Gold Limited | China | CID002312 | Outreach Required |
| Gold | Umicore Precious Metals Thailand | Thailand | CID002314 | Non Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | CID002509 | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | CID002511 | Conformant |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | CID002515 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | CID002516 | Non Conformant |
| Gold | Shandong Humon Smelting Co., Ltd. | China | CID002525 | Outreach Required |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | CID002527 | Outreach Required |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | CID002560 | Non Conformant |
| Gold | Emirates Gold DMCC | United Arab Emirates | CID002561 | Non Conformant |
| Gold | International Precious Metal Refiners | United Arab Emirates | CID002562 | Outreach Required |
| Gold | Kaloti Precious Metals | United Arab Emirates | CID002563 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Sudan Gold Refinery | Sudan | CID002567 | Outreach Required |
| Gold | T.C.A S.p.A | Italy | CID002580 | Conformant |
| Gold | REMONDIS PMR B.V. | Netherlands | CID002582 | Conformant |
| Gold | Fujairah Gold FZC | United Arab Emirates | CID002584 | Outreach Required |
| Gold | Industrial Refining Company | Belgium | CID002587 | Non Conformant |
| Gold | Shirpur Gold Refinery Ltd. | India | CID002588 | Outreach Required |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | CID002605 | Conformant |
Internal Information - Polestar
| Gold | Marsam Metals | Brazil | CID002606 | Non Conformant |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | CID002615 | Conformant |
| Gold | Abington Reldan Metals, LLC | United States Of America | CID002708 | Conformant |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China | CID002750 | Outreach Required |
| Gold | Albino Mountinho Lda. | Portugal | CID002760 | Outreach Required |
| Gold | SAAMP | France | CID002761 | Non Conformant |
| Gold | L'Orfebre S.A. | Andorra | CID002762 | Non Conformant |
| Gold | 8853 S.p.A. | Italy | CID002763 | Non Conformant |
| Gold | Italpreziosi | Italy | CID002765 | Conformant |
| Gold | WIELAND Edelmetalle GmbH | Germany | CID002778 | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | CID002779 | Active |
| Gold | AU Traders and Refiners | South Africa | CID002850 | Non Conformant |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India | CID002852 | Non Conformant |
| Gold | Sai Refinery | India | CID002853 | Outreach Required |
| Gold | Modeltech Sdn Bhd | Malaysia | CID002857 | Non Conformant |
| Gold | Bangalore Refinery | India | CID002863 | Active |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | CID002865 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | CID002867 | Outreach Required |
| Gold | Pease & Curren | United States Of America | CID002872 | Communication Suspended - Not Interested |
| Gold | JALAN & Company | India | CID002893 | Outreach Required |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | CID002918 | Conformant |
| Gold | Planta Recuperadora de Metales SpA | Chile | CID002919 | Conformant |
| Gold | ABC Refinery Pty Ltd. | Australia | CID002920 | Outreach Required |
| Gold | Safimet S.p.A | Italy | CID002973 | Non Conformant |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | CID003153 | Outreach Required |
Internal Information - Polestar
| Gold | African Gold Refinery | Uganda | CID003185 | RMI Due Diligence Review - Unable to Proceed |
| Gold | Gold Coast Refinery | Ghana | CID003186 | Outreach Required |
| Gold | NH Recytech Company | Korea, Republic Of | CID003189 | Conformant |
| Gold | QG Refining, LLC | United States Of America | CID003324 | Outreach Required |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates | CID003348 | Outreach Required |
| Gold | CGR Metalloys Pvt Ltd. | India | CID003382 | Outreach Required |
| Gold | Sovereign Metals | India | CID003383 | Outreach Required |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | CID003424 | Conformant |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | CID003425 | Conformant |
| Gold | Augmont Enterprises Private Limited | India | CID003461 | Non Conformant |
| Gold | Kundan Care Products Ltd. | India | CID003463 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India | CID003487 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India | CID003488 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India | CID003489 | Outreach Required |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India | CID003490 | Outreach Required |
| Gold | K.A. Rasmussen | Norway | CID003497 | Outreach Required |
| Gold | Alexy Metals | United States Of America | CID003500 | Non Conformant |
| Gold | MD Overseas | India | CID003548 | Outreach Required |
| Gold | Metallix Refining Inc. | United States Of America | CID003557 | Outreach Required |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | CID003575 | Conformant |
| Gold | WEEEREFINING | France | CID003615 | Conformant |
| Gold | Gold by Gold Colombia | Colombia | CID003641 | Conformant |
| Gold | Dongwu Gold Group | China | CID003663 | Outreach Required |
| Gold | Sam Precious Metals | United Arab Emirates | CID003666 | In Communication |
Internal Information - Polestar
| Gold | NOBLE METAL SERVICES | United States Of America | CID003690 | Outreach Required |
| Gold | Coimpa Industrial LTDA | Brazil | CID004010 | Conformant |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | China | CID004435 | Outreach Required |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION | India | CID004491 | Active |
| Gold | GG Refinery Ltd. | Tanzania, United Republic Of | CID004506 | Conformant |
| Gold | Attero Recycling Pvt Ltd | India | CID004697 | Outreach Required |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) | South Africa | CID004714 | Conformant |
| Gold | Elite Industech Co., Ltd. | Taiwan, Province Of China | CID004755 | Conformant |
| Gold | Gasabo Gold Refinery Ltd | Rwanda | CID005006 | Outreach Required |
| Gold | Minera Titán del Perú SRL (MTP) - Belen Plant | Peru | CID005014 | Active |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | CID000291 | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | China | CID000460 | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | CID000616 | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | CID000914 | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | CID000917 | Conformant |
| Tantalum | AMG Brasil | Brazil | CID001076 | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | CID001163 | Conformant |
| Tantalum | Mineracao Taboca S.A. | Brazil | CID001175 | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | CID001192 | Conformant |
| Tantalum | NPM Silmet AS | Estonia | CID001200 | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | CID001277 | Conformant |
| Tantalum | QuantumClean | United States Of America | CID001508 | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | CID001522 | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | CID001769 | RMI Due Diligence Review - Unable to Proceed |
| Tantalum | Taki Chemical Co., Ltd. | Japan | CID001869 | Conformant |
| Tantalum | Telex Metals | United States Of America | CID001891 | Conformant |
Internal Information - Polestar
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | CID001969 | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | CID002492 | Conformant |
| Tantalum | D Block Metals, LLC | United States Of America | CID002504 | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | China | CID002505 | Conformant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | CID002506 | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | CID002508 | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | CID002512 | Conformant |
| Tantalum | KEMET de Mexico | Mexico | CID002539 | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | CID002544 | Conformant |
| Tantalum | TANIOBIS GmbH | Germany | CID002545 | Conformant |
| Tantalum | Materion Newton Inc. | United States Of America | CID002548 | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | CID002549 | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002550 | Conformant |
| Tantalum | Global Advanced Metals Boyertown | United States Of America | CID002557 | Conformant |
| Tantalum | Global Advanced Metals Aizu | Japan | CID002558 | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | CID002707 | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | CID002842 | Conformant |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583 | Conformant |
| Tantalum | 5D Production OU | Estonia | CID003926 | Outreach Required |
| Tantalum | PowerX Ltd. | Rwanda | CID004054 | Conformant |
| Tantalum | Jiangxi Sanshi Nonferrous Metals Co., Ltd | China | CID004813 | In Communication |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | CID000228 | Conformant |
| Tin | Alpha | United States Of America | CID000292 | Conformant |
| Tin | PT Aries Kencana Sejahtera | Indonesia | CID000309 | Conformant |
| Tin | PT Premium Tin Indonesia | Indonesia | CID000313 | Conformant |
| Tin | Dowa | Japan | CID000402 | Conformant |
| Tin | EM Vinto | Bolivia (Plurinational State Of) | CID000438 | Conformant |
| Tin | Estanho de Rondonia S.A. | Brazil | CID000448 | Conformant |
| Tin | Fenix Metals | Poland | CID000468 | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | CID000538 | Conformant |
Internal Information - Polestar
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | CID000555 | Non Conformant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | CID000942 | Non Conformant |
| Tin | China Tin Group Co., Ltd. | China | CID001070 | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | CID001105 | Conformant |
| Tin | Metallic Resources, Inc. | United States Of America | CID001142 | Conformant |
| Tin | Mineracao Taboca S.A. | Brazil | CID001173 | Conformant |
| Tin | Minsur | Peru | CID001182 | Conformant |
| Tin | Mitsubishi Materials Corporation | Japan | CID001191 | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | CID001231 | Conformant |
| Tin | Novosibirsk Tin Combine | Russian Federation | CID001305 | RMI Due Diligence Review - Unable to Proceed |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | CID001314 | Conformant |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | CID001337 | Conformant |
| Tin | PT Artha Cipta Langgeng | Indonesia | CID001399 | Conformant |
| Tin | PT Babel Inti Perkasa | Indonesia | CID001402 | Conformant |
| Tin | PT Babel Surya Alam Lestari | Indonesia | CID001406 | Conformant |
| Tin | PT Bangka Tin Industry | Indonesia | CID001419 | Conformant |
| Tin | PT Belitung Industri Sejahtera | Indonesia | CID001421 | Conformant |
| Tin | PT Bukit Timah | Indonesia | CID001428 | Conformant |
| Tin | PT Mitra Stania Prima | Indonesia | CID001453 | Conformant |
| Tin | PT Panca Mega Persada | Indonesia | CID001457 | Outreach Required |
| Tin | PT Prima Timah Utama | Indonesia | CID001458 | Conformant |
| Tin | PT Refined Bangka Tin | CID001460 | Conformant | |
| Tin | PT Sariwiguna Binasentosa | CID001463 | Conformant | |
| Tin | PT Stanindo Inti Perkasa | CID001468 | Conformant | |
| Tin | PT Timah Tbk Kundur | Indonesia | CID001477 | Conformant |
| Tin | PT Timah Tbk Mentok | Indonesia | CID001482 | Conformant |
| Tin | PT Timah Nusantara | Indonesia | CID001486 | Conformant |
| Tin | PT Tinindo Inter Nusa | CID001490 | Conformant | |
| Tin | PT Tommy Utama | Indonesia | CID001493 | Conformant |
| Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 | Conformant |
| Tin | Thaisarco | Thailand | CID001898 | Conformant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | CID001908 | Non Conformant |
Internal Information - Polestar
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | CID002015 | Outreach Required |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | CID002036 | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | CID002158 | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | CID002180 | Conformant |
| Tin | CV Venus Inti Perkasa | CID002455 | Conformant | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | CID002468 | Conformant |
| Tin | PT Tirus Putra Mandiri | Indonesia | CID002478 | Outreach Required |
| Tin | Melt Metais e Ligas S.A. | Brazil | CID002500 | Active |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | CID002503 | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | CID002517 | Conformant |
| Tin | CV Ayi Jaya | Indonesia | CID002570 | Conformant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | CID002572 | Non Conformant |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002573 | Outreach Required |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574 | Outreach Required |
| Tin | PT Rajehan Ariq | Indonesia | CID002593 | Conformant |
| Tin | PT Cipta Persada Mulia | Indonesia | CID002696 | Conformant |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | CID002703 | Outreach Required |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 | Conformant |
| Tin | Super Ligas | Brazil | CID002756 | Conformant |
| Tin | Aurubis Beerse | Belgium | CID002773 | Conformant |
| Tin | Aurubis Berango | Spain | CID002774 | Conformant |
| Tin | PT Bangka Prima Tin | Indonesia | CID002776 | Conformant |
| Tin | PT Sukses Inti Makmur | Indonesia | CID002816 | Conformant |
| Tin | PT Menara Cipta Mulia | Indonesia | CID002835 | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | CID002844 | Conformant |
| Tin | Modeltech Sdn Bhd | Malaysia | CID002858 | Non Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | CID003116 | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | CID003190 | Conformant |
| Tin | PT Bangka Serumpun | Indonesia | CID003205 | Conformant |
| Tin | Pongpipat Company Limited | Myanmar | CID003208 | Outreach Required |
| Tin | Tin Technology & Refining | United States Of America | CID003325 | Conformant |
Internal Information - Polestar
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | CID003356 | Non Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | CID003379 | Non Conformant |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381 | Conformant |
| Tin | Luna Smelter, Ltd. | Rwanda | CID003387 | Conformant |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | CID003397 | Conformant |
| Tin | Precious Minerals and Smelting Limited | India | CID003409 | Non Conformant |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 | Outreach Required |
| Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449 | Conformant |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | CID003486 | Conformant |
| Tin | CRM Synergies | Spain | CID003524 | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 | Non Conformant |
| Tin | DS Myanmar | Myanmar | CID003831 | Conformant |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | CID003868 | Conformant |
| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | CID004065 | Conformant |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | CID004403 | Conformant |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | CID004434 | Conformant |
| Tin | PT Mitra Graha Raya | Indonesia | CID004685 | Outreach Required |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | India | CID004692 | Outreach Required |
| Tin | Woodcross Smelting Company Limited | Uganda | CID004724 | Conformant |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | Australia | CID004754 | Conformant |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | China | CID004796 | Outreach Required |
| Tungsten | A.L.M.T. Corp. | Japan | CID000004 | Conformant |
| Tungsten | Kennametal Huntsville | United States Of America | CID000105 | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | CID000218 | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | CID000258 | Conformant |
Internal Information - Polestar
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | CID000281 | Outreach Required |
| Tungsten | Global Tungsten & Powders LLC | United States Of America | CID000568 | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | CID000766 | Conformant |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China | CID000769 | Non Conformant |
| Tungsten | Japan New Metals Co., Ltd. | Japan | CID000825 | Conformant |
| Tungsten | Kennametal Fallon | United States Of America | CID000966 | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | CID002044 | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | CID002082 | Conformant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | CID002313 | Communication Suspended - Not Interested |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | CID002315 | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | CID002316 | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | CID002317 | Conformant |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | CID002318 | Conformant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | CID002319 | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | CID002320 | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | CID002321 | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | CID002494 | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | CID002502 | Conformant |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | CID002513 | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | CID002541 | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | CID002542 | Conformant |
| Tungsten | Masan High-Tech Materials | Viet Nam | CID002543 | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | CID002551 | Conformant |
| Tungsten | Niagara Refining LLC | United States Of America | CID002589 | Conformant |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | CID002641 | Conformant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | CID002649 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Unecha Refractory metals plant | Russian Federation | CID002724 | Non Conformant |
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| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | CID002827 | Conformant |
| Tungsten | ACL Metais Eireli | Brazil | CID002833 | Non Conformant |
| Tungsten | Moliren Ltd. | Russian Federation | CID002845 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | CID003407 | Conformant |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | CID003408 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation | CID003416 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | CID003417 | Conformant |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | CID003427 | Non Conformant |
| Tungsten | Cronimet Brasil Ltda | Brazil | CID003468 | Conformant |
| Tungsten | Artek LLC | Russian Federation | CID003553 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | CID003609 | Conformant |
| Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | OOO “Technolom” 1 | Russian Federation | CID003614 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | LLC Vostok | Russian Federation | CID003643 | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China | CID003662 | Outreach Required |
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| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of | CID003978 | Outreach Required |
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam | CID003993 | Conformant |
| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam | CID004034 | Outreach Required |
| Tungsten | MALAMET SMELTING SDN. BHD. | Malaysia | CID004056 | Outreach Required |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | CID004060 | Outreach Required |
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan, Province Of China | CID004397 | Conformant |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | CID004430 | Conformant |
| Tungsten | Philippine Carreytech Metal Corp. | Philippines | CID004438 | Active |
| Tungsten | Kenee Mining Corporation Vietnam | Viet Nam | CID004619 | Conformant |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | Philippines | CID004797 | Conformant |
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Appendix B: Countries of Origin
| Albania | Ecuador | Kyrgyzstan | Saudi Arabia |
| Andorra | Egypt | Liberia | Senegal |
| Angola | El Salvador | Liechtenstein | Serbia |
| Argentina | Eritrea | Lithuania | Sierra Leone |
| Armenia | Estonia | Luxembourg | Singapore |
| Australia | Ethiopia | Madagascar | Slovakia |
| Austria | Fiji | Malaysia | Solomon Islandss |
| Azerbaijan | Finland | Mali | South Africa |
| Belarus | France | Mauritania | South Sudan |
| Belgium | Georgia | Mexico | Spain |
| Benin | Germany | Mongolia | Sudan |
| Bermuda | Ghana | Morocco | Suriname |
| Bolivia (Plurinational State of) | Guam | Mozambique | Sweden |
| Botswana | Guatemala | Myanmar | Switzerland |
| Brazil | Guinea | Namibia | Taiwan |
| Bulgaria | Guyana | Netherlands | Tajikistan |
| Burkina Faso | Honduras | New Zealand | Tanzania |
| Burundi | Hong Kong | Nicaragua | Thailand |
| Cambodia | Hungary | Niger | Togo |
| Canada | India | Nigeria | Turkey |
| Central African Republic | Indonesia | Norway | Uganda |
| Chile | Ireland | Oman | United Arab Emirates |
| China | Israel | Panama | United Kingdom |
| Colombia | Italy | Papua New Guinea | United States of America |
| Congo | Ivory Coast | Peru | Uruguay |
| Cyprus | Japan | Philippines | Uzbekistan |
| Democratic Republic of Congo | Jersey | Poland | VietNam |
| Djibouti | Kazakhstan | Portugal | Zambia |
| Dominica | Kenya | Russian Federation | |
| Dominican Republic | Korea | Rwanda | |
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Appendix C: CMRT Declaration Rejection/Approval Criteria
The following tables map the Assent Sustainability Platform’s status outputs and CMRT logic structure when determining supplier conflict mineral statuses as displayed on the dashboard. Using this table, and referencing the CMRT questions listed above, users will be able to determine what answers were provided by their suppliers to earn their conflict minerals statuses.
| Supplier Status | Description | |
| Not Submitted | A CMRT has not been submitted by the supplier | |
| Complete | A CMRT has been submitted, and is valid and complete | |
| Incomplete | A supplier with parts associated to them has submitted a partially completed Product-Level or User-Defined CMRT | |
| Invalid Submission | A CMRT has been submitted and deemed invalid based on contradicting responses in the template | |
| Out of Scope | The supplier is out of scope for conflict minerals and does not need to be contacted |
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