Apple Conflict Minerals Report
Apple Conflict Minerals Report
Apple Conflict Minerals Report
Broadridge Financial Solutions, Inc. Description: SD [email protected] Created using Broadridge PROfile
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Apple Inc.
(Exact name of the registrant as specified in its charter)
California 001-36743
(State or other jurisdiction of incorporation or organization) (Commission File Number)
Katherine Adams
Senior Vice President,
General Counsel and Secretary
(408) 996-1010
(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:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.
☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .
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Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit Conflict Minerals Disclosure
A copy of Apple Inc.’s (“Apple’s”) Conflict Minerals Report for the reporting period January 1, 2022 to December 31, 2022 is provided as Exhibit 1.01
hereto and is publicly available at investor.apple.com/sec-filings.*
Not applicable.
*****
* The reference to Apple’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.
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SIGNATURES
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.
Apple Inc.
3
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Exhibit 1.01
We seek to one day use only recycled and renewable minerals and materials in our products and packaging, and are
committed to achieving carbon neutrality for our entire footprint by 2030 — from our supply chain to the use of the products we
make. Nearly 20 percent of all material used in Apple products in 2021 was recycled. Tin, tantalum, tungsten, and gold ("3TG”)
are among 14 materials prioritized in our initial efforts to transition to recycled and renewable materials, based on an evaluation
of the environmental, social, and supply impacts of 45 mined elements and raw materials. The results of this evaluation and
the related methodology (“Material Impact Profiles”) are available on Apple’s website for others to access and use.1
As we make progress toward these ambitious goals, we continue to source 3TG and other minerals, such as cobalt and
lithium, responsibly, while working to improve conditions in and around mining communities, including in the Democratic
Republic of the Congo (“DRC”) and adjoining countries. Although Apple does not directly purchase, procure, or source primary
minerals, we are committed to meeting and exceeding internationally-accepted due diligence standards for primary minerals
and recycled materials in our supply chain. Our responsible minerals sourcing program includes requirements that apply to all
levels of Apple’s supply chain. Conducting human rights and environmental due diligence in alignment with the Organisation for
Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas (2016) and related Supplements (“OECD Due Diligence Guidance”) and the United
Nations Guiding Principles on Business and Human Rights (“UN Guiding Principles”) is the foundation of Apple’s responsible
sourcing programs for primary and recycled minerals and materials.
Our Supplier Code and Responsible Sourcing Standard requires suppliers, smelters, refiners, and recyclers in our supply
chain to identify and assess a broad range of risks beyond conflict, including social, environmental, and human rights risks.
Suppliers are also required to review reported incidents and public allegations linked to their smelters and refiners, and to
participate in 3TG traceability and independent third-party audit programs to mitigate identified risks.
1 Available at apple.com/environment/pdf/Apple_Material_Impact_Profiles_April2019.pdf
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As of December 31, 2022 — for the eighth consecutive year — 100 percent of the identified smelters and refiners in our supply
chain for all applicable Apple products manufactured during 2022 participated in or completed an independent third-party
conflict minerals audit for 3TG. These audits encompassed the identified smelters and refiners that provide materials for the
following Apple product categories: iPhone®, Mac®, iPad®, AirPods®, Apple TV®, Apple Watch®, Beats® products,
HomePod®, HomePod mini®, iPod touch®, Apple Card®, and all Apple® accessories.
Since 2009, Apple has directed the removal of 198 3TG smelters and refiners from its supply chain (a total of 10 tantalum, 60
tin, 27 tungsten, and 101 gold smelters and refiners). In 2022, we removed 23 smelters and refiners from our supply chain,
including those that were not willing to participate in or complete an independent third-party audit, or that did not otherwise
meet our requirements for the responsible sourcing of minerals. Based on our due diligence efforts, including analyzing the
information provided by third-party audit programs, upstream traceability programs, and our suppliers, we found no reasonable
basis for concluding that any of the 238 smelters and refiners of 3TG determined to be in our supply chain as of December 31,
2022 directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.
As we work to strengthen industry-wide due diligence programs operating in areas where 3TG minerals are sourced, we
engage with and support a broad range of multistakeholder and community initiatives. This includes support for human rights
and environmental defenders as well as whistleblower initiatives that work to empower independent, local voices to raise
issues and report incidents at the mining level. Input from stakeholders and rights-holders contributes to our robust due
diligence program and drives industry-wide progress. As part of our widespread efforts to support education initiatives, we also
aim to expand access to learning opportunities and skills development for people across our supply chain through a $50
million Supplier Employee Development Fund which was launched in 2022, in partnership with the International Labor
Organization, the International Organization for Migration, and education experts around the world.
We believe that all stakeholders (including governments, civil society, and industry) should enhance their efforts to implement
comprehensive due diligence programs, measure impact, and work together with, and support, local communities to improve
conditions and drive economic and social development in mining areas, including in the African Great Lakes region.
The below chart summarizes the comprehensive set of tools we utilize to drive progress throughout our supply chain.2
Apple conducts business ethically, honestly, and in compliance with applicable laws and regulations. This applies to every
business decision in every area of the company worldwide.
Apple’s Supplier Code and Responsible Sourcing Standard applies to all levels of Apple’s supply chain, including traders,
suppliers, sub-suppliers, mining companies, and operators of collection points for recycled minerals used in Apple products.
The Supplier Code and Responsible Sourcing Standard is based on industry and internationally accepted principles, including
the UN Guiding Principles, the International Labour Organization’s International Labour Standards, and the OECD Due
Diligence Guidance.
The Supplier Code and Responsible Sourcing Standard outlines Apple’s requirements for its suppliers in the areas of labor
and human rights, health and safety, the environment, ethics, and management systems. The Responsible Sourcing Standard
specifically outlines Apple’s extensive requirements on the responsible sourcing of minerals and other materials, including
expectations for suppliers concerning 3TG due diligence and related sourcing matters. The Supplier Code and Responsible
Sourcing Standard is available in 17 languages and is evaluated and strengthened each year, raising the bar suppliers must
meet.
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• Business Conduct Policy: provides a standard guide for what is required of everyone at Apple. Apple expects its
suppliers, contractors, consultants, and other business partners to follow the Business Conduct Policy’s principles of
honesty, respect, confidentiality, and compliance when providing goods or services to Apple or acting on its behalf.
• Human Rights Policy: governs how Apple treats everyone, from customers and teams to business partners and people
at every level of its supply chain.
• Global Whistleblowing Policy: applies to all current and former employees, directors and officers, contractors and
subcontractors of Apple and its subsidiaries, and sets out Apple’s approach to protecting and supporting individuals
who report potential misconduct.
• Environment and Supply Chain Innovation (“ESCI”) team: within Apple’s Worldwide Operations group, ESCI has
primary responsibility for upholding Apple’s values across the global supply chain. The ESCI team coordinates efforts
related to Apple’s Supplier Code and Responsible Sourcing Standard and works across Apple’s business teams and
functions, including product design, manufacturing operations, environmental initiatives, procurement, legal, finance,
and retail. The ESCI team also regularly reports to, and consults with, Apple’s senior management to review progress
and set ongoing strategies for our responsible sourcing of materials and human rights and environmental due diligence
efforts.
Board Oversight
• Board of Directors: oversees Apple’s CEO and other senior management in the competent and ethical operation of
Apple on a day-to-day basis.
• Audit and Finance Committee: consisting entirely of independent directors, the committee assists Apple’s Board of
Directors in monitoring significant business risks, including operational and reputational risks.
• Nominating and Corporate Governance Committee: consisting entirely of independent directors, the committee assists
Apple’s Board of Directors in overseeing Apple’s strategies, policies, and practices relating to environmental and social
matters.
Supplier Engagement
Apple requires its suppliers to adhere to the Supplier Code and the Responsible Sourcing Standard, including any subsequent
amendments or updates. Suppliers are also required to apply Apple’s requirements upstream to their own suppliers
throughout all levels of the supply chain. In this way, and through direct outreach by Apple to all 3TG smelters and refiners
identified in its supply chain, Apple implements its requirement that smelters and refiners in its supply chain comply with
Apple’s strict standards, including participation in independent third-party audit programs.
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We annually communicate our 3TG sourcing requirements to our direct suppliers. Additionally, throughout the year we engage
with suppliers using tailored communication and guidance including:
• Conducting annual 3TG due diligence training webinars with suppliers that have reported to Apple the use of 3TG in
parts and products.
• Providing suppliers access to our SupplierCare portal, which includes online training materials (in multiple languages)
that focus on Apple’s due diligence expectations and requirements for 3TG reporting, among other topics.
We conduct third-party assessments of our suppliers who report to Apple the use of 3TG in their parts and products to confirm
alignment with the OECD Due Diligence Guidance and our Supplier Code and Responsible Sourcing Standard. Additional
information about these assessments is provided in Step 4 of this report. Suppliers can also reach out to Apple with questions
about 3TG sourcing through the SupplierCare portal, or through a dedicated Apple email that allows suppliers to report
concerns or grievances related to 3TG mining, processing, and trading. The concerns or grievances submitted are reviewed
by Apple, and follow-up activities are conducted as appropriate. If we discover that our standards are not being met, we work
collaboratively with suppliers to help them improve, in line with the OECD Due Diligence Guidance framework of progressive
improvement, including terminating applicable business relationships if suppliers are unwilling or unable to meet our
standards. We also support industry-wide grievance and allegations mechanisms at the smelter and refiner level and
whistleblowing programs deeper in the supply chain at the mining level. These programs are discussed further in Step 2 of this
report.
We are committed to working in collaboration with stakeholders beyond our own supply chain. As part of this commitment, we
regularly engage with a broad range of stakeholders and rights holders – including human rights, environmental, and minerals
experts from civil society, non-governmental organizations (“NGOs”), industry, academia, and government – to review and
gather feedback on Apple’s programs and discuss strategies for engaging industry and other stakeholders on innovative
approaches to the responsible sourcing of recycled and primary sourced minerals in supply chains.
In 2022, we convened human rights, environmental, and minerals experts – including representatives from industry, NGOs,
and civil society – to discuss strategies for engaging industry and other stakeholders on innovative approaches to advancing
human and environmental rights across supply chains. We also continued to engage with and work to incorporate learnings
from human rights and environmental defenders, including from the DRC, through our work with the Fund for Global Human
Rights, a public foundation that works with human rights organizations globally.
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In 2022, we continued our active participation and leadership in multiple industry associations and multistakeholder initiatives,
including serving on:
Throughout 2022 we drove and actively contributed to a variety of activities with leading industry organizations and
multistakeholder initiatives, including:
• Supporting the continued development of industry-wide, responsible sourcing standards, including a responsible
artisanal and small-scale mining (“ASM”) sourcing framework being co-developed by the RMI and other stakeholders.
• Being featured at the annual OECD Forum on Responsible Mineral Supply Chains for discussing best practices for
environmental due diligence.
• Joining with other PPA member companies to provide funding to the Congo Power Project, which supports solar power
initiatives for the Panzi Foundation’s healthcare facilities in DRC mining areas.
A foundational step in Apple’s 3TG risk assessment due diligence process is the requirement that all suppliers that utilize 3TG
submit to Apple an industry-standard Conflict Minerals Reporting Template (“CMRT”). We collect and process data provided by
suppliers through their completion of the CMRT to map our supply chain to the smelter and refiner level and, to the extent
available, to the mining level. Our Responsible Sourcing Standard requires suppliers to inform Apple immediately if they
identify certain high risks included in Annex II of the OECD Due Diligence Guidance, such as conflict or human rights risks
associated with 3TG.
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In addition to conducting our own supply chain due diligence, we help strengthen and increase the transparency of
independent third-party audit programs – in particular, audit programs by the RMI and the London Bullion Market Association
(“LBMA”) – to help identify a broad range of social, environmental, human rights, and governance risks at the smelter, refiner,
and mining levels.
We continue to innovate, develop, and scale tools to enhance risk identification and assessment beginning at the mining level,
and emphasize the importance of cross-industry and multistakeholder collaboration in the use and refinement of these tools in
order to drive greater collective impact throughout global supply chains. This includes a variety of tools aimed at enhancing risk
identification and assessment, such as:
• Risk Readiness Assessment (“RRA”): First funded and developed in 2016 by Apple the RRA has been a tool of the
Responsible Minerals Initiative (RMI) and is a pre-requisite self-assessment for RMI Responsible Minerals Assurance
Process (“RMAP”) auditees, since 2017. The RRA is widely adopted by industry via the RMI and available to all RMI
member companies to assess risks in mineral supply chains. 428 RRAs were completed by RMI industry members
and auditees as of December 31, 2022, compared with 366 completed as of 2021. The Copper Mark, an assurance
framework for responsible copper production, also used the RRA to assess copper producers at 46 sites during 2022,
an increase from 31 in 2021.
• Minerals Grievance Platform: a cross-industry platform managed by RMI where allegations concerning minerals supply
chains are investigated and addressed. Grievances can be anonymously submitted by NGOs, companies, or any
member of the public.
• Material Insights Platform: a resource for RMI member companies to identify and assess environmental, social, and
governance issues in their materials supply chains, and encourage collective action in addressing risks and creating
positive impacts for mining communities.
Blockchain traceability
Throughout 2022, we continued to use blockchain solutions for tracing 3TG and other minerals in the supply chain while
aiming to protect data privacy. Apple believes that blockchain solutions are a tool to support — but not replace — supply chain
due diligence. The interests of people working at the mining level and in surrounding communities should be taken into
consideration when utilizing new technologies such as blockchain. As the use of new technologies increases, our goal is to
ensure that data captured contributes to positive impacts along the supply chain.
Apple believes that only addressing allegations that potentially affect its own supply chain will not lead to systemic progress.
Accordingly, we have taken steps to work with a broad group of stakeholders to address public allegations together. This
includes reviewing public allegations from civil society groups and analyzing investigative reports by international organizations
— including NGOs and the United Nations Group of Experts on the DRC — related to risks outlined in Annex II of the OECD
Due Diligence Guidance.
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Apple believes that empowering independent voices at the mining level is critical to identifying and assessing risks in the 3TG
supply chain. In 2022, this included our work on the following initiatives:
• Support for human rights and environmental defenders in the DRC: we continued our partnership with the Fund
for Global Human Rights in support of human rights, labor, and environmental defenders in the DRC who work on a
range of issues, including the economic and social rights of mining communities, inclusive economic growth, judicial
advocacy, environmental justice, the rule of law, as well as health, safety, and fair compensation for mining
communities.
• Whistleblowing mechanisms at mining level: for the seventh consecutive year, Apple funded the International Tin
Supply Chain Initiative’s (“ITSCI”) whistleblowing mechanism in the DRC, which enables people in and around mining
communities in seven provinces of the DRC to place anonymous voice calls using a toll-free hotline to raise concerns
related to mineral extraction, trade, handling, and exporting via local networks. In 2022, ITSCI and its partner
organizations continued to increase awareness and utilization of the whistleblowing mechanism through radio
campaigns in mining communities, distributing promotional material, and consulting with local civil society actors and
other stakeholders.
• Rights awareness trainings: Apple supported a sixth year of programming with international development NGO Pact
to deliver rights awareness training to miners, youth, and community officials in ASM communities in the DRC. These
training sessions were designed to raise awareness on a range of human rights issues and were based in part on
curriculum developed by the United Nations Children’s Emergency Fund (“UNICEF”).
• Vocational education: Apple also provided funding to the RBA Foundation in support of Pact’s sixth year of a
vocational education program for youth living in mining communities in the Lualaba province of the DRC. In continued
response to the COVID-19 pandemic, Pact coordinated with local communities and health officials to provide
information and resources, including access to free face masks, soap, and educational materials on symptoms and
prevention measures.
We closely monitor completion of independent third-party audits and corrective action plans by the smelters and refiners in our
supply chain. In the instances where smelters or refiners delay implementation of corrective action plans developed by third-
party audits, we leverage our downstream position, conducting applicable smelter or refiner outreach to reiterate the
requirement for the smelter or refiner to complete and close the associated corrective action plan in order to remain in our
supply chain.
If smelters or refiners are unable or unwilling to meet our standards, we take necessary actions, through our suppliers, to
terminate the applicable business relationships. As of December 31, 2022, we found that all identified smelters and refiners in
our supply chain participated in or completed an independent third-party audit that met Apple’s requirements for the
responsible sourcing of minerals. Since 2009, Apple has directed removal of 198 3TG smelters or refiners from our supply
chain, including more than 100 gold refiners.
Each year, we analyze incident data provided by ITSCI and RCS Global Group’s Better Mining program (“Better Mining”), two
upstream traceability and due diligence programs that monitor tin, tantalum, and tungsten mines in the DRC and across the
African Great Lakes region. We work with these programs to help strengthen their incident review processes, and review and
monitor incidents generated through their respective reporting systems, including reviewing mitigation actions and confirming
incidents are closed in accordance with the programs’ standards and procedures.
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In 2022, we continued to review incidents and accompanying analysis reported by both ITSCI and Better Mining. As part of this
process, we also reviewed reported incidents that could have directly or indirectly benefited or financed armed groups in the
DRC or adjoining countries. In 2022, we found no reasonable basis for concluding that any of the reported incidents were
connected to tin, tantalum, or tungsten included in Apple’s products. The challenges of tracking specific mineral quantities
through the supply chain continue to impede the traceability of any specific mineral shipment through the entire product
manufacturing process.
Apple continues to address remaining challenges in the global gold supply chain through its due diligence program, which is
aligned with the OECD Due Diligence Guidance Supplement on Gold and other sources. As part of our risk assessment and
due diligence efforts, we designed and implemented systems that focus specifically on the gold supply chain. Apple accepts
certification from the RMI’s RMAP and the LBMA’s Responsible Gold Program for gold refiners in our supply chain. We also
prioritize gold in our efforts to transition to recycled and renewable materials in our products, and 100 percent of our recycled
gold refiners are audited. In 2022, we reviewed gold refiners in our supply chain to identify potential risks and other sourcing
challenges, and subsequently worked with suppliers to address such identified risks and challenges and to remove refiners as
necessary.
Apple believes that innovative and data-driven solutions to sourcing help reduce risk and improve traceability, and is leading on
responsible gold sourcing innovation. This includes pioneering industry-leading traceability mechanisms for recycled materials
to build a supply chain of exclusively recycled gold. In 2022, we also expanded our use of certified recycled gold across all
cameras for iPhone 14 family and in multiple printed circuit boards across Apple products, including the latest iPhone, iPad,
Watch, MacBook Pro, Apple TV 4K and HomePod. We also worked with sustainability non-profit RESOLVE to fund the
Regeneration project, which focuses on re-mining and processing waste material from legacy mines to restore natural
environments and support rehabilitation and biodiversity. Regeneration is an expansion of the Salmon Gold project, which we
continued to fund and scale with Tiffany & Co. and RESOLVE in 2022. The Salmon Gold project works with small-scale
miners and Indigenous Peoples in remote regions of the Yukon, Alaska, and British Columbia to support a mining practice that
helps restore rivers and streams so that salmon and other fish can thrive. Since RESOLVE first introduced the Salmon Gold
project in 2017, the organization has connected local placer miners, environmentalists, and government agencies to mitigate
the damage done by historic mining activities. The gold mined from this project is then traced from its origin to a refiner in
Apple’s supply chain using blockchain technology.
Further building on innovative approaches to gold sourcing globally, in 2022, we supported the expansion of and continued to
work with the Massachusetts Institute of Technology’s D-Lab Innovation Centers in Colombia. These Innovation Centers
support training for local gold miners and community leaders to develop sustainable solutions to ASM challenges.
Apple believes that the lessons learned from these programs will help support further innovation across the supply chains of
additional minerals.
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In addition to smelter and refiner audit participation, in 2022 we continued to engage an independent audit firm to conduct
specialized responsible sourcing audits of select suppliers in order to have a deeper review of their internal management
systems and implementation of Apple's requirements related to 3TG and other minerals. These specialized audits continue to
be part of Apple’s supplier engagement program which includes our Supplier Code assessments. At the end of an Apple-
managed assessment or specialized audit, the supplier is given a list of areas to strengthen with regard to our Supplier Code
and Responsible Sourcing Standard, and the supplier is required to correct any identified nonconformances in a timely
manner. We provide support to help suppliers complete a corrective action plan to meet and exceed our requirements within
the timeline identified as a result of the assessment or specialized audit. Timelines for corrective actions typically range
between 30 and 90 days. If a supplier is unwilling or unable to meet Apple's requirements, we will terminate applicable
business relationships.
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In addition to conducting independent assessments of our own supply chain, we continue to support a range of
multistakeholder initiatives that contribute to broader learnings on the impact of due diligence programs, and opportunities for
future innovations. In 2022, building on research Apple previously supported which assessed the human rights impacts of due
diligence programs, these initiatives included:
• Developing strategies for generating better data on due diligence: we contributed to the conceptualization,
design, and presenter selection for a virtual “data for impact symposium” held for PPA members in June 2022.
• Supporting new tools to connect ASM and downstream actors: we worked with IMPACT to support the continued
development of a digital framework based on the United Nations Sustainable Development Goals which aims to
harmonize how the impact of supply chain-related activities on socioeconomic and environmental wellbeing in ASM
communities is measured.
• Highlighting standards for remediation: in 2022, the International Organization for Migration continued to utilize the
Remediation Guidelines for Victims of Exploitation in Extended Minerals Supply Chains, created previously in
consultation with Apple.
• Leveraging technology for supply chain transparency: via our partnership with the Working Capital Fund, we
supported 11 companies that are developing scalable innovations in technological solutions for more transparent
supply chains.
Determination
As of December 31, 2022, based on our due diligence efforts, including the information provided by our suppliers, Apple
believes that the smelters and refiners listed in Annex I were used to process 3TG in our products at some point during 2022.
Through our smelter and refiner identification and validation process, we have identified a total of 261 smelters and refiners
that processed 3TG in our supply chain during 2022. Of these 261 smelters and refiners:
• 23 were removed including those that: previously participated in but subsequently stopped participating in an
independent third-party audit program; were not willing to participate in or complete an independent third-party audit
within given timelines; exceeded independent third-party audit corrective action plan timelines; or failed to meet Apple’s
Supplier Code, Responsible Sourcing Standard, or 3TG mineral requirements.
• 238 remained in Apple’s 3TG supply chain as of December 31, 2022.
Based on the information provided by our suppliers, smelters, and refiners, as well as from third-party audit programs, Apple
believes that the 3TG contained in our products originated from the countries listed in Annex II, as well as from recycled and
scrap sources. Apple’s reasonable country of origin inquiry is based on third-party audit information and, to the extent the
information has not been made available through audit programs, via the collection of additional information by Apple using
other sources such as the United States of America Geological Survey. To the extent reasonably possible, we have
documented the country of origin of identified smelters and refiners based on information received through the RMI’s RMAP,
the LBMA, a survey of smelters and refiners, or third-party reviews of publicly available information. However, some country of
origin information has not been audited by a third-party because, for example, applicable smelters and refiners ceased
operations before completing an independent third-party audit. Therefore, Apple does not have sufficient information to
conclusively determine the countries of origin of the 3TG in all of our products.
Of all 238 smelters and refiners of 3TG determined to be in our supply chain as of December 31, 2022, Apple found no
reasonable basis for concluding that any such smelter or refiner sourced 3TG that directly or indirectly financed or benefited
armed groups in the DRC or an adjoining country.
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Apple believes it constitutes a “downstream” company in that Apple or its suppliers purchase cassiterite, columbite-tantalite
(coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold related materials
after processing by smelters or refiners. In addition, Apple does not directly purchase or procure primary sourced minerals
from mine sites.
This report relates to the process undertaken in accordance with OECD Due Diligence Guidance for Apple products that were
manufactured, or contracted to be manufactured, during 2022 and that contain 3TG. These product categories are iPhone®,
Mac®, iPad®, AirPods®, Apple TV®, Apple Watch®, Beats® products, HomePod®, HomePod mini®, iPod touch®, Apple
Card®, and all Apple® accessories. Third-party products that Apple retails but that it does not manufacture or contract to
manufacture are outside the scope of this report.
The smelters and refiners identified in this report include those producing inputs for service or spare parts contracted for
manufacturing in 2022 for use in connection with the subsequent service of previously-sold products, including products
serviced in subsequent years using those parts. This report does not include smelters of tin, tantalum, or tungsten or refiners
of gold where such 3TG are included in end-of-life service parts for products that Apple no longer manufactures or contracts to
manufacture.
This report’s use of the terms “smelters” and “refiners” refers to the facilities processing primary 3TG to retail purity. Apple
suppliers have in some cases reported smelters and refiners that Apple believes are not operational or may have been
misidentified as smelters and refiners. As a result, Apple continues to conduct independent research on smelters and refiners
and to work with suppliers throughout its supply chain to revalidate, improve, and refine their reported information, taking into
account supply chain fluctuations and other changes in status or scope and relationships over time. “Identified” smelters and
refiners are those that (i) have been reported in a supplier’s CMRT, (ii) Apple believes are currently operational, were
operational at some point during the applicable year, or, while inoperative, capable of re-engagement with minimal delay or
effort, and (iii) otherwise meet the definition of a smelter or refiner, provided that Apple may determine to treat a third-party as
an identified smelter or refiner notwithstanding a reclassification of such third-party or a change in its status. As part of its
reasonable country of origin inquiry, Apple has determined that certain suppliers are utilizing at least some 3TG from
secondary materials (i.e., scrap or recycled materials). Facilities that process only secondary materials (i.e., scrap or recycled
materials) are excluded from the scope of this report.
Participating smelters and refiners are those that have agreed to participate in or have been found compliant with independent
third-party conflict minerals audit programs confirming their 3TG sourcing practices. Such programs may also include audits
of traceability requirements, conformity with the OECD Due Diligence Guidance, management systems, and/or risk
assessments. Independent third-party 3TG audit programs include the RMI’s RMAP and the LBMA’s Responsible Gold
Program. Throughout this report, the audits by these programs are included in references to “independent third-party audit”
programs.
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Location of Smelter or
Conflict Mineral Name of Smelter or Refiner Refiner
Tungsten A.L.M.T. Corp. * Japan
Tungsten ACL Metais Eireli ** Brazil
Tungsten Asia Tungsten Products Vietnam Ltd. Vietnam
Tungsten China Molybdenum Tungsten Co., Ltd. China mainland
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China mainland
Tungsten Cronimet Brasil Ltda Brazil
Tungsten Fujian Ganmin RareMetal Co., Ltd. China mainland
Tungsten Fujian Xinlu Tungsten Co., Ltd. China mainland
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. China mainland
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. China mainland
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. * China mainland
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China mainland
Tungsten Global Tungsten & Powders Corp. * United States
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China mainland
Tungsten H.C. Starck Tungsten GmbH * Germany
Tungsten Hubei Green Tungsten Co., Ltd. China mainland
Tungsten Hunan Chenzhou Mining Co., Ltd. China mainland
Tungsten Hunan Jintai New Material Co., Ltd. China mainland
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou
Tungsten Tungsten Products Branch China mainland
Tungsten Japan New Metals Co., Ltd. * Japan
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. China mainland
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China mainland
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China mainland
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China mainland
Filer: Apple Inc Form Type: SD Job Number: BRHC10048434 Ver: 3 Page: 16 of 22
Broadridge Financial Solutions, Inc. Description: Exhibit 1.01 [email protected] Created using Broadridge PROfile
* The smelter/refiner is believed to process at least some 3TG from recycled or scrap sources.
** The smelter/refiner has changed its compliance or operational status since December 31, 2022.
*** The smelter/refiner continues to be in the process of removal as of the filing of this report and/or is no longer approved to
be in Apple’s supply chain.
Filer: Apple Inc Form Type: SD Job Number: BRHC10048434 Ver: 3 Page: 22 of 22
Broadridge Financial Solutions, Inc. Description: Exhibit 1.01 [email protected] Created using Broadridge PROfile