UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Adient plc
(Exact name of registrant as specified in its charter) | | | | | | | | |
| Ireland | 001-37757 | 98-1328821 |
| (State or Other Jurisdiction of Incorporation) | (Commission File Number) | (IRS Employer Identification Number) |
| | |
3 Dublin Landings, North Wall Quay,
Dublin 1, Ireland D01 H104 |
| (Address of principal executive offices) |
| | | | | | | | |
| Gregory S. Smith |
| Senior Vice President and Chief Accounting Officer |
| 734-254-5000 |
(Name and telephone number, including area code,
of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
[x] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
[ ] Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for fiscal year ended ___________.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Adient plc’s Conflict Minerals Report for the reporting period from January 1, 2023 to December 31, 2023 is provided as Exhibit 1.01 hereto and is publicly available at www.adient.com/suppliers/corporate-responsibility.
Item 1.02 Exhibit
See Item 3.01 of this Form.
Section 2 - Resource Extraction Issuer Disclosure and Report
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits
SIGNATURE
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.
| | | | | | | | | | | |
| Adient plc |
| Date: May 29, 2024 | By: | | /s/ Gregory S. Smith |
| Name: | | Gregory S. Smith |
| Title: | | Senior Vice President and Chief Accounting Officer |
Adient plc
Conflict Minerals Report
For the Calendar Year Ended December 31, 2023
I. Background
Under Section 13(p) of the Securities Exchange Act of 1934, the Securities and Exchange Commission (the “SEC”) imposes reporting requirements (the “Rule”) on SEC issuers concerning the use of Conflict Minerals and the metals derived from such minerals that originate in the Democratic Republic of the Congo (the “DRC”) or the adjoining countries (collectively, the “Covered Countries”).
The Rule defines the term “Conflict Mineral” to include cassiterite, columbite-tantalite, gold, and wolframite and their derivatives, including tantalum, tin and tungsten (“3TG”) regardless of their source.
This is the Conflict Minerals Report (“Report”) of Adient plc (“Adient”) for reporting year (“RY”) 2023. It covers all activities conducted for the calendar year ended December 31, 2023.
II. Adient Overview
Adient is one of the world’s largest automotive seating suppliers and has relationships with the largest global auto manufacturers. Adient designs, manufactures and markets a full range of seating systems and components for passenger cars, commercial vehicles and light trucks, including vans, pick-up trucks and sport and crossover utility vehicles. Adient’s proprietary technologies extend into virtually every area of automotive seating solutions, including complete seating systems, frames, mechanisms, foam, head restraints, armrests, and trim covers.
Adient operates more than 200 wholly owned and majority-owned manufacturing or assembly facilities in 29 countries and employs more than 70,000 employees worldwide. Its products are incorporated into more than 12 million vehicles each year.
As used in this Report, and except where the context otherwise requires, the terms “we” and “our” refer to Adient, as well as its majority-owned subsidiaries and variable interest entities that are required to be consolidated for SEC reporting purposes.
III. Product Overview
As noted above, Adient’s products include complete automotive seating systems, as well as automotive seating frames, mechanisms, foam, head restraints, armrests, and trim covers.
IV. Supply Chain Description
Adient is committed to the responsible sourcing of Conflict Minerals and is a member of the Responsible Minerals Initiative (“RMI”). RMI was founded by members of the Responsible Business Alliance (“RBA”). Adient encourages its suppliers to conduct conflict-free sourcing from RMI certified smelters.
As a large multinational company, Adient has a complex, multi-tiered supply chain. The products that Adient manufactures are typically highly engineered, complex, and contain thousands of parts sourced from a vast network of globally dispersed suppliers.
As a downstream consumer with many tiers in its supply chain, Adient generally does not have a direct relationship with smelters and refiners. In most instances, Adient obtains products containing 3TG from unrelated third-party suppliers with their own independent supply chains. These third-party supply chains are also complex and multi-tiered. Accordingly, Adient relies on its first-tier suppliers to provide information regarding the potential origin of any Conflict Minerals contained in the components and parts they supply to Adient.
V. Reasonable Country of Origin Inquiry (“RCOI”)
A. Process Summary
Adient designed and implemented a compliance framework consistent with the processes enumerated in the Organization for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected Areas and High-Risk Areas (“OECD Guidance”).
In addition to Conflict Minerals, Adient also supports U.S. and European Union (“EU”) critical raw materials initiatives to secure resilient, diverse, and secure supply chains by providing usage data to identify Conflict Minerals and Critical Raw Materials (“CRMs”) that are important for the automotive industry. This includes actively engaging in the European Association of Automotive Suppliers (“CLEPA”) working groups to support the phase out and substitution of CRMs in automotive products. Adient also evaluates supply chains for CRMs like Cobalt and Mica, and requires suppliers using these materials to monitor their supply chain and report their efforts. Monitoring for these other CRMs follows a similar process to the one described for Conflict Minerals reporting.
Due to the complexity of Adient’s supply chain, Adient relied on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in components and parts supplied to Adient. In addition, Adient sent the RMI Conflict Minerals Reporting Template (the “CMRT”) to these first-tier suppliers to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.
Adient elected to use the unaltered CMRT and a survey tool to facilitate its RCOI. The questions on the CMRT include, but are not limited to; (1) the use of Conflict Minerals; (2) the need for Conflict Minerals with respect to product functionality or production; (3) the origin of such Conflict Minerals; and (4) whether smelters producing Conflict Minerals were validated as compliant in accordance with applicable RMI standards. Adient communicated with In-Scope Suppliers (as defined below), notifying them of the RCOI and Adient’s expectations, and provided these in-scope suppliers with additional instructions to assist with completing the CMRT.
In addition to the RCOI efforts described above, Adient also undertook the following additional measures to determine the mine or country of origin of any Conflict Minerals:
•Adient considered the following supply base categories as the relevant universe for RCOI purposes: manufactured products, products contracted to be manufactured, and spare parts. This identification of suppliers that were subject to the RCOI (“In-Scope Suppliers”) occurred as part of Adient’s global scoping exercise. It examined both the presence of 3TG in the products and contractual agreements to determine the degree of influence that Adient has over In-Scope Suppliers with respect to their supply chain sourcing decisions. Adient modified its scoping process for RY 2023 to capture high risk commodities likely to contain Conflicts Minerals, as well as suppliers in the supply chain that might present potential economic sanctions or human rights risks.
•Specifically, Adient assigned a risk level of “High,” “Low” or “None” to each In-Scope Supplier based on the likely presence of Conflict Minerals in each component. We made these rating determinations based on a joint assessment of our Procurement and Engineering Departments. High risk suppliers were identified using the International Material Data System (“IMDS”), which provides data used to identify commodities likely to contain Conflict Minerals. Data from the IMDS analysis is used to determine commodities with a high likelihood of the presence of Conflict Minerals (high risk commodities) and non-high risk suppliers listed in these commodities are considered low risk. Commodities without proof of Conflict Minerals usage and their suppliers are considered as “None.” Adient’s scoping process sought to capture 75-80% of its spend on high risk commodities identified using this methodology. All suppliers with risk rankings of “High” were considered in-scope for RCOI procedures. Low risk suppliers were considered in-scope if their spend exceeded a set threshold to ensure that a minimum of 80% of the commodity spend is covered.
•In addition to leveraging IMDS data, Adient’s process for identifying “In-Scope” suppliers also considered parties from known countries of concern, as well as countries that might pose elevated economic sanctions or human rights risks. Adient applied similar risk ratings to prioritize the Procurement Department’s efforts to escalate communications and verification efforts in cases involving non-responsive suppliers.
•Adient required each In-Scope Supplier to provide information regarding the use of Conflict Minerals from their suppliers, who, in turn, were expected to solicit that information from their next tier of suppliers. The Conflict Minerals Supplier Letter that was sent to each In-Scope Supplier can be found on Adient’s website at: https://adient.portal.covisint.com/adient_en_US/Accordion/Corporate%20Responsibilities.page.
•Adient provided support to its suppliers during the RY, including explanations regarding the relevant requirements of the Rule and their obligations under the Rule, and reiterated Adient’s expectation that suppliers cooperate to support Adient’s compliance efforts. This support included an online training course that can be found on Adient’s website at: https://adient.portal.covisint.com/adient_en_US/Accordion/Corporate%20Responsibilities.page. Additional information regarding other supplier resources is available in the “Supplier Engagement and Training” section below.
•Adient subsequently reviewed the responses received from the In-Scope Suppliers for accuracy and completeness, and, if necessary, flagged specific suppliers for additional follow-up and/or due diligence.
•Adient instructed the In-Scope Suppliers who provided incomplete or inconsistent responses to review their responses and resubmit their information.
•Adient enhanced its escalation process for In-Scope Suppliers in 2023 to further integrate its Procurement and Commercial Departments into the effort to contact In-Scope Suppliers regarding the remediation of potential risks, and to promote greater supplier accountability. The purpose of this approach was to strengthen Adient’s leverage while improving our engagement with the relevant suppliers.
As part of the process described above, Adient also works to identify smelters that may be located in countries subject to territorially-based U.S. economic sanctions programs, as well as smelters that may be owned by sanctioned parties. If Adient identifies potential economic sanctions risk as part of the CMRT review process, then it works with the relevant suppliers to evaluate and remediate such risks in a manner consistent with applicable U.S. economic sanctions program requirements. This tailored approach reflects the fact that the relevant risks and requirements may vary depending on the countries, parties, and economic sanctions programs.
B. RCOI Results
Adient determined there were 681 In-Scope Suppliers for RY 2023. Adient sent communications to its In-Scope Suppliers notifying them of the RCOI and received delivery confirmation receipts from 94% of those In-Scope Suppliers.
The overall response rate among the In-Scope Suppliers surveyed was 60%, including 293 responses that were received and accepted (representing 76% of the suppliers who returned a CMRT or an adequate declaration). Adient considers a response as received and accepted when a completed CMRT has been returned to Adient and the CMRT has been validated as accurate by our compliance specialists. Below are the results of the RCOI survey:
| | | | | |
| RCOI Survey Results* |
| No 3TG | 80% |
| Acknowledged 3TG Sourced from the Covered Countries | 1% |
| Acknowledged 3TG Not Sourced from the Covered Countries | 3% |
| 3TG Origin Uncertain or Unknown | 16% |
*results based on the number of received and accepted CMRTs
C. Improvement Measures to be Taken
As explained briefly above, Adient modified its scoping process for RY 2023 to capture high risk commodities likely to contain Conflicts Minerals, as well as suppliers in the supply chain that might present potential economic sanctions or human rights risks. This broader risk pool captured new suppliers for the first time and, ultimately, resulted in a lower overall response rate as compared with previous years. Adient anticipated this outcome given the changes in scoping methodology. Adient is also taking steps to support the new suppliers captured by its broader survey methodology and improve their response rates. Notable examples include offering training
opportunities to certain regional suppliers in the relevant local languages. Adient expects that its collaboration and training efforts with these suppliers will continue to yield improvements in response rates in future years. In addition, Adient will continue to review its supplier in-scoping process.
In addition, in cases where suppliers report the 3TG Origin as uncertain and unknown, Adient plans to evaluate whether their supply is actually supporting the products delivered to Adient.
VI. Conflict Minerals Due Diligence
A. Compliance Framework
i. Framework Design and Overview
Adient designed and implemented a compliance framework that conforms to the primary principles of the OECD Guidance, which is the internationally recognized framework for Conflicts Minerals due diligence. Our compliance framework includes elements drawn from those principles and the corresponding supplements for each of the four conflict minerals. These include: (1) establishing strong company management systems; (2) identifying and assessing risk in the supply chain; (3) designing and implementing a strategy to respond to identified risks; (4) carrying out an independent third-party audit of smelters’/refiners’ due diligence practices; and (5) reporting annually on supply chain due diligence. We described each of these elements further below.
ii. Establish Strong Company Management Systems
Conflict Minerals Policy
Adient is committed to the responsible sourcing of Conflict Minerals, and it supports the humanitarian goal of ending violent conflict in the Covered Countries. Adient’s Sustainability Report and its Conflict Minerals Policy Statement confirm that we continue to promote and encourage suppliers to conduct conflict-free sourcing from the Covered Countries, and to use responsible sourcing practices. We also expect our suppliers to conduct due diligence on their respective supply chains and to assist us with our compliance efforts. To the extent that a supplier refuses to cooperate with our compliance efforts or does not conduct conflict-free sourcing from the Covered Countries, we may reconsider our supply arrangement and/or implement remedies available to us. Our Conflict Minerals Policy Statement is publicly available on Adient’s website at: https://adient.com/ConflictMineralsPolicyStatement.
Internal Management System
Adient maintains an internal management system in which senior management with the necessary expertise, knowledge, and experience oversee the RCOI and due diligence process. These managers continuously seek new ways to evaluate and address potential risk in our supply chain processes through initiatives that often involve stakeholder engagement or consultation with outside experts.
Adient’s Conflict Minerals Executive Steering Committee (“Steering Committee”) comprised of leaders from the company’s Procurement, Legal, Engineering, Communications and Finance Departments, meets several times a year. The Steering Committee oversees and supports Adient’s Conflict Minerals compliance program, including monitoring plans to comply with all requirements.
This Report was also shared with Adient’s Disclosure Committee, which is currently comprised of Adient’s Chief Financial Officer, Chief Legal and Human Resources Officer, Chief Accounting Officer, and other senior Adient managers with relevant oversight roles.
System of Controls and Transparency
Due to the complexity of Adient’s global supply chain, Adient relies on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in materials supplied to Adient. Adient’s RCOI and due diligence processes are designed to gather information on the chain of custody for the necessary Conflict Minerals that may ultimately be integrated into Adient’s products.
Supplier Engagement and Training
Adient provides online training for suppliers as part of the initial communication package to the In-Scope Suppliers. This training explains the relevant requirements of the Rule, Adient’s obligations under the Rule, and Adient’s expectation that our suppliers support our Conflict Minerals compliance efforts. The training is available on our website at: https://adient.portal.covisint.com/adient_en_US/Accordion/Corporate%20Responsibilities.page. Adient encourages its suppliers to confer with its compliance team and strengthen their understanding of the Rule and our expectations. Adient also provides additional training to its suppliers on request.
In addition to online training, Adient provides In-Scope Suppliers with instructions for responding to the survey. Our Conflict Minerals compliance specialists used standardized scripts to help explain our requests and the reason behind the requests. Communications sent to suppliers also contain reference links to the Rule and additional SEC guidance, as well as guidance from the Automotive Industry Action Group (“AIAG”), RMI, and OECD. To help suppliers identify and address smelters of concern, Adient provides links to other Non-Governmental Organization (“NGO”) smelter information resources, such as those published by Global Witness or Amnesty International.
Where appropriate, Adient includes a Conflict Minerals compliance provision in commercial agreements when it renews or enters into new contracts with its suppliers. This provision requires suppliers to conduct inquiries and collect information regarding the smelters and refiners of any Conflict Minerals incorporated into the products supplied to Adient. This includes making reasonable country of origin inquiries. Adient’s Global Supplier Standards Manual (available at https://www.adient.com/suppliers/supplier-expectations/) further reflects and reinforces these expectations.
Internal Training
Adient maintains a web-based Conflicts Minerals training module designed specifically for employees within its Sales, Procurement, and Engineering Departments. This training educates employees about the relevant requirements of the Rule, Adient’s obligations under the Rule, and the processes Adient uses to evaluate and respond to related supply chain risks. It places special emphasis on new and upcoming supply chain risks related to smelter management.
Records Management
Adient retains relevant Conflict Minerals documentation in accordance with its existing corporate records retention procedures.
Complaint Mechanism
Adient maintains a 24-hour Integrity Helpline (available at: https://adient.ethicspoint.com/). The Integrity Helpline provides any interested party (e.g., employees, customers, suppliers, or other external third parties) with a confidential and anonymous mechanism to report potential violations of the law, regulations, professional standards, and policies (including Adient’s Ethics Policy and its Conflict Minerals Policy Statement), as well as concerns regarding Adient’s supply chain. All good-faith reports are investigated. The Legal Department is responsible for evaluating concerns reported through this reporting mechanism, conducting internal investigations where appropriate, and resolving cases that may require remedial or corrective action.
iii. Identify and Assess Risk in the Supply Chain
Adient’s RCOI was designed to determine whether the Conflict Minerals necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by Adient either originated in the Covered Countries or were from recycled or scrap sources. Through communications with the In-Scope Suppliers, Adient sought to identify the smelters and refiners for Conflict Minerals that may be used in its products.
Adient exercises ongoing due diligence and escalation processes of its suppliers to remove Covered Countries, comprehensively sanctioned countries, and non-certified smelters from its supply chain. Adient asks suppliers whether they:
•provided information on all relevant smelters and the country of origin of any Conflict Minerals;
•performed due diligence procedures for non-certified smelters; and
•were able to determine if the Conflict Minerals financed or benefited armed groups in the Covered Countries.
iv. Design and Implement a Strategy to Respond to Identified Risks
Adient has established due diligence guidelines to be followed if it identifies information indicating that a supplier may have sourced Conflict Minerals from the Covered Countries or embargoed countries through a review of the received CMRT.
Once an In-Scope Supplier indicates that it might be sourcing Conflict Minerals from the Covered Countries, Adient initiates due diligence procedures to collect more detailed information from that supplier. This includes engaging with such supplier and validating information with other reliable sources. Suppliers reporting RMI-certified smelters from the Covered Countries are generally exempt from further due diligence as long as there were no incident reports available from NGOs or other reliable sources regarding the listed smelter(s) or refiner(s).
Any findings from the due diligence procedures are discussed with Adient’s Procurement Department. Based on this information, Adient maintains a list of suppliers identified as using Conflict Minerals from a Covered Country as well as the indicated smelters. This list is then compared to the RMI smelter listing to verify the accuracy of the supplier responses as well as the source of the Conflict Minerals, which is then shared with the responsible procurement team.
In addition to these measures, Adient engages and actively cooperates with industry groups, including RMI and AIAG. Adient provides its smelter list to the RMI to support RMI’s risk assessments.
v. Carry Out Independent Third-Party Audit of Smelters’/Refiners’ Due Diligence Practices
Adient does not purchase raw ore or unrefined Conflict Minerals, and, to the best of its knowledge, conducts no purchasing activities directly in the Covered Countries. Instead, Adient is a downstream consumer of Conflict Minerals and is many steps removed from the mining of Conflict Minerals. In order to meet its obligations under the Rule, Adient supports independent third-party audits by being a member of the RMI and relies on the RMI’s Conflict-Free Smelter Program in connection with our due diligence efforts.
This program helps Adient to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. Adient evaluates the supplier reports it receives using the RMI smelter database and then reports any unknown smelter or smelters that have not been certified to the RMI for further investigation and inclusion in the smelter certification scheme.
vi. Report Annually on Supply Chain Due Diligence
This Report (and the related Form SD) was filed with the SEC and is available on our website at:
https://www.adient.com/suppliers/corporate-responsibility.
B. Due Diligence Results
i. Facilities Used to Process Necessary 3TG Originating from Covered Countries
Each of the measures described above was designed to provide Adient with information on the smelters and refiners that the In-Scope Suppliers used to process Conflict Minerals incorporated into the products they supply to Adient. As previously discussed, Adient is a downstream consumer of 3TG and generally does not have a direct relationship with smelters and refiners. Consequently, it must rely on responses from its suppliers in order to determine the facilities used to process Conflict Minerals. Much like Adient, our suppliers generally have their own complex, highly attenuated global supply chains and do not have direct relationships with the smelters or other facilities that process Conflict Minerals.
Adient’s CMRT evaluation process allows for the rejection of CMRTs that appear to be incorrect or that do not provide RCOI information about listed smelters that are uncertified. The Conflict Minerals team categorizes these CMRTs as “3TG origin uncertain or unknown” and includes all data received from suppliers providing these CMRTs into the Report.
In RY 2023, none of the supplier responses stated that they were unable to provide smelter and refinery information. Only 9 suppliers (3%) stated that they do not source from the Covered Countries. Another 3 (1%) acknowledged that they sourced 3TG from one or more Covered Countries. The suppliers sourcing from the Covered Countries indicated that they only sourced from smelters that the RMI identifies as DRC conflict free. None of the responses acknowledged that 3TG was sourced from smelters or mines that financed or benefited armed groups, after reviewing information from NGOs and other sources.
In addition, 48 suppliers (16%) reported using smelters that were not certified and were consequently rated as “3TG uncertain or unknown”. These suppliers received information that their CMRT was rejected after closure of the reporting period in January 2023. Given this response and the low response rate for this reporting period, Adient does not know all of the countries of origin, or the facilities used to process all the Conflict Minerals incorporated into its products.
ii. Smelter Lists (Appendix A)
As explained above, Adient compared the smelter lists provided in responses from its In-Scope Suppliers with the RMI list of compliant smelters to determine which smelters the RMI identifies as DRC conflict free. The information provided by our suppliers was used to conduct our due diligence, including assessing reports for completeness and consistency.
Appendix A includes a list of the smelters identified in received and accepted CMRT’s from our In-Scope Suppliers as part of our RCOI and due diligence efforts. A total of 311 RMI certified smelters were identified by these In-Scope suppliers. Out of these, 18 smelters reportedly ceased operations during the reporting year. Some of Adient’s In-Scope suppliers also identified potential smelters in Russia, as well as one potential smelter owned by a party subject to economic sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). As in previous reporting years, Adient followed its escalation process to have those
potentially problematic smelters removed from its supply chain. At this juncture there is no information indicating that Adient directly or indirectly engaged in any transactions with sanctioned smelters or other parties subject to U.S. economic sanctions programs.
C. Risk Mitigation Measures
Adient’s current processes and procedures for mitigating Conflict Minerals supply chain risks include the following:
•Membership in the RMI, which has allowed for the comparison of all supplier responses to the RMI smelter listing to confirm the accuracy of supplier responses;
•Updating and adapting our scoping, due diligence and escalation guidelines;
•Reviewing and utilizing our internal information technology systems and tools to increase process reliability and apply best business practices; and
•Identifying other unrelated risks during the Conflict Minerals reporting process and addressing them through the responsible Adient departments.
The purpose of these processes is to encourage smelters to make responsible sourcing decisions, and to reduce the likelihood that the sale of these Conflict Minerals will benefit armed groups in the Covered Countries.
Adient is committed to promoting these same objectives by complying with the OECD Guidance and the Rule in a manner consistent with our Conflict Minerals Policy Statement. To that end, Adient will continue its efforts with its In-Scope Suppliers to improve the response rate and the completeness of the surveys. These efforts include:
•Directing suppliers to Adient’s Conflict Minerals Policy Statement, which emphasizes the responsible sourcing of Conflict Minerals;
•Striving to improve supplier awareness to identify potential risks at an early stage by improving our supplier training and sending out detailed feedback related to information received from suppliers;
•Following-up with suppliers that source Conflict Minerals from, or were identified as potentially sourcing from, smelters and refiners not participating in certification schemes;
•Striving to improve the effectiveness of the escalation process to enhance supplier communications and the quality of responses by addressing concerns related to customer buy arrangements to the affected customer;
•Enhancing our RCOI and due diligence measures, as well as the review process for existing and new suppliers included in the scoping guidelines;
•Working with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance; and
•Working with the RMI smelter engagement team to support their engagement and certification efforts.
VII. Determination
For RY 2023, Adient is unable to determine the mine or country of origin for each of its necessary Conflict Minerals or the facilities used to process Conflict Minerals in its supply chain with the greatest possible specificity due to either a lack of survey responses or inconclusive survey responses from its In-Scope Suppliers. As such, Adient is currently unable to determine conclusively whether all products manufactured, or contracted to be manufactured, by Adient in RY 2023 have been found to be free of necessary Conflict Minerals that directly or indirectly financed or benefited armed groups in the Covered Countries. These products include those identified in “Part III. Product Overview” above. See Appendix A for a list of smelters for each of the Conflict Minerals identified as part of Adient’s efforts and country of origin information.
Cautionary Statement Regarding Forward-Looking Statements:
Adient has made statements in this Report that are forward-looking and, therefore, are subject to risks and uncertainties. All statements in this Report other than statements of historical fact are statements that are, or could be, deemed “forward looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. In this document, statements regarding Adient’s future plans, objectives, outlook, targets, guidance or goals are forward-looking statements. Words such as “may,” “will,” “expect,” “intend,” “estimate,” “anticipate,” “believe,” “should,” “forecast,” “project” or “plan” or terms of similar meaning are also generally intended to identify forward-looking statements. Adient cautions that these statements are subject to numerous important risks, uncertainties, assumptions and other factors, some of which are beyond Adient’s control, which could cause Adient’s actual results to differ materially from those expressed or implied by such forward-looking statements. These risks and uncertainties are difficult to predict accurately and may include (but are not limited to) regulatory changes and other developments relating to Conflict Minerals disclosures, changes in or developments related to Adient’s products or Adient’s supply chain, changes to Adient’s supplier base and industry developments relating to supply chain diligence, disclosure and other practices. A detailed discussion of risks related to Adient’s business is included in the section entitled “Risk Factors” in Adient’s Annual Report on Form 10-K for the fiscal year ended September 30, 2023 filed with the SEC on November 17, 2023, and in subsequent reports filed with or furnished to the SEC, available at www.sec.gov. The forward-looking statements included in this Report are made only as of the date of this Report and, except as required by law, Adient assumes no obligation, and disclaims any obligation, to update such statements. In addition, Adient is not including the information contained on, or that can be accessed through, its website as part of, or incorporating it by reference into, this Report.
Appendix A – Smelters by Mineral
The below smelter information refers to data available in the RMI smelter database as of January 2024. Any changes to the RMI smelter database that took place after January 2024 are not covered.
List 1: Smelters and Refiners reported in received and accepted CMRTs that have been included in Adient’s supply chain as of December 31, 2023:
| | | | | | | | |
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Tantalum | AMG Brasil | BRAZIL |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET de Mexico | MEXICO |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | PowerX Ltd. | RWANDA |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | TANIOBIS GmbH | GERMANY |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| | | | | | | | |
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | Aurubis Berango | SPAIN |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | CRM Synergies | SPAIN |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | DS Myanmar | MYANMAR |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Precious Minerals and Smelting Limited | INDIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| | | | | | | | |
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sukses Inti Makmur (SIM) | INDONESIA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Super Ligas | BRAZIL |
| Tin | Thaisarco | THAILAND |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| | | | | | | | |
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Masan High-Tech Materials | VIET NAM |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Agosi AG | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangalore Refinery | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden Ronnskar | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Coimpa Industrial LTDA | BRAZIL |
| Gold | Dowa | JAPAN |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| | | | | | | | |
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Gold by Gold Colombia | COLOMBIA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TÜRKIYE |
| Gold | Italpreziosi | ITALY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MKS PAMP SA | SWITZERLAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TÜRKIYE |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| | | | | | | | |
| Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | REMONDIS PMR B.V. | NETHERLANDS, KINGDOM OF THE |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SAFINA A.S. | CZECHIA |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | WEEEREFINING | FRANCE |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
*Country names according to ISO 3166-1
List 2: Smelters and Refiners reported in received and accepted CMRTs that were included in Adient’s supply chain but identified as having ceased operation prior to December 31, 2023:
| | | | | | | | |
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | Meta Materials | NORTH MACEDONIA |
| Tantalum | QSIL Metals Hermsdorf GmbH | GERMANY |
| Tantalum | Taike Technology (Suzhou) Co.,Ltd. | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tin | An Thai Minerals Co., Ltd. | VIET NAM |
| Tin | CFC Cooperativa dos Fundidores de Cassiterita da Amazonia Ltda. | BRAZIL |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | Cooperativa Metalurgica de Rondonia Ltda. | BRAZIL |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | Dragon Silver Holdings Limited | CHINA |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Jinye Mineral Company | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Linqu Xianggui Smelter Co., Ltd. | CHINA |
| Tin | Minmetals Ganzhou Tin Co. Ltd. | CHINA |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | PT Bangka Putra Karya | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT Fang Di MulTindo | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | PT Justindo | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | INDONESIA |
| Tin | PT Koba Tin | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| | | | | | | | |
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Tin | PT Seirama Tin Investment | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION** |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY |
| Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Morris and Watson Gold Coast | AUSTRALIA |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION** |
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS, KINGDOM OF THE |
| Gold | Sellem Industries Ltd. | MAURITANIA |
| | | | | | | | |
Conflict Mineral | Smelter or Refiner Name | Location of Smelter or Refiner* |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Value Trading | BELGIUM |
* Country names according to ISO 3166-1
Potential Countries of Origin of Conflict Minerals:
| | | | | | | | |
| Andorra | French Guiana | Nigeria |
| Antigua and Barbuda | Georgia | Oman |
| Argentina | Germany | Pakistan |
| Australia | Ghana | Panama |
| Austria | Greece | Papua New Guinea |
| Azerbaijan | Grenada | Peru |
| Bahamas | Guatemala | Philippines |
| Bangladesh | Guinea | Poland |
| Barbados | Guyana | Portugal |
| Belarus | Honduras | Puerto Rico |
| Belgium | Hong Kong | Romania |
| Benin | Hungary | Russian Federation** |
| Bolivia (Plurinational State of) | India | Rwanda* |
| Bosnia and Herzegovina | Indonesia | Saint Kitts and Nevis |
| Botswana | Ireland | Saint Vincent and the Grenadines |
| Brazil | Israel | Senegal |
| Bulgaria | Italy | Serbia |
| Burkina Faso | Japan | Sierra Leone |
| Burundi* | Jordan | Singapore |
| Cambodia | Kazakhstan | Slovakia |
| Cameroon | Kenya | Slovenia |
| Canada | Korea, Republic of | South Africa |
| Cayman Islands | Kuwait | Spain |
| Chile | Kyrgyzstan | Sudan |
| China | Lao People's Democratic Republic | Suriname |
| Colombia | Latvia | Sweden |
| Congo, Democratic Republic of the* | Liberia | Switzerland |
| Costa Rica | Lithuania | Taiwan, Province of China |
| Côte d'Ivoire | Luxembourg | Tanzania, United Republic of |
| Croatia | Madagascar | Thailand |
| Curaçao | Malaysia | Trinidad and Tobago |
| Cyprus | Mali | Tunisia |
| Czechia | Malta | Türkiye |
| Denmark | Mauritania | Turks and Caicos Islands |
| Dominican Republic | Mexico | Uganda* |
| Ecuador | Mongolia | United Arab Emirates |
| Egypt | Mozambique | United Kingdom of Great Britain and Northern Ireland |
| El Salvador | Myanmar | United States of America |
| Estonia | Namibia | Uruguay |
| Ethiopia | Netherlands, Kingdom of the | Uzbekistan |
| Fiji | New Zealand | Viet Nam |
| | | | | | | | |
| Finland | Nicaragua | Zambia* |
| France | Niger | Zimbabwe |
| | | | | |
| * | DRC and adjoining countries |
| |
| ** | Information from supplier CMRTs identified smelters located in the Russian Federation as a potential source of metals used by Adient’s third-party suppliers. These smelters lost their certification during the Reporting Year. They are still listed here because they were part of Adient’s supply chain prior to their status change. |
| |
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