Document


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
___________________________
FORM SD
Specialized Disclosure Report
___________________________
VERA BRADLEY, INC.
(Exact name of registrant as specified in its charter)
___________________________
 
Indiana 001-34918 27-2935063
(State or Other Jurisdiction
of Incorporation)
 (Commission
File Number)
 (IRS Employer
Identification No.)
 
12420 Stonebridge Road,
Roanoke, Indiana
 46783
(Address of Principal Executive Offices) (Zip Code)
John Enwright, Chief Financial Officer    (877) 708-8372
(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:
xRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.



Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Company Overview

The terms “Company” and “Vera Bradley” refer to Vera Bradley, Inc. and its subsidiaries, except where the context requires otherwise or where otherwise indicated.

Vera Bradley manufactures or contracts to manufacture products that may contain gold, tantalum, tin and tungsten (“3TG”), such as handbags, accessories, and luggage and travel items. The Company determined that certain of its products may have zippers, fasteners or other components and materials, which are necessary to the production or functionality of its products, that may contain 3TG. 

As these materials are necessary to Vera Bradley’s products, the Company is dedicated to tracing the origin of these metals with the goal of ensuring that our sourcing practices do not support conflict or human rights abuses in the Democratic Republic of Congo and adjoining countries.

Conflict Minerals Disclosures

Vera Bradley has concluded in good faith that during calendar year 2020,
a)    Vera Bradley manufactured or contracted to manufacture products for which “conflict minerals” (as defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act) may be necessary to the functionality or production.
b)    Based on a Reasonable Country of Origin Inquiry (“RCOI”) and subsequent due diligence, Vera Bradley does not have concrete findings on whether its sourcing practices directly or indirectly fund armed groups in the Covered Countries (as defined in Exhibit 1.01). Vera Bradley has, however, found no reasonable basis for concluding that its suppliers sourced 3TG that directly or indirectly finance or benefit armed groups.

This Specialized Disclosure Form and the associated Conflict Minerals Report are posted in the “Customer Service” section, under “Supply Chain,” of the Company’s website at www.verabradley.com.

Item 1.02 Exhibit

See Exhibit 1.01 to this specialized disclosure report, incorporated herein by reference.

Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report



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.
Vera Bradley, Inc.
Date: June 1, 2021
By:
/s/ John Enwright
John Enwright
Chief Financial Officer


Document

Exhibit 1.01
Conflict Minerals Report of Vera Bradley, Inc.
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934


This is the Conflict Minerals Report of Vera Bradley, Inc. for calendar year 2020 (excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). The terms “Company” and “Vera Bradley” refer to Vera Bradley, Inc. and its subsidiaries.

1.Introduction
For the 2020 calendar year, Vera Bradley determined that tin, tungsten, tantalum and/or gold (“3TGs”) may be necessary to the functionality or production of Vera Bradley products that were manufactured or contracted to be manufactured. Therefore, Vera Bradley conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs that may be in its products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, Vera Bradley believes that its products 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”), performed due diligence on the source and chain of custody of the 3TGs in question to determine whether its products are “DRC Conflict Free.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).

Vera Bradley is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, the Company has put into place a due diligence program to contribute towards upholding human rights and responsible practices across the supply chain.

2.Reasonable Country of Origin Inquiry

To determine whether necessary 3TGs in products originated in Covered Countries, Vera Bradley retained Assent Compliance (“Assent”), a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager (“ACM”).

To collect data on the materials’ sources of origin within the supply chain, Vera Bradley utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.0 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, the Company contacted suppliers via the ACM, a software-as-a-service (SaaS) platform provided by Assent that 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 ACM 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 performed, are managed through this platform.

Via the ACM and the 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 ACM for future reporting and transparency. Vera Bradley directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that these suppliers complete the CMRT and submit it to Assent.

The Company’s program continues to include 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 help to identify areas that require further classification or risk assessment, and are designed to facilitate an understanding of the due-diligence efforts of the Tier 1 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 forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also 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, Vera Bradley tracks program gaps to account for future improvement opportunities.

As of March 31, 2021, there were 57 suppliers in scope of the conflict minerals program for the 2020 reporting year and 45 of such suppliers provided a completed CMRT. Vera Bradley’s total response rate for the 2020 reporting year was 79%. These metrics are summarized in the table below in order to assess progress from prior year:

YearSuppliers in Scope% Responded% Invalid
RY 20195454%0%
RY 20205779%2%

Based on the findings through the RCOI process, the Company was able to determine the countries of origin for a large portion of the 3TGs in its products. As such, Vera Bradley continued to perform further due diligence on the source and chain of custody of the minerals in question.

3.Product Description
Vera Bradley contracts to manufacture products that may contain gold, tantalum, tin and tungsten (“3TG”), such as handbags, accessories and luggage and travel items. The Company determined that certain of its products may have zippers, fasteners or other components and materials, which are necessary to the production or functionality of its products, that may contain 3TG.  As these materials are necessary to Vera Bradley's products, the Company is dedicated to tracing the origin of these metals to safeguard that our sourcing practices do not support conflict or human rights abuses in the Democratic Republic of Congo (“DRC”) and adjoining countries.

4.Design of Due Diligence Measures
Vera Bradley 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 identify continuous improvement opportunities.

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 fully be owned by the Company. However, through continued outreach and process validation, the Company believes its processes align with industry standards and market expectations for downstream companies’ due diligence.

5.Due Diligence Measures Performed
Internal Compliance Team

Vera Bradley established a cross-functional Compliance Team led by its Director of Global Quality & Compliance. The Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.




The Company 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 the Company will undertake with suppliers in regards to conflict minerals.

The Company leverages Assent’s Managed Services in order to work with dedicated program specialists
who support Vera Bradley’s conflict minerals program. The Company communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.

Control Systems

The Company expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Vera Bradley are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. The Company relies on 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.

Vera Bradley’s Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviors and practices. 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 Supplier Code of Conduct is provided to all direct suppliers. If a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. The Supplier Code of Conduct is reviewed annually in an effort to ensure that it continues to align with industry best practices.

Supplier Engagement

Vera Bradley believes that it has a strong relationship with its Tier 1 direct suppliers. As an extremely important part of the supply chain, Vera Bradley has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. Vera Bradley’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.

The Company engages with suppliers directly to request a valid CMRT for the products that they supply to the Company and continues to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources.

The Company believes that the combination of the Supplier Code of Conduct and direct engagement with suppliers for conflict minerals training and requests constitute a strong supplier engagement program.

Grievance Mechanisms

The Company established grievance mechanisms whereby employees and suppliers can report violations of Vera Bradley’s policies, including conflict minerals. Suppliers and others outside of Vera Bradley may contact the Company, including to report grievances, via a dedicated email address that is published. In addition, employees may anonymously report suspected violations. Any violations are reported to corporate management.

Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (the “RMI”) directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.

Maintain Records

The Company has adopted 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. The Company stores all of the information and findings from this process in an auditable database.




6.Identifying Risks in the Supply Chain
Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at the company level. In those cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Vera Bradley is unable to determine if all of the specified smelters and refiners were used for 3TGs in the products supplied to the Company.
Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners consolidated by the RMI in order to determine that the facilities met the recognized definition of a 3TG processing facility that was operational during the 2020 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”). Vera Bradley does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters that have completed an RMAP audit are considered to be DRC-conflict free. In cases where the smelters due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.
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 the DRC and covered countries.
Known mineral source country of origin.
RMAP audit status.
Credible evidence of unethical or conflict sourcing.
Peer assessments conducted by credible third-party sources.
Risk mitigation activities are initiated whenever a supplier’s CMRT reported facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier 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 Vera Bradley. Additional escalation may in some cases be necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate 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.
7.Design and Implement a Strategy to Respond to Risks
Together with Assent, Vera Bradley developed processes to assess and respond to the risks identified in the supply chain. Vera Bradley has a risk management plan, through which the conflict minerals program is implemented, managed and monitored. As the program progresses, escalations are 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.
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. The Company engages suppliers believed to be supplying 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not



support such conflict, as provided in the OECD Guidance. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.
In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, the Company will assess the feasibility of replacing that supplier. The results of the program and risk assessment are shared with the Compliance Team and the Vera Bradley leadership team to ensure transparency within the Company.

8.Identified Smelters or Refiners (“SORs”)
Based on survey responses received from Vera Bradley’s suppliers, Vera Bradley was not able to identify all SORs for all 3TG that may be used in its products. Vera Bradley has identified the SORs listed below that may have processed 3TG used in its products. SORs with a “Not Applicable” RMI Audit Status have not been verified to be legitimate SORs.
MetalSmelter NameCountryRMI Audit Status
Gold8853 S.p.A.ItalyConformant
GoldAdvanced Chemical CompanyUnited States Of AmericaConformant
GoldAida Chemical Industries Co., Ltd.JapanConformant
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesConformant
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GermanyConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanConformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilConformant
GoldArgor-Heraeus S.A.SwitzerlandConformant
GoldAsahi Pretec Corp.JapanConformant
GoldAsahi Refining Canada Ltd.CanadaConformant
GoldAsahi Refining USA Inc.United States Of AmericaConformant
GoldAsaka Riken Co., Ltd.JapanConformant
GoldAU Traders and RefinersSouth AfricaConformant
GoldAurubis AGGermanyConformant
GoldBangalore RefineryIndiaConformant
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesConformant
GoldBoliden ABSwedenConformant
GoldC. Hafner GmbH + Co. KGGermanyConformant
GoldCCR Refinery - Glencore Canada CorporationCanadaConformant
GoldCendres + Metaux S.A.SwitzerlandConformant
GoldChimet S.p.A.ItalyConformant
GoldChugai MiningJapanConformant
GoldDODUCO Contacts and Refining GmbHGermanyConformant
GoldDowaJapanConformant
GoldDS PRETECH Co., Ltd.Korea, Republic OfConformant
GoldDSC (Do Sung Corporation)Korea, Republic OfConformant
GoldEco-System Recycling Co., Ltd. East PlantJapanConformant
GoldEmirates Gold DMCCUnited Arab EmiratesConformant
GoldGeib Refining CorporationUnited States Of AmericaConformant
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaConformant
GoldHeimerle + Meule GmbHGermanyConformant
GoldHeraeus Metals Hong Kong Ltd.ChinaConformant
GoldHeraeus Precious Metals GmbH & Co. KGGermanyActive
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaConformant
GoldIshifuku Metal Industry Co., Ltd.JapanConformant
GoldIstanbul Gold RefineryTurkeyConformant
GoldItalpreziosiItalyConformant
GoldJapan MintJapanConformant



MetalSmelter NameCountryRMI Audit Status
GoldJiangxi Copper Co., Ltd.ChinaConformant
GoldJSC UralelectromedRussian FederationConformant
GoldJX Nippon Mining & Metals Co., Ltd.JapanConformant
GoldKazzincKazakhstanConformant
GoldKennecott Utah Copper LLCUnited States Of AmericaConformant
GoldKGHM Polska Miedz Spolka AkcyjnaPolandConformant
GoldKojima Chemicals Co., Ltd.JapanConformant
GoldKorea Zinc Co., Ltd.Korea, Republic OfConformant
GoldKyrgyzaltyn JSCKyrgyzstanConformant
GoldL'Orfebre S.A.AndorraConformant
GoldLS-NIKKO Copper Inc.Korea, Republic OfConformant
GoldLT Metal Ltd.Korea, Republic OfConformant
GoldMarsam MetalsBrazilConformant
GoldMaterionUnited States Of AmericaConformant
GoldMatsuda Sangyo Co., Ltd.JapanConformant
GoldMetalor Technologies (Hong Kong) Ltd.ChinaConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeConformant
GoldMetalor Technologies (Suzhou) Ltd.ChinaConformant
GoldMetalor Technologies S.A.SwitzerlandConformant
GoldMetalor Technologies S.A.SwitzerlandConformant
GoldMetalor Technologies S.A.SwitzerlandConformant
GoldMetalor USA Refining CorporationUnited States Of AmericaConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoConformant
GoldMitsubishi Materials CorporationJapanConformant
GoldMitsui Mining and Smelting Co., Ltd.JapanConformant
GoldMMTC-PAMP India Pvt., Ltd.IndiaConformant
GoldMoscow Special Alloys Processing PlantRussian FederationConformant
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyConformant
GoldNihon Material Co., Ltd.JapanConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaConformant
GoldOhura Precious Metal Industry Co., Ltd.JapanConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationConformant
GoldOJSC Novosibirsk RefineryRussian FederationConformant
GoldPAMP S.A.SwitzerlandConformant
GoldPlanta Recuperadora de Metales SpAChileConformant
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationConformant
GoldPT Aneka Tambang (Persero) TbkIndonesiaConformant
GoldPX Precinox S.A.SwitzerlandConformant
GoldRand Refinery (Pty) Ltd.South AfricaConformant
GoldREMONDIS PMR B.V.NetherlandsConformant
GoldRoyal Canadian MintCanadaConformant
GoldSAAMPFranceConformant
GoldSafimet S.p.AItalyConformant
GoldSamduck Precious MetalsKorea, Republic OfConformant
GoldSAXONIA Edelmetalle GmbHGermanyConformant
GoldSEMPSA Joyeria Plateria S.A.SpainConformant
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaConformant
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaConformant
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationConformant
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaConformant



MetalSmelter NameCountryRMI Audit Status
GoldSumitomo Metal Mining Co., Ltd.JapanConformant
GoldSungEel HiMetal Co., Ltd.Korea, Republic OfConformant
GoldT.C.A S.p.AItalyConformant
GoldTanaka Kikinzoku Kogyo K.K.JapanConformant
GoldThe Refinery of Shandong Gold Mining Co., Ltd.ChinaConformant
GoldTokuriki Honten Co., Ltd.JapanConformant
GoldTorecomKorea, Republic OfConformant
GoldUmicore Precious Metals ThailandThailandConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumConformant
GoldUnited Precious Metal Refining, Inc.United States Of AmericaConformant
GoldValcambi S.A.SwitzerlandConformant
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaConformant
GoldWIELAND Edelmetalle GmbHGermanyConformant
GoldYamakin Co., Ltd.JapanConformant
GoldYokohama Metal Co., Ltd.JapanConformant
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaConformant
TantalumAsaka Riken Co., Ltd.JapanConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaConformant
TantalumD Block Metals, LLCUnited States Of AmericaConformant
TantalumExotech Inc.United States Of AmericaConformant
TantalumF&X Electro-Materials Ltd.ChinaConformant
TantalumFIR Metals & Resource Ltd.ChinaConformant
TantalumGlobal Advanced Metals AizuJapanConformant
TantalumGlobal Advanced Metals BoyertownUnited States Of AmericaConformant
TantalumGuangdong Zhiyuan New Material Co., Ltd.ChinaConformant
TantalumH.C. Starck Co., Ltd.ThailandConformant
TantalumH.C. Starck Hermsdorf GmbHGermanyConformant
TantalumH.C. Starck Inc.United States Of AmericaConformant
TantalumH.C. Starck Ltd.JapanConformant
TantalumH.C. Starck Smelting GmbH & Co. KGGermanyConformant
TantalumH.C. Starck Tantalum and Niobium GmbHGermanyConformant
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaConformant
TantalumJiangxi Tuohong New Raw MaterialChinaConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaConformant
TantalumJiujiang Tanbre Co., Ltd.ChinaConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaConformant
TantalumKEMET Blue MetalsMexicoConformant
TantalumLSM Brasil S.A.BrazilConformant
TantalumMetallurgical Products India Pvt., Ltd.IndiaConformant
TantalumMineracao Taboca S.A.BrazilConformant
TantalumMitsui Mining and Smelting Co., Ltd.JapanConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaConformant
TantalumPower Resources Ltd.Macedonia, The Former Yugoslav Republic OfConformant
TantalumQuantumCleanUnited States Of AmericaConformant
TantalumResind Industria e Comercio Ltda.BrazilConformant
TantalumSolikamsk Magnesium Works OAORussian FederationConformant
TantalumTaki Chemical Co., Ltd.JapanConformant
TantalumTelex MetalsUnited States Of AmericaConformant
TantalumUlba Metallurgical Plant JSCKazakhstanConformant
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaConformant



MetalSmelter NameCountryRMI Audit Status
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaConformant
TinAlphaUnited States Of AmericaConformant
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaConformant
TinChina Tin Group Co., Ltd.ChinaConformant
TinDowaJapanConformant
TinEM VintoBolivia (Plurinational State Of)Conformant
TinFenix MetalsPolandConformant
TinGejiu Kai Meng Industry and Trade LLCChinaConformant
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaConformant
TinGuanyang Guida Nonferrous Metal Smelting PlantChinaConformant
TinHuiChang Hill Tin Industry Co., Ltd.ChinaConformant
TinHuichang Jinshunda Tin Co., Ltd.ChinaNot Applicable
TinJiangxi New Nanshan Technology Ltd.ChinaConformant
TinMa'anshan Weitai Tin Co., Ltd.ChinaConformant
TinMagnu's Minerais Metais e Ligas Ltda.BrazilConformant
TinMalaysia Smelting Corporation (MSC)MalaysiaConformant
TinMelt Metais e Ligas S.A.BrazilConformant
TinMetallic Resources, Inc.United States Of AmericaConformant
TinMetallo Belgium N.V.BelgiumConformant
TinMetallo Spain S.L.U.SpainConformant
TinMineracao Taboca S.A.BrazilConformant
TinMinsurPeruConformant
TinMitsubishi Materials CorporationJapanConformant
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandConformant
TinO.M. Manufacturing Philippines, Inc.PhilippinesConformant
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)Conformant
TinPT Artha Cipta LanggengIndonesiaConformant
TinPT ATD Makmur Mandiri JayaIndonesiaConformant
TinPT Bangka SerumpunIndonesiaConformant
TinPT Mitra Stania PrimaIndonesiaConformant
TinPT Refined Bangka TinIndonesiaConformant
TinPT Timah Tbk KundurIndonesiaConformant
TinPT Timah Tbk MentokIndonesiaConformant
TinResind Industria e Comercio Ltda.BrazilConformant
TinRui Da HungTaiwan, Province Of ChinaConformant
TinSoft Metais Ltda.BrazilConformant
TinThai Nguyen Mining and Metallurgy Co., Ltd.Viet NamConformant
TinThaisarcoThailandConformant
TinTin Technology & RefiningUnited States Of AmericaConformant
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaConformant
TinYunnan Tin Company LimitedChinaConformant
TinYunnan Tin Company LimitedChinaConformant
TinYunnan Tin Company LimitedChinaConformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaConformant
TungstenA.L.M.T. Corp.JapanConformant



MetalSmelter NameCountryRMI Audit Status
TungstenACL Metais EireliBrazilConformant
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamConformant
TungstenChenzhou Diamond Tungsten Products Co., Ltd.ChinaConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaConformant
TungstenFujian Jinxin Tungsten Co., Ltd.ChinaNot Applicable
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaConformant
TungstenGlobal Tungsten & Powders Corp.United States Of AmericaConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaConformant
TungstenH.C. Starck Smelting GmbH & Co. KGGermanyConformant
TungstenH.C. Starck Tungsten GmbHGermanyConformant
TungstenHunan Chenzhou Mining Co., Ltd.ChinaConformant
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiChinaConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.ChinaConformant
TungstenHydrometallurg, JSCRussian FederationConformant
TungstenJapan New Metals Co., Ltd.JapanConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaConformant
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaConformant
TungstenKennametal FallonUnited States Of AmericaConformant
TungstenKennametal HuntsvilleUnited States Of AmericaConformant
TungstenKGETS Co., Ltd.Korea, Republic OfConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaConformant
TungstenMasan Tungsten Chemical LLC (MTC)Viet NamConformant
TungstenMoliren Ltd.Russian FederationConformant
TungstenNiagara Refining LLCUnited States Of AmericaConformant
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesConformant
TungstenTejing (Vietnam) Tungsten Co., Ltd.Viet NamConformant
TungstenUnecha Refractory metals plantRussian FederationConformant
TungstenWolfram Bergbau und Hutten AGAustriaConformant
TungstenWoltech Korea Co., Ltd.Korea, Republic OfConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaConformant
TungstenXiamen Tungsten Co., Ltd.ChinaConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.ChinaConformant

9.Independent Private Sector Audit
Vera Bradley does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters and refiners conducted as part of the RMAP. The 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 and refiners that agree to participate in the program.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. Vera Bradley is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.







10.Forward Looking Statements
This CMR contains forward-looking statements that are subject to risks and uncertainties. All statements other than statements of historical or current fact included in this report are forward-looking statements. Forward-looking statements refer to our current expectations and projections. You can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. These statements may include words such as “anticipate,” “estimate,” “expect,” “project,” “plan,” “intend,” “believe,” “may,” “might,” “will,” “should,” “can have,” and “likely” and other words and terms of similar meaning in connection with any discussion of the timing or nature of future events. All forward-looking statements are subject to risks and uncertainties that may cause actual results to differ materially from those that we expected. The Company undertakes no obligation to update or revise any forward-looking statements to reflect subsequent events or circumstances.