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:
| x | Rule 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
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 | ||||||||||||||
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:
| Year | Suppliers in Scope | % Responded | % Invalid | ||||||||
| RY 2019 | 54 | 54% | 0% | ||||||||
| RY 2020 | 57 | 79% | 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.
| Metal | Smelter Name | Country | RMI Audit Status | ||||||||
| Gold | 8853 S.p.A. | Italy | Conformant | ||||||||
| Gold | Advanced Chemical Company | United States Of America | Conformant | ||||||||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | Conformant | ||||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Conformant | ||||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant | ||||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant | ||||||||
| Gold | Argor-Heraeus S.A. | Switzerland | Conformant | ||||||||
| Gold | Asahi Pretec Corp. | Japan | Conformant | ||||||||
| Gold | Asahi Refining Canada Ltd. | Canada | Conformant | ||||||||
| Gold | Asahi Refining USA Inc. | United States Of America | Conformant | ||||||||
| Gold | Asaka Riken Co., Ltd. | Japan | Conformant | ||||||||
| Gold | AU Traders and Refiners | South Africa | Conformant | ||||||||
| Gold | Aurubis AG | Germany | Conformant | ||||||||
| Gold | Bangalore Refinery | India | Conformant | ||||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant | ||||||||
| Gold | Boliden AB | Sweden | Conformant | ||||||||
| Gold | C. Hafner GmbH + Co. KG | Germany | Conformant | ||||||||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | Conformant | ||||||||
| Gold | Cendres + Metaux S.A. | Switzerland | Conformant | ||||||||
| Gold | Chimet S.p.A. | Italy | Conformant | ||||||||
| Gold | Chugai Mining | Japan | Conformant | ||||||||
| Gold | DODUCO Contacts and Refining GmbH | Germany | Conformant | ||||||||
| Gold | Dowa | Japan | Conformant | ||||||||
| Gold | DS PRETECH Co., Ltd. | Korea, Republic Of | Conformant | ||||||||
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of | Conformant | ||||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | Conformant | ||||||||
| Gold | Emirates Gold DMCC | United Arab Emirates | Conformant | ||||||||
| Gold | Geib Refining Corporation | United States Of America | Conformant | ||||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant | ||||||||
| Gold | Heimerle + Meule GmbH | Germany | Conformant | ||||||||
| Gold | Heraeus Metals Hong Kong Ltd. | China | Conformant | ||||||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Active | ||||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant | ||||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Istanbul Gold Refinery | Turkey | Conformant | ||||||||
| Gold | Italpreziosi | Italy | Conformant | ||||||||
| Gold | Japan Mint | Japan | Conformant | ||||||||
| Metal | Smelter Name | Country | RMI Audit Status | ||||||||
| Gold | Jiangxi Copper Co., Ltd. | China | Conformant | ||||||||
| Gold | JSC Uralelectromed | Russian Federation | Conformant | ||||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Kazzinc | Kazakhstan | Conformant | ||||||||
| Gold | Kennecott Utah Copper LLC | United States Of America | Conformant | ||||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | Conformant | ||||||||
| Gold | Kojima Chemicals Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | Conformant | ||||||||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Conformant | ||||||||
| Gold | L'Orfebre S.A. | Andorra | Conformant | ||||||||
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | Conformant | ||||||||
| Gold | LT Metal Ltd. | Korea, Republic Of | Conformant | ||||||||
| Gold | Marsam Metals | Brazil | Conformant | ||||||||
| Gold | Materion | United States Of America | Conformant | ||||||||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | Conformant | ||||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Conformant | ||||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | China | Conformant | ||||||||
| Gold | Metalor Technologies S.A. | Switzerland | Conformant | ||||||||
| Gold | Metalor Technologies S.A. | Switzerland | Conformant | ||||||||
| Gold | Metalor Technologies S.A. | Switzerland | Conformant | ||||||||
| Gold | Metalor USA Refining Corporation | United States Of America | Conformant | ||||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | Conformant | ||||||||
| Gold | Mitsubishi Materials Corporation | Japan | Conformant | ||||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant | ||||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | Conformant | ||||||||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | Conformant | ||||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant | ||||||||
| Gold | Nihon Material Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Conformant | ||||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Conformant | ||||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | Conformant | ||||||||
| Gold | OJSC Novosibirsk Refinery | Russian Federation | Conformant | ||||||||
| Gold | PAMP S.A. | Switzerland | Conformant | ||||||||
| Gold | Planta Recuperadora de Metales SpA | Chile | Conformant | ||||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Conformant | ||||||||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant | ||||||||
| Gold | PX Precinox S.A. | Switzerland | Conformant | ||||||||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | Conformant | ||||||||
| Gold | REMONDIS PMR B.V. | Netherlands | Conformant | ||||||||
| Gold | Royal Canadian Mint | Canada | Conformant | ||||||||
| Gold | SAAMP | France | Conformant | ||||||||
| Gold | Safimet S.p.A | Italy | Conformant | ||||||||
| Gold | Samduck Precious Metals | Korea, Republic Of | Conformant | ||||||||
| Gold | SAXONIA Edelmetalle GmbH | Germany | Conformant | ||||||||
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | Conformant | ||||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant | ||||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant | ||||||||
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | Conformant | ||||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Conformant | ||||||||
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | Conformant | ||||||||
| Metal | Smelter Name | Country | RMI Audit Status | ||||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant | ||||||||
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | Conformant | ||||||||
| Gold | T.C.A S.p.A | Italy | Conformant | ||||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant | ||||||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | Conformant | ||||||||
| Gold | Tokuriki Honten Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Torecom | Korea, Republic Of | Conformant | ||||||||
| Gold | Umicore Precious Metals Thailand | Thailand | Conformant | ||||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Conformant | ||||||||
| Gold | United Precious Metal Refining, Inc. | United States Of America | Conformant | ||||||||
| Gold | Valcambi S.A. | Switzerland | Conformant | ||||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | Conformant | ||||||||
| Gold | WIELAND Edelmetalle GmbH | Germany | Conformant | ||||||||
| Gold | Yamakin Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Yokohama Metal Co., Ltd. | Japan | Conformant | ||||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant | ||||||||
| Tantalum | Asaka Riken Co., Ltd. | Japan | Conformant | ||||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Conformant | ||||||||
| Tantalum | D Block Metals, LLC | United States Of America | Conformant | ||||||||
| Tantalum | Exotech Inc. | United States Of America | Conformant | ||||||||
| Tantalum | F&X Electro-Materials Ltd. | China | Conformant | ||||||||
| Tantalum | FIR Metals & Resource Ltd. | China | Conformant | ||||||||
| Tantalum | Global Advanced Metals Aizu | Japan | Conformant | ||||||||
| Tantalum | Global Advanced Metals Boyertown | United States Of America | Conformant | ||||||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Conformant | ||||||||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | Conformant | ||||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Conformant | ||||||||
| Tantalum | H.C. Starck Inc. | United States Of America | Conformant | ||||||||
| Tantalum | H.C. Starck Ltd. | Japan | Conformant | ||||||||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant | ||||||||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | Conformant | ||||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant | ||||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant | ||||||||
| Tantalum | Jiangxi Tuohong New Raw Material | China | Conformant | ||||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant | ||||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | Conformant | ||||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant | ||||||||
| Tantalum | KEMET Blue Metals | Mexico | Conformant | ||||||||
| Tantalum | LSM Brasil S.A. | Brazil | Conformant | ||||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | Conformant | ||||||||
| Tantalum | Mineracao Taboca S.A. | Brazil | Conformant | ||||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant | ||||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant | ||||||||
| Tantalum | Power Resources Ltd. | Macedonia, The Former Yugoslav Republic Of | Conformant | ||||||||
| Tantalum | QuantumClean | United States Of America | Conformant | ||||||||
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | Conformant | ||||||||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Conformant | ||||||||
| Tantalum | Taki Chemical Co., Ltd. | Japan | Conformant | ||||||||
| Tantalum | Telex Metals | United States Of America | Conformant | ||||||||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant | ||||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | Conformant | ||||||||
| Metal | Smelter Name | Country | RMI Audit Status | ||||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant | ||||||||
| Tin | Alpha | United States Of America | Conformant | ||||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant | ||||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | Conformant | ||||||||
| Tin | China Tin Group Co., Ltd. | China | Conformant | ||||||||
| Tin | Dowa | Japan | Conformant | ||||||||
| Tin | EM Vinto | Bolivia (Plurinational State Of) | Conformant | ||||||||
| Tin | Fenix Metals | Poland | Conformant | ||||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | Conformant | ||||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant | ||||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Conformant | ||||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Conformant | ||||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant | ||||||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | Conformant | ||||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | Conformant | ||||||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | China | Not Applicable | ||||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | China | Conformant | ||||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China | Conformant | ||||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant | ||||||||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant | ||||||||
| Tin | Melt Metais e Ligas S.A. | Brazil | Conformant | ||||||||
| Tin | Metallic Resources, Inc. | United States Of America | Conformant | ||||||||
| Tin | Metallo Belgium N.V. | Belgium | Conformant | ||||||||
| Tin | Metallo Spain S.L.U. | Spain | Conformant | ||||||||
| Tin | Mineracao Taboca S.A. | Brazil | Conformant | ||||||||
| Tin | Minsur | Peru | Conformant | ||||||||
| Tin | Mitsubishi Materials Corporation | Japan | Conformant | ||||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant | ||||||||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant | ||||||||
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | Conformant | ||||||||
| Tin | PT Artha Cipta Langgeng | Indonesia | Conformant | ||||||||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant | ||||||||
| Tin | PT Bangka Serumpun | Indonesia | Conformant | ||||||||
| Tin | PT Mitra Stania Prima | Indonesia | Conformant | ||||||||
| Tin | PT Refined Bangka Tin | Indonesia | Conformant | ||||||||
| Tin | PT Timah Tbk Kundur | Indonesia | Conformant | ||||||||
| Tin | PT Timah Tbk Mentok | Indonesia | Conformant | ||||||||
| Tin | Resind Industria e Comercio Ltda. | Brazil | Conformant | ||||||||
| Tin | Rui Da Hung | Taiwan, Province Of China | Conformant | ||||||||
| Tin | Soft Metais Ltda. | Brazil | Conformant | ||||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | Conformant | ||||||||
| Tin | Thaisarco | Thailand | Conformant | ||||||||
| Tin | Tin Technology & Refining | United States Of America | Conformant | ||||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant | ||||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Conformant | ||||||||
| Tin | Yunnan Tin Company Limited | China | Conformant | ||||||||
| Tin | Yunnan Tin Company Limited | China | Conformant | ||||||||
| Tin | Yunnan Tin Company Limited | China | Conformant | ||||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Conformant | ||||||||
| Tungsten | A.L.M.T. Corp. | Japan | Conformant | ||||||||
| Metal | Smelter Name | Country | RMI Audit Status | ||||||||
| Tungsten | ACL Metais Eireli | Brazil | Conformant | ||||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant | ||||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Not Applicable | ||||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Global Tungsten & Powders Corp. | United States Of America | Conformant | ||||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant | ||||||||
| Tungsten | H.C. Starck Tungsten GmbH | Germany | Conformant | ||||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | Conformant | ||||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Hydrometallurg, JSC | Russian Federation | Conformant | ||||||||
| Tungsten | Japan New Metals Co., Ltd. | Japan | Conformant | ||||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Kennametal Fallon | United States Of America | Conformant | ||||||||
| Tungsten | Kennametal Huntsville | United States Of America | Conformant | ||||||||
| Tungsten | KGETS Co., Ltd. | Korea, Republic Of | Conformant | ||||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | Conformant | ||||||||
| Tungsten | Moliren Ltd. | Russian Federation | Conformant | ||||||||
| Tungsten | Niagara Refining LLC | United States Of America | Conformant | ||||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant | ||||||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam | Conformant | ||||||||
| Tungsten | Unecha Refractory metals plant | Russian Federation | Conformant | ||||||||
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | Conformant | ||||||||
| Tungsten | Woltech Korea Co., Ltd. | Korea, Republic Of | Conformant | ||||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Conformant | ||||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | Conformant | ||||||||
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.